Food Protection Trends - November/December 2022 - 461

The PSR was finalized in 2015, to take its place as one
of the seven foundational rules under FSMA; it is the first
U.S. federal regulation to have established science-based
minimum standards for the safe growing, harvesting, packing,
and holding of fruits and vegetables grown for human
consumption. In December 2021, the FDA proposed a revision
to Subpart E of the PSR that would change the preharvest
agricultural water requirements for covered produce, other
than sprouts (32). The FSMA PSR and the proposed
revision state the considerations and requirements related to
agricultural water management to improve the microbial safety
of agricultural water and, therefore, of produce. In December
2021, FDA announced their intent to exercise enforcement
discretion and also act to extend the compliance date for the
agricultural water (31).
As per the FSMA PSR, " agricultural water means water
used in covered activities on covered produce where water is
intended to, or is likely to, contact covered produce or food
contact surfaces. " Agricultural water is classified into two
categories based on the different usage periods: production
water and postharvest water. Production water refers to
water used during growing activities, whereas postharvest
water includes all uses of water during or after harvest (7,
31). Because the use of postharvest water occurs so close to
consumption, microbial water quality is especially important
(6). Thus, produce growers must meet the requirements of
§112.44(a), i.e., no detectable generic E. coli per 100-mL water
sample for water used postharvest. The proposed revisions
to Subpart E focus on production (i.e., preharvest) uses of
agricultural water. These revisions emphasize conducting
agricultural water assessments for production water sources
and uses, eliminating the federal requirement of an ongoing
microbial water quality profile with periodic updates through
water quality monitoring.
Each year, Kansas and Missouri growers produce approximately
$26 million (13) and $81 million (7), respectively, of
fruits and vegetables. Kansas State University and University
of Missouri Extension educators have been providing training
and information on agricultural water microbial quality, based
on current and newly proposed FSMA PSR agricultural water
requirements, to help produce growers from Kansas and Missouri
reduce risk to produce from agricultural water. Although
research shows that knowledge gain alone leads to limited
behavior change, it can provide people with more informed
choices that may or may not lead to behavior change (16).
Pratt and Bowman (21) suggest that individually relevant,
problem-focused, and hands-on activities can help extension
educators prompt personal behavior change. To help prompt
this positive behavior change, educators need a better understanding
of the gap between water quality best practices and
produce growers' knowledge and actions related to agricultural
microbial water quality.
Survey research (20) is one method that allows extension
educators to easily understand a large number of growers'
current water practices and knowledge gaps in a relatively short
time. Surveys have previously been conducted to assess growers'
general produce safety knowledge (18, 19) and needs (17)
to help them to comply with produce safety best practices.
Perry et al. (18) found that North Central U.S. produce growers
have a knowledge gap in understanding agricultural water
handling practices compared with other topics of the FSMA
PSR, which highlights the need for food safety extension educators
to focus on delivering information on agricultural water
best practices to produce growers.
This survey aims to determine gaps between safe water
management practices (as outlined in the FSMA PSR
requirements and proposed requirements and other produce
safety best practices) and (i) the current knowledge and
(ii) the current practices of produce growers from Kansas
and Missouri related to agricultural water quality. Based on
this knowledge, extension educators will be able to develop
additional training and resources on agricultural microbial
water quality to better meet the needs of growers.
MATERIALS AND METHODS
The project team developed a 14-question survey
instrument based on similar surveys (17). Before
implementing the survey, four extension experts reviewed
the survey questions for face and content validity. The Kansas
State University Produce Safety Extension Associate also
performed cognitive interviews (14) with growers from the
target population to further validate the survey. The Kansas
State University Human Research Institutional Review Board
approved the use of the survey. The survey (Appendix 1)
included questions on the growers' knowledge and practices
related to microbial water quality and was administered from
October 2020 to August 2021. Due to in-person meeting
restrictions related to the COVID-19 pandemic, produce
growers mainly completed the survey online in Qualtrics
software (Qualtrics XM, Seattle, WA) (n = 76) during online
produce safety-related trainings or by distribution of the online
survey link to email listservs of produce growers in Kansas and
Missouri. Other respondents (n = 30) completed paper copies
of the survey during an in-person horticulture farm field day
or in-person produce safety training sessions. Two drawings
for gift cards were utilized to incentivize participation in the
survey both online and in-person. To optimize data collection,
potential survey respondents were asked to complete the
survey only if they were able to answer questions related
to their operations' water management practices. Because
most produce farms in Kansas and Missouri have only a few
people working on them (29, 30), we are confident that most
people filling out the survey are actively involved in the water
management practices on their farm and are, thus, qualified to
complete the survey.
The 14-question survey instrument included multiple
choice questions with some open text response options designed
to understand growers' knowledge and practices related
November/December Food Protection Trends 461
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