Introduction to Agri-Food Safety Podcast
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. I'm Allison Work and I'm the digital media designer for MSU Extension.
Water Risks and Produce Safety Rule Requirements
00:00:18
Speaker
Today we're going to be talking about the risks associated with water and what's required by the Produce Safety Rule when it comes to inspecting your water systems.
00:00:28
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My name is Marissa
Marissa Hsu's Role and Experiences
00:00:29
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Hsu. I'm with Michigan State University Extension. I'm a vegetable production educator. So the summer I spend a lot of time right now looking at a lot of rotten pumpkins, mushy peppers, stuff like that. But I also do a lot of this food safety, FSMA stuff on the side.
Jordan DeVries on Risk Assessments and Training
00:00:47
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My name is Jordan DeVries. I'm a produce safety technician covering the western half of the lower peninsula of Michigan.
00:00:56
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And I work with producers on the produce safety risk assessment. It's a meep like program to assess risks and get a certificate to show customers. And I also work with MSU extension on the on-farm readiness reviews and PSA grower trainings.
Don Steckle on Training and FSMA Compliance
00:01:16
Speaker
Steckle. I'm with the Produce Safety Alliance at Cornell University. I am actually located in Columbus, Ohio because I work with the 12 states of the Midwest or upper or north central region working on produce safety training, specifically the Produce Safety Alliance grower training in support of FSMA, produce safety rule. So I know we talk a lot about water here. Why is water such a big deal when it comes to produce safety?
Water as Contaminant Carrier
00:01:43
Speaker
I like to use the example that water is the universal solvent and it is also really good at being a carrier in that respect. And so it can get into a lot of the places on fruits and vegetables that we don't necessarily want something being introduced to that might be carrying a bacterial or fungal spore or a viral virion.
00:02:06
Speaker
And so what we're trying to, you know, reduce risk here, water can bring a lot of things in, be it through irrigation water or crop protection sprays, or even some post-harvest water. So we have to be on the lookout for, you know, bugs don't just magically appear on things. There's a carrier that moves from A to B, or they're moving through the air and the wind. And water is probably the best one out there for being a carrier.
00:02:33
Speaker
I think Jordan made some really good points that water is really important for crop production, and it's commonly used from post-harvest handling and sanitation. On a lot of the farms, water from those piped systems touches almost every unit of produce, so the sanitary quality of that water is really important for safety. I think it's important to point out how many outbreaks in the past several years have had water as a potential contributing factor in terms of how did the contamination get onto the produce.
00:03:03
Speaker
I think it's not just helpful to think about how important water is on the farm, but also how important water is to a lot of these pathogens that cause outbreaks. Water moves them around, but water is also one of the things things like bacteria need to reproduce. They can be a really good place for things like bacteria to reproduce. So not only do they move stuff around, but they can be places where, you know, one bug can become a lot of bugs if the conditions are right.
Ranking Water Sources by Risk
00:03:28
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So if we're talking about water sources, how would you rank water sources from the highest risk to the lowest risk? So I think it's helpful when you're looking at the different water sources you have on the farm to think about how much control you have over that water source.
00:03:44
Speaker
how much people, you know, maybe not just you, but maybe the municipality you live in, how many people are keeping an eye on what's happening with that water source. If you're using maybe city water on a small farm, there's a whole system in place that keeps bacteria out of that water if you're looking at a river that flows through multiple farms, multiple counties, multiple municipalities.
00:04:07
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All kinds of stuff could be happening in that river. And it's really hard to know what's happening upstream and how that might impact how sanitary that water is. So I think it all starts thinking about kind of control, how much you as a grower are able to control what's happening with your water sources.
00:04:24
Speaker
I guess I wanted to start by just going to the basics and a lot of the outbreaks that have happened with produce are from pathogens that are known as fecal oral pathogens and you can figure that one out for yourselves. It turns out that a lot of animals on the landscape
00:04:40
Speaker
Well, they don't use toilets. So not just water flows downhill, but everything water carries flows downhill. And so that's why I would start off by saying that surface water tends to be the highest risk because it has the exposure for all those things that are in the environment. So since we're talking about surface water, what are some other sources of contamination of surface water and how might growers minimize some of those risks?
