REPORT OF THE WORKING GROUP ON MRL IN TEA

BY

T C CHAUDHURI

Jt. Coordinator, Working Group on MRL in TEA,

IGG on TEA, FAO

References of works to WG on MRL

Recalling the relevant MINUTES of 19th IGG , Delhi, May 2010 on MRL,

Para 20 The Group

Para 21 Tea should be compliant with regulations……..;

Para 22 (i) Immediate Action Plan………..;

(ii) Strategy review………….;

Para 23 Global Harmonization in MRL regulations..

AGENDA

Immediate Action Plan

(i) Submissions on pesticide MRLs in Tea

(ii) Position of Field Trial data

(iii)Identification of Compounds for field trials, also developing IPM

Reviewing of WG Strategy(i) Progress on the Action plan

Investigating residue in tea brew

ACTIONS TAKEN on MRL

Reviewed on Status of Pesticide use globally on tea Establishing Uniform Protocol for data generation Prioritized Compounds and generated residue data Commutation of available data and submission to Codex Data bank used in harmonization of MRL in many tea

importing countries and at national level More compounds are targeted for data generation Country regulations on MRL are updated Tea brew data for residue generated IPM in place

ACTIONS TAKEN on MRL

Reviewing of WG StrategyA side line meeting of the Strategy Group was held at the time

of 1st Annual North American Tea Conference on 21st Sept 2010 at Niagara Falls to develop ACTION PLANS

To agree on vision for MRLs To identify major issues facing tea industry To agree the goals to tackle identified issues Annex 2 Action plans, goals are circulated

Annex 2: Identification of issues and goals (Minutes of Canada meeting)

Key issues Goal Responsibility

Evolving pest pressures

Develop and implement IPM strategies

Dr. Chaudhuri & Sri Lanka?

limited compounds to control pests/diseases

new compounds and new control IPM strategies

new pest problems faced each year - environment changes

biocontrol, chemical ecology methods

Lack of MRLs, non harmonised MRLs

Obtain reclassification of tea as minor crop in JMPR to speed MRL setting for tea Prof. Chen

only 1 MRL for tea in Canada

obtain MRLs for chemicals in use in producing/consuming countries K. Donnelly

Annex 2: Identification of issues and goals (Minutes of Canada meeting)

Key issues Goal Responsibility

compliance relies on a default MRL of 0.1, but could be taken away at any time more regulations for country of origin

MRL is essential for chemicals being used

rejection of shipments because of pesticides - lack of MRLs

convergence of methodologies for MRL setting

need to harmonise specific group of pesticides

common agreed risk assessment process for tea

Annex 2: Identification of issues and goals (Minutes of Canada meeting)

Key issues Goal Responsibility

continuous change of residue regulations - industry has to think ahead

transparency of risk assessment processes in different countries

loss of authorisation in EU - ensuring enough chemicals available to effectively fight pestsInconsistent viewpoint between producing and consuming countries on MRLs

Annex 2: Identification of issues and goals (Minutes of Canada meeting)

Key issues Goal Responsibility

stringent MRLs in importing countriesone global MRL for compounds desiredNeed more pesticides through CCPR, and for them to be adopted in other country legislationanalytical issues - lower LOQs require specialist knowledge

Annex 2: Identification of issues and goals (Minutes of Canada meeting)

Key issues Goal Responsibility

replacement of old chemicals/banning of old chemicals

replacement programme to replace old/banned with new chemicals Dr. Chaudhuiri

JMPR - Some current pesticides will be banned in 2-3 years (OP, triazole group)replacement of old chemicals done slowlyreplacement of old substancesnew compounds are slowly registered for use in producing country - acceleratesome pesticides are banned, so can't obtain import MRL for tea

Annex 2: Identification of issues and goals (Minutes of Canada meeting)

Key issues Goal Responsibility

health, safety, sustainability

pesticide priority list based on sustainability, affordability and safety Thomas Henn

Current MRLs not rational – transfer into brew most important

reconsideration of risk assessment in Codex

consumer sensibilities - don't want residues even if safeenvironmental impact - climate change & sustainability

Annex 2: Identification of issues and goals (Minutes of Canada meeting)

Key issues Goal Responsibility

consumer perception - tea marketed on healthsustainability of tea - environment, workers etc.people are starting to eat and cook with teamore emphasis on food safetyofficial developments - evaluation of multiple residues in productstougher regulatory environment

Annex 2: Identification of issues and goals (Minutes of Canada meeting)

