REPORT OF THE WORKING GROUP ON MAXIMUM RESIDUE LIMIT (MRL) IN TEA Dr. T C CHAUDHURI & Ms KATIE DONNELLY CO-ORDINATORS

Reporting and Compilations : Dr. K. Mohotti, Dr. Abeysighe (Srilanka), Ms Roshni Sen, Dr. M. Kumar, Dr. A. Barooah, Dr B. Bera (India) Dr. K. Yoshida (Japan) Prof. Z. Chen (China) Dr. Wachira, Dr E. Cheramgoi (Kenya) Dr. T. Henn (EU) Ms. L. Roberge (Canada) Mr. J. Simrany (US) Ms P. Parra (Argentina) Dr. M. Ahmed (Bangladesh) And Associated Scientists from Member countries

BACKGROUND (Ref doc CCP: TE 12/5) Recommendations of 19 th Session of IGG, Delhi (i) co-ordination, prioritization and acceleration of submission of dossiers for MRLs in tea, (ii) Producing countries shall carry out field trials on alternative pest management systems (iii) Involvement of all stakeholders, Codex, EU and other standard setting bodies (iv) pursue other activities to broaden the group to ensure alignment, (v) conduct a strategy review with a small subgroup of Working Group members to review the action plan.

ACTIONS TAKEN Holding Sub group meeting of WG in CANADA on 21 Sept, 2010 Following discussions, the participants once again reiterated the goal of the Group as: “To achieve global cooperation obtaining maximum residue levels (MRLs) in tea” and Identified major issues after deliberations on country positions, finally agreed on the goals of the group to tackle the issues. Finally, QUESTIONNAIRES developed and circulated

Report of the Sub Group was presented in the WG meeting in Kenya, Jul 18-19, 2011 along with information submitted by few members. The WG on MRL finally agreed in Kenya meeting on the Action Plan as decided.

ACTION PLAN IN WG MEETING, KENYA July, 2011 A.Agreed activities to achieve Objectives & Goal 1.To continue to generate data for MRL, submit to CODEX; 2.To identify Compounds for future trial; 3.To continue field trials on priority compounds; 4.To develop IPM in member countries

B. Action plans for all Four (4) GOALS  To develop & implement IPM strategies  To continue MRL submissions to JMPR, producing, consuming countries  To programme replacement of old / banned compounds, discouraging sudden withdrawal of approval without alternatives  To develop priority list of pesticides based on sustainability, affordability, safety  To give advance notice of changes in authorization  To develop effective communication plan.

ACTIVITIES identified to achieve GOALS PRODUCING countries --- key issues, goals SL Key issues (short)Goal (short) 1 Evolving pest pressures Develop and implement IPM strategies 2 Lack of MRLs, non harmonized MRLs Reclassification of tea from minor to major crop at JMPR; Obtain MRLs for chemicals in use in both producing and consuming countries 3 Replacement of old chemicals/banning of old chemicals Replacement programmes 4 Health, safety, sustainability Prioritization of chemicals based on health, safety and sustainability 5 Communication among stakeholders Effective plan for communication

QUESTIONNAIRES Re-CIRCULATED TO THE STAKEHOLDERS AND INFORMATION SOUGHT

Information from Questionnaires addressing Goals and Objectives GOAL - Pests affecting crop losses in tea. Objective – To identify different pests and economically important pests. – IPM strategies adopted in tea pest management. Objective – To identify different IPM strategies and record methods used to minimize use of pesticides used in pest management – Pesticide use in tea. Objectives - To identify old / banned / replaceable / withdrawn pesticides and record current list of substances / pesticides and alternatives / potential chemicals – Priority chemicals for MRL generation. Objective – To update the priority list of chemicals requiring MRLs in consuming countries and Codex.

