Chemical Use in Fodder Crops

Transcription

1 Chemical Use in Fodder Crops Interim Report A report for the Rural Industries Research and Development Corporation by Anthony Flynn EUREKA! AgResearch (Vic) Pty Ltd July 2005 RIRDC Publication No 05/092 RIRDC Project No EAV-1A

2 2005 Rural Industries Research and Development Corporation. All rights reserved. ISBN ISSN Chemical Use in Fodder Crops Interim Report Publication No. 05/092 Project No. EAV-1A The information contained in this publication is intended for general use to assist public knowledge and discussion and to help improve the development of sustainable industries. The information should not be relied upon for the purpose of a particular matter. Specialist and/or appropriate legal advice should be obtained before any action or decision is taken on the basis of any material in this document. The Commonwealth of Australia, Rural Industries Research and Development Corporation, the authors or contributors do not assume liability of any kind whatsoever resulting from any person's use or reliance upon the content of this document. This publication is copyright. However, RIRDC encourages wide dissemination of its research, providing the Corporation is clearly acknowledged. For any other enquiries concerning reproduction, contact the Publications Manager on phone Author s disclaimer The data provided in this document has been prepared by the author in good faith but neither the author nor Eureka! AgResearch (Vic) Pty Ltd warrants that the data is free of errors. The author recommends that the reader validate any or all data provided herein using alternative sources. Researcher Contact Details Anthony Flynn EUREKA! AgResearch (Vic) Pty Ltd PO Box 2006 Werribee, VIC 3030 Phone: Fax: eurekaagresearch@bigpond.com In submitting this report, the researcher has agreed to RIRDC publishing this material in its edited form. RIRDC Contact Details Rural Industries Research and Development Corporation Level 1, AMA House 42 Macquarie Street BARTON ACT 2600 PO Box 4776 KINGSTON ACT 2604 Phone: Fax: rirdc@rirdc.gov.au. Website: Published in July 2005 Printed on environmentally friendly paper by Canprint. ii

3 Foreword The Australian Fodder Industry (AFIA) has identified the entry of chemical residues into the food chain from fodder as one of its greatest risks to markets overseas and in Australia. Exceeding maximum residue levels (MRLs) in any market will likely see Australian fodder barred from that market (and possibly others) for the short to medium term and result in a loss of confidence in the Australian product for the longer term. This project is strong evidence that the Australian fodder industry is pro-active in preventing harmful chemical residues, and provides data that can be used to allay fear of residues. Currently some products used on fodder are not registered for that use and no relevant MRLs are available. This project seeks to amend this situation by listing registered products and their MRLs and identifying chemicals for which MRLs should be attained. This project is funded from RIRDC Core Funds which are provided by the Australian Government. This report is an addition to RIRDC s diverse range of over 1200 research publications. It forms part of our Fodder Crops R&D program which aims to facilitate the development of a sustainable and profitable Australian fodder industry. Most of our publications are available for viewing, downloading or purchasing online through our website: downloads at purchases at Peter O Brien Managing Director Rural Industries Research and Development Corporation iii

4 Contents Foreword... iii Executive Summary... v 1. Introduction What are Maximum Residue Levels? Trading partners and the CODEX Previous Work National Residue Survey Australian Total Diet Survey Victorian Produce Monitoring Program Pesticide market data Trends in product registrations Trends in MRLs Crops Lucerne Active ingredients without MRLs Comparison between for fodder and food requirements Oats Pasture Major fodder trading partners Japan Major fodder competitors USA CANADA CHINA Residues that pose risk to the fodder industry Registered products Products registered on a similar crop - wheat Products not registered but used on fodder crops Recommendations References Appendices Appendix I Maximum Residue Limits for active ingredients registered for use on lucerne.20 Appendix II Products (and their active ingredients) Registered For Use on Lucerne...22 Appendix III Active Ingredients (and their product names) Registered For Use on Lucerne.30 Appendix IV Maximum Residue Limits for active ingredients registered for use on oats...38 Appendix V Products (and their active ingredients) Registered For Use on Oats...40 Appendix VI Active Ingredients (and their product names) Registered For Use on Oats...51 Appendix VII Maximum Residue Limits for active ingredients registered for use on pasture.62 Appendix VIII Products (and their active ingredients) Registered For Use on Pasture...64 Appendix IX Active Ingredients (and their product names) Registered For Use on Pasture...65 iv

