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The relevance of residues.

The Relevance of Residues

Manufacturers are coming under increasing pressure. To be successful, they have to meet the requirements of legislation, the specifications of the own label customer, and the wishes of the customer. The latter is greatly influenced by pronouncements in the media. One issue on which these pressures coincide, to a degree, is that of pesticide residues in food, prompting a reaction from the food industry.

Concern in the UK over pesticide residues in food has gained momentum since the introduction of the Food and Environment Protection Act 1985, which enabled the fixing of statutory Maximum Residue Levels. The current MRLs for foodstuffs can be found in Statutory Instrument No. 1378, which states that 'no person may leave or cause to be left ..... a level of residue exceeding any Maximum Residue Level applicable to such food'. Currently, MRLs have been set for a limited number of pesticides in specified commodities drawn from fruit, vegetables, cereals and products of animal origin.

Maximum Residue Levels are intended to reflect 'good agricultural practice', so that a crop which has been treated according to label recommendations for a pesticide should not normally exceed the MRL. Hence, MRLs are trading standards, set no higher than necessary to effect pest or disease control; they are not safety standards. The Acceptable Daily Intake is the safety standard for a pesticide. This ADI is taken into account when the MRL is set; it must be ensured that the sum of the residues of that pesticide from all known uses will not exceed the ADI in the diet.

The EC has also set a range of MRLs. Those which are statutory are incorporated into UK legislation. It is intended that on December 31st 1992 a comprehensive range of statutory EC MRLs will be in place, ready for adoption by all member States.

A third source of MRLs is the Codex Alimentarius Commission, a joint organ of the UN Food and Agriculture Organisation and the World Health Organisation. Codex MRLs are intended to harmonise world trade. The number of pesticides and commodities is greater than in the UK or EC legislation. Some listed commodities seem esoteric from a UK perspective-horse offal, for example. Codex MRLs are not statutory. However, in the absence of a UKMRL, they are used as guidelines by MAFF. This can be seen in the reports of the Working Party on Pesticide Residues, in which the results of official monitoring of food stuffs are published. The inference is that it is valuable to gather data on pesticide residues even if there is no statutory MRL-a recognised international yardstick can be used to judge the results.

It is important to remember that, if an organisation wishes to publicise adversely the presence of minute traces in a food, it will not be deterred by the presence of a UK MRL-any available measure will be pressed into service.

The Maximum Residue Levels, strictly speaking, only apply to the fresh (UK, EC and Codex), frozen (UK and EC) and dried (EC) forms of the specified products, with certain exceptions, such as Codex MRLs for bread and for named dried products. Hence, highly processed foods and multi-ingredient products not covered by MRLs. This does not mean that no residues occur in such foods, nor that they are of no significance. Indeed, MAFF carries out analysis of processed foods as well as primary agricultural commodities.

Under the Food and Environment Protection Act, a UK grower would be held responsible for leaving a residue in his crop in excess of the statutory MRL. However, any party in the food production and retailing chain could be charged with an offence under the new Food Safety Act 1990. Key phrases in the listed offences relate to food which is alleged to be 'injurious to health', 'unfit for human consumption', so contaminated that it would be unreasonable to expect it to be eaten' and 'not of the nature, quality or substance demanded'. The government booklet The Food Safety Act 1990 and You - a Guide for the Food Industry makes it clear that 'maximum residues (levels) for pesticides..... may also be relevant to prosecutions for the main offences under the Food Safety Act 1990'.

Manufacturers will be well aware of the defence of 'due diligence' available under the Food Safety Act. What approaches can be taken by a company wishing to satisfy the due diligence requirement with respect to pesticide residues? It can examine the controls on pesticide usage by the agricultural producer and find out what pesticides may be used. Where controls are weak, more emphasis may be placed on checks on residue levels. A second strategy is to require a programme of analysis by the supplier. Lastly, the manufacturer can initiate its own checks. In reality, a combination of all three approaches may be needed.

Every company embarking on a programme of pesticide residues analysis must first decide whether to place the emphasis on analysis of raw materials or final products. The advantages of the former are that there are may be relevant MRLs to compare the results with, and that any problems can be traced to source. This may result in an improvement in the situation in the future. The advantage of analyzing final product is that a picture can be built up of what the consumer actually purchases. Any positive data in the final product may be hard to put into perspective but, where there are no positives, a package of re-assuring data is on hand for public relations purposes.

The question of which products should have priority for analysis, and which pesticide groups to analyze, is too complex to deal with here. A reputable laboratory specialising in this work should be able to give assistance in planning a sampling calendar and advising on the most relevant pesticides to analy, if the spray programme is not known.

In choosing a laboratory, it is advisable to ensure that the person in charge has several years' experience in multi-residues analysis. The laboratory should confirm all positive data; this guards against the reporting of false positives. There has already been an instance this year of a laboratory's unconfirmed results being released to the press by its client, only for the data to be repudiated by MAFF. Of course, the damage had already been done to those companies whose products had been sampled by the pressure group which commissioned the work.

When remedial action is taken on the basis of unconfirmed data, it is important for the company to record such action since it would be hard to establish a due diligence defence if such data had been, or appeared to have been, ignored.

It is to be hoped that legal actions based on pesticide residues in foods will be rare. Indeed, by setting up systems and organised checks that could constitute a due diligence defence, any isolated problem area should be identified and solved before it becomes a crisis.

Readers wanting more information should contact the author at Restec located at Birlingham, Pershore, Worcestershire, tel: 0386 750799.
COPYRIGHT 1991 Food Trade Press Ltd.
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1991 Gale, Cengage Learning. All rights reserved.

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Title Annotation:pesticide residues in food
Author:Snowdon, Sue
Publication:Food Trade Review
Date:Jul 1, 1991
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