Industry Reaction and Perceived Barriers to Implementation of the Preharvest Water Requirements (Subpart E) from the United States Food and Drug Administration Produce Safety Rule

The United States Food and Drug Administration proposed new Produce Safety Rule requirements for preharvest water in December 2021. It is unclear if growers are utilizing water treatment as a corrective or mitigation measure or perceive the proposed requirements as easier to implement. The objectives of this study were to describe fresh produce grower responses to the proposed rule for preharvest water management, query if growers are currently treating preharvest water, and identify the most significant barriers growers face when treating preharvest water. An anonymous survey was distributed via Qualtrics™ to various sectors of the produce industry from March to August 2023. Descriptive statistics were used to determine frequencies and distribution of responses. Ranking of barriers to effective preharvest water treatment were assessed by inversely weighting. Statistical analysis was conducted using RStudio version 4.2.3. Forty-six respondents completed the survey (n = 46), identifying primarily as growers (36/46; 78.3%). Approximately half of respondents reported having read the proposed rule (15/32) and having a poor understanding of the requirements (20/40). The largest barrier identified was the impact of treatment on soil. Educational water treatment programs emphasizing practical implementation and decision-making strategies are needed to support grower use of water treatment as a corrective action or mitigation measure.