Maximum Residue Levels –Why Should You Care?

Cindy BakerGowan Group

March 17, 2010

Definition MRL = Maximum Residue Level MRL is the maximum residue level legally permitted in

or on food or animal feed –it is an enforcement tool for product in trade –in the US called a tolerance

MRLs are set for each pesticide on individual commodities or for crop groups

MRLs are set by regulatory authorities – US EPA, PMRA (Pest Management Regulatory Agency -Canada), CODEX, European Union (EU), Japan, Taiwan, etc.

MRLs are generally expressed in mg/kg (ppm) – based on a use pattern and a risk assessment- an exceedance does not equal an unsafe risk

MRLs can be set differently by different regulatory authorities

Why should you care? Because your customers are or will be asking you

more questions about them as they’ve become a bigger focus for growers, shippers, registrants, researchers, etc.

Global trade – 20-30% of US production is exported to about 150 countries. When making spray recommendations, you might not know where the commodity will go and if an MRL is an issue

More countries establishing and enforcing their own regulations –lack of harmonization

Old tolerances are being lost or changed Tolerances for new chemistry not all in place

globally at the time of US registration

Unique challenges for Minor Crops

Perishable commodity Generally higher value Generally fewer products

registered for use Crops grown in close proximity to

each other Crop Groups

What is happening around the World with MRLs United States – Food Quality Protection Act

(FQPA) over 9,000 tolerances reassessed Canada –Default MRL (.1 ppm) going away EU –harmonization –Sept 2008 CODEX –Committee on Pesticide Residues Japan –Positive List -enforcement Taiwan –process-enforcement Australia

Private Regulation Global Gap

Not an MRL per se Certification

Nature’s Choice Not an MRL per se either List of products –red, yellow, green

Food Chain Activity Wal-mart, McDonald’s, Tesco

How do you keep up? Start with the registrant also can check

these websites www.mrldatabase.com www.mrlharmonization.com

Additionally, some time in November, Western Farm Press is planning to offer for CEU credits a MRL class for free so check it out at www.westernfarmpress.com or www.capca.com

What to do if there is no MRL for a product you want to use

Contact the registrant Understand the impact of the use

pattern Understand the requirements of

the country to which you are exporting

Registrant Perspective – what is needed Clear, transparent process around the world Harmonization of data requirements and

review Consideration about what to do with minor

crops Minimize impact of changing processes,

data requirements – transition, consideration of sharing data and data reviews, etc.

Potential Solutions Continue global registration process

and acceptance More acceptance of Codex

tolerances Better communication among all

stakeholders An accepted system that helps to

prevent multiple regulatory and private company standards

Thank You very much for your role in producing the most abundant, safe and affordable food in the world