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Assessing Your Agricultural Water Risk
61 Plays1 month ago
In this special episode of Produce Bites, we’re excited to share an insightful conversation originally recorded on The Food Safety Dish podcast, brought to you by the National Farmers Union’s Local Food Safety Collaborative. In this episode, Kathryn Cavenaugh interviews Phil Tocco as they explore the new FSMA Produce Safety Rule on pre-harvest agricultural water, along with tips for assessing your own ag water for potential hazards and risks. A big thanks to Kathryn and the National Farmers Union for allowing us to cross-post this valuable episode.
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Transcript
00:00:00
Speaker
Hello and welcome to the Agri-Food Safety Produce Bites podcast, where we discuss all things produce safety and dive into the rules and regulations surrounding the Food Safety Modernization Act Produce Safety Rule. In this special episode of Produce Bites, we're excited to share an insightful conversation originally recorded on the Food Safety Dish podcast, brought to you by the National Farmers Union's Local Food Safety Collaborative.
00:00:25
Speaker
In this episode, Catherine Cavanaugh interviews Phil Tocco as they explore the new FSMA Produce Safety Rule on pre-harvest agricultural water, along with tips for assessing your own ag water for potential hazards and risks. A big thanks to Catherine and the local Food Safety Collaborative for allowing us to cross-post this valuable episode. We hope you enjoy listening.
00:00:48
Speaker
Hello and welcome back to the Food Safety Dish, a production brought to you by National Farmers Union's Local Food Safety Collaborative. I'm your host, Kathryn Cavanaugh. Today, we're talking all about assessing your own agricultural water. It's true that you can't farm without water. It's also true that water can be the conduit of significant risk on farms. After all, water is life, and this includes all kinds of life. Unfortunately, this also includes some pathogens that also love water.
00:01:19
Speaker
If you haven't heard the news, there's a new water rule rollout from FISMA's produce safety rule that has just come into effect this year, 2024. And with it, plenty of conversations and questions on what is and isn't relevant.
00:01:33
Speaker
One of our goals here at and NFU's Local Food Safety Collaborative is to make information and resources more accessible to all farmers, including small farmers who are not covered or qualified exempt from the produce safety rule. But just because you aren't covered or have exemptions doesn't mean your knowledge of good food safety practices has to slip.
00:01:52
Speaker
We got today's scoop from Michigan State University's Extension educator and on-farm food safety statewide coordinator, Phil Tocco. Welcome to the food safety dish, Phil. We're really delighted to have you here and learn all about your expertise. um We'd love to have you introduce yourself and share a little bit about your background in food safety. Sure. um My name is Phil Toko. I work with Michigan State University Extension. I am based in Jackson County, but I cover the entire state with respect to to farm produce safety. I work with produce growers, very large and very small and everything in between. um Water happened to be one of those things that I sort of fell into, I sort of fell into the well. When they put the water rule on hold for a while, I got deeper into it, drilled deeper and deeper into the well.
00:02:40
Speaker
Very cool. And all water analogies are welcome if you if you feel like splashing into that. oh and ah Okay, so I guess let's just start off very broadly. And um the question is, how do you define risk on a small farm? And generally, what are the major risks associated with agricultural water? Okay, so what's interesting to me is the differences between hazards and risks. um the And we're going to talk a little bit about the FDA Water Rule, and it's really a hazard-based model. It asks you to look at all of the different things that could potentially introduce risk. So that's that's a hazard.
00:03:21
Speaker
But when an actual risk is the probability that that stuff, that hazard, is going to get into the water source and and foul it so that it actually makes people sick. So when I look at risks for people, we try really hard to separate the difference between a hazard and a risk.
00:03:41
Speaker
because there are lots of hazards that that won't ever be risks. If you're growing with an eight foot fence around your orchard, wildlife is not going to be a risk, but they are a present hazard in terms of around the the field. So it's it's important to look at it that way.
00:04:01
Speaker
So ah the hazard is like the potential and then the risk is like the hazard that is activated. Is that right? Is it is it a big deal? the The possible versus the probable. If it's possible, it's a hazard. If it's probable, it's a risk. With water, it's all about the poop, finding ways that that poop can travel. It's the routes of contamination and then the sources of contamination. So you know there's really three areas that we concern ourselves with in the broad sense with respect to water risk. And first is the source. you We've got high-risk sources and low-risk sources, high-risk sources like surface waters, particularly those waters that move. that Those are higher-risk sources. and And then as we move down, wells are sort of an intermediate risk. And then the lowest risk is treated municipal water.
