REPORT OF THE WORKING GROUP ON
MAXIMUM RESIDUE LIMIT (MRL) IN TEA
Dr. T C CHAUDHURI
&
Ms KATIE DONNELLY
CO-ORDINATORS
Reporting and Compilations :
Dr. K. Mohotti, Dr. Abeysighe (Srilanka),
Ms Roshni Sen, Dr. M. Kumar, Dr. A. Barooah, Dr B. Bera (India)
Dr. K. Yoshida (Japan)
Prof. Z. Chen (China)
Dr. Wachira, Dr E. Cheramgoi (Kenya)
Dr. T. Henn (EU)
Ms. L. Roberge (Canada)
Mr. J. Simrany (US)
Ms P. Parra (Argentina)
Dr. M. Ahmed (Bangladesh)
And Associated Scientists from Member countries
BACKGROUND (Ref doc CCP: TE 12/5)
Recommendations of 19th Session of IGG, Delhi
(i) co-ordination, prioritization and acceleration of
submission of dossiers for MRLs in tea,
(ii) Producing countries shall carry out field trials on
alternative pest management systems
(iii) Involvement of all stakeholders, Codex, EU and other
standard setting bodies
(iv) pursue other activities to broaden the group to ensure
alignment,
(v) conduct a strategy review with a small subgroup of
Working Group members to review the action plan.
ACTIONS TAKEN
• Holding Sub group meeting of WG in CANADA on
21 Sept, 2010
Following discussions, the participants once again
reiterated the goal of the Group as:
“To achieve global cooperation obtaining
maximum residue levels (MRLs) in tea” and
Identified major issues after deliberations on
country positions, finally agreed on the goals of the
group to tackle the issues.
Finally, QUESTIONNAIRES developed and circulated
Report of the Sub Group was presented in the
WG meeting in Kenya, Jul 18-19, 2011 along
with information submitted by few members.
The WG on MRL finally agreed in Kenya
meeting on the Action Plan as decided.
ACTION PLAN IN WG MEETING, KENYA
18-19 July, 2011
A. Agreed activities to achieve
Objectives & Goal
1. To continue to generate data for
MRL, submit to CODEX;
2. To identify Compounds for future
trial;
3. To continue field trials on priority
compounds;
4. To develop IPM in member countries
B. Action plans for all Four (4) GOALS
To develop & implement IPM strategies
To continue MRL submissions to JMPR, producing,
consuming countries
To programme replacement of old / banned
compounds, discouraging sudden withdrawal
of approval without alternatives
To develop priority list of pesticides based on
sustainability, affordability, safety
To give advance notice of changes in authorization
To develop effective communication plan.
ACTIVITIES identified to achieve GOALS
PRODUCING countries --- key issues, goals
SL
Key issues (short)
1 Evolving pest pressures
2 Lack of MRLs, non
harmonized MRLs
3 Replacement of old
chemicals/banning of old
chemicals
4 Health, safety,
sustainability
5 Communication among
stakeholders
Goal (short)
Develop and implement IPM
strategies
Reclassification of tea from minor to
major crop at JMPR; Obtain MRLs
for chemicals in use in both
producing and consuming countries
Replacement programmes
Prioritization of chemicals based on
health, safety and sustainability
Effective plan for communication
QUESTIONNAIRES Re-CIRCULATED TO
THE STAKEHOLDERS AND
INFORMATION SOUGHT
Information from Questionnaires
addressing Goals and Objectives
GOAL
- Pests affecting crop losses in tea. Objective – To identify
different pests and economically important pests.
– IPM strategies adopted in tea pest management. Objective –
To identify different IPM strategies and record methods used
to minimize use of pesticides used in pest management
– Pesticide use in tea. Objectives - To identify old / banned /
replaceable / withdrawn pesticides and record current list of
substances / pesticides and alternatives / potential chemicals
– Priority chemicals for MRL generation. Objective – To update
the priority list of chemicals requiring MRLs in consuming
countries and Codex.
RESULTS
Table 1: SUMMARY OF PESTS / Diseases AFFECTING CROP LOSSES
(number of key pests given in parenthesis)
Arge Banglad
India
Japan
Kenya
Sri Lanka
China
ntina
esh
Insects
-
8 (2)
12 (5)
104 (9)
5 (3)
16 (5)
-
Mites
1 (1)
4 (1)
4 (1)
9 (1)
4 (1)
5 (2)
-
Nematodes
-
2 (2)
2 (1)
14 (1)
1 (0)
3 (2)
-
Foliar disea
-
4 (2)
2
10 (2)
2 (2)
5 (1)
-
Stem diseas
-
-
2
-
4 (2)
5 (3)
-
Root diseas
-
2 (0)
2
2 (0)
2 (1)
6 (2)
-
Weeds
-
-
Num-ous
-
-
Numerous
-
Misc.
-
-
-
1 (0)
2 (0)
-
-
Ware H pest
-
-
-
-
6 (0)
3 (0)
-
Total
1
20
24 +
140
26
43 +
23
Table 1: SUMMARY OF PESTS AFFECTING CROP LOSSES
25
20
Argentina
Bangladesh
India
15
Japan
Kenya
10
Sri Lanka
China
5
0
Insects
Mites
Nematodes Diseases: Diseases: Diseases:
Foliar
Stem
Root
Misc.
