FDA and EPA Approve Pre-Harvest Water Antimicrobial

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FDA and EPA Announce Approval of Antimicrobial Treatment for Pre-Harvest Water

by: Food and Drug Law at Keller and Heckman of Keller and Heckman LLP - The Daily Intake

Friday, November 8, 2024

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On November 4, 2024, the U.S. Food and Drug Administration (FDA) and the U.S. Environmental Protection Agency (EPA) announced the registration of the first antimicrobial treatment for pre-harvest agricultural water. This new treatment, a combination of hydrogen peroxide and Ethaneperoxoic acid, can kill harmful pathogens like Salmonella and E. Coli in the water used to grow crops prior to being harvested.
This approval marks a significant step forward in agriculture and food safety practices. Previously, treatments for pre-harvest agricultural water were limited to managing algae, biofilm formation, or produce rot, with no treatments specifically approved for killing human pathogens.
The new registered product aligns with the FDA’s revised rule under the Food Safety Modernization Act (FSMA) on agricultural water. This rule replaces previous microbial quality criteria and testing requirements with system-based assessments. Farms must evaluate various factors, including the nature of the water source, water distribution systems, and potential contamination sources from nearby land uses. The rule also requires farmers to implement appropriate mitigation measures to minimize risks. Treating water with this new approved antimicrobial treatment aligns with the mitigation requirements under this rule.
Products designed to protect humans from disease-causing pathogens are referred to as “public health” pesticide uses, which require a high bar for efficacy data at the EPA, making cross-collaboration between the EPA and the FDA essential in moving this registration forward. The development and registration of this treatment involved joint collaboration between government agencies, academia and industry, highlighting the importance of joint efforts in advancing food safety.