MRL legislation

1
MRL legislation

• FLT course, Polokwane
• 9 March 2005

2
Overview

• Pesticide residues
• Legislation in EU and RSA
• Residues on Exports How big is the problem
• SA PIP
• Questions and Discussion

3
Expectations

• What do you want to know?

4
Definitions

• MRL
• Import tolerance (IT)
• LoD (Limit of detection)
• LoQ (Limit of quantification)
• CPP (Crop Protection Product)

5
What is an MRL?

• Maximum level legally permitted in or on food
• Set per crop x CPP combination
• Represents maximum amount of residue expected in
  a fruit under a defined GAP
• Trading standard

6
Setting of MRLs

• MRL  frequently mis-interpreted as safety limit
  instead of trading standard

7
Europe
8
MRLs in EU
In the past

• Member States set own national MRL in absence of
  EU MRL
• National MRLs may differ from country to country
  (and from EU MRL)

9
National MRLs in EU
In absence of EU MRL, National MRL applies

1mg/kg
0.2mg/kg
1mg/kg
10
Example for National MRL
Fenthion (Lebaycid)

2 mg/kg
0.5 mg/kg
1mg/kg
2 mg/kg
0.5 mg/kg
11
Europe

• MRL HARMONISATION based on
• member states and
• review of safety of each MRL

By Elmé Coetzer, EUREP GAP
12
Harmonised EU MRL
Applies to all Member States and takes precedent
over National MRLs

13
Example for harmonised MRL in EU
Prochloraz (Omega)
MRL5 mg/kg
2 mg/kg
10 mg/kg
14
MRL future in EU
FUTURE

• One Regulation where all MRLs will be
  established, monitored and controlled at EU level
• Rapid alert system in place

15
Dossier
By Marius Boshoff, Syngenta
16
Current status in EU
NOW till 2008

• Some harmonised EU MRLs
• Establishing temporary MRLs
• Default approach (LoD 0.01 mg/kg)

17
South African Export Legislation

• Act 36 of 1947
• Crops or products exported meet the default
  export MRL or IT in the country of destination
• Records are kept of applications (pre- and
  post-harvest)
• Monitoring samples are drawn and tested
• Exporters and producers have the responsibility
  to
• comply with Act 36
• keep records of applications, provide on request
• verify MRLs with importer or agent in relevant
  country
• keep up with registrations and changes in SA and
  importing countries
• inform Directorate Plant Health and Quality of
  rejections due to residues

18
Residues on SA Exports

• 46 no residues
• 52 residues MRL
• 2.29 residues gt MRL

• In 2002 - 2004

19
SA PIP

• South African Pesticide Initiative Program
• EU co-funded
• Maintain access to EU market
• For the benefit of SA producers

20
SA PIP deliverables

• Resolve grey area in regulations
• Local registrations
• EU MRL / EU Import Tolerances
• Knowledge and confirmation
• Breakdown curves
• Adaptive research
• Improve practice
• Train farmers
• Available information

21
Links

• For citrus MRL www.cga.co.za
• Default MRL in RSA on regulated crops
  www.nda.agric.za

22
Questions ?
23
Do you know ?

• What means MRL?
• Is the safety limit higher or lower than the MRL
  of a specific CPP?
• Name 3 countries in Europe that are not part of
  the EU.
• Why are MRLs harmonised in the EU?
• Why dont we have harmonised MRLs for all CPPs in
  Europe right now?

24
Do you know ??

• Which law governs pesticide use in SA?
• Which MRL applies for export fruit from SA?
• What means SA PIP?
• How big is the risk of exported subtropical fruit
  to exceed the default export MRL?