Arizona and California LGMA Programs Meet and Exceed FDA’s Proposed Water Rule

On December 2, 2021, the U.S. Food and Drug Administration (FDA) announced the release of a proposed revision to Subpart E (Agricultural Water) of the Produce Safety Rule (PSR).   The LGMA Food Safety Programs in Arizona and California have conducted an initial review of FDA’s proposal and have determined that the LGMA requirements appear to meet and exceed what is in the proposed new rule.  See the table here for a comparison.

The LGMA programs have always required growers to assess and test their water because it can be a potential carrier of pathogens. In 2019 LGMA requirements were updated to include additional safeguards that ensure growers: categorize the source of the water; consider how and when water is applied to the crop; conduct water testing to assure the water is safe for the intended use; treat water if necessary; and verify that all the above precautions have been taken.  This is called a systems approach, and FDA is proposing similar methodology in their new water requirements.

FDA published the Produce Safety Rule as a part of the Food Safety Modernization Act in 2015.  Both LGMA programs worked with FDA subject matter experts to align with the Produce Safety Rule.  In 2017 both organizations were formally recognized by FDA for aligning their food safety standards (also called guidelines or metrics) with FDA’s Produce Safety Rule.  It is a priority for both organizations to align with FDA requirements.  

The Arizona and California LGMA’s applaud FDA for its work to enhance water requirements under the Produce Safety Rule.  FDA has initiated a 120-day comment period on the proposed revision, which will be followed by the FDA rulemaking process. The LGMA organizations will be submitting comments to FDA.  When the final rule is approved the LGMA programs will review and if needed quickly make changes to ensure their metrics remain aligned with FDA requirements.

About The LGMA:   LGMA members produce over 90% of the Nation’s lettuce and leafy greens – adding up to over 50 billion servings a year.    In an effort to provide consumers with safe leafy greens, the LGMA verifies food safety practices, enforces through government audits and requires a commitment to continuous improvement.  Learn more at