The FDA has issued a proposed Final Rule relating to agricultural water for green produce other than sprouts.

The Rule specifically: -

• Establishes requirements for agricultural water assessment based on proximity to sources of contamination.
• Requires assay of pre-harvest water use for irrigation.
• Requires farms to implement “effective mitigation measures within specific time frames”.
• Provides options for mitigation with “additional flexibility in responding to findings from pre-harvest agricultural water assessments”.

Basically, the new rule dances around the reality that runoff from intensive livestock facilities contaminates water with a range of pathogens including E.coli O:157 and other STECs; Listeria; Salmonella and possibly pathogenic viruses. 

It is axiomatic that a foodborne public health problem attributed to contamination cannot be resolved by “testing”.  Contamination of irrigation water is inevitable and accordingly FDA are attempting to regulate the wrong end of the production chain” Emphasis should be placed on a possible kill step that will destroy bacterial pathogens since green produce is consumed raw.

The FDA is committed to an “educate before and while we regulate” approach that is essentially ameliorative and does little to provide absolute protection from contamination.  At present, eating green produce is effectively “lettuce roulette”.

The FDA should get serious over contamination of produce and abandon the current pas de deux with producers of leafy greens, face reality and develop an effective and durable solution at the processing and packaging level.