5 Executive Summary There is increasing awareness and concern amongst consumers and the general public of pesticide residues in food. Any evidence that chemical residues may have entered the food chain from Australian fodder, either domestically or overseas, is one of the greatest marketing risks facing the fodder industry. Exceeding Maximum Residue Levels in any market will likely see Australian fodder barred from markets for the short to medium term and result in a loss of confidence in the Australian product for the longer term. There is evidence that countries importing Australian fodder are becoming more determined to police residues in imported product s including fodder. The objective of this project is to review current literature for any information of the levels of chemical residues in fodder crops and to collect new data on the risk posed from the use registered and unregistered chemicals on the Australian fodder industry. There is almost no literature directly related to chemical residues in fodder in Australia. The most relevant information was found to be a number of comprehensive food commodity surveys. These surveys analyse thousands of meat and grain samples for pesticides. Although these are not fodder samples many of the crops used to produce the grain would be treated in a similar fashion to fodder crops. Also some animals in the meat surveys would have been fed on fodder. A limitation of these surveys is the relevance of the pesticides screened to fodder. A large number of organophosphates are analysed for as they are used in the treatment of stored grain and can be found in food but they are not used on fodder. There are few herbicides tested despite their importance in fodder crops. The surveys indicate that food commodities in Australia rarely exceed acceptable levels of the pesticides. The biggest residue issue facing the fodder industry is the large number of registered agricultural chemicals for which there is no established Maximum Residue Levels. MRLs are the maximum amount of an active ingredient that can be legally contained in a product. MRLs vary between countries; they are set for each active ingredient and for each commodity or commodity group. More than half of the products registered for use on fodder crops in Australia do not have an established MRL. This means that it is illegal to have any residue of these chemicals in fodder. Almost all of these products were first registered between 1960 and the mid 1980s when minimum detection level were part per million. A residues less than 10 ppm could not be detected. Most active ingredients can now be detected at ppm, this is one thousandth of the level anticipated in the 1980 s. It is very likely that illegal residues can be detected in fodder. Most of these older products pose no health risk at these very low levels and most have MRLs in food that are far above the minimum limit of detection. The fodder industry needs to address this anomaly or risk having illegal residues found in fodder. Recommendations of how this can be approached are given in this document. Approximately 80% of all Australian fodder sold for export goes to Japan. Japan is in the process of dramatically changing the way it deals with residues in food and food commodities and is likely to extend these changes into fodder. These changes will greatly increase the residues being tested for and it will be illegal to bring commodities into Japan that exceeds their MRLs. The fodder industry needs to work with Japanese authorities to ensure that Australian exporters and the farmers supplying them are aware of these changes in MRLs. The Japanese are instituting preliminary MRLs and these are often based on the mean of MRLs of trading partners. At present only the USA has MRLs for a significant number of fodder crops and so these are likely to become the defacto Japanese MRLs. There is an opportunity for the Australian fodder industry to work with the Japanese to aid in the coordination of MRLs between the two countries. The USA, Canada and China are Australia s major competitors in export fodder markets. Of these only the USA has MRLs in fodder for a significant number of pesticides. The opportunity exists for exporters to adopt the US MRLs for exported product. v

