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FSMA Compliant Water Testing
36 Plays5 years ago
This episode features Marissa Schuh, a vegetable production educator with MSU Extension, and Mike Snarski, manager of Summit Laboratory out of Grand Rapids, MI. They clarify what exactly is required by the Food Safety Modernization Act in terms of water testing, and they discuss how growers can communicate with a lab in order to get what they need.
For help finding a water testing lab in your area, visit:
https://www.canr.msu.edu/agrifood_safety/produce-safety-education/water
For a demonstration on how to take a water sample, watch this video: https://www.youtube.com/watch?v=uvjPyKKt66k&feature=youtu.be
Funding for this podcast was made possible, in part, by the Food and Drug Administration through grant PAR-16-137. The views expressed in the written materials do not necessarily reflect the official policies if the Department of Health and Human Services; nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
Funding for this podcast was made possible in part by the Food and Drug Administration through grant PAR-16-137. The views expressed in the posted materials do not necessarily reflect the official policies of the Department of Health and Human Services, nor does any mention of trade names, commercial practices or organization imply endorsement by the United States Government.
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Transcript
Introduction to Produce Safety
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. My
Meet the Experts: Marissa Shue and Mike Snersky
00:00:14
Speaker
name is Marissa Shue and I'm a vegetable production educator at Michigan State University Extension. I'm Mike Snersky. I'm the manager
Challenges in FSMA Water Testing Compliance
00:00:20
Speaker
of Summit Laboratory out of Grand Rapids, Michigan.
00:00:23
Speaker
So the reason we wanted to get together and talk about water testing is because when it comes to doing FSMA compliant water testing, it seems like growers speak one language, labs speak another language, and the FDA speaks a whole other language. So it can be very tricky to figure out what you need from a lab and how to find a lab that can give you the testing, the numbers that you need to comply with the Food Safety Modernization Act.
00:00:46
Speaker
So we just wanted to have a conversation to help you figure out how to get what you need from a lab. So in
Effective Lab Communication Strategies
00:00:52
Speaker
our experience reaching out to labs and figuring out if they can do the testing that's required by the law, we found that you can really get ping ponged around by the people who answer the phone, the sanitarian, all kinds of people can be involved in trying to figure out if a lab can do the testing you need to do. So we wanted to get a little input from Mike here, who has been on the other side of the line, who can do the testing on how to help you navigate this system.
00:01:14
Speaker
So I want to run by a couple of questions with you, Mike. Things a grower might ask and how, what you as a lab, what you hear when a grower asks this question. So a grower might call up, start the conversation with, can I get a water test from your company? What do you guys hear when you hear this kind of question? So when I receive a call from a farm that's doing the irrigation water, the main thing I need to know is what is the test for? Once they tell me it's irrigation water and they know that it's E. coli testing, then we know on our end that what they need, they need the enumeration E. coli.
00:01:44
Speaker
method ran on that water. So what it would transform into from there is I need to tell them there is a certain sampling period time that they need to get that sample to us. There is paperwork
Timing and Handling of Water Samples
00:01:58
Speaker
that they need to fill out. We'd like them to fill out the paperwork ahead of time if they can. That paperwork should be available. If they don't have access to the website, we can email that to them.
00:02:12
Speaker
Otherwise if they don't have that, we will fill that out when they bring the sample to the lab.
00:02:17
Speaker
Yeah, so you mentioned timing. One of the key parts about all the different testing methods under this rule is that it has a whole time of six hours. So that means you as a grower have six hours from the time you dunk that bottle in the water, take it from your spigot, whatever, to get it to the lab for testing. So you have a really short turnaround time. So it's important that even before you call labs, you know they're local and they're somewhere you can get in a pretty short turnaround time. Do you have any tips, Mike, for when you're transporting the sample from the farm to the lab, how to keep that sample good?
00:02:45
Speaker
Key thing is that timing because you need to look at your scheduling, when you're going to collect that sample, do you have time to transport that sample to us pretty much promptly after you collect it, how will that fit the schedule, making sure you're going to get to the lab within their normal business hour times.
00:03:01
Speaker
Our business hours are 830 to 5. Sometimes we can accommodate outside of those hours if you can't get to us in that time frame. But the
Guidelines for Sample Submission and Testing
00:03:09
Speaker
main thing is we have to receive that sample within that six hours. It has to be processed within that six hours.
00:03:17
Speaker
What you want to do with that sample is if you're holding it at any point of time you want to put that sample either in a refrigerator or in a cooler with an ice pack. Something that an ice pack better than ice we don't want ice melting and leaking and potentially contaminating the sample.
