"AHPA members rely on the availability of raw agricultural commodities that are not contaminated with excessive levels of environmental pollutants," said AHPA President Michael McGuffin. "This requires that clean air, water, and soil be available for the production of food crops."
AHPA's recommendations focus on EPA pesticide regulations and were submitted in response to EPA's April invitation for comments on regulations that may be appropriate for repeal, replacement, or modification.
Expand & Finalize the 'Herbs and Spices' Crop Group
AHPA recommended EPA add nearly 200 commercially available herbal crops to Crop Group 19, "Herbs and Spices." Inclusion of herbal crops in EPA regulatory crop groups is essential to ensure that pesticide use on herbal crops, when needed, is carried out in compliance with EPA's pesticide regulations.
Under current EPA policy, no detectable residue of a pesticide chemical is permitted on a food crop unless a tolerance or tolerance exemption has been established. As a result, any raw agricultural commodity or processed food is adulterated if it contains detectable traces of a pesticide for which no tolerance (or tolerance exemption) has been established by EPA for that crop or crop group. The vast majority of herbal crops are specialty or minor crops so they are seldom the subject of attempts by pesticide chemical producers to establish a pesticide tolerance solely and specifically for an individual herbal crop.
Adding new crops to a crop group reduces mandatory paperwork requirements and results in no appreciable costs or negative impacts to consumers, minor crop producers, pesticide registrants, the environment, or human health.
Exceptions for Unavoidable, Inadvertent Pesticide Residues
There is a significant disconnect between the occurrence of detectable pesticide residues on foods with no tolerance or a tolerance exemption and the technical requirements of the existing enforcement policies. This discrepancy between the requirements and the reality of widespread pesticide use and trace contamination has been causing problems in the food industry for decades and will increase dramatically with the enforcement of new regulations under the Food Safety Modernization Act (FSMA).
AHPA stressed that EPA has a variety of tools to remedy these problems and urges EPA to use this authority to create rational policies for trace levels of pesticide residues in foods.
AHPA also encouraged EPA to consider harmonizing U.S. pesticide tolerances with Maximum Residue Levels (MRLs) established by the Codex Alimentarius Commission.