RESULTS

Table 1: SUMMARY OF PESTS / Diseases AFFECTING CROP LOSSES (number of key pests given in parenthesis) Arge ntina Banglad esh IndiaJapanKenyaSri LankaChina Insects-8 (2)12 (5)104 (9)5 (3)16 (5)- Mites1 (1)4 (1) 9 (1)4 (1)5 (2)- Nematodes-2 (2)2 (1)14 (1)1 (0)3 (2)- Foliar disea-4 (2)210 (2)2 (2)5 (1)- Stem diseas--2-4 (2)5 (3)- Root diseas-2 (0)2 2 (1)6 (2)- Weeds--Num-ous--Numerous- Misc.---1 (0)2 (0)-- Ware H pest----6 (0)3 (0)- Total

Table 1: SUMMARY OF PESTS AFFECTING CROP LOSSES

Table 2: SUMMARY OF IPM STRATERGIES IN PEST MANAGEMENT Number of Asterisks (*) level of IPM practices adopted IPM strateg. Arge ntina Bangla desh IndiaJapanKenya Sri Lanka China Clone/cult--*** ****- Agronom** - Cultural********* - Biological-*********- Nat. enem******* *****- Pest forecs****-*- Chemical********* ** -

1.Agronomic and cultural methods are more prominent. 2.Harnessing of clonal selections, biological control, pest forecasting and modeling etc. are resorted only in a few countries. 3.Success experiences of clonal selections, biological control (biopesticides), pest forecasting and modeling etc. need to be incorporated in IPM strategies. 4.IPM strategies for weed management have become strengthening. 5.Mammalian and stored / ware house pest control warrants control measures. IPM strategies adopted:

Table 3: SUMMARY OF PESTICIDE USE No. pesticides used TypeArg’tnaB’deshIndJapKenyaSLkaChina Insecticides Acaricides Nematicides Fumigants Fungicides Weedicides

Table 3: SUMMARY OF PESTICIDE USE

Table 4: SUMMARY OF PESTICIDE USE STATUS Name of pesticide StatusArgt’naB’deshIndJapKenyaS LnkaChina Old Replaced Withdrawn Alternate Current Use

Table 4: SUMMARY OF PESTICIDE USE STATUS

OBSERVATIONS ON DATA 1. Pest occurrences are more in Japan, Srilanka, India and China – Old plantations, agro climate. 2. Major pests are leaf eating pests, stem pests, mites 3.Leaf, stem and root diseases are common. 4.Weed control is a major problem in tea 5. A few ware house pests are found as potential pests 6. Damage of pests depend on change in climatic scenario. 7. IPM is a new attempt to all – GOOD SIGN

North America Developments USA Endosulfan – FDA proposed deletion of all tolerances Apr 11 – All food crops except tea given 3-5 year expiry date – China on behalf of Tea industry lodged an objection, requesting 5 year extension/expiry date – Outcome awaited Petitions lodged with EPA for 3 compounds 2 new MRLs granted CANADA 1 new MRL granted

Submissions for Tea - MRLs Granted Australia CanadaUSA Lambda cyhalothrin 1 mg/kg May 102 mg/kg Jun 10 Petition with EPA Fenpropathrin2 mg/kg Sep 102 mg/kg Jun 11 Petition with EPA Bifenthrin5 mg/kg May 10 Petition with PMRAPetition with EPA Deltamethrin5 mg/kg Sep 10 Cypermethrin0.5 mg/kg May 10 Fenvalerate0.05 mg/kg May 10 Glyphosate2 mg/kg Sep 10 Chlorpyrifos2 mg/kg May 10 Acetamiprid 50 mg/kg Feb 10 Etoxazole 15 mg/kg Apr 11 Ethiprole 30 mg/kg Jun 11 Chlorantranilprol e 50 mg/kg Jul 11 Items in green - New since July 2011

Submissions for Tea - New MRL Petitions Australia CanadaUSA PropiconazolePetition with PMRA Submission 2012? Buprofezin Submission 2011 Petition with EPA Nov 2011, 20mg/kg Tolfenpyrad Submission 2010Submission 2011 Fenpyroximate Submission 2011 Clothianidin Petition with EPA Dec 2011, Plucked leaves 50 mg/kg Permethrin IR4 submission 2011 Dinotefuron Petition with EPA Sep 2011, Plucked leaves 25mg/kg ChlorfenapyrSubmission planned 2011/12

CODEX MRLs Confirmed CAC July 2011 – Endosulfan – revised 10 mg/kg – Bifenthrin 30 mg/kg – Thiamethoxam 20 mg/kg – Clothianidin 0.7 mg/kg – Etoxazole 15 mg/kg – Flubendiamide 50 mg/kg Scheduled 2012 – Chlorfenapyr BASF – Dinotefuran Mitsui – Buprofezin Nichino Planned submissions 2013 – Tolfenpyrad Nichino – Fenpyroximate Nichino – Fenpropathrin Sumitomo

