April 2019 - 24

IRRIGATION & WATER MANAGEMENT
Water system food safety inspections vital
By Marissa Schuh and Phillip Tocco
Michigan State University
Inspecting irrigation water
systems, much like monitoring fields
for wildlife intrusion, is something
that often happens without much
thought to recordkeeping. Crops
need water, so growers are always
keeping an eye on and maintaining
their irrigation equipment.
When approaching irrigation
from a food safety perspective, be
it to meet requirements of good
agricultural practices (GAP) or the
Food Safety Modernization Act
(FSMA) Produce Safety Rule, some
key factors besides basic function
need to be taken into account. This
starts with thinking of the whole
system, from the water source to the
last emitter.
Why spend some time thinking
about your whole system? It can
help you make sure everything
is in working order and it is now
required under the FSMA Produce
Safety Rule. For those already being
audited by a third party in food
safety or complying with GAP, these
requirements will not be as in-depth
and all you will need to do to
comply is formalize things with a
record. For example, your water
system inspection will start by
guaranteeing the integrity of the
delivery system. These are usually
obvious from pressure sensor
monitoring. If pressure sensors show
an unexpected pressure drop in the
system, a grower's natural response
is to go looking for the leak. Regular
checks to ensure the function of
the pressure sensors may help avoid
going on wild goose chases looking
for leaks that don't exist.
Apart from checking if pressure
Water system inspections are a key part of the Produce Safety Rule. Photo: Michigan
State University
as what growers are used to. The text
of the FSMA Produce Safety Rule
highlights several key components in
§112.42(a):
112.42(a) At the beginning of a
growing season, as appropriate, but
at least once annually, you must
inspect all of your agricultural
water systems, to the extent they
are under your control (including
water sources, water distribution
systems, facilities, and equipment),
to identify conditions that are
reasonably likely to introduce
known or reasonably foreseeable
hazards into or onto covered
produce or food contact surfaces
in light of your covered produce,
practices, and conditions, including
consideration of the following:
(1) The nature of each
agricultural water source (for
example, ground water or surface
water);
(2) The extent of your control
over each agricultural water source;
(3) The degree of protection of
each agricultural water source;
(4) Use of adjacent and nearby
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land; and
(5) The likelihood of
introduction of known or
reasonably foreseeable hazards to
agricultural water by another user
of agricultural water before the
water reaches your covered farm.
The considerations required
Michigan Valley Irrigation
www.mvi.farm
4802 W. Caro Rd.
Vassar, MI 48768
989-673-6741
14265 Beadle Lake Rd.
Battle Creek, MI 49014
269-565-4426
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under the FSMA Produce Safety
Rule are qualitative in nature (i.e.,
is a water source very controlled
by you, somewhat controlled by
you or poorly controlled by you?)
It requires the grower to make
judgments to define the water
sources. The other thing that a
grower will see after following
the criteria in §112.42(a) for a
few years is the results likely will
change very little if the water
meets the water quality profile.
These items serve to double-check
everything that used to be true
about the water system when the
inspection was last conducted. It
confirms that these things continue
to be true.
To cover the last part of
this requirement, an annual
water system inspection can be
conducted. Many parts of this
inspection are likely wrapped up
in the farm's day-to-day activities,
sensors are in working order, it is
important to ensure check valves are
functioning properly. This is only
possible in those instances where a
check valve is accessible. If the system
you use does not have an accessible
check valve, one should be installed
when making equipment upgrades.
Another area of concern is the
water intake area for surface water.
In general, it must be kept " free
of debris, trash, domesticated
animals, and other possible
sources of contamination of
covered produce to the extent
practicable and appropriate under
the circumstances, " according to
§112.42(c) Checking for trash
around the intake or any things the
intake may have sucked to itself
is essential to both meeting GAP
requirements and the FSMA Produce
Safety Rule.
If one of the sources of water is a
well, it should be inspected as part
of this annual inspection too. Look
to ensure the wellhead is locked and
the conduit pipe for the electrical
is present and secure enough to
prevent access of insects and other
animals to the well. The same
goes for the vent hole. It should
be screened to prevent access. If
a concrete pad exists, ensure that
it isn't cracked, as this may be a
sign that liquid is infiltrating the
bentonite seal below it and swelling,
placing pressure on the concrete.
Currently, the FSMA Produce
Safety Rule water section is under
review. It is important to understand,
however, the requirements as they are
currently proposed, as there are often
key similarities between what was
under review and what ends up being
enacted. To find out more about water
system inspections, check out this
helpful YouTube video on water systems
inspections created by Michigan State
University Extension.
If you have specific questions
about water system inspections as
they relate to the Produce Safety Rule
or have difficulty performing one,
contact the Michigan State University
Extension Agrifood Safety Work
Group at gaps@msu.edu. VGN
http://www.valleyirrigation.com http://www.mvi.farm http://www.VegetableGrowersNews.com
April 2019

Table of Contents for the Digital Edition of April 2019
