Transcript Maximum Residue Levels - University of California, Davis

Maximum Residue Levels –
Why Should You Care?
Cindy Baker
Gowan 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



Nature’s Choice



Not an MRL per se
Certification
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