FSMA Agricultural Water Compliance: Could Ozone Treatment Be the Answer?

The April 6 FSMA agricultural water compliance deadline marked an important milestone for small produce farms.

Leah Morganroth
Ozone International

April 6 Deadline

The April 6, 2026, FSMA agricultural water compliance deadline marked an important milestone for covered small produce farms. Under the FDA’s Food Safety Modernization Act (FSMA) Produce Safety Rule, these farms must conduct agricultural water assessments, document potential risks, and implement corrective or mitigation measures when hazards are identified.

For many produce operations, the practical question is: What does an effective corrective measure actually look like?

Ozone water treatment is one option worth considering.

Effective water treatment is only part of a food safety program. Documentation matters, too.

How Ozone Supports Agricultural Water Safety

Ozone is an established antimicrobial technology used in food processing and produce wash-water applications. Under appropriate treatment conditions, it can reduce bacterial and microbial pathogens, including E. coli, Salmonella, and Listeria.

For pre-harvest agricultural water, the suitability of ozone treatment depends on the specific system, intended application, and applicable regulatory requirements. Operations should confirm that their chosen treatment method meets the requirements for their particular use.

Unlike treatments that rely on stored chemical products, ozone can be generated on-site from oxygen or air. It breaks down into oxygen and does not leave a persistent chemical residue under normal treatment conditions. On-site generation can also reduce the need for chemical storage and handling, although appropriate system operation and safety procedures remain essential.

One Technology for Multiple Food Safety Needs

For fresh-cut processors and packinghouses, ozone may offer benefits beyond agricultural water treatment. Depending on the system configuration, it can also be used in produce wash water and to support the sanitation of equipment and product-contact surfaces.

Using one technology across multiple applications can help operations streamline their approach to microbial risk management. The appropriate system and treatment parameters will depend on water quality, the intended use, and the requirements of each application.

Why Documentation Matters Under FSMA

Effective water treatment is only part of a food safety program. Documentation matters, too.

Covered farms must maintain records of their agricultural water assessments and applicable corrective or mitigation measures. Treatment monitoring and performance records can provide additional evidence of how a water management program operates.

Ozone systems with integrated remote monitoring and datalogging can help operators track treatment performance and maintain supporting records. These records can contribute to compliance documentation, alongside required assessments and other applicable records. Monitoring data alone, however, does not establish compliance with every FSMA requirement.

Is Ozone Right for Your Operation?

With the compliance deadline now passed for covered small farms, growers, fresh-cut processors, and packinghouses have an opportunity to review their current water treatment methods, identify potential gaps, and ensure their food safety documentation is in order.

Ozone may be a practical option for operations looking to manage microbial risks while reducing reliance on stored treatment chemicals. The first step is determining whether the technology is appropriate for the specific application and regulatory requirements.

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