It can cost $50 million or more to federally register a new active ingredient pesticide for use in American agriculture.
Registration involves literally decades of product testing in labs and fields where rates are established and detailed use recommendations are developed — not only for maximum efficacy, but to ensure that the product does not pose harmful risks to people or animals.
U.S. growers, pest control advisers, consultants and applicators must follow those recommendations to the letter.
However, all that is increasingly going out the window because customers worldwide who buy U.S. products are demanding their own set of rules be followed for what they consider safe pesticide residue levels. This can come from individual countries, as well as individual buyers.
These maximum residue level (MRL) standards are often arbitrary and unscientific; yet growers who want global customers to buy their products must abide by these MRLs. Regardless of the safety of a product, shipper/marketers prohibit growers to use a product that may go into a market where there is no MRL established yet. Major domestic retailers like Wal-Mart also are setting their own MRLs and dictating how growers produce crops these larger retailers market.
A panel representing growers, consultants and grower associations brought this regulatory morass to the ground level when they talked about the impact of MRLs on production.
Renee Rianda, a licensed pest control adviser (PCA) for the nation’s largest tomato processor, Morning Star Packing Co., Williams, Calif., sends outs lists of approved pesticides to Morning Star contract growers.
Some pesticides on that list go with the caveats that growers may use the product only at half the label, EPA approved rate with a longer pre-harvest interval.
These requirements, she admits, come with “no rhyme or reason. You have to do as they say if you want to sell product,” she lamented at an MRL workshop on global regulations sponsored by the California Specialty Crops Council.
The MRL issue becomes even thornier because when a product is harvested and processed in the case of tomato paste, the grower and packer are not certain who will buy the product. Therefore, what applies to one customer spills over to other customers who are more than happy to abide by EPA.
The other part of this is crop and product reliability. Manufacturers, agchem retailers and others would likely not warrant products used at less than recommended rates and longer pre-harvest intervals.
Rianda acknowledged that the MRL issue can become an explosive one. A week before the MRL workshop in June, Morning Star had to relent on some of its half-rate edicts when growers were faced with major disease challenges during one of the wettest early seasons in several years. Growers were told they could use full label rates, if the crop condition warranted.
Brian Cieslar, agronomist for Enfield Farms, Lynden, Wash., a major raspberry/blueberry and strawberry shipper in the Pacific Northwest, called himself “the poster boy” for what can happen in this new world of MRLs and global marketing.
Two years ago, the farm shipped several containers of berries to Japan, testing them thoroughly for MRLs before they left. None were found. However, when the fruit reached Japan, authorities there detected trace amounts of a disallowed pesticide. The containers were shipped back at considerable expense.
This experience has made Cieslar even more cautious in making pest management recommendations. If he is considering using a product, he sees where it has an MRL established. If it has no MRL where the berries may be shipped, he looks for alternatives.
Gary Obenauf of the California Dried Plum Board said the state’s 22 prune processors make the decision as to what plum growers can use.
California prunes are shipped to more than 60 markets worldwide, which Obenauf said is typical of many California specialty crops. A large percentage of the state’s almond, walnut and pistachio crops are exported.
Fifty percent of California’s prune production from 70,000 acres is exported.
“MRLs have been on the radar screen for the past several years. Most packers pay close attention to the MRL databases that are available and test for residue levels before shipping,” he said.
The Dried Plum Board monitors MRLs worldwide and e-mails processors of any changes.
Even though plums are dehydrated in heat for 17 hours, which likely breaks down most pesticides, Obenauf says the industry continues to watch the MRL issue closely.
Since the industry is relatively small, it is easier to track and monitor pesticide use in the prune industry.
“There’s no MRL issue until a processor calls about a residue and that does not go over well,” he said. “Fortunately, there have been no overseas shipments of California prunes black-lined over MRLs.”
Dan Botts, Florida Fruit and Vegetable Association, said his producer members grow increasingly frustrated when they are told how to grow safe crops by buyers.
The system of MRLs is growing more complicated and he hopes it will some day become less burdensome with a global approach to registering new agchem products.
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