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egularly evaluated. To date, no study has been<br />

conducted to approximate the likelihood of<br />

<strong>il</strong>lness in people that consume fresh produce<br />

that has been irrigated with water at different<br />

indicator E. coli concentrations.<br />

Before the hard work of understanding risk<br />

to consumers can be done, however, we need<br />

to first understand the quality of irrigation<br />

water supplies across the United States. This<br />

is where irrigation districts in California and<br />

Washington have been helping. Following the<br />

release of the Produce Safety Rule and the<br />

subsequent AWP, my colleagues and I began<br />

actively pursuing irrigation districts across the<br />

western United States as partners in research.<br />

Since that time, we have successfully completed<br />

a multistate survey of indicators and pathogens<br />

in surface irrigation water supplies, followed<br />

by a multiyear study to validate the use of data<br />

sharing as allowed under section 112.47(a)(2)<br />

of the rule. Specifically, this provision allows<br />

growers to collaboratively monitor their water<br />

ABOVE: Melissa Partyka.<br />

The<br />

microbial<br />

quality of<br />

irrigation<br />

water<br />

supplies<br />

is at the<br />

heart of the<br />

matter.<br />

—MELISSA<br />

PARTYKA<br />

supplies, provided there are no reasonably<br />

foreseeable sources of contamination in<br />

between monitoring locations. In short, this<br />

means that growers along an irrigation canal<br />

or a piped lateral can all share their data and<br />

dramatically reduce the burden on any one<br />

grower. Without preliminary data, however,<br />

it is unclear how far away growers can be<br />

from one another and st<strong>il</strong>l collaborate, or<br />

even which factors along a canal should be<br />

considered “reasonably foreseeable sources of<br />

contamination.” We are actively analyzing our<br />

data collected from eight districts over 3 years<br />

to provide guidance on these questions and<br />

help growers begin the work of complying with<br />

the AWP. But much more work remains.<br />

Though we currently enjoy ample<br />

participation, it took us years to gain the<br />

trust of enough districts to make a robust<br />

study possible. In western states, irrigation<br />

districts are a gateway that researchers must<br />

pass through to gain access to surface water<br />

distribution networks. Though the AWP<br />

places the sole responsib<strong>il</strong>ity of water testing<br />

on the grower, in the West the source of<br />

many growers’ water is under irrigation<br />

district control. Partnering with irrigation<br />

districts is also much more efficient for<br />

researchers, since districts already have a<br />

bu<strong>il</strong>t-in relationship with growers and can act<br />

as honest brokers of information. However,<br />

fear of potential liab<strong>il</strong>ity has led some districts<br />

to respectfully decline opportunities for<br />

Food Safety Modernization Act–related<br />

collaboration. Thus, the science of agricultural<br />

water tends to be concentrated in a few<br />

research-friendly irrigation districts, reducing<br />

our ab<strong>il</strong>ity to capture the broad diversity of<br />

agricultural water conditions experienced by<br />

the majority of produce growers. Even with<br />

access and helpful partners, public funding<br />

for this type of research is extremely limited,<br />

and research takes time. Again, districts may<br />

be able to help by lobbying state and federal<br />

legislators for increased funding for rigorous,<br />

and ultimately publishable, research of surface<br />

water irrigation supplies. But for now, growers<br />

and regulators w<strong>il</strong>l have to make do with the<br />

best ava<strong>il</strong>able research and hope for better. IL<br />

Dr. Melissa Partyka is an extension specialist<br />

at Auburn University and is an aff<strong>il</strong>iate for<br />

the UC Davis Western Institute for Food<br />

Safety and Security. She can be reached at<br />

m.partyka@auburn.edu.<br />

IRRIGATION LEADER 19

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