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7 1. Introduction The entry of chemical residues into the food chain from fodder is one of the greatest risks to markets overseas and in Australia. Exceeding Maximum Residue Levels in any market will likely see Australian fodder barred from markets for the short to medium term and result in a loss of confidence in the Australian product. There is increasing evidence amongst countries importing Australian fodder that they will police infringements of residues in imported product s including fodder. The objective of the project is to review current literature on the levels of chemical residues in fodder crops and to collect new data on the risk posed from the use of registered chemicals in fodder crops on the Australian fodder industry in domestic or export markets. This report provides a comprehensive analysis of the situation of residues in fodder and collates information never previously collected on products currently registered for use on oats, lucerne and pasture. This information includes the MRL for each registered active ingredient, lists of all registered active ingredients crossed referenced with the numerous product names and lists of product names crossed referenced with active ingredients. These lists represent a valuable aid to agronomists, other farm advisors and to farmers. They will allow the advisor or fodder grower to readily search for the active ingredient of a product or to identify all the products that contain a particular active ingredient. The report also identifies reside related risks to the fodder industry and recommends further work required to minimise this risk. 1.1 What are Maximum Residue Levels? There is considerable concern in the public around the world that they are being exposed to harmful residues in their food. The Australian Pesticides and Veterinary Medicine Authority (APVMA) sets MRLs in Australia for each active ingredient that is registered for use on a crop. The MRLs are the maximum concentration of a residue, resulting from the registered use of an agricultural chemical that is legally permitted in or on a food, an agricultural commodity, or animal feed. In the case of fodder crops MRLs are set using the 'the maximum label use pattern' and takes into account such factors as: ability to detect and measure the chemical in fodder, the rate of degradation of the chemical in soil, in the crop or in the animal fed the fodder, the potential for bio-accumulation with repeated application and; the acceptable dietary exposure to low levels of chemicals in food. 1.2 Trading partners and the CODEX Countries have traditionally set their own MRLs but efforts have been made to increase the uniformity of these between countries. The United Nations World Health Organisation and other international bodies have worked together to set uniform standards for foodstuffs in international commerce. The resultant list has become known as the Codex Classification of Foods and Anima/ Feeds (Codex Alimentarius Commission 1993). MRLs in Australia are often the same as in the Codex but differences do occur to account for unique climatic, environmental or use conditions in Australia. The number of active ingredients listed in the Codex is limited and there are numerous MRLs defined in Australia for which there are not yet entries in the Codex. Many of Australia s trading partners use the Codex as the basis of their MRL s. However the USA has its own extensive list (US EPA 2004) and Japan is in the process of moving from a Codex based system to defined MRLs. 1

8 1.3 Previous Work There is very little published information in Australia on chemical residues in fodder. We could find no previous review of MRLs in fodder or fodder crops. The best indication of whether MRLs are being exceeded comes from food surveys. There are two key national surveillance systems that monitor pesticide residues in food produce. These are the National Residue Survey and the Australian Total Dietary Survey. The Australian Department of Agriculture, Forestry and Fisheries undertakes a comprehensive annual survey of residues of selected agricultural chemicals in food commodities. This survey is discussed in detail in the following sections. At best it may be an indication of the situation in fodder. There are many published sources listing which chemicals are registered for use in fodder crops. The APVMA has gazetted all registered agricultural chemical products with their registered uses and provides this information on its internet site (APVMA 2004a). Other sources provide copies of registered product labels (Primary Industries and Resources, SA 2004 and Pest Genie 2004, Queensland Department of Primary Industries InfoPest 2004a). The APVMA publish data on MRLs for some registered active ingredient (APVMA 2004b). However, most products used on fodder crops are not listed in these tables indicating that they have a non-detected limit. This means that no detectable residue is allowed in fodder. There are numerous papers that warn about the need to ensure that there are no chemical residues that exceed MRL in stock feed and warn that withholding periods must are adhered to (Bennett 2002, Crook 2003, Graham et al 2004, McKenzie 1999) National Residue Survey The Australian Department of Agriculture, Forestry and Fisheries undertakes an annual National Residue Survey. This survey monitors 15 animal, 13 plant and selected fisheries and aquaculture products. It is reasonable to expect that the farming practises of farmers growing food commodities are similar to those growing fodder. This is especially likely when comparing similar commodities. For example many farmers growing oat hay also grow oats for grain. The NRS conducts four types of surveys (AFFA 2004a): Random Monitoring Designed to obtain a statistically valid profile of the occurrence of a residue (or residues) in a commodity, by a randomised sampling process. Targeted Monitoring Designed to obtain information about a known or potential residue problem, by a targeted (nonrandom) sampling process. Compliance Regulatory control measures designed to prevent the normal marketing, from specific sources, of product that is known to be contaminated. Residue Prevention Designed to prevent or minimise the risks of unacceptable residues to public health and trade. The NRS produces an annual report of its findings. The range of residues tested is determined on the basis of risk profiles and may change from year to year. Acaricides, fungicides, herbicides, fumigants and metals have all been tested for at some time. The NRS does not sample fodder and so the status of residues in fodder remains unknown. There have been considerable numbers of samples of grain and meat and as some of the meat would have been fed with fodder and some of the grain crops would have been treated in a similar fashion to fodder crops, the survey offers some indirect evidence of the situation in fodder. Surveys since 1995 are summarised below. 2

