Assessing the Scientific Basis of the Agricultural Water Provision of the FSMA Produce Safety Rule

Janet A. Gradl and Michelle R. Worosz


The Food Safety Modernization Act of 2011 (FSMA) requires the U.S. Food and Drug Administration (FDA) to establish science-based minimum standards for the safe production and harvesting of raw produce. This paper examines the scientific basis of the Produce Safety Rule’s agricultural water provision, highlighting several criteria: microbial indicators for fecal contamination and decay rates; water source testing; wash water temperature; and water treatment. Analysis finds that FDA made a good faith effort in rulemaking. Implementing the rule, however, is complex for both producers and regulators, requiring additional research to fill gaps in the scientific literature and gaps in knowledge about application of the standards.