The Need to Harmonize Maximum Residue Levels

Nearly All Produce Has Zero Residues of Crop Protection Products

By Mikenzi Meyers, Associate Editor

It can be tempting to grab a piece of produce right off the shelf and take a bite. We have the California Specialty Crops Council and the MRL Workshop to thank for this! MRL stands for the Maximum Residue Level on any agricultural produce.

Now, the words “residue level on produce” may be alarming, but it is important to note that we are talking about parts per billion that are far below the unhealthy level. In fact, nearly all produce has zero residues!

maximum residue level
Gary Van Sickle, Specialty Crops Council

The MRL Workshop is an event that has been held for the past 12 years in San Francisco, where experts from around the world come together to discuss new findings and challenges.

Gary Van Sickle, executive director of the California Specialty Crops Council, explained that a significant issue within the industry is the lack of harmonization amongst the countries.

“You’ve gone from a situation where many countries that used to use the Codex Food Safety Standard are now moving forward with setting their own, and every one of these standards is a little different,” Van Sickle said. “This creates problems for agriculture producers trying to export produce to countries with their standard.”

The MRL Workshop helps to identify these problems and recognize how to start solving them. According to Van Sickle, the keys are transparency and regulations that are reasonable.

When considering the number of specialty crops California exports across the world, the importance of this workshop becomes more and more evident.

Safe Food Alliance Helps Farmers Cope with MRL Disharmony

California Farmers Cope with MRL Disharmony


By Patrick Cavanaugh, Farm News Director


California farmers are careful with crop protection products because they know the importance of producing safe and wholesome food for their customers across the nation and in their export markets. “However, I think that there are some real challenges facing growers in California today,” said Thomas Jones, senior analytical services director for the Fresno-based Safe Food Alliance.

“As growers send their commodities around the world, they’re facing increasing challenges of knowing the right chemicals to apply and at what levels. We have our own strict regulations within California, if needed, [that govern] not only the application but also the maximum residue levels (MRL) or tolerances allowed for various crops,” said Jones.

Thomas Jones, senior analytical services director, Safe Food Alliance, MRL Disharmony
Thomas Jones, senior analytical services director, Safe Food Alliance

“That’s also carried onto the federal level; we have very strict EPA regulations. But as we [export] into other countries, they may have entirely different regulations,” said Jones. He noted this could be confusing not only to farmers, but also to registrants of crop protection materials because there is a lack of standardization of MRLs in different countries.

“Historically, there was the CODEX system, a UN-based system geared towards a more international standard for pesticide residues. It was very thought out, and very scientifically based,” Jones said.

However, as Jones explained, many countries do not want to follow the important scientific standard. “Increasingly, we are seeing countries want to establish their own systems, their own tolerances. They may be responding to their own political pressures within their countries.”

“We are seeing a process called ‘deharmonization’ in which every country wants to establish its own positive list of what is allowed and what is not allowed in [farm] products. Sometimes, those are in agreement with U.S. regulations and California state regulations; sometimes they are not. So it is important that [our] growers know not only what is legal in this country and in our state, but also what is allowed in their target [export] markets.”

Jones commented it is now known that some of these marketers [apply] random low MRLs and keep other MRLs high on some of their own products in order to get a marketing edge. “Some of those MRLs may or may not be based on any scientific standards.”

“There are a number of great tools out there,” he said. “There are a number of great software programs. Obviously, anything that [information growers] can get out of the print media or any educational courses are really essential. It is important to work with your Pest Control Adviser (PCA), as well. It’s important that [farmers] know what they are up against, as far as growing these crops,” said Jones.

The Safe Food Alliance is available to growers to help them qualify to meet the standards in the U.S. and abroad. “We [provide] training twice a year on fumigation safety for the various processors of dried fruits and tree nuts. We focus particularly on commodity fumigations and on what treatments are allowed and not allowed. We also have a full-service pesticide-testing laboratory and are very aware of the requirements in these other countries, so we’re happy to help both processors and growers with our monitoring efforts,” noted Jones.

Featured Photo: For these California-grown peaches to be shippable to any out-of-state U.S. consumers or international export markets, they must meet scientific Maximum Residue Levels (MRLs).

C O D E X  A L I M E N T A R I U S, the international food standards, guidelines and codes of practice contribute to the safety, quality and fairness of the international food trade. Begun in 1963, Codex standards are based on the best available science assisted by independent international risk assessment bodies or ad-hoc consultations organized by Food and Agricultural Organization of the United Nations (FAO) and World Health Organization (WHO). Consumers can trust the safety and quality of the food products they buy and importers can trust that the food they ordered will be in accordance with their specifications.

Rossi Tackles MRL Harmonization

Lois Rossi Tackles MRL Harmonization

By Patrick Cavanaugh, Deputy Editor

Lois Rossi, who signed off on nearly all crop protection products at the United States Environmental Protection Agency (EPA) for nearly 37 years, spoke to attendees at the recent Maximum Residue Levels (MRL) Harmonization Workshop in San Francisco. Rossi gave her thoughts on the need for MRL harmonization throughout the world.

Rossi was responsible not only for the registration of all conventional pesticides but also for the re-evaluation of approximately 400 active ingredients. Since 2004, she served on the Codex Committee on Pesticide Residues (CCPR) and was a member of the US delegation to the Organization for Economic Cooperation and Development (OECD) Working Group on Pesticides and the Registration Steering group.