Key issues Goalcommunication among stakeholders

an effective communication plan with stakeholders L. Roberge

communication to the smallholder community

set up an efficient communication tool for the relevant stakeholders

media and consumer attention identify the relevant stakeholderstea small crop - low interest in tea by pesticide companies

responsibility, implementation, monitoring,

timely communication about regulatory changes

development of a universal position statement

Q. 1. Pesticides with residue data in last 4 years

China India Japan Sri Lanka Kenya

10 ? 14 6-10 13 1LcyhalothrinBifentrinThiamethoxanCopper compoundSpyromesifenThiaclopridDimethoateGlyphosphate BifenazateClothianidinPropiconazoleHexaconazole2,4-DSulphur

(2 trials only) CopperBitertanolPropiconazoleTebuconazoleChlorofluazuronImidaclopridCopper hydroxideBitertanolPropiconazoleTebuconazoleImidaclopridChlorfluazuronBitertanol

Copper Oxychloride

Q. 2. Current Pesticide use in tea

China India Japan Sri Lanka Kenya

10 ? 18 50 ? 8EthionDicofolGlyphosateFenazaquinPropergateDeltamethrinFenpropathrinFenpyroximateHexythazoxPropiconazole………..

Insecticide MiticideFungicide

CopperBitertanolPropiconazoleTebuconazoleChlorofluazuronImidaclopridCopper hydroxideBitertanolPropiconazoleTebuconazoleImidaclopridChlorfluazuronBitertanol

Glyphosate DicofolSulphurAl phosphideGlufosinate Am.ChlorpyrifosEndosulfanparaquat

Q.3. Regulatory position of pesticide use

China India Japan Sri Lanka Kenya

Min. Agril. Pesticides Regulations

CIB / RCFSSAIAll Regulatory Bodies of GOI

Registration with Min. Agril., Forest and Fisheries.MRL fixation by MOH, Lab. Welfare.

Regulatory Body of the Govt.

Kenya Standard Guide on MRL.

Q.4. Position of IPM

China India Japan Sri Lanka Kenya

Dependent on bio formulations

PP, GOIBio Control, Natural Enemies, safer molecules, Plant origin formulations.

Food and Agril. Materials Inspection Centre

Using herbal formulations

Monitored by Govt.

Q.5. Pesticide Related issues

Need for Harmonization of MRL with different agencies like EU, CODEX.

Harmonization of MRL with tea imported countries. Constraint in sudden change of MRL status and loss

of authorization

Q.6 Exchange of MRL data

China India Japan Sri Lanka Kenya

Submitted some data to CODEX

Data for 6 compounds submitted to CODEX. 2006.Support data for MRL fixation to Canada, Australia, EU.

Short of number of trials

Data for 6 compounds submitted to CODEX.

Data for one chemical submitted to CODEX.

Q.7 Latest regulatory position on MRL in tea

China India Japan Sri Lanka Kenya

Govt. Regulation.

CIB/RC regulation.New FSSAI 2006 Food Safety Standard.

MHLW – Guideline for application for establishment and revision of MRL.

Govt. Regulation.

Kenya Borough of Standard

SUMMARY

1. Most of the tea producing countries are now equipped with residue lab and man power to generate residue data on tea.

2. Voluminous residue data have been generated by China, India, Sri Lanka. Others are attempting to equip in the near future.

3. Generic pesticides are gradually withdrawn, substituting by new generation compounds.

4. Pesticide load on tea have reduced in the recent years by adopting IPM measures.

5. Bio-control measures like herbal, microbial formulations are now widely used in tea. Entomopathogens, pheromons are also being tried successfully.

SUMMARY

6. Rotational use of different pesticides and bio-agents for controlling pests and diseases are integral part of IPM in most of the countries.

7. Information on pesticides use in tea in different countries with MRL are now available as transparent information.

8. National Regulators for MRL are active to update approved lists with MRL.

9. Tendency to generate residue data both on dry tea and brew is growing.

CONSTRAINTS

1. Lack of harmonization is confusing the producers and the trade.

2. For healthy growth of the tea trade, impediments like new regulations for MRL in the importing countries are creating confusion, also cost of production is increasing.

3. Exchange of information on MRL supported by realistic field data base is required.

4. More active participation of producers and importers in functioning of this WG is needed.

CONCLUSION

1. Ongoing programmes of data generation, submission to National Regulators and to CODEX should continue.

2. Countries not well equipped with data base and infrastructure may strengthen their venture to support the industry scientifically.

3. Exchange of information on residue and prompt compilation of database will help IGG Working Group.

4. Existing programmes should continue after formulation of action plans as per identified areas listed in Annex-2 of the Strategy Group Meeting held in Canada in September, 2010.

ACKNOWLEDGEMENT

THANKS are due to co-operations of scientists from the Producing & Consuming countries.

I acknowledge support from IGG secretariat, particularly from Mr. K. Chang and my co-chair Ms K. Donnelly.

Thankful to Indian Groups from TRA, UPASI-TRF and the Authorities from the MOC&I, GOI, Tea Board,

particularly, Mr. M. R. Sharma and Ms R. Sen, DC, and Tea industry for full support.