9 National Residue Survey The latest National Residue Survey report is from (AFFA 2004b). There were samples collected and analyses across all food types and commodities. There were just 11 samples that had residues of agricultural chemicals above Australian MRLs and three of these were in samples where no Australian Standard was set. There were 5883 samples of cattle meat, 5693 from sheep and 1216 from pigs. It is likely that a small proportion of these animals would have been regularly fed on fodder. Residues were tested for nine organochlorines, of these only endosulfan is still registered for use in Australia, ten organophosphate (including chlorpyrifos, diazinon, fenitrothion and malathion), eight synthetic pyrethroids (including cypermethrin and deltamethrin), and four benzoyl ureas. Of all meat samples tested for agricultural chemicals none exceeded the MRL. There were 4805 grain samples analysed of which nearly 80% were wheat and barley and only 120 or 2.5% were oats, a crop of more interest to the fodder industry. No organochlorines were found to exceed the MRL but there were four samples that contravened organophosphate MRLs. One of these was in an oat sample. Two of the four organophosphates contraventions were from products used to treat grain in storage. This is an application that is not relevant to fodder. One contravention was for chlorpyrifos in wheat where the chemical was used off-label to treat an empty grain storage unit. The contravention on oats was also for chlorpyrifos residues but a trace-back was unable to determine that cause. There were tests undertaken on other, non-organophosphate, agricultural chemicals. These chemicals include selected insecticides, growth regulators, synthetic pyrethroids and carbamates. This also covers some agricultural chemicals that are applied to crops during the growing season. Tests were conducted on 1273 samples and the only residues found were of registered grain protectants. Residues were detected in 10.5% of samples but none of these residues exceeded MRLs. National Residue Survey prior to The results of analyses on the samples conducted during the reporting period indicate only 61 analyses detected residues above MRLs (AFFA 2003). These included 47 residues of agricultural and veterinary chemicals. The meat monitoring project covered 14 commodities (largest number of samples being for cattle, sheep and pig) with samples collected. Ten organochlorines, 14 organophosphates and eight synthetic pyrethroids were analysed for. There were analyses of which only 26 residues were above MRL. These were all veterinary rather than agricultural chemicals. The grains analysed included 10 commodities (wheat contributing the largest number of samples) with 5924 samples collected; analyses were conducted with 21 residues above Australian Standards. Ten of the contraventions were due to dichlorvos residues from treatment of grain storage and the other contraventions were associated with either the misuse of products for the treatment of grain in storage or the cause could not be determined There was only one meat sample which had organochlorines that exceeded the MRLs (AFFA 2002). A successful trace-back was not made. Four samples were found to have residues of the synthetic pyrethroid - bioresmethrin for which there are no MRLs and so this was designated as a contravention. Tracebacks indicated that residues likely resulted from the treatment of grain in storage. No other agricultural chemical residues were found in meat that contravened MRLs. In grain, of the more than 6000 samples analysed 16 samples contravened organophosphate MRLs. Of these 14 contained dichlorvos which had been used to treat stored grain. The other two were also 3

