The California Leafy Greens Marketing Agreement (LGMA) is changing the way growers will be looking at water on farms. The food safety certification program represents all but one percent of the leafy greens growers in the state, which means its stringent new requirements for water use in irrigation will have sweeping changes for the industry.

“One of the big paradigm shifts is that we're looking at the complete water system,” said Hank Giclas, vice president at Western Growers who has been closely involved with LGMA in the revision process. “This is about going in and evaluating the source, evaluating the distribution system and evaluating the manner in which the water is used.”

The new standards are a direct response to the two E. coli outbreaks in romaine lettuce last year, traced back to farms in California and Arizona. The Food and Drug Administration announced in February that the California farm had used untreated surface water for overhead irrigation. The new LGMA standards now require any open water sources used for irrigation within the 21 days prior to harvest to now be treated.

Giclas admitted that, while the research as it stands today points to 21 days as a conservative estimate, academics have argued over variations in the amount of days needed to kill off bacteria depending on climates. The metric may change as LGMA and others pursues more scientific investigation. 

LGMA also mandates growers to start categorizing every water source (canal, reservoir, well, etc.). The classification will determine if testing beyond the generic E. coli is needed. This addresses recent concerns over bacteria like the deadly E. coli O157: H7 strain. Testing for generic E. coli is still required for all water classes, while open water sources will require more testing for total chloroform.

“We’ve come to the agreement that not all water is created equal,” said Dan Sutton, chair of the LGMA executive committee.

Sutton, who is also the general manager of the Pismo Oceano Vegetable Exchange, noted that LGMA is continually looking for ways to improve the standards. With the outbreaks, however, the leafy greens community felt a sense of urgency and went to work right away, he said.

“This represents a very significant step forward,” said Stephen Ostroff, who was serving as the FDA’s deputy commissioner for foods and veterinary medicine during the outbreaks. “The things that I think are really important that I see in these changes are: really assessing the intended use of the water, how it's being used, and to assure that the water is adequate for its intended use.”

The LGMA guidelines now call for routine monitoring and verification that all precautions have been taken.

Ostroff did have concerns over continuing with the current standard of testing for generic E. coli, but recognized it will take time to come up with better ways to improve that testing. Other details will also be ironed out as LGMA refines the metrics over the coming weeks and months. Further down the road, LGMA will likely be returning to the issue of concentrated animal feeding operations (CAFOs) and the proximity to water sources.

Implementation of the new water standards will depend on how quickly the FDA and the California Department of Food and Agriculture upgrade their audits for the five mandatory government inspections required each year for LGMA members.

Meanwhile, LGMA’s organizational work is shifting toward outreach, as it educates growers on the new standards and encourages food retailers and distributors to select LGMA-certified growers.