FDA Publishes Agricultural Water FAQs and Information on FDA’s Implementation of the Pre-harvest Agricultural Water Requirements under the FSMA Produce Safety Rule
Constituent Update
September 30, 2025
Today, the FDA posted new frequently asked questions (FAQs) related to the agricultural water requirements in the FDA Food Safety Modernization Act (FSMA) Produce Safety Rule, as well as updated information on how it will implement the pre-harvest agricultural water requirements. These efforts are part of FDA’s continued commitment to engagement and collaboration with stakeholders to improve science-based strategies to prevent foodborne illness from produce.
As shown through outbreak investigations, agricultural water can be a major conduit of pathogens that contaminate produce. As such, the FSMA Produce Safety Rule establishes requirements related to agricultural water. In May 2024, FDA published a final rule that revised certain requirements for pre-harvest agricultural water for covered produce (other than sprouts). These systems-based requirements are in addition to those that were already in place for harvest and post-harvest agricultural water.
The FAQs were developed to provide information about the agricultural water requirements based on topics covered in the final rules, including the following:
- Inspection and maintenance of agricultural water systems,
- Pre-harvest agricultural water assessments (including testing as part of an assessment and assessment outcomes),
- Harvest and post-harvest agricultural water requirements,
- Corrective and mitigation measures, and
- Agricultural water treatment.
In addition to these new FAQs, FDA is also collaborating with industry on the development of a forthcoming best practices document for managing agricultural water.
Compliance dates for the pre-harvest agricultural water requirements for covered produce (other than sprouts) are staggered based on farm size, beginning on April 7, 2025, for large farms. Compliance dates for the harvest and post-harvest agricultural water requirements have passed for all farms.
The FDA is also releasing updated information about how it plans to implement the pre-harvest agricultural water provisions of the Produce Safety Rule. The updated information focuses on the key elements of the agency’s approach to FSMA implementation, including education (for both industry and regulators), industry training, technical assistance, inspections, and compliance, both domestically and internationally. The agency is committed to taking an “educate before and while we regulate” approach to supporting compliance with the pre-harvest agricultural water requirements. The FDA continues to work closely with state regulators, educators, industry partners, and others as these requirements are implemented.