CFA submitted the following comments on the U.S. Food and Drug Administration’s Proposed Rule to amend the agricultural water standards of the produce safety rule under the Food Safety Modernization Act (FSMA). While CFA supports FDA’s efforts to finally implement FSMA’s water standards, the comments raise concerns with the lack of enforceable, prescriptive standards in the Proposed Rule. According to the comments, FDA should provide clearer directions for growers and inspectors alike in the final rule, and in particular, clarify that water assessments required under the Proposed Rule must incorporate validated microbial testing, and that growers must treat water in certain high-risk circumstances.