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Grower Perspectives on Maximum Residue Limits

Grower Perspectives on Maximum Residue Limits . James R. Cranney California Citrus Quality Council Minor Crop Farmer Alliance. Minor Crop Farmer Alliance.

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Grower Perspectives on Maximum Residue Limits

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  1. Grower Perspectives on Maximum Residue Limits James R. Cranney California Citrus Quality Council Minor Crop Farmer Alliance

  2. Minor Crop Farmer Alliance • Founded in 1989 to provide a unified voice for United States specialty crop producers on national and international policy issues that impact the availability of critical pest management tools • Members are over 30 state, regional, and national grower organizations, agricultural trade associations and commodity commissions. • Cranney is Secretary of MCFA and Chairman of the International Subcommittee

  3. More Than 400 “Minor” or “Specialty” Crops in the United States Vegetable Acres Harvested Total Acres of Orchards

  4. Presentation Highlights • Insect and plant disease problems • How Maximum Residue Levels (MRL) impact production practices • MRL Policy Issues • Recommendations

  5. It Starts with the Pests!

  6. Pesticides are a reality • Technologies to control plant diseases and insects are limited • Phytosanitary demands require pesticides • Organic production does not usually meet commercial requirements for trade • Growers large and small depend on pesticides to control plant diseases and insects • Pesticides will continue to play a key role in IPM programs

  7. Growers try to Minimize Pesticide Use • Cost is an incentive to reduce use • Desire to preserve beneficial insects for IPM • Concern about the environment • Growers use Integrated Pest Management (IPM) to address these issues

  8. Integrated Pest Managment • "IPM is a sustainable approach to managing pests by combining biological, cultural, physical and chemical tools in a way that minimizes economic, health and environmental risks." Source: National IPM Network 

  9. IPM Examples • Identification of pests • Beneficial species are not pests • Use of predatory insects • Mating disruption

  10. IPM Examples (Continued) Predicting key life stage events for codling moth Zero ‘0’ line represents date of observed egg hatch Deviations for calendar (blue) versus model (black) approach are shown on the figure below • Models that predict insect and disease life stages to determine when to make pesticide applications • Requires weather data, knowledge of insect life stages and behavior CM Model Accuracy II (WSU-Beers and Brunner) • How does the model compare to spraying 21 days after full bloom of Red Delicious?

  11. Growers Export to Many Markets • Growers can not manage production for specific export markets • Processors mix production lots • If there are no MRLs in major markets the pesticide is not used U.S. Orange Exports Thousands of Dollars

  12. IPM is Complex! • Growers need a wide variety of pesticide tools to fit complex IPM systems • Limited MRLs reduce IPM options and limit sustainable approaches to agricultural production

  13. Growers Need a Variety of Pesticide Tools • Insects and diseases acquire resistance to repeated applications using the same mode of action or when too little is applied • Growers rotate pesticides to avoid resistance • Growers also use combinations of pesticides with different modes of action to prevent resistance • Fewer broad spectrum pesticides requires more alternatives • Pesticide rotation and use of pesticide combinations reduce pesticide use

  14. U.S. Agriculture Exports(Billions of U.S. Dollars) Source: Department of Commerce, U.S. Census Bureau, Foreign Trade Statistics

  15. Grower Reality Growers need a wide variety of pesticide tools Greater demand for agricultural trade Conclusion: Scarcity of MRLs prevents trade, delays transition to newer, safer pesticides, reduces pesticide alternatives and fosters pesticide resistance

  16. Grower Concerns • Diminishing reliance on Codex MRLs or refusal to use Codex or other established MRLs (USA, EU) • Growing backlog of Codex reviews • Proliferation of country-specific MRLs • Long, protracted MRL reviews that delay establishment of MRLs • Food retailer “MRLs” that are lower than national standards and pesticide use restrictions • MRLs should be based on science

  17. Case Study No. 1Unreasonable MRL Delays Impact: Growers use older pesticides that have MRLs, pesticide resistance can develop, defeats IPM practices, growers lose money from insect infestation and reduced quality and consumers suffer Scenario: A new pesticide is registered, but there is no MRL in the most important export market. Growers do not use the pesticide until MRLs are established; sometimes for five years after registration.

  18. Case Study No. 2Food Retailers Require Lower MRLs Impact: Growers are forced to “manage” residues – no late season use, insect and quality losses, less residue leads to resistance, fewer pesticides causes resistance, disrupts IPM. No real safety improvement is achieved. Scenario: Food retailers set arbitrary pesticide residue levels or limit specific pesticides to convince consumers their food is “safer.”

  19. Case Study No. 3Invasive Species Impact: Growers must control the new insect or disease. Can regulators provide temporary MRLs? Codex? USA? EU? Scenario: Invasive species enters production region unexpectedly. Growers use most effective alternatives. Are there MRLs?

  20. Case Study No. 4Different MRLs in Different Markets Impact: Containers can be rejected in low MRL markets, more complex to manage, buyers question the safety of higher MRLs Scenario: Growers use the same pesticide with the same GAP, but must meet different MRLs in different markets

  21. Recommendations • Increase the pace of harmonization in all aspects of MRL development • Speed and efficiency are critical • More global joint reviews • Greater data sharing and review sharing to establish MRLs • Increase use of Codex MRLs • Possibly as temporary MRLs while country-specific MRLs are established • Greater use of crop-group MRLs • Greater regulatory opposition to food retailer MRLs

  22. Recommendations (continued) • Reaffirm that MRL establishment is a process among (i) technology providers (ii) regulators and (iii) growers • Elevate agricultural production problems (grower problems) as a justification for regulatory response – establishing MRLs

  23. MCFA • Minor Crop Farmer Alliance • James R. Cranney, Jr. • California Citrus Quality Council • 853 Lincoln Way, Suite 206 • Auburn, CA 95603 • Tel: (530) 885-1894 • Fax: (530) 885-1546 • Mobile: (530) 906-6546 • jcranney@CalCitrusQuality.org

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