Association Develops Pre-Harvest Agricultural Water Assessment to Support Grower Compliance

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As new Food and Drug Administration (FDA) food safety requirements for growers take effect this year, the Association has been working diligently to support members with practical tools to ease compliance burdens.

The compliance year for the FDA Produce Safety Rule (PSR) Pre-Harvest Agricultural Water requirements began last April. During the first year, the U.S. Food and Drug Administration adopted an “educate before we regulate” approach, allowing growers time to understand and implement the new water assessment requirements without formal enforcement actions. That education period has now concluded.

Beginning this April, large farms defined as those with more than $500,000 in annual produce sales will be expected to demonstrate compliance during on-farm inspections. Small farms ($250,000–$500,000 in annual produce sales) and very small farms will see their compliance deadlines phased in over the next two years.

With inspections now transitioning toward enforcement, it is critical that growers understand how to conduct, document, and tailor their pre-harvest agricultural water assessments to their specific operations.

Recognizing the complexity and paperwork associated with yet another regulatory requirement, the Association has developed a Pre-Harvest Agricultural Water Assessment specifically for pistachio and walnut farms (almonds are currently exempt from the PSR). The goal is to provide a clear, structured framework that simplifies the process while ensuring farms meet the Produce Safety Rule requirements.

The assessment is designed to help growers:

Evaluate water sources and irrigation practices
Identify potential contamination risks
Maintain inspection-ready records

By developing this tool, the Association continues its commitment to helping members navigate regulatory changes. Members who would like a copy of the Pre-Harvest Agricultural Water Assessment should contact mandy@wtna.org. If you have any questions please contact priscilla@wtna.org.