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Fresh produce residue testing: an industry perspective: [paper presented to ChemCert Australia's National 2004 Conference, Canberra: 1 September 2004]



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Fresh Produce Residue Testing - An Industry Perspective Helen Lipton, Director, Helen Lipton & Associates

Ladies and gentlemen, What’s on that apple you’re eating? Hands up anyone who is concerned… Put your hand down if you prefer to eat organic produce. Thank you very much. Here is a simple indication of the level of confidence in the fresh produce industry.

The industry is very concerned about that apple and what else might be on it. The whole supply chain is working together to make it fit for consumption, and today I seek your support to make it a truly national initiative.

I plan to outline my experience with produce residue management during my role as a second party auditor for a large national fruit and vegetable wholesaler over the past five years.

I plan to cover the following points:

1. How do we reassure the public that fresh produce is fit for consumption? 2. What is residue management achieving? 3. The need for National consistency in chemical standards

1. How do we reassure the public?

But first, how do we reassure the public that the fresh produce they buy every day is fit for consumption? Just how effective is residue testing as a method of QC or quality control? I propose to you that a better approach is on-farm QA, to provide assurance that produce is grown under systems that minimise the risk of any residues.

If you know the industry is taking random samples for residue testing, would that make you more confident about eating that particular apple in your hand now? Can I really convince you with science and data and trends analysis?

Or would you be more reassured to hear that the industry has a comprehensive system of QA accreditation on-farm that includes residue management?

Research overseas indicates that the public don’t really care how much we know, they just want to know how much we care. And that is why programs such as Freshcare have been so effective on-farm. And “care” means preventative and pro-active residue management, using spray diaries, and an understanding of equipment calibration and with-holding periods.

Picture all those fruit and vegetable growers in their fields or glasshouses spraying their crop protection chemicals - they do it because they care, and because they cannot sell it to the “Fresh Food People” without strong documented evidence of their commitment, in the form of test data and QA certificates.

I am disturbed at the increasing pressure placed on growers by retailers for “quality standards” which are, in fact, contradictory.

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Current retail specifications demand demonstration of compliance to chemical residue standards through annual residue testing by every grower, as a form of quality control. I have been told repeatedly by retail executives that when a $28 billion brand is at stake, they will continue to require annual testing.

The contradiction arises when retailers will accept no more than 10% Minor defects, such as skin blemishes and marks. Surely this would increase pressure on growers to use more chemicals for that perfect apple! I observed that worrying trend in England last October, while on a Eurepgap tour.

Here is a clear opportunity for Government to review the impact of retail specifications on fruit and vegetable production, to ensure that residue management is effective. What better way to reassure the public that the fresh produce they buy every day is fit for consumption.

2. Residue Management.

I would now like to outline what is happening along the supply chain to manage residues. I spent five years auditing some 2,000 growers in Australia who were categorised as “Preferred Suppliers” to a major fruit and vegetable wholesaler. They had to meet stringent requirements in order to supply, as the final destination was often to some of the most demanding retailers and food service companies in Australia. So they may not have been representative of the industry.

I provided suppliers with a Preferred Supplier Manual, outlining the required standards, which in turn reflected the needs of customers. It referred to food safety requirements for water quality, fertilizer and chemical use, as well as harvesting and transport protocols to minimise produce damage and deterioration.

I maintained a comprehensive database to track my program of on-farm visits, to verify that a high level of food safety and quality assurance was actually implemented on-site.

By collecting copies of spray diaries, calibration records and QA certificates I monitored growers chemical use, and QA implementation. Growers were encouraged to identify each paddock as they harvested produce, to ensure complete traceability.

Growers have raised the issue of batch traceability on chemicals, and Avcare advises that the manufacturing industry needs to gear up for identification through bar coding in the future.

The Freshcare program is strongly promoted to growers who have not yet implemented QA accreditation, as this program is viewed as an ideal way to improve Good Agricultural Practice.

Residue testing is conducted through the excellent services of FreshTest Australia who receive hundreds of samples of fruit and vegetables collected by wholesale agents in Melbourne, Sydney and Brisbane. They test for 101 different analytes on a multi-residue screening program. I am very pleased to announce that Martin Clark, Program Manager of FreshTest Australia, has provided me with the latest national figures to present to you today, which provide a real insight into industry performance.

Let me start by defining the Maximum Residue Limit (or MRL), which is established by the Australian Pesticides and Veterinary Medicines Authority or APVMA for registered crop protection

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chemicals. The MRL is the legal limit allowed for residues of these chemicals on fruit and vegetables grown on-farm, and is usually at least 100 times lower than the food safety limit, so the margin of safety is therefore very high.

This data refers to a total of 7,879 tests conducted since November 2001, a period of two and a half years.

Chemical Violation Summary for all Produce Tested (FreshTest Australia, 27 Nov 2001 - 31 July 2004)

Chemical Common examples Number of

MRL Violations

Off Label Use Detections

Acaricides - Propargite - Buprofezin - Tebufenpyrad

Omite

1 6

Carbamates - Carbaryl - Pirimicarb - Fenoxycarb

Bugmaster Pirimor, Aphidex 500 Insegar

1 4

Fungicides - Chlorothalonil - Iprodione - Metalaxyl - Prochloraz - Procymidone

Bravo, Barrack 720, Rover Rovral, Civet Ridomil Sportak, Mirage Sumisclex 500, Fortress 50

5

6

3

2

22

0

17 1

5

20

Organophosphates Chlorpyrifos Dimethoate Methamidophos

Lorsban, Pirifoz, Chlorfos Rogor, Saboteur, Roxion Monitor, Nitofol

67 3

7

25 0

11

Synthetic Pyrethroids Bifenthrin Cypermethrin Permethrin

Talstar Summit Ambush

5

16 4

9

5

8

The first table shows that for all produce tested, Procymidone (commonly called Sumisclex 500, or Fortress 50) had 22 MRL and 20 “off label” use violations. Iprodione (commonly called Rovral) recorded 17 “off label” use detections. Chlorpyrifos (commonly called Lorsban, Pirifoz, or Chlorfos) has the highest chemical violation rate of all tests, with 67 tests over the MRL and 25 “off label” use violations. Cypermethrin (or Summit) was recorded with 16 MRL violations.