10 associated with the treatment of grain, including one off label use of chlorpyrifos. There were 1544 sample of grain tested for other agricultural chemicals without any contravention of MRLs There were three meat samples which had organochlorins that exceeded the MRLs (AFFA 2001). Tracebacks determined the cause of these contraventions and none were associated with recent use of these products. There were no other agricultural chemical residues in meat that contravened MRLs. In grain, of the more than samples analysed 26% had residues detected. Only 21 samples had residues that contravened MRLs. All but one of these were associated with the treatment of grain in storage. One sample of oats contained chlorpyrifos which may have resulted from a registered use application in the field or by an off-label use on stored grain A summary report for five years of residue surveys in grain samples taken from was released in 2000 (AFFA 2000). Dichlorvos was detected at lower than MRL levels in 6% of samples of oat grain analysed, fenitrothion in 6%, piperonyl butoxide in 5% and chlorpyrifos-methyl in 4%. In sorghum grain, chlorpyrifos-methyl was detected in 19% of analyses, dichlorvos in 6%, fenitrothion and methoprene in 4%. The only above MRL results were 3 chlorpyrifos-methyl and 2 dichlorvos from 1516 analyses. In wheat, residues of chlorpyrifos-methyl were detected in 23% of analyses, fenitrothion in 13%, methoprene in 10% and dichlorvos in 4%. The only above MRL results were for dichlorvos (6 from analyses). The MRL for dichlorvos was 2 mg/kg at this time and has subsequently been increased to 5 mg/kg, this would reduce the number of contraventions to two. In barley, residues of fenitrothion were detected in 24% of analyses, piperonyl butoxide in 9%, bioresmethrin in 8% and dichlorvos in 6%. The only above MRL detection were for fenitrothion (one from 3472 analyses) and dichlorvos (12 from 3472 analyses). Had the MRL for dichlorvos been 5 mg/kg then none would have been above the MRL. National Residue Survey implications for the fodder industry The NRS undertakes the analysis of an enormous number of grain samples each year and finds a very small number of contraventions of the MRLs of agricultural chemicals, generally less than 0.5%. Almost all of these are associated with the treatment of grain in storage, an application that is not relevant to fodder. It is important to note two critical weaknesses in the NRS when extrapolating to fodder. It has not targeted fodder and the agricultural products analysed for are largely the banned organochlorines or those products used to treat stored grain. Secondly MRLs exist for food commodities for almost all products used, including the main grain grains. By comparison MRLs are not determined for more than 50% of the active ingredients used on fodder crops Australian Total Diet Survey Food Standards Australia New Zealand is a bi-national statutory authority that develops standards for foods produced or imported in Australia and New Zealand. It is the role of FSANZ to protect the food supply of Australians and New Zealanders. It monitors foods for pesticide residues and other contaminants. FSANZ s Total Diet Survey (FSANZ 2003) is a comprehensive assessment of consumers dietary intake to pesticide residues, contaminants and other substances. There have been 20 surveys conducted approximately every two years. The results of the 20 th survey demonstrated that the levels 4

