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Growers that have been testing their wells for years have been asking us if that historical data
would meet the four-sample requirement for FSMA for the first year and the answer we got from the
FDA is NO.
What that means for you:
For harvest and post-harvest water, you are required to test each well for non-detectable generic E.
coli four times in the first year. If all initial results meet the numerical requirements of 112.44(a) (no
detectable generic E. coli per 100 ml) then you are only required to test those harvest and postharvest
water wells once a year moving forward.
The four-sampling requirement is now in effect for operations over $250,000 and smaller
operations ($25,000-250,000) will be required starting in January 2025. Remember not all wells
need to be tested four times. It is only water from wells used in harvesting or in the packing area
which come in direct contact with the produce or the harvesting and packing equipment during
cleaning and sanitizing.
Here is the answer we got from the FDA:
“As farms come into compliance with harvest and post-harvest agricultural water requirements,
those growers who are using untreated ground water for the purposes of 112.44(a) must test
the water 4x per year initially. If all initial results meet the numerical requirements of 112.44(a)
(no detectable generic E. coli per 100 ml), then the grower may reduce the testing frequency to
one sample year, as long as the agricultural water continues to be reflective of use. FDA may
consider guidance on what growers might be able to do with historical data as compliance and
implementation guidance is developed.”