The U.S. Food and Drug Administration (FDA) has proposed to delay enforcement of agricultural water standards required under the Food Safety Modernization Act. CFA submitted the following comments in response, opposing the delay, which FDA’s own cost-benefit analysis shows will hurt consumers more than it will help industry. The comments also question the length of the delay, which would set compliance dates for some provisions back by four years, from 2018 to 2022 for large companies. Critics of the rules have argued that most large companies must already comply with similar water standards required by private, third-party certification schemes. However, food safety regulations and government inspection serve an important check on these private certifiers, who are paid by the companies they are tasked with scrutinizing.