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 Food Chain Activity 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