00:03:35
Speaker
What you would use is maybe a cooler box with an ice pack that you have designated for these types of samples and keeping it on an ice pack. Typically you're going to be out in the field so you probably have something that some kind of carrying vessel for your containers. So a cooler box that's designed to hold temperatures and then you can use that to transport that to the lab. The main thing is cooling it after you collect it, keep it cool.
00:04:01
Speaker
Don't let it get hot. Don't let it get into direct sunlight. So if you're using some kind of carrying vessel, it will protect it from that.
00:04:11
Speaker
Yeah, and when you're transporting it, it's also important that when you're taking the sample, before you even take it at all, that you have the right kind of sample bottle. In our experience, most labs in Michigan will provide you with a sample bottle. Mike, do you want to talk about what to look
Lab Capabilities and Surface Water Testing
00:04:23
Speaker
for in those? Yeah, the thing is what we are held to is they would state it as an approved container, and ideally an approved container is sterile. That was our best. We typically have those containers on hand. If you need several, we can provide you with that.
00:04:40
Speaker
That's the main thing is sterile container because you know when you put the sample in that that is what's being represented. It's just that sample not what was in that container. So our lab times, you know, we're open from like a Monday through Friday. We will accept samples Monday through Friday.
00:04:56
Speaker
from you know anywhere from 8 30 to 5 but we do on those on those days that if you're running towards the end of the day ideally we want to see that sample by like 4 30 so we have time to process that sample if it if it's going to run towards right the very end of the day letting us know ahead of time we're always willing to stay a little bit after to get that sample process but ideally we want that sample process by five o'clock yeah
00:05:23
Speaker
Another important question for Gore to ask is, do you do the tests in-house?
Testing Requirements and Methodologies
00:05:28
Speaker
This comes back to that six hour hold time we discussed. If that lab is patching up the sample and sending it out to the state lab in Lansing, you're going to miss your six hour hold time and that sample is going to be no good. So it's really important to understand that the lab is going to be able to do your test in the six hour timeframe, which likely means being able to do it in-house.
00:05:46
Speaker
Yeah, most definitely. The lab would have to do that. And what I would anticipate is that you're seeking out a lab that is certified by the state for the enumeration of E. coli that is offered to labs. I know it's a Michigan DEQ requirement.
00:06:06
Speaker
One thing that I've run into when trying to figure out if labs can do compliant testing is the language surface water. This is something that we talk about a lot with the rule. There's different testing requirements for what the FDA calls surface water. What do you guys hear as a lab when you hear surface water and what kind of information can the grower have to help you figure out what they're actually trying to get done?
00:06:26
Speaker
Yeah, the main thing, like I said earlier, is if they know that this is ultimately for irrigation, whether it's surface water, a well, either way, it's still going to be tested for the same enumeration of the E. coli. We know that the surface water obviously is going to have more of an influence from the E. coli than a well, but still they're going to be held to that same requirement to test for that.
00:06:55
Speaker
Under the rule, any water that touches the harvestable portion of the crop would be water that needs to be tested. So irrigation, even if it's, you know, water using for a fungicide spray that you need tested, irrigation might be a keyword for a grower to use to help really break through with the lab at what you're trying to get done. Another important thing I think to ask with surface water is if the lab can handle water that's cloudy or turbid. If you're taking the water sample from a stream or a pond, for example.
00:07:20
Speaker
Yeah, the turbidity will have an influence. It does make it harder for interpretation of the results. Ideally, the less turbid, the better. If the water has some turbidity to it, it's just a natural turbidity. That's fine. But if it's something that's stirred up because you're getting into the water and you're stirring up the sediment, and it's more turbid than normal, that will have an influence. We want to see that turbidity as less as possible.
00:07:48
Speaker
If it's a stream and you have to get in there, you know, obviously when you're going in you're collecting upstream the samples collected upstream of you instead of downstream because you're gonna be stirring that up if you have to get into a pond or surface water Same thing, you know getting in there and getting that sample collected as soon as you can so you're not stirring up a lot of sediment that's gonna be in there that naturally isn't there and
Tips for Accurate Water Testing
00:08:13
Speaker
So once you've figured out that the lab is able to test your surface bar, it's really important to make sure you're using one of the EPA testing methods that has been approved by the FDA. So as you're calling a lab that's new as a grower, it might be helpful to print out the list of approved methods. They're not easy to remember off the top of your head. They don't sound like regular English. So it can be helpful to have those printed off so that you can, if you're working with a new lab, kind of run through, I'm looking for
00:08:39
Speaker
Quantitrade 2000, Colatec, Colort type tests. Really know what you're asking for with the new labs. You can get what you want. Yes. As lab personnel, is there anything you want growers to know as they bring you tests, common mistakes you see in water testing?