There appears to be an increasing number of detections of residues for which there is no established MRL. It is important for the industry to pursue APVMA approval for these chemicals, to avoid them being used “off label”, which automatically classifies as an MRL violation if detected, unless a Permit has been approved. I am mindful that there is some variation between different states about “off label” use, which supports the need for a national approach.

I emphasise that produce monitoring indicates that a wide range of Australian fruit and vegetables have recorded no chemical residues at all. This is shown on the right hand column of the next table, for the produce data I chose to share with you today.

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Produce Summary for Chemical Violations (FreshTest Australia, 27 Nov 2001 - 31 July 2004)

Produce MRL

Violation s

Main chemical involved Off Label Use

Main chemical involved Number with NO

residues detected

Apples Beans Capsicum Cucumber

Herbs (total) of which: - Basil

- Parsley - Sage

Lettuce Mango Melon Strawberries Tomatoes

4

5

19 14

34 9

7

4

20 4

9

7

5

Fungicides Chlorpyrifos, Cypermethrin Chlorpyrifos Chlorpyrifos, Methamidophos

Cypermethrin Chlorothalonil Procymidone, Synthetic Pyrethroid

Procymidone Prochloraz Chlorpyrifos Chlorpyrifos Chlorpyrifos

1

6

6

6

30 1

8

3

1

0

3

13 5

Methamidophos Iprodione Iprodione

Endosulfan Chlorpyrifos Fenthion

Deltamethrin

Diazinon Bifenthrin, Permethrin Fungicides

188 112 229 211

257 29 56 7

243 190 264 268 558

On this table the high MRL violations on capsicums and cucumbers, can be linked to the Chlorpyrifos I previously mentioned . You will note 20 MRL violations on lettuce, which was mainly procymidone, which has an MRL of 2mg/kg. MRL and “off label” use violations were high for herbs. There were also numerous MRL violations for Chlorpyrifos used on melons, strawberries and tomatoes. Off label use of synthetic pyrethroids was detected on strawberries.

A problem arises when a chemical is only registered for a specific fruit or vegetable, with the default MRL set close to the limit of detection, at less than 0.01 mg/kg, which usually results in an MRL violation when detected. To overcome this, if a chemical was registered for a group such as “leafy vegetables” for example, rather than just lettuce, there would be fewer “off label” violations on other leafy lines, such as endive and spinach.

Please take note that corrective action has been taken for all MRL violations. These have been communicated to the growers, usually through their customer, the Market Agent, who sought a written response as to the action taken to improve residue management. This is a very effective way of publicly increasing grower accountability, and ensuring test data is acted on. Otherwise the grower will not be able to sell any more produce.

So what seems to be the problem with growers? They don’t seem to understand how to calibrate their spray equipment, particularly the smaller rigs that have to be manually calibrated. In addition, the chemical labels are providing confusing instructions for application rates. These are both issues for ChemCert trainers to address in the future. For all those involved in training or other aspects of industry, I urge you to incorporate this vital information in your future decision-making.

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One initiative I know of in the Freshcare Grower Program is the translation of Training Manuals into Cambodian, Vietnamese, Mandarin and Tamil, to improve grower understanding. You heard some of these issues outlined earlier this morning. More funds are needed to support such schemes.

This is valuable information! Why isn’t Government showing more interest in it?

Here is an excellent database that could be purchased by Government to consolidate a national approach to monitoring. State Departments of Agriculture could use this information as part of their chemical residue programs, to determine where to target problem areas in each State.

Given the limited resources available these days, what areas should we be concentrating on? One important area is the need for a National Standard of Chemical Use Approval. Can you imagine the confusion and disruption it causes when a grower is supplying to a number of different states, or indeed if a wholesaler is sourcing from across Australia?

It is time this country developed a national approach to such an important area of control, to remove the anomalies between States! What is the scientific basis for allowing a chemical to be used, say, in Victoria but not elsewhere, without a Permit?

I question the value of the APVMA regulating chemical use on-farm, then immediately after harvest, the responsibility transfers to Food Standards Australia New Zealand or FSANZ. Different States have different chemicals registered for use on-farm, but if produce complies with the FSANZ standards at point of sale, it is considered “fit for consumption”.

While some progress has been made in this area, it takes 3-6 months to obtain an APVMA permit to use a chemical on-farm, then a further 12 months to have it registered by FSANZ. So theoretically a grower may not be able to sell produce if it is harvested between these two approval periods.

The challenge I put to this audience, is to seek your support for a national initiative in Chemical Safety Standards. Another issue needing attention is the increasing trend in off-label use of crop protection chemicals. The current system is not effective, as indicated by the test data.

What can Government do to streamline registration and use of these chemicals, which will encourage all growers to implement effective residue management?

Government must take a leadership role to clarify the current Standards and remove anomalies between States. This would prevent retailers driving the standard through Retail Specifications, which could prove very costly indeed to both growers and the community as a whole.

To sum up ladies and gentlemen, let’s make better use of this important data, to focus resources on growers needing support to use crop protection chemicals.

By adopting a National approach to chemical standards, we can ensure the most cost effective supply of fresh produce that is fit for consumption.