Ware
h.pests
Table 2: SUMMARY OF IPM STRATERGIES IN PEST MANAGEMENT
Number of Asterisks (*) level of IPM practices adopted
IPM
Arge Bangla
Sri
India
Japan
Kenya
Lanka
China
strateg.
ntina
desh
Clone/cult
-
-
**
*
**
****
-
Agronom
**
**
**
**
**
**
-
Cultural
**
***
**
*
*
**
-
Biological
-
**
***
**
*
*
-
Nat. enem
**
***
**
**
*
****
-
Pest forecs
*
*
*
*
-
*
-
Chemical
**
****
***
***
**
**
-
IPM strategies adopted:
1. Agronomic and cultural methods are more prominent.
2. Harnessing of clonal selections, biological control, pest
forecasting and modeling etc. are resorted only in a few
countries.
3. Success experiences of clonal selections, biological control
(biopesticides), pest forecasting and modeling etc. need to be
incorporated in IPM strategies.
4. IPM strategies for weed management have become
strengthening.
5. Mammalian and stored / ware house pest control warrants
control measures.
Table 3: SUMMARY OF PESTICIDE USE
No. pesticides used
Type
Arg’tna B’desh
Ind
Jap Kenya SLka China
Insecticides
-
9
20
82
6
3
Acaricides
1
3
7
17
4
1
Nematicides
-
2
2
3
1
1
Fumigants
-
-
-
-
-
2
Fungicides
-
2
2
22
5
7
Weedicides
-
-
2
6
3
7
21
2
Table 3: SUMMARY OF PESTICIDE USE
Arg’tna
B’desh
Ind
Jap
Kenya
SLka
China
40
22
21
20
17
9
7
6
3
0
Insecticides
3
1
7
5
4
1
Acaricides
2 2
0
3
1 1
Nematicides
2
0 0 0 0 0
Fumigants
2 2
0
Fungicides
7
6
2
3
2
0 0
Weedicides
Table 4: SUMMARY OF PESTICIDE USE STATUS
Name of pesticide
Status
Argt’na B’desh Ind
Jap
Kenya S Lnka China
Old
1
-
13
30
14
9
Replaced
-
-
-
-
-
3
Withdrawn
-
-
-
-
3
1
Alternate
-
-
19
-
6
11
Current Use
-
17
15
100
6
23
23
Table 4: SUMMARY OF PESTICIDE USE STATUS
120
100
Old
80
Replaced
60
Withdrawn
40
Alternate
Current
Use
20
0
Argt’na B’desh
Ind
Jap
Kenya S Lnka China
OBSERVATIONS ON DATA
1. Pest occurrences are more in Japan, Srilanka, India
and China – Old plantations, agro climate.
2. Major pests are leaf eating pests, stem pests, mites
3.Leaf, stem and root diseases are common.
4.Weed control is a major problem in tea
5. A few ware house pests are found as potential
pests
6. Damage of pests depend on change in climatic
scenario.
7. IPM is a new attempt to all – GOOD SIGN
North America Developments
USA
• Endosulfan
– FDA proposed deletion of all tolerances Apr 11
– All food crops except tea given 3-5 year expiry date
– China on behalf of Tea industry lodged an objection,
requesting 5 year extension/expiry date
– Outcome awaited
• Petitions lodged with EPA for 3 compounds
• 2 new MRLs granted
CANADA
• 1 new MRL granted
Submissions for Tea - MRLs Granted
Australia
Canada
Lambda
cyhalothrin
1 mg/kg May 10
Fenpropathrin
2 mg/kg Sep 10
2 mg/kg Jun 11
Bifenthrin
5 mg/kg May 10
Petition with PMRA
Deltamethrin
5 mg/kg Sep 10
Cypermethrin
0.5 mg/kg May 10
Fenvalerate
0.05 mg/kg May
10
Glyphosate
2 mg/kg Sep 10
Chlorpyrifos
2 mg/kg May 10
USA
2 mg/kg Jun 10
Petition with EPA
Petition with EPA
Petition with EPA
Acetamiprid
50 mg/kg Feb 10
Etoxazole
15 mg/kg Apr 11
Ethiprole
30 mg/kg Jun 11
Chlorantranilprol
e
Items in green - New since July 2011
50 mg/kg Jul 11
Submissions for Tea - New MRL Petitions
Australia
Propiconazole
Canada
USA
Petition with
PMRA
Submission 2012?
