MRLS FOR TEA IN CANADA Chris Warfield Fifth Annual North American Tea Conference The Carstone Group Legal Requirements for Maximum Residue Limits • • • • • The Food and Drug Act of Canada 0.1 ppm default Maximum Residue Limit (MRL) Exempt Banned The Carstone Group How are MRLs established? • Someone must request establishment of an MRL • They must make an application to the Pest Management Regulatory Agency (PMRA) • Include required data – – – – Product Chemistry Toxicology Metabolism Residue Chemistry, etc. The Carstone Group How are MRLs established? • Data must be “good”, i.e., GLP, international guidelines, etc. • Can use scientific rationales • PMRA reviews data within a service standard – generally 1 year for Import MRLs • PMRA will consult with the Canadian public and internationally through WTO notification • Finally import MRLs will normally be established. The Carstone Group Canadian MRLs in/on Tea • • ~90 chemical pesticides used in tea production globally In Canada, there are only 5 specific MRLs established Ethiprole Tea (dried leaves) 30 Fenpropathrin Tea (dried leaves) 2 Lambda-cyhalothrin Tea (dried leaves) 2 Propiconazole Tea (dried leaves) 4 Spiromesifen Tea (dried leaves) 60 The Carstone Group Government monitoring and compliance • Canadian Food Inspection Agency (CFIA) routinely test domestic and imported food commodities • Violations may result in: • Letter to producer/importer • Requests for safety data • Seizure of food The Carstone Group Government monitoring and compliance •CFIA reports from 2009-2011 have shown many violations in tea 2009-10 2010-2011 100 samples collected 267 samples collected 41% violation rate 25% violation rate 340 pesticides tested 430 pesticides tested Canadian Tea Association Strategy to Address MRLs in Canada • Monitor and comment on laws/regulations, directives, proposals affecting the tea industry, e.g., Crop Life America White Paper on Challenges to Establishing Harmonized MRLs, CFIA proposals • Prepared discussion paper “Overview of the WTO Notification Process and International Developments in Establishing MRLs” • Prepared discussion paper “Potential Collaboration of CCPR-JMPR in Global Joint Reviews” The Carstone Group Canadian Tea Association Strategy continued • Participated in Government meeting regarding iMRLs and prepared letter supporting establishing MRLs by reference. • Since PMRA, a Regulatory Agency cannot promote pesticide use or the establishment of MRLs, the Tea Association has undertaken a project to encourage and establish import MRLs to address violations in Canada. • We have created a Master List of pesticides used in tea production and Canadian and international MRLs (US, EU, Australia, Codex) from available sources. The Carstone Group Canadian Tea Association Strategy continued • We have identified chemicals that require MRLs in tea and are consulting with the major registrants to determine their plans for submitting applications to HC for MRLs. • We have priorized the chemicals on the list and have identified opportunities for the TAC to prepare and submit applications in 2014 • Clothianidin (Valent, Sumitomo) • Thiamethoxam (Syngenta) • Cypermethrin (BASF) The Carstone Group Questions? The Carstone Group
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