According to a recent article in Food Safety News, (More delay for Produce Safety Rule as industry balks over water testing) by Dan Flynn, March 20, 2017 the FDA are reviewing the water requirements and that could extend the compliance date into 2018.

I really think what got my attention in this article was a better understanding of what the regulation looked like.

Take a look at the regulation discussion here.

Look Closer at the Analysis Requirements

Surface Water Testing
Will require a minimum of 20 initial samples collected over two to four years. After that, farms must test a minimum of five samples a year. The microbial water quality profile will thus be updated annually on a rolling basis using a minimum of 20 samples. The calculation of the GM and STV will typically be based on the five new samples and 15 of the most recent
earlier samples.
Ground Water Testing
Will require a minimum of four initial samples over one year, followed by a minimum of one new sample each year. The profile will be updated annually using at a minimum the most recent four samples.
These are the minimum numbers of samples we consider statistically necessary to provide a picture of the surface and ground water quality.
A lot of pre-planning and management of analysis results will be needed going forward. At Midwest Laboratories, we currently have client systems in place for our customers to access their data online and we are looking at updating and improving this interface in 2017 to make it easier and more robust for our clients. In addition, our staff will be going through training in 2017 on this regulation and in particular this area of FSMA Produce Safety.
If you have questions about FSMA and how analysis is related to the regulation, please let us know how we can assist you.