Minimizing Surface Water Contamination Risks
00:05:06
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So I guess how much ability you have to minimize those risks again depends on how much control you have over the water source, even with something like a surface water source. You might, if you know it's an irrigation pond on the farm, you might have a little bit more ability to control how attractive that area is to animals who bite poop in the water. You have more control in that situation than you do if you're talking about
00:05:28
Speaker
pulling water from a river or stream. So I guess when you get into some of those really tricky kind of frustrating wildlife management type issues you have to tackle, you know, how do you, ways to make ponds and attractives that geese don't want to lay, you know mowing, riff-raff, scare tactics potentially, stuff like that can help
00:05:49
Speaker
keep animals out, so even the surface water that can be really risky or at least preventing some of the poop from getting on that hill to flow downward in the first place to return to what Dawn said earlier. I guess they haven't talked about really wells at all at this point, another really common source. One of you guys want to talk a little about wells and some of the risks there and what you can do?
Well Water Risks and Precautions
00:06:09
Speaker
I'll take that on. Even though things that are pooping don't normally live deep underground where the well water is coming from, we do have to be aware of some of the risks with wells. Basically, we're talking about how can water get from the surface into the well. I know we're going to talk more about the water safety system inspections later in the episode, but things like backflow prevention to make sure that water doesn't pour down the inside of the well,
00:06:37
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having sanitary seals on the well cap so water can't go down. Knowing whether or not your space around the well borehole is well-grounded and that water can't flow around the outside of the well. And then the other thing that makes me think about wells and risks with wells is the geology of the area that you're living in.
00:07:03
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people refer to karst areas where there are underground caves as areas where there are underground rivers. So even though the water might be coming out of the ground and coming from deep, the water that's feeding that well might have been on the surface fairly recently and might be carrying some fecal contamination. So although well water is generally considered to be safer because it has, if it's a well-developed well, it has that impervious layer between the surface and the aquifer that it's drawing from.
00:07:32
Speaker
there are still some vulnerabilities to be aware of. And Don, that's a great point too. In my area of West Michigan, we've got some areas where there's a little saltwater inundation into the deep horizons of the aquifers. So a lot of farms that do blueberries have to have a horizontal sock well, which is more or less maybe a 20 to 30 foot deep recharge well that they draw off. And we have to consider those as surface water sources because there's not a
00:08:01
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confining layer of clay to really filter out any bad pathogen bacteria. So we've talked a lot about these risk factors, but it's kind of hard for farmers to actually know how much poop is in the water source unless they're setting up motion cameras and being able to see when and where every animal poops.
Using E. coli Tests for Water Quality
00:08:21
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Is there any tests that can be done for them to get an idea of the sanitary quality of their water source? Yeah, so under the produce safety rule,
00:08:31
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you use testing for generic E. coli in your water to get an idea of if there might be bacteria and poop in the water. So when you're doing the test under FSMA, you're doing what are called generic E. coli tests. And what these are really telling you is that there's poop in the water. We're talking about E. coli. There's one toxicgenic E. coli species we're concerned about that causes outbreaks, but it's too expensive to test for just that one. So we test for just
00:08:59
Speaker
E. coli generally and E. coli bacteria that like to live, you know, like we've talked about in the digestive tracts of animals. So when you're getting generic E. coli hits, that basically is telling you there's poop in this water and there might be this toxicgenic E. coli in there, but there might be some of the other stuff we know can hang out and poop like salmonella, hepatitis A, cryptosporidium are all different things that can be found in poop. So if you're getting hits for generic E. coli, that means there's some poop in the water and there's some stuff you might
00:09:26
Speaker
You need to take a look at and think about when you're thinking about using that water for a really deep dive into the specific water testing requirements under FISMA and how to find a lab. Check out the notes of this podcast. We've done a whole episode about working with a water lab and figuring out the testing. So that's a good thing to check out if you want to really dig into this generic E. coli testing. All right.
Irrigation Methods and Risks
00:09:49
Speaker
So if we move on to irrigation, what method of irrigation is the highest risk when it comes to produce safety? And what's the lowest risk?
00:09:57
Speaker
I think what's usually considered high risk in the food safety industry is something where a surface water is going to directly contact the growing or harvestable portion of the crop, where we're really concerned with anything that may be in that surface water, being able to find a niche where it might be protected from sunlight on that crop, and then be able to have that be infected or contaminated.
