Although yesterday’s announcement (FDA Proposes Changes to Food Safety Modernization Act Rule to Enhance Safety of Agricultural Water Used on Produce) is a bit to fully digest in one sitting, I am intrigued by FDA’s focus on pre-harvest risk assessment of water risk as opposed to water testing for pathogens generally.
The FDA’s requirement of an annual water risk assessments by farms to “determine whether corrective or mitigation measures are reasonably necessary to reduce the potential for contamination,” arguably creates “HACCP for produce.”
