 Right, so let's shift gears here and talk a little bit about produce and safety of fresh fruits and vegetables. And today I'm going to be talking specifically about agriculture water and some updates, referring to the FISMA produce safety rule. So, first of all, why we need to focus on water? I always say that water is the major contributor to fresh produce contamination in the field. Also, post harvest is a big when it when produce is washed. But previous foodborne outbreaks there were linked to fresh produce. They identify that the source of contamination was contaminated water that was used in the field. And what water must need produce safety requirements. So agriculture water means all the water that is intended to use or is likely to contact the harvestable portion of the crop or food contact surfaces. So when we talk about agriculture water is water that is used for irrigation that is likely or touching the produce water that is used for fumigation frost protection. Water that is used for washing hands and food contact surfaces and what water that is used for facilitating washing and even washing produce up in the post harvest practices. And the water that we talked that the major requirement that we that it needs to meet its must be safe adequate sanitary quality for its intended use. So obviously we're not going to be using water from a pond full of cows to irrigate fresh produce, right. But also we need to make sure that these water is safe and adequate sanitary condition to use safely use for produce production, because we eat produce raw so there's no killer step in between that can ensure microorganisms are killed during the process so we need to make sure the contamination doesn't happen in the first into instance. And most of you that that are covered by the produce safe rule or our gap certified might remember this microbial water quality profile where growers were using for example, surface water, pond water, creek water. They had to do a 20 sample water sample over a period of two to four years and do and then after that period they they need to do a rollover of five samples annually and build the microbial water quality profile in order to comply with the requirements of the rule. If they're something that needed to be changed or if the water quality was compromised growers should take corrective measures to or stop using the water or treat the water or respect the water system in order to start getting back to the water to the same water source. Now the FDA stopped that criteria that 20 roll up water sampling and the microbial water quality it's now it's no longer required as the major component of the agriculture water for pre harvest. There is a new proposed rule that was released December last year for post hard for pre harvest egg water harvest and post harvest. It is still in the same standards they had it hasn't been changed so there's no. The stand is no the tech for generic equal eye in the water, and when they're tested, and now the new proposal rule for egg water it's it's talking about production water, and there are big changes on that rule. And if you're not covered by the produce safety rule but you're still get food safety certification through 30 parties. Keep in mind that food safety certifications they follow the regulations so once that this new rule the new proposed rule is finalized, the other food safety certifications will definitely shift gears to follow the regulatory requirements. And so what is new so I, I mentioned that the rule has changed it for production water. So we have some new definitions that grow or need to be familiar with. With the addition of a water assessment plan so growers need to do a new water assessment of the water source and the whole area that is the water that the whole system in order in documented in order to meet the record the regulatory requirements, which means a new required record to keep on on your system. Again, no changes to harvest and post harvest requirements or sprout water has been made. So this is just for production water for water that is used for pre harvest. And this new water assessment is based on the inspection of the water source and water system, maintenance of this water system, and much more. So this new water assessment replaces water testing that was I just mentioned that the 20 sample water in two to four years then five following samples every year in the microbial water quality profile. This is no longer our requirement it's becoming an option. What is the required is now the water assessment. And keep in mind that gap certification might still require water testing. The regulation hasn't been finalized yet and they gap regular gap gap certification normally requires a lot more than the water regulation asks. And right now, since the the regulation is not finalized yet. The inspections inspectors are enforcing discretion for agriculture water compliance states. So, goers should be learning at this point how to do a water assessments, but they're not going to be expected right now, because the, the, the rule hasn't been finalized yet. So this is a good time for goers to start getting more familiar learning how to do the water assessment before they have to do it for documentation and inspection purpose. So what is what is this water assessment. So it, it, it covers different factors so the first one is the agriculture water system so growers will be required to document the location in nature of the water source. Where the where the water sources is placed down the hill or uphill of the of the field. If you have animals around it's up here or down here as well. What is the type of the water source it's a groundwater is a surface water. So if you have water distribution. If you have an enclosed at systems or if you have a pump that is pulling out of the, of your creek or of your pond. And how much the system is protected, and a main is of the system as well so if you're in a good main is or if you're good. If you're using more, more than one water source so you have to describe each, each water source that you're using. If you have animals on your operation. If you have working animals grazing animals or wild animals or even domesticated animals you have to report that and where the animals are located. So you're starting your, your water and and at Jason and the nearby land use related to animal activity so let's say you don't have any more on your farm, but your neighbor, five miles away, they have it. It is, you have to report it because it might implicate on the quality of the water that you receiving on your farm. So we have to assess agricultural water practices, what kind of method of irrigation you're using if you're using overhead, or if you're using drip, or any kind of other irrigation system we know that irrigation plays a rest role and on on when is applied to the props so let's say if you're using drip irrigation is safer than you're using overhead and depending on the crop. So there's an interval between the last application of the water from the harvest. So the closer to the harvest the higher the risk. So you have to report when when you do the last water application for your specific crops crop characteristic so susceptible crops to surface adhesion and internalization so we know that leafy greens are more susceptible to contamination we see a lot of outbreaks on the news. So we have to report you if you have those more riskier crops or not environmental conditions so if you have a heavy heavy rain on your area if you have flooding events before or if you know that you have you're susceptible to flooding, or if you have a runoff that is going to