How will it impact you?

How will it impact you?

In December of 2021, the Food and Drug Administration (“FDA”) announced that they would postpone the Produce Safety rule water compliance requirements, subpart E, while seeking agriculture industry feedback. The comment period on the proposed rule change ends on April 5, 2022.

The Michigan Greenhouse Growers Council is seeking grower members’ thoughts, feedback and rule impacts.

Specifically, the proposed rule would amend the subpart E of the FDA Food Safety Modernization Act’s Produce Safety Rule. The change would implement pre-harvest agricultural water “assessments” versus the pre-harvest microbial quality criteria and testing requirements for “covered produce” other than sprouts. The assessments are being looked at as a way to identify conditions that are likely to introduce hazards into or onto produce/food contact surfaces and to determine if corrective actions are needed to minimize risks.

Under the rule, “covered farms” would be required to do pre-harvest agricultural water assessments once annually. As part of the pre-harvest assessments, there will be a requirement to evaluate the following factors:

  • Agricultural Water System(s) – Location and water source
  • Agricultural Water Practices – Application method
  • Crop Characteristics
  • Environmental Condition – Frequency of rain, air temperatures, and sun exposure

The Michigan Greenhouse Growers Council asks for your review and feedback on the proposed changes on the FDA’s website located here (

Click here ( for a frequently asked questions document.

Other Water Rule Resource, produced by MSU Extension and MDARD are available at .

Please send your questions and/or concerns to Cindy Ray ( or or  by March 31, 2022.

Jared Rodriguez
Executive Director, Michigan Greenhouse Growers Council

Cindy Ray
Author: Cindy Ray

Cindy has years of experience in association management and administrative support.