Submission 2011
Petition with EPA Nov
2011, 20mg/kg
Tolfenpyrad
Submission 2010
Submission 2011
Fenpyroximate
Submission 2011
Submission 2011
Buprofezin
Clothianidin
Petition with EPA Dec
2011, Plucked leaves
50 mg/kg
Permethrin
IR4 submission 2011
Dinotefuron
Petition with EPA Sep
2011, Plucked leaves
25mg/kg
Chlorfenapyr
Submission
planned
2011/12
Submission planned
2011/12
CODEX MRLs
• Confirmed CAC July 2011
– Endosulfan – revised 10
mg/kg
– Bifenthrin 30 mg/kg
– Thiamethoxam 20
mg/kg
– Clothianidin 0.7 mg/kg
– Etoxazole 15 mg/kg
– Flubendiamide 50
mg/kg
• Scheduled 2012
– Chlorfenapyr BASF
– Dinotefuran Mitsui
– Buprofezin Nichino
• Planned submissions
2013
– Tolfenpyrad Nichino
– Fenpyroximate Nichino
– Fenpropathrin Sumitomo
EU Developments
Changes to authorisations
• Granted 2011
Bitertanol, Buprofezin, Fenazaquin, Hexythiazox, Lime
sulphur, Oxyfluorfen, Pyridaben, Azadirachtin
• Non-approved
Propargite
• Resubmitted applications pending
Bifenthrin
Proposed changes to MRLs
• SANCO 12226 Adoption of Codex MRLs approved CAC July
2011
– Endosulfan, Bifenthrin, Clothianidin, Flubendiamide,
Thiamethoxam, Etoxazole
Discussed at Standing Committee Feb 2012
• EFSA opinion
– Hexythiazox 0.05* → 4 mg/kg
EU Developments
‘Article 12’ review of existing MRLs
• Substances a) not approved for use
b) consumer risk identified → MRLs deleted
unless substantiated Codex or Import tolerance
• Draft proposal SANCO 10691
– Dicofol 20 → 0.1* will lose EU & Codex MRL unless new Tox. data
given to JMPR
– Fenitrothion 0.5 → 0.05*
– Tridemorph 20 → 0.05*
– Chlorfenapyr 50 → 0.05* or no change? JMPR evaluation 2012
• Change to LODs for a number of substances
– E.g. DDT 0.2* → 0.05*
* denotes LOD
• Discussed at Standing Committee Feb 2012
Process for Making MRL Submissions
1.
Priority lists of MRLs
1. Priority chemicals for tea production
2. Priority chemicals for regulations internationally
2. Submissions for MRLs in tea
1. Identify opportunities
2. Identify field trial data from producing countries /
AgroChem Co.s
3. Provide residue monitoring data
4. Provide summary of MRLs globally for tea
3. Build working partnership with Agrochemical Co.s
1. Open dialogue with AgroChem Co.s
2. Discuss priority compounds for tea & Co.s
3. Agree inclusion of tea in submissions
4. Provision of field trial data etc.
Important issues
1. Generally, all are pursuing revision of list of
pesticides replacing old by new generation
pesticides.
2. Current recommendations for pesticide use are
based on upgraded list.
3. Current recommendations can be considered as
PRIORITY list.
4. CONFUSION for chemicals as existing in both
current and old list, e.g. Hexythiazox in old list in
Japan; paraquat, carbofuran are old in India but in
current list in Sri Lanka.
ISSUES for FUTURE Actions
1. Reviewing of existing national MRLs for tea and go for new
label claim with MRL for new compounds.
2. Strike a balance between old and new generation
compounds based on safety, sustainability, economics
3. IPM strategies are to be more effective reducing chemical
load.
4. Residue data for computation and submission to JMPR
5. Importing country regulations to recognize efforts of
producers taking residue data support from producers
ISSUES for FUTURE Actions (contd.)
6. Withdrawal of chemicals is a concern to producers.
7. Short and long term goals of WG to persist .
8. For better harmonizing of MRLs between EU, Codex, Japan and US –
FAO to intervene for acceptance of information / field data
9. Develop uniform Risk assessment criteria
10. Based on the list of chemicals used in producer countries, to
prioritize them and generate data for submissions
11. Make use of electronic forum of the FAO to share and exchange all
information on pest management, pesticide use and data
12. To place pesticide manufactures on board for toxicological data
submissions.
13. WG to meet soon in intersessional meeting for prioritization and to
collate data.
GRAY AREAS
• Country information are lacking on –
** MRL, Number of compounds under
trial, submission of data to JMPR.
** Capacity building in residue works.
** Cooperation in computation of dossiers with
minimum 8 expts.
**Communication gap
CONCLUSION
1. Priority list of chemicals and generation of residue
data as per JMPR and submission to National
regulators / JMPR / Importing country regulators.
2. To share constraints in pest and disease control in
Producing countries by Non Producing countries to
achieve Harmonization in MRL.
3. Sharing of residue Data bank by the Regulators
while fixing MRL for tea is essential.
4. If points 1 to 3 above are followed, all will gain to
over come this non-tariff barrier for sustainability
SUMMARY
1. Responses to Questionnaires strengthened the efforts in
HARMONISATION of MRLs, but still a long way.
2. The efforts of residue data generation should continue for
national as well as international use.
3. IPM to be strengthened.
4. Fixation of realisticTHANK
MRLs is essential
all
through.
YOU
5. Tea as perennial crop needs ‘time allowance’ to switch
over to new compounds vis a vis new MRLs