The U.S. Food and Drug Administration (FDA), in early December 2021, announced a proposed revision to Subpart E (Agricultural Water) of the Produce Safety Rule. Leafy Green Marketing Agreements (LGMA) in both California and Arizona have conducted a review of the initial proposal and say that the LGMA requirements meet and exceed the criteria in the proposed rule.

Since water can be a possible carrier of pathogens, the LGMA programs have always required growers to test their water. In 2019, the requirements were updated to include extra safeguards that ensure that growers complete the following:

• Categorize the source of the water
• Consider how and when water is applied to the crop
• Conduct water testing to make sure the water is safe for the intended use
• Treat water, if necessary
• Verify all of the above steps have been carried out.

This approach is called a "systems approach," and FDA is asking for a similar method in its new water requirements. 

The Produce Safety Rule, a part of the Food Safety Modernization Act, was published in 2015 by FDA. Both LGMA programs collaborated with FDA subject matter experts to align with the Produce Safety Rule. FDA formally recognized both organizations in 2017 for corroborating their food safety standards with the Produce Safety Rule. 

Both LGMA organizations will submit comments to FDA. When the final rule is approved, the LGMA programs will review and, if needed, make changes to ensure their metrics remain aligned with FDA's requirements.