“There are process challenges from Korea, Taiwan, the EU, and Japan,” said Rossi, adding some are so difficult that not much can be done because of policy and regulation challenges. “Of course,” she explained, “I will suggest some harmonization opportunities, of which there are a plethora, and there is even a new one now with the Crop Group MRL. Just as you think you nailed that MRL calculator, somebody comes up with a different way,” she noted.

Rossi said at some point the industry needs to figure out how to tackle more of its impediments. “We have tackled some, but I don’t think everyone is there yet.” Rossi suggests information is probably the hardest hurdle to manage because there are so many foreign journals and varieties of global websites. “Like I said,” she explained, “the global MRL database has certainly been a lifesaver for many of us. But to keep up with regulations and procedures from countries to which our growers export commodities is somewhat of a full-time job for many, let alone those whose livelihoods depend on exports or who are dealing with MRLs.”

Determining and understanding different data requirements are also challenging. Rossi noted registrants struggle to determine not only how many field trials a particular country requires, but whether they can be conducted within or outside of the country. Some countries require six, some four. Some regulations vary if it’s a minor crop or a major crop. Rossi said keeping up with these requirements, updated testing methods, NGOs doing their own testing, as well as improved technologies that measure smaller amounts of residues is difficult. So, going to one place to figure it all out would be great.

“And then there is the wonderful world of Codex*, particularly with its capacity limitations. Rossi believes the Codex process has improved, but not its capacity. “That’s pretty much as old as Codex is,” she said.

“Some countries have default MRLs that differ, and some have private standards, which will take hold if the public loses confidence in the public standards and the national processes,” Rossi said. “So countries are establishing their own MRLs because of public pressure; consumers want safe food and they want their government to guarantee them safe food. If that confidence is lost, you will probably still have standards, but you will probably have less control because you are going to have private standards.”

*”The Codex Alimentarius or “Food Code” was established by FAO and the World Health Organization in 1963 to develop harmonized international food standards, which protect consumer health and promote fair practices in food trade.”  Source: C O D E X  A L I M E N T A R I U S,

MRLs and Crop Protection Materials are Improving but Complicated

MRLs and Crop Protection Materials are Improving but Complicated!

By Laurie Greene, Editor and Patrick Cavanaugh, Associate Editor

Rachel Kubiak, Environmental & Regulatory Affairs director with the Western Plant Health Association, based in Sacramento, commented that crop protection materials are improving. They target specific pests and they are set to maximum residue levels (MRL’s) when sold domestically or internationally. Yet, they are quite complicated.

“The materials are getting better,” Kubiak said, “but I would say that there is a large component that I don’t believe the activist community understands,” noted Kubiak.

Richard Cornett, director of communications for WPHA, blogged, “What most people are unaware of is that there is a highly integrated and multi-layered process of safety procedures to assure that pesticides are accessed for their safe use around humans and in the environment.”

U.S. EPA (a) scientifically reviews all pesticides for safety before registration, (b) involves EPA scientists at the Office of Pesticide Programs, the Department of Fish and Wildlife, as well as other departments, (c) guarantees that any pesticide used in the U.S. has been accessed and is safe and (d) applies tolerances only to produce grown in or imported into the United States.

In California, the Department of Pesticide Regulation (DPR) enforces EPA tolerances by sampling produce for pesticide residues from throughout the channels of trade, both domestic and imported, including wholesale and retail outlets, distribution centers, and farmers markets.

“There are complications in making those products available to our growers,” Kubiak said, “because so much of what we produce in California is exported to other countries, and this MRL issue complicates things.”

Foreign countries follow an international standard called CODEX Alimentarus which contains a list of pesticide MRLs. EPA tolerances and International Codex MRLs are not harmonized; residue on an imported commodity can trigger a no-tolerance-established assessment and removal by California DPR while being a legal residue in other countries.

“I think this is a large area in which we could do better. Educating those who don’t live in our world on the difficulties in bringing new products to market isn’t as simplistic as they like to make it seem,” said Kubiak.

IR-4 Update

IR-4 To Focus on New Strategic Plan

By Courtney Steward, Associate Editor

At a recent meeting, California Ag Today met up with Dan Kunkel, associate director of the IR-4 Project for The Food and International Program at Rutgers University in New Jersey.

IR-4 Project LogoSince 1963, the IR-4 Project has been a major resource for supplying pest management tools for specialty crop growers by developing research data to support EPA tolerances and labeled crop protection product uses. The main goal of the IR-4 program, according to Kunkel, is to help specialty crop growers in California, but with a new emphasis on crop exportation.

Commenting on this new strategic plan for the IR-4 program, Kunkel said, “We are going to be doing a lot of the same things, like residue work, efficacy testing and our biopesticide and ornamental programs. But we are taking a larger focus on international harmonization of the pesticide residue limits for our grower exporters so they can feel more confident that their commodities won’t have issues in foreign trade.

“Of course we submit crop protection registration to the EPA for our growers. But when the commodities go abroad, we also submit the data to CODEX, an international database with maximum residue limits (MRLs), a type of tolerance standard, for pesticides,” said Kunkel.

“We also share data with some of the U.S. commodity groups to submit to the Asian and European markets so our growers’ exports can meet these residue limits as well,” he said.