00:10:27
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So certainly that's a high risk practice when we're talking about either solid set or maybe even a traveler or center pivot irrigation system that's coming off of a surface water source. Maybe even a pond that has been filled by a well, we still have to consider that surface water.
00:10:46
Speaker
I guess the other thing we see at least in Michigan as far as irrigation would go would be drip irrigation, which is generally considered a lot safer food safety wise for most crops, you know, if your drip irrigation system is working fine, no one has punctured it right over the track or anything that water is not going to touch the tomatoes, it's not going to touch the thing you actually end up harvesting. If you
00:11:10
Speaker
drip irrigating carrots, for example, that water would be touching the carrots. So there might be some risk there. But it's all about thinking about for your irrigation system you have on your farm, is that water going to touch the thing you eventually harvest? And if it is, there's going to be some level of risk.
00:11:26
Speaker
Marissa, you just brought up a great point, and I guess I wanted to ask a question of you to bring it out a little more. A lot of people think that drip irrigation, because it's not intended to contact the covered produce, it's lowest risk in general, but sometimes people don't think about what could go wrong. And I know you've got a lot of experience set in the field, and so do you, Jordan.
00:11:51
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Would you have some things that you might want to point out that could go wrong with drip irrigation that would cause it to be a higher risk?
Issues with Drip Irrigation and Precautions
00:11:59
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I mean, I would just say, you know, there are people operating your machines. There are people hand weeding out there like mistakes happen.
00:12:08
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I think a couple times a year, you know, I'm asked, like, I'm seeing some tomatoes with spots. Can you go out and look at them? It's like, you know, this is the reason there's spots in tomatoes. I'm going to send you a map point here. Your irrigation system is leaking like crazy and there's like a huge puddle and water squirting everywhere in the air. Like, I think this is the thing you really, like the tomatoes are spotted, but make sure you deal with this first.
00:12:28
Speaker
So even if you don't intend for your drip water to touch the produce, in any given year, things can happen with that system where it might still touch your produce. So I think it's good to acknowledge that that happens. And then that's one of the reasons it's still good to know something about the water using. Even if you don't intend for it to touch your crop, it still might. Just because, you know, we're working in human, human run system outside where, you know, errors in nature can make all kinds of things happen.
00:12:57
Speaker
Yeah, I've actually seen it on a few risk assessments where, and I often recommend to have people start their drip system up, even when they're not needing it, when there may not be a crop on the plants, but to see where it's spraying or emitting before there's a real risk out there with a covered crop on the plants. I've seen where voles have chewed drip lines and you might even get with enough pressure.
00:13:23
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a stream of water shooting straight up onto the crop and that would make that a overhead application like scenario. So then how can the timing of irrigation affect the safety of the crop?
00:13:40
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Well, I'll start because this is one of my sticking points a little bit.
Irrigation Timing and Crop Safety
00:13:47
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One thing that we know about is that the bacteria and other pathogens that can cause disease
00:13:55
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are generally happiest inside a warm-blooded animal that we've been talking about before. So they're expecting a 98 degree temperature. They're expecting moisture. They're protected from sunlight. So when the pathogen gets onto a crop in the environment, generally speaking, they're not well acclimated to being in that environment. They don't survive very well on that environment. So they're generally going to die off. So more time between application and harvest is considered a risk reduction measure.
00:14:25
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But I do want to point out that it's not fail safe. I believe it was Keith Schneider down in Florida, has research showing that salmonella on the outside of a tomato, if that tomato is oozing any juices with sugars, those salmonella can actually grow on the tomato. There's also research that researchers at USDA-ARS have done.
00:14:49
Speaker
showing that when water that is contaminated with pathogens is sprayed onto a blossoming fruit, those pathogens can actually get incorporated to the inside of the fruit, and they can survive inside that fruit. So in that case, time isn't going to be your savior. So in general, time helps, but the better approach or the safer approach is to avoid using contaminated water in the first place. All right.
00:15:16
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And then lastly, what is required by the FSMA Proto Safety Rule when it comes to inspecting your water systems?
FSMA Water System Inspection Requirements
00:15:24
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So when you look at what the FISMA Produce Safety Rule says about inspections, I think the most important thing to point out is the overall goal. And I'll quote just a little bit from the rule. It says that you need to identify conditions that are reasonably likely to introduce known or reasonably foreseeable hazards into or onto covered produce or food contact services. So, I mean, your goal is to find out
00:15:46
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Where is the hazard? And by hazard, we're talking about pathogens that might get onto the produce, and how are they going to get there? So there are a couple of clear elements on how to do that. Some factors in the rule that the FDA requires to be part of the water system inspection. First thing is, is it groundwater, surface water, or municipal water? What's the type of water? Second thing is, do you have control over it?