your water source and the anything that impact or damage produce safety and and then we are in the hurricane season right now so we have to report that as well we don't often see hurricane our area but eventually we have heavy rainfall that could impact you know they will quality of the water, air temperature sunlight UV exposure. So let's say we are down here in Alabama we have much more sun exposure than than growers that are in Boston for example so we that's why it is important to report sunlight UV exposure and and any other relevant factors so that is where water testing results are included here so water testing is not it's no longer a requirement but it's a it's a it's optional. So it is to ensure is to show you that all of the things that you report and then it's, it's being under control. So, water testing this is still very important so this is the only way that you know the quality of the water if you're having high loads of microorganisms equal I, and then, depending the time of the year so it is an addition to your water assessment. So if you're doing any kind of the one of those three options here you don't have to do the water assessments. So if you can demonstrate by using one of the water testing that your water contains no detectable generic equal I. For example, you're for using ground water, and you've been consistently showing that you have zero generic equal I on your water. You don't have to do the water assessment you just have to keep testing and showing that you'd have zero generic detectable generic equal I or if you're using water from a public supply like city water. You can show a certificate or test his results from the from the from city water, and that show that is meeting record microbial standards so the annual report, you can get the annual report to keep on your records so if you're using city water, and then, and I have the, the, the annual test report, you don't have to do the water assessment, or if you're treating your water using EPA approved sanitizers, and this is not just an ordinary or shocking or well, once in a while, it is needs to be a validated certified method that it's it's ensuring over time that it's been an effective method. If you're doing one of these three options you don't have to do this water assessment that I just mentioned. And after you're doing all the water assessment. You're going to determine if your water is safe or not and the level of safety of the water. So let's say if your water, if you're after your assessment you, you conclude that the water is not safe at all you have a heavy animal operation in a farm. And if you have a lot of run off and the test results show that you have had loads of equal I, you need to immediately discontinue the we use, or use any of the water treatment or any corrective measure to, to fix that problem. If you have any, any problem that doesn't need to be immediately. If you have any problem that is related to animal activity. You can implement mitigation measures, if you're showing that you have animals around on a farm, but test results are still showing low bacteria count equal accounts that you don't have to immediately discontinue to use but you have to take mitigation measures to prevent contamination. If you're having a risk that is not related to animals, you don't have to take more immediate action, you have to test the water to see if that is getting within the, the range that sets the microbial water quality profile is still valid here so you can do it over time and use it. And if you're identifying that you don't have any risk that your water source is protected, you just need to do a regular inspector inspection and maintenance, at least once a year. Some of the mitigation measures that FDA suggested that you can do is you can, you need to maintain and do keep changes or repairs when you see any problems with your water application method or your well cap, or any well system or anything. You can increase time interval application between harvest, a minimum four day before harvesting so you can apply apply water for four days before harvesting so we will reduce or minimize the risks that are related to contaminated water. You can use time interval and storage, for example, and onions that are stored for long times that it accounts for die off of microorganisms. You can use commercial washing for example for citrus but be careful commercial washing is not for all produce so it needs to be for a specific and documented application methods so let's say if you have a higher risk water, you can use drip irrigation, if you're using overhead, let's say, we can treat your water but again you have to use validated methods and using EPA certified sanitizers for that or you can use UV method or non chemical methods as you know, but it has to be validated, or you can use any other alternative that is scientific based, scientifically validated, so they can minimize or reduce risks. And for post harvest and pre harvest post harvest and harvesting water. Again, no changes has been made remains the same so no detectable generic equal I per water sample and gap requires water testing but also requires SOPs for water use temperature treatment is required. So you're using dump tanks, which is not required for the produce safe to rule and monitoring of the treatment that you're adding to the water so this is this is one thing that you can keep in mind that produce rule. It stands for the basic regulatory standards but gap normally adds a little bit more so gaps already doing the water assessment for that, then the pre harvest water so for girls that are gap certified, you will not be much to add to your to your documentation is going to just need to be a little bit more detailed. And once the, the final rule, once the rule is finalized for pre harvest water. Growers that have business that make more than 500 K per year will have nine months to comply with the rule after the rule is proposed so the rule hasn't been proposed yet hasn't been finalized yet. So after it's finalized grows that make more than 500 K will have nine months to comply grows there between 250 500 K will have a year and nine months after defective date and very small business between 25 and 250 K per year, we have two years and nine months after defective dates to to be in compliance. So, within this period we can start grows can start working on the water assessment and getting more familiar before the rule is finalized and for post harvest and harvest water and compliance date sees the rule hasn't changed growers that make more than 500 K the compliance date is January 26 next year, small businesses January 2526 24 and very small businesses January 2025. And for those ones that want to become more familiar with this new water changes and regulation and and and want to test the water, because it's, it's, it's still important, even though it's not going to be required is still important to keep on a documentation and ensure that the water is safe. We have a program that is called egg water safety program that we offer my feed free microbial water testing, and also we provide educational support to growers to navigate to through the new requirements. So, you can scan the QR code here or you can access the link that is here, and you're going to fill up a pre screening survey and then we will reach out to you to provide more information how to receive the sampling. The sampling kit and how to ship it back to us and it will provide at the end a test result, a report that you can keep keep on your records. And if you have questions, please let me know just reach out to me I'm open for questions and discussion.