00:04:54
Speaker
the So the source is one thing and then the next is how it's applied. So you can if you have a high risk source and you apply it in a manner that doesn't contact the harvestable portion of the crop, then you've got a ah you've mitigated that risk. It's a way to get in front of a risk. So the the application, obviously the safest is indirect application like drip under plastic when you're dealing with something that isn't gonna contact the harvestable portion of the crop.
00:05:21
Speaker
And if you're going to use a sprinkler and sprinkle all through the the canopy of say a tomato plant, that would be a a much higher risk application rate because it's there. And then the the timing of the application is important. If it's right up close to harvest, that's going to be a high risk application. So we need to make sure that we use a low risk source and a low risk application right up close to harvest. um A lot of times, a good example out west, and south in the southwest, a lot of times what what growers will do in leafy greens is they'll apply water overhead on leafy greens to crisp them up before they go through and and harvest them so that they're nice and firm because they grow in the desert.
00:06:07
Speaker
So if we think about that, that's a super high risk. It's right before harvest, like 12 hours before harvest. So it's a high risk application. So that water really needs to be super de-duper clean in order to get us a good product. There's not a lot of margin for error on that application. However, yeah a small grower that's planting tomato plants with a water wheel, that water can be super poopy.
00:06:32
Speaker
And in in the water wheel, and it can deposit, but because there's no flowers, because you're just transplanting tomato plants, it's never going to contact that harvestable portion of the crop. So the the water quality is immaterial. Hey Phil, Billy McCarthy from NFU and Smoker or myself here. um I'm wondering what are some examples of tools that for
00:06:59
Speaker
I could imagine, you know, visual inspection of equipment, doing water testing, but what are some things that you recommend and and how growers go about taking a look at cataloging maybe some of their hazards and risk potentials.
00:07:14
Speaker
One of the tools that's out there is a risk prioritization tool, which we'll probably discuss a little more as we get into things, but also there's an Ag Water Assessment Builder that FDA put together. ah it is It tries to help growers think through where the poop comes from, how the poop gets to the produce, and really help the growers think about ways that they can essentially get in front of the poop or stop the poop from getting on the produce. Whatever tool or whatever educational material you're you're working with, it really comes down to where's the poop, how's it getting there, and are there ways that you can get in between the poop and the produce so that it doesn't get on the produce.
00:08:02
Speaker
Absolutely. And if you'll indulge me, I'm thinking of an example from my own farm. Um, we, uh, just moved to a new location within the last year. And as we were doing an assessment of our infrastructure and, and going through the process of buying and moving into a new property, we have well water and we thought, you know, okay, that's a pretty reliable source of water. But when we did a full assessment, uh, it, or we, we have one well for irrigation and for household use and our septic tank is, uh, or was, um, too close within the county and state codes to our wellhead, uh, to be considered safe. And now when you're doing a hazard risk, is the septic, is the poop gonna float back uphill 75 feet is an extra 25 to 50 feet away from the wellhead, uh, gonna reduce the risk. I think it will. And it was interesting to go through that process with our county health Department and recognize that even though we thought we had a pretty safe source of water, there were some hazards
00:09:08
Speaker
present because of the way that the system had been constructed So within that, um you know, we talked a little bit about the different sources of water. You have surface water, pond water. I have friends that have to irrigate from streams because their wells have run dry or they don't have a ah current well or they don't have the electricity at the site to pump. So are there any you know particular other concerns that we wanted to talk about in terms of water source? And do you have any examples of where growers have had to consider you know changing or or supplementing their water because of you know contamination concerns. All the time Billy, first off my question to you about your well is how deep your well? You know that was one thing that we didn't get an answer on and I
00:09:55
Speaker
in it from a food safety perspective. I'm also interested, uh, you know, from a production and irrigation perspective, how deep does our well, how reliable is it? We did a flow test on it and we did, you know, contamination of a battery of contamination tests. Uh, we have one additional layer on top of that. We are, um, within the catchment area of the municipal water reservoir.
00:10:20
Speaker
So we have an additional layer of oversight and inspection, ah ag production facilities within this you know area. um get Get a checkup because we don't want to be contaminating ah you know a big reservoir.
00:10:35
Speaker
It makes good sense, but I mean, there's issues potentially around wells that go back to structural issues around the well. The depth of the well is a good example. The deeper the well, it tends to be safer than wells that are more shallow. um You get a lot more surface water influence if that if that well is less than 30 feet. In some areas, it's pretty easy to hit water. You could drill down five feet and hit water.
