1. Maximum Residue Levels –Why Should You Care?
Cindy Baker
Gowan Group
March 17, 2010

2. 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

3. 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

4. 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

5. 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

6. 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

7. How do you keep up?
Start with the registrant also can check these websites
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 or

8. 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

9. 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.

10. 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

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