00:16:10
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In other words, if it's a pond on your property, you have control over it. But if it's a river flowing into your property, well, then you don't have control over it. So understanding your level of control is an important part of that inspection.
00:16:22
Speaker
Understanding if it's protected. In particular, we were talking about wells earlier. Are those wells grounded appropriately? Is the aquifer protected from infiltration from above, from surface water? So what's the level of protection of that water source? Another thing that's valuable to know and part of the rules requirements are what are the uses of adjacent land?
00:16:47
Speaker
You might know about the uses of adjacent land. You might not be able to control those uses of adjacent land, but we think about in particular things like the CAFO operations in Arizona that were potentially a contributing factor to some of the Romain outbreaks that we've had recently. Knowing what that adjacent land is being used for can help you understand some of the risks that might come onto your property, some of the hazards that might come onto your property.
00:17:13
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and help you make appropriate decisions. And then finally, in general, the requirement of the inspection is to know the likelihood that the water coming onto your land is contaminated. And all those factors kind of weigh into that decision of what's the likelihood that the water is contaminated. Then there's a whole other section about maintenance, but I'll stop there and let anybody else weigh in with their thoughts on the topic.
00:17:39
Speaker
Thanks, Don. That was a really great overview. I just wanted to point out that, you know, I think in a lot of cases, because farms are used to especially testing for any housing that they have of doing their, you know, standard E. coli test presence absence every year, really kind of almost relying on the test too much and not thinking about any possible changes to their water system that have occurred. Maybe it was a new person connecting things and putting them together.
00:18:08
Speaker
maybe even putting on the backflow preventer backwards. You want to follow that arrow that's there. And another one I like to point out too is in some areas with a lot of high calcium or even iron in the water, a backflow system, you want to check the actual plug or prevention mechanism to see if it's making a good seal because you may not be able to consistently get that seal year after year if you
00:18:36
Speaker
uh, got, uh, dissolved particles in the water. Or even just like zooming out a little from that, like is your back flow on your well, even something you yourself can see, or is it something that the guy who put in your well is telling you is there and it's underground somewhere, but you have no way of looking at it and verifying that it's still functional. That's something that I run into a lot on farms. Yeah. And if I had a dollar for every time I've seen, uh,
Maintaining Water Systems to Prevent Contamination
00:19:05
Speaker
well caps or cracks conduits, I might have a new career field to go into. And I think those comments play directly into the part of the inspection that has to do with maintenance because the rule does require that the distribution system be inspected and maintained to prevent water distribution system from becoming a source of contamination. So that's where backflow protection
00:19:32
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That's where cross connections come in. I have been aware of situations not in Michigan where people are using the distribution system to pump
00:19:44
Speaker
holding pond, manure pond water for a land application. And then they turn around and use that for irrigation the following season. So that's a situation where the distribution system might be a source of contamination. And then finally, the inspection of the water source or the maintenance of the water source requires that you look at conditions that might introduce hazards to the produce and correct deficiencies. And that's where they're talking specifically about, and they mentioned specifically,
00:20:13
Speaker
the well cap, the well casing, sanitary seals, tanks, treatment equipment, and cross connections as deficiencies in a well water source and distribution system that need to be corrected.
00:20:24
Speaker
The surface water has to be free from debris, trash, and domesticated animals, so you can't let your... So, I count children in with domesticated animals. Swimming in the irrigation pond is not an appropriate thing to do if you're using it as agricultural water. And then there's always the catch-all, anything that is practicable and appropriate under the circumstances.
00:20:45
Speaker
But it's not rocket science. We're trying to keep poop off of produce. And these are all things that we can look for to evaluate whether or not there's a contamination source or a hazard that could be carried to the produce or food contact services with the water. Yes, what I'm hearing is that the first part of it is kind of thinking through your systems you have, thinking about the things you see, and thinking about where the risks might be, and then a part that involves kind of walking through your irrigation system, making sure everything is functional.
Accessing Resources and Definitions
00:21:20
Speaker
Links or definitions 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.