00:11:06
Speaker
that water looks like well water, but it's actually surface water. It's basically surface water influenced, if nothing else. Even if it's not essentially surface water, it's definitely influenced by surface water. So recognizing the fact that there's nuances of safety within each of these categories is really important. And it's a good reminder to me and hopefully to some of our listeners, if you don't know about what you have, it's a good first step to just do an assessment And I want to go back and try to figure out how deep my well is. And there are, you know, issues. I know that the well was drilled in 1954. So are there any structural, you know, long-term issues there as much information and knowledge as you can have about your setup that gives you a good basis to, I think. analyze what your hazards and risks might be. um Speaking of which, you mentioned the tool that you worked on, MSU, Cornell, University of Minnesota altogether. Can you talk a little bit more about that tool? I was really excited when I got to see it in person and I think our listeners would really value learning a little bit about
00:12:10
Speaker
The risk prioritization tool is a systematic way of helping to show you your risk in terms of a number. And the number ist is arbitrary. So with each risk or each bit of information you enter, we have worked with experts and looked at the literature to try and put together sort of the relative amount of risk contributed by each individual bit of information.
00:12:40
Speaker
So with that, each individual bit of information you get at the end, you get a a score that has that's sort of based in science, but also based in in professional judgment. So there there is a fair bit of professional judgment built into this. And that score then at the end is broken down. What were the contributors to that score?
00:13:06
Speaker
And the highest percentage contributors, you can then, if you if you did something to mitigate mitigate those highest percentage contributors, it could bring down your score. So you have a roadmap to reduce the potential risk. The higher the score, the higher the risk. So reducing the number means reducing the risk. and And really, the focus is where's the poop, how much poop is there on the landscape,
00:13:30
Speaker
or on the farm and then how much risk is there of that poop moving into the water sources. It really looks at, it or it incorporates a lot of interdependent variables. um Like, for instance, there may be poop on the landscape, but if that if there's no slope to the land and if there's no rain to move that poop into a water source, it's not getting there. And people out west are a good example. When it doesn't rain for 90,
00:13:59
Speaker
to 10 months out of the year, there could be a ton of poop on the landscape, but it doesn't get in the water sources because there's no way to carry it into the water. So thinking more holistically about those interdependent variables um with respect to um water, ah like like water wells, for instance, there's four basic ways that poop can get into the water so source.
00:14:24
Speaker
You know, it can it can come in through cross connections basically right down the pipe into it. And then there's also around the pipe. If the if there's no grouting or if there's bad grouting around a ah well, it basically can serve as a conduit down.
00:14:39
Speaker
to pollute the water source. Then there's surface water intrusion. If it's a shallow well, surface water can get in there. And then poop and all of the the contaminants that we associate with poop can also percolate down into the soil and slowly work their way into the well that way. So looking at all of those different variables, so recognizing that the amount of poop on the landscape is important,
00:15:04
Speaker
really breaking those down and helping a grower think through, okay, so I have a lot of poop on the landscape, we get a lot of water, how does that affect what I'm doing? And then what percent of the contribution of each of these risk factors contributes to that score? So you can go through, look at your ah list of risks at the end and say, okay, I can reduce my number or reduce my risk by thinking in terms of, okay, I'll change this, and then that'll reduce my risk further.
00:15:34
Speaker
Yeah, Phil, I got to see your tool back in March when I was at the North Central Regional Meeting. And um it was really timely that you guys were workshopping that right before the water rule came out, which if you're plugged into food safety, you know, is it a big part of FISMA that just dropped? So i'm I'm wondering if you could talk about the new FISMA subpart E specifically, that role and how it's different from the previous one. um And what, what are the most important things that growers should know?
00:16:03
Speaker
Okay, so subpart E is the new FSMA water rule. One of the key things to to realize is that ah water testing in the previous rule was the gold standard. You did a ah water system inspection and it was meant to be a real general, real light. There were five major aspects of the Ag water inspection.
00:16:28
Speaker
but it was very simplistic and the idea was that if something changed on that list significantly that was a signal to the grower that they really needed to pay attention to their water. It wasn't necessarily meant to be something that they do every time they irrigate or even more than about once a year. It was meant to be something that's sort of like okay I'm kind of thinking through this we've got We've got no problem. We're good to go. The the important part of the the original subpart E was the water testing. And it set a threshold that growers had to stay under. When it came to this new rule, they de-emphasized water testing. They said, you can test your water, but you don't have to test your water.
00:17:15
Speaker
you will instead need to do um something called an ag water assessment. The ag water assessment is sort of like a next level um ag water system inspection, water system inspection. So it does look at the water system, it looks at all of the factors that were in that initial water system inspection, and it adds a whole lot more underneath it.
00:17:40
Speaker
The goal of this is to get growers to think about, okay, for the water sources that I'm using that come into contact with a harvestable portion of the crop or food contact surfaces, the the first step is, is that water safe and of adequate sanitary quality? If it's not safe and not of adequate sanitary quality, then I need to stop using it altogether and either find another source or do some kind of of corrective action.
