Protecting families from contaminated food and water
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Protecting families from contaminated food and water
Posted in Food Policy,Food Safety,Our Blog on October 9, 2025
Recent changes to pre-harvest water requirements for domestically grown produce may help improve the safety of our food supply. Irrigation water is a common source of foodborne outbreaks in the United States.
The recent update to pre-harvest water requirements is a step in the right direction. Many farms already do these things. Others may be unintentionally lagging behind.
What are these pre-harvest water requirements? How will they help? Follow along as we dive in to safe irrigation practices.
One of major factors responsible for foodborne illness outbreaks seems so unlikely. That is, until you really think about it.
Irrigation water.
Like humans, plants need a lot of water to survive. Farms have to acquire and move gallons upon gallons of this precious liquid to keep the food supply going. Farmers use ground water, surface water, processed human waste water, or some combination of the three, depending on their location and specific situation.
Poor, unhealthy water, can have a disastrous effect on the outcome.
Processed human wastewater is one of the more risky water sources. This type of water requires extensive treatment to render it safe for irrigation use.
Ground water is often the safest option for irrigation water. Unless it is contaminated by poorly processed water human waste water or runoff from surface water. Upstream feedlot runoff is a significant concern.
In some cases, irrigation water can be contaminated. Bacteria, protozoa, and viruses can hitch a ride on this water and deposit onto those crops.
Your leafy greens, tomatoes, mangoes, and other fruits and vegetables become at risk.
Common foodborne germs associated with irrigation water include:
As well as other foodborne germs.
Bacteria and protozoa don’t do well outside of the human body. Viruses and certain other germs on the other hand, can remain in the soil for months. Years even.
Prevention is key. Prevention in the form of using safe irrigation water.
Certain requirements for irrigation water have already been on the books. However, this recent update for pre-harvest water requirements strengthens those procedures by enacting specific actions.
What is the reason, specifically, for pre-harvest irrigation?
Crops are irrigated throughout the growing season. So why is there an emphasis specifically on the pre-harvest period?
The answer is simple.
What goes on the crops just before they are harvested can remain on the plant until it reaches the consumer. While theoretically, earlier watering is potentially filtered by the soil or washed off the plant by subsequent watering.
Ideally, I would like clean/safe water on the plant for the entirety of their growing cycle. But that doesn’t seem to be much of a regulatory concern.
As part of the final rule, all pre-harvest agricultural water for covered produce (other than sprouts), must conduct agricultural water assessments once a year. This should also take place whenever a significant change occurs that “increases the likelihood that a known or reasonably foreseeable hazard will be introduced into or onto produce or food contact surfaces.”
Pre-harvest water requirements now include evaluation of certain aspects of the farm’s situation. Their agricultural water systems, their agricultural water practices, crop characteristics, environmental conditions, and other contributing factors like test results from environmental sampling.
Understanding the types of water systems used by the farm is the first start.
Do they use ground water?
Surface water?
How is it distributed? Is it open or closed? How easily can it become contaminated? Are there animals nearby (working, grazing, or wild)?
How the water is applied should also be considered. Does the farm use overhead sprinklers or sprayers? Do they use drip, flood, furrow, or seepage irrigation practices? Each method has its pros and cons. As well as specific risks.
Additionally, the FDA also wants farmers to consider the time interval between the last “direct application” of irrigation water and when the produce is harvested.
Specific crops are also considered in this assessment. Some crops are more prone to holding onto germs. Both internally and externally. Some, like certain leafy greens, are capable of pulling these microbes inside themselves along with the water. Others have nooks and crevices that can hold onto those pathogens. Making them more likely to remain contaminated up to when the consumer brings it home.
Other environmental conditions can also impact crop safety. Air temperatures and UV exposures are considered. However, weather events can be significant factors.
Have there been heavy rains or flooding? Could human pathogens make their way downstream to the crops. Could pathogens lurking within the soil become stirred up and reintroduce surface level contamination?
All of these things matter.
Depending on the results of the assessment, certain corrective actions are necessary according to the updated pre-harvest water requirements. Some of these requirements have been previously instituted. Others have been strengthened.
For example, if the agricultural water is deemed unsafe or contains inadequate sanitary quality for the intended use, its use should be immediately discontinued. Corrective actions to bring it back up to expressed standards is necessary prior to use for pre-harvest activities.
If animal activity, untreated or improperly treated human waste (on adjacent or nearby land) for which “mitigation is reasonably necessary,” mitigation measures within the same growing season are required. If this same risk assessment does not involve these contributing factors, mitigation measures may be employed as soon as practical. But before the next growing season.
If all is well, the farm can continue to test the water annually (at a minimum) or as the need arises.
The pre-harvest, harvest, and pos-harvest use of agricultural water for sprouts has not changed. This product, based on how it is grown, incurs additional risks that could impact consumer health.
Requirements for this crop are consequently more stringent than that of others.
These implementation dates for the updated pre-harvest water requirements were staggered, based on farm size. Large farms were required to implement these practices by April 7, 2025. Smaller farms were required to meet these requirements soon after. By now, all farms should be adhering to the updated requirements.
If you’d like to know more about food safety topics in the news, like “Recent Changes to Pre-Harvest Water Requirements Address Major Reasons for Outbreaks and Recalls in Domestically Grown Produce,” check out the Make Food Safe Blog. We regularly update trending topics, foodborne infections in the news, recalls, and more! Stay tuned for quality information to help keep your family safe, while The Lange Law Firm, PLLC strives to Make Food Safe!
By: Heather Van Tassell (contributing writer, non-lawyer)