Earlier this week, the California Citrus Quality Council (CCQC) contacted the industry to provide information to citrus growers and packers on how to comply with FDA pre-harvest agricultural water regulations.
On May 6, 2024, the U.S. Food and Drug Administration (FDA) finalized its rule on pre-harvest agricultural water requirements under the Food Safety Modernization Act (FSMA). The rule mandates that covered farms conduct an annual written pre-harvest agricultural water hazard assessment and additional assessments when significant changes occur that could introduce hazards. These assessments are intended to identify and mitigate potential risks associated with pre-harvest agricultural water, following the FDA’s focus on prevention.
The regulations are effective April 7, 2025, for large farms (annual sales greater than $500,000), April 6, 2026, for small farms (annual sales between $250,000 – $500,000), and April 5, 2027, for very small farms (annual sales $25,000 – $250,000).
The hazard assessment includes several modules, including one about “crop characteristics,” which requires a written response about the susceptibility of the covered produce to surface adhesion or internalization of hazards. With the help of industry members, CCQC has provided the following response that industry members can voluntarily use when drafting the assessment: “Internalization has not been demonstrated to occur under field or packing conditions.”
CCQC has also provided a summary of the agricultural water regulation and a blank assessment template that can be used to develop a draft. The FDA has also created a web-based tutorial to familiarize stakeholders with the assessment.
If you have questions, please contact CCQC President Jim Cranney at (530) 906-6546 or jcranney@ccqc.org.
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