00:18:08
Speaker
With that in mind, like there being a new type of assessment, would you say subpart E looks at risk differently than previously? Yes, yes. um Basically, the feds are saying you can't test your way out of doing an actual assessment. The number one question is tell me what I got to do and I'll go do it. Unfortunately, this rule defies that thinking, that kind of thinking. It's not ah tell me what I got to do and I'll go do it. It's really trying to develop in growers a sense of looking at their water source, looking at the potential hazards. Can they get into my water source? What can I do about it? so that That's why you know it's it's very different. we're going to have a lot of There's going to be a lot of education. There needs to be a lot of education for a grower to be able to do this in a way that makes sense.
00:19:04
Speaker
So would you say that, um you know, by using these tools for risk and hazard assessment and analysis, would you say that it has an added effect beyond food safety that affects operational effectiveness or efficiency?
00:19:19
Speaker
So I think the biggest thing is really for growers, the more they can limit the amount of agricultural water they use, the better. Reducing the number of sources that you use to contact not only the harvestable portion of the crop, but those food contact surfaces and only selecting those sources that are high quality for that. Generally how, like if somebody identifies that they need to switch their water source, how difficult or easy is it usually to do that?
00:19:47
Speaker
Part of this this issue with the with these water system assessments or the ag water assessments is the number of sources you have, the greater the number of sources you have, the the more essentially paperwork, the more work you're going to have to do. Yes, testing can help you, can help reduce your potential for problems.
00:20:08
Speaker
But ultimately, if you can reduce those numbers of sources, in some cases it may be really easy. If I'm doing overhead irrigation on tomatoes, if I switch to drip irrigation on tomatoes, all of a sudden I don't have to worry about the water quality of that irrigation water anymore. I'm i'm more worried about just making sure I get enough water on there and maintaining my drip lines.
00:20:31
Speaker
Um, so there's, there's some value in not, uh, not using overhead irrigation, for instance. Um, in the case of like blueberries, for instance, you might have a blueberry field that's, that's hooked up with both drip and overhead irrigation, overhead for frost control and drip irrigation. So they need to think about, okay, if I'm going to use my overhead irrigation. during the season and they may use it overhead during the season, I'm going to have to worry about the risk of that water source. Whereas if I just use the drip during the season, I'm not going to have to worry about it it. It really requires them to think with every application, um is is the water going to get on the produce? Is there poop in that water? And how can I get in front of that poop? so Does that help?
00:21:25
Speaker
Yeah, I think so. um Basically kind of streamlining the water that people have is making it easier paperwork wise as well as ah without the kind of cloudiness of like, if there are contaminations, it makes it, I imagine, harder to identify which one it is because you have various water sources. Is that is that correct? And and um from the standpoint of paperwork and doing ag water assessments, if you can say, I have one source that I use for crop sprays, and I use that same source for post harvest water, and I use that same source for
00:21:58
Speaker
what little irrigation I do, particularly in the Northeast and the Midwest where we get rain. Those situations, that's a way to a way to really streamline your paperwork, reduce your exposure to the rule, and provide safer produce all at the same time.
00:22:16
Speaker
Well, do you have any um final advice or or I guess, yeah, any final advice to growers who are assessing risk, maybe they're new to it, ah resources to refer to, et cetera, just like what are kind of some of your golden rules or just good philosophies that you would share with people? So keep poop off food. Pay attention to where the poop is. Don't pick poopy produce. um Think about poop and and be the poop in the sense that for For lack of a better term, be the poop in terms of like, okay, where am I? How am I getting on my produce and what can I do to like like really try and and put yourself inside the bug's shoes, the bacteria's shoes, and really think about how it can get there and then get in front of it. I think there's ah real value in talking about what risks the things in water
00:23:07
Speaker
pose and how water carries those things onto crops. It's going to require all of us to work together and all of us to talk about this and get everyone thinking about, okay, I'm using this water today from this source and there's a potential that these things could be in this water. So the best way for me to use this water is X or Y.
00:23:30
Speaker
Great. Well, thanks so much for taking the time to talk with us and shed some light on this subject. I know there's a lot of confusion and some stickiness around Sephardi and just generally with regarding wire risk. So I think this will be really helpful. And yeah, we really look forward to sharing this. Thanks so much, Phil.
00:23:49
Speaker
Links to anything referenced in this episode are provided in our show notes, which can be accessed on the website at canr.msu.edu slash agri-food underscore safety. Thank you to everyone for listening, and don't forget to tune in next month for another episode of our Produce Bites podcast.