00:08:56
Speaker
The main thing is obviously the representation, making sure the sample just represents what you're collecting, making sure you're collecting it in what we would say is an aseptic way you're not contaminating the inside of the container.
00:09:12
Speaker
And the key thing is documenting the date and time that the sample is collected, identification of that sample. So when we report it, that's what you want on the reports. The whole time that you're only allowed six hours and the type of container and how you're handling that sample from when you collect it to getting it to the lab.
00:09:38
Speaker
You don't want to go outside of that and make sure that it's not a true representation of that sample. Yeah, so all kinds of things that could artificially cause your E. coli numbers to go up or down. It could be you didn't handle that bottle, right? Maybe you didn't think it was clean, so you rinsed it out. E. coli is in the environment all around us. We have pets, we have kids. So we can introduce E. coli artificially into our water samples if we're not handling things correctly.
00:10:04
Speaker
The other thing too, the other thing is making sure you're collecting at least 100 milliliters of that sample. Most containers, they have an indicator on the container. If you're using an approved EPA container, it does have an EPA mark on there at the 100 milliliter mark. We want to make sure that you're collecting at least that. It can be more than that, but it needs to be at least 100 milliliters for a representation.
00:10:30
Speaker
And if your lab is doing one of these approved methods and giving you a bottle, it should be the kind that's going to give you the 100 milliliters you need to get one of these tests done. Thanks, Mike. I think
Building a Microbial Water Quality Profile
00:10:40
Speaker
this is really helpful. Lots of good information there that can help growers around the state figure out how to get the water testing they need done.
00:10:46
Speaker
So let's talk a little bit about what the law wants to see in terms of your water testing. So depending on your farm's gross annual produce sales, sometimes between 2022 and 2024, farms need to start building a microbial water quality profile. The numbers used by this profile are taken from a series of water tests. The water tests are meant to be representative of use, meaning you take them at the times while you're using the water. So you use it in time with frost protection, when you start your crop sprays, when you start irrigating, that kind of stuff.
00:11:15
Speaker
the number of tests you need to take to build and maintain the profile vary by your water source. For municipal water sources, no additional testing is required. Instead, growers need to get documentation about the monitoring and treating of the water from their local municipality. For groundwater sources like wells, in the initial year of testing, growers need to take four samples to the lab. These four samples will be the basis of the microbial water quality profile.
00:11:40
Speaker
The next year, one new test has to be done, and then you'll kick out one of the original tests in your profile, add in the new one, and do your math over again. From here on out, you'll just be taking one water test to the lab a year, adding that one to your profile, kicking one of your old numbers out of your profile, and redoing your math. So you'll be eventually working off a kind of rolling four-test average for your microbial water quality profile.
00:12:03
Speaker
Surface water sources like rivers, streams, canals, and holding ponds are open to the environment. This means it is much harder to predict the quality of the water. Thus, these sources require more testing. To build the initial profile, 20 samples have to be taken over the course of two to four years. Once you have these 20 samples, you generate your microbial water quality profile.
00:12:23
Speaker
The next year, you'll only need to take five tests. To regenerate your profile, you'll kick five old tests out of the profile, add your new five tests in, and from there recalculate with your new 20 sample microbial water quality profile.
00:12:36
Speaker
If you are currently testing, you don't need to do any radical changes yet, you're doing the right thing already. If you are a farm that has never tested your water before, it's good to start, as you can hear from this conversation, it can be really complex getting your water sampling regime in place and figuring out what labs can do the testing you need. So if you've never
Integrating Water Testing into Farm Practices
00:12:54
Speaker
tested before, it's a good time to start talking to labs, taking some test samples and figuring out how you're gonna work water testing into your farm's regular procedures.
00:13:04
Speaker
Links or definitions to anything referenced in this episode are provided in our show notes, which can be accessed on the website at c-a-n-r dot m-s-u dot e-d-u slash agri-food underscore safety. You may also visit the Agri-Food Safety website for additional produce safety resources, trainings, and assistance offered by MSU Extension. Thank you to everyone for listening, and don't forget to tune in next month for another episode of our Produce Bites podcast.