EU Developments Changes to authorisations Granted 2011 Bitertanol, Buprofezin, Fenazaquin, Hexythiazox, Lime sulphur, Oxyfluorfen, Pyridaben, Azadirachtin Non-approved Propargite Resubmitted applications pending Bifenthrin Proposed changes to MRLs SANCO Adoption of Codex MRLs approved CAC July 2011 – Endosulfan, Bifenthrin, Clothianidin, Flubendiamide, Thiamethoxam, Etoxazole Discussed at Standing Committee Feb 2012 EFSA opinion – Hexythiazox 0.05* → 4 mg/kg

EU Developments ‘Article 12’ review of existing MRLs Substances a) not approved for use b) consumer risk identified → MRLs deleted unless substantiated Codex or Import tolerance Draft proposal SANCO – Dicofol 20 → 0.1*will lose EU & Codex MRL unless new Tox. data given toJMPR – Fenitrothion 0.5 → 0.05* – Tridemorph 20 → 0.05* – Chlorfenapyr 50 → 0.05* or no change? JMPR evaluation 2012 Change to LODs for a number of substances – E.g. DDT 0.2* → 0.05* * denotes LOD Discussed at Standing Committee Feb 2012

Process for Making MRL Submissions 1.Priority lists of MRLs 1.Priority chemicals for tea production 2.Priority chemicals for regulations internationally 2.Submissions for MRLs in tea 1.Identify opportunities 2.Identify field trial data from producing countries / AgroChem Co.s 3.Provide residue monitoring data 4.Provide summary of MRLs globally for tea 3.Build working partnership with Agrochemical Co.s 1.Open dialogue with AgroChem Co.s 2.Discuss priority compounds for tea & Co.s 3.Agree inclusion of tea in submissions 4.Provision of field trial data etc.

Important issues 1.Generally, all are pursuing revision of list of pesticides replacing old by new generation pesticides. 2.Current recommendations for pesticide use are based on upgraded list. 3.Current recommendations can be considered as PRIORITY list. 4.CONFUSION for chemicals as existing in both current and old list, e.g. Hexythiazox in old list in Japan; paraquat, carbofuran are old in India but in current list in Sri Lanka.

ISSUES for FUTURE Actions 1.Reviewing of existing national MRLs for tea and go for new label claim with MRL for new compounds. 2.Strike a balance between old and new generation compounds based on safety, sustainability, economics 3.IPM strategies are to be more effective reducing chemical load. 4.Residue data for computation and submission to JMPR 5.Importing country regulations to recognize efforts of producers taking residue data support from producers

ISSUES for FUTURE Actions (contd.) 6.Withdrawal of chemicals is a concern to producers. 7.Short and long term goals of WG to persist. 8.For better harmonizing of MRLs between EU, Codex, Japan and US – FAO to intervene for acceptance of information / field data 9.Develop uniform Risk assessment criteria 10.Based on the list of chemicals used in producer countries, to prioritize them and generate data for submissions 11.Make use of electronic forum of the FAO to share and exchange all information on pest management, pesticide use and data 12.To place pesticide manufactures on board for toxicological data submissions. 13.WG to meet soon in intersessional meeting for prioritization and to collate data.

GRAY AREAS Country information are lacking on – ** MRL, Number of compounds under trial, submission of data to JMPR. ** Capacity building in residue works. ** Cooperation in computation of dossiers with minimum 8 expts. **Communication gap

CONCLUSION 1.Priority list of chemicals and generation of residue data as per JMPR and submission to National regulators / JMPR / Importing country regulators. 2.To share constraints in pest and disease control in Producing countries by Non Producing countries to achieve Harmonization in MRL. 3.Sharing of residue Data bank by the Regulators while fixing MRL for tea is essential. 4.If points 1 to 3 above are followed, all will gain to over come this non-tariff barrier for sustainability

SUMMARY 1.Responses to Questionnaires strengthened the efforts in HARMONISATION of MRLs, but still a long way. 2.The efforts of residue data generation should continue for national as well as international use. 3.IPM to be strengthened. 4.Fixation of realistic MRLs is essential all through. 5. Tea as perennial crop needs ‘time allowance’ to switch over to new compounds vis a vis new MRLs THANK YOU