11 of pesticide residues in food in Australia are very low, and in all cases they are within acceptable safety limits. The survey samples food as table ready rather than as the raw commodity (eg bread rather than flour and flour rather than wheat) and selection is made on the basis of a number of standard diets (eg male aged years). It analysed for similar agricultural chemicals to the NRS. These consisted of: 11 organochlorines, 36 organophosphates, 9 synthetic pyrethroids and 4 carbamate insecticides, 21 fungicides, 1 synergist and 6 other chemicals (Table 1). Table 1 Pesticides and metabolites analysed for in the 20 th Australian Total Diet Survey in Organophosphorus Carbamates Fungicide Pesticides Acephate Aldicarb* Bupirimate Azinphos ethyl Carbaryl Captan Azinphos-methyl Fenoxycarb Chlorothalonil Bromophos-ethyl Pirimicarb Dicloran Carbophenothion Difenoconazole Chlorfenvinphos Chlorinated Organic Dimethomorph Pesticides Aldrin Diphenylamine -methyl BHC (total: α,β,γ[lindane],δ) Flusilazole Coumaphos Chlordane Hexaconazole Demeton-S-methyl Total DDT Imazalil Diazinon Dicofol Iprodione Dichlorvos Dieldrin Metalaxyl Endosulfan Myclobutanil Dioxathion Endrin o-phenylphenol Ethion Heptachlor Procymidone Fenamiphos Hexachlorobenzene Propiconazole Fenchlorphos Tetradifon Pyrimethanil Fenitrothion Tebuconazole Fenthion Synthetic pyrethroids Triadimefon Formothion Bifenthrin Triadimenol Malathion/Maldison Bioresmethrin Vinclozolin Methacrifos Cyfluthrin Methamidophos Cyhalothrin Synergist Methidathion Cypermethrin Piperonyl butoxide Mevinphos Deltamethrin Monocrotophos Fenvalerate & Esfenvalerate Other Omethoate Flumethrin Coumatetralyl Parathion Permethrin Methoprene Parathion-methyl Oxyfluorfen Phorate Pendimethalin Phosalone Propargite Phosmet Tebufenpyrad Pirimiphos-methyl Thiometon Trichlorfon Vamidothion All estimated dietary exposures to pesticide residues were below 16% of the respective Allowable Daily Intake and therefore all exposures are less than the applicable health standards. An assessment of the data showed that there were 38 agricultural chemicals found in food with the synergist, piperonyl butoxide being found in the most foods. It was found in 11 food s including rolled oats. No agricultural chemical was found to exceed MRL levels. 5

12 The foods with the most number of chemicals found in them were nectarines with 13 and tomatoes with 12. Of the nine samples of rolled oats analysed, seven contained trace amounts of chlorpyrifos, three piperonyl butoxide and one fenitrothion. These are all insecticides or synergist for insecticides. It is important to note that the concentrations of these products were very low, less than 0.06 part per million but still detectable. Australian Total Diet Survey implications for the fodder industry Had these tests been undertaken on fodder oats these very low levels would have exceeded the MRLs for chlorpyrifos and piperonyl butoxide as these active ingredients have no MRLs of fodder. By comparison an MRL has been established for fenitrothion at 10 part per million which is very more than 100 time higher than the levels of fenitrothion found Victorian Produce Monitoring Program The Department of Primary Industries, Victoria s annual pesticide monitoring survey found that more than 99% of fresh produce samples tested by DPI did not contravene MRLs (McGowan 2002). This survey being on fresh produce is of limited use to fodder growers but importantly it does include some herbicides, which are not commonly included in other surveys but are regularly used on fodder crops. The program included 3549 analyses on 259 samples of 22 different types of produce. Of the analyses, 3492 were for residues of agricultural chemicals on buckwheat, fresh fruit and vegetables; and 57 analyses for residues of heavy metals in vegetables. Samples of fresh fruit, vegetables and buckwheat were analysed for the agricultural chemicals: aldicarb, azinphos ethyl, azinphos methyl, carbaryl, carbofuran, chlorfenapyr, chlorothalonil, chlorpyrifos, cfluthrin, cyhalothrin, cypermethrin, deltamethrin, diazinon, dichlorvos, dimethoate, dithiocarbamates, endosulfan, endrin, esfenvalerate, ethion, enchlorphos, fenitrothion, fenthion, fenvalerate, fipronil, flumethrin, indoxacarb, iprodione, linuron, malathion, maleic hydrazide, methiocarb, methomyl, metolachlor, mevinphos, parathion, permethrin, pirimicarb, procymidone, propiconazole, pyrimethanil, spinosad, tebufenpyrad and trichlorfon. There were also two programs of random sampling on asparagus and nectarines. Of the 3549 analyses for agricultural chemical residues conducted under the Victorian Produce Monitoring Program, the Maximum Residue Limits (MRLs) were exceeded on 7 occasions. There were contraventions of MRLs in: 3 samples of spinach for chlorpyrifos and one for cypermethrin, one carrot for linuron, one strawberry for trichlorfon and one raspberry for procymidone. Of all the contraventions only one was for a herbicide which was linuron Pesticide market data Information exists on the market for agricultural chemicals in Australia. This market data concentrates on the major crop uses such as grains and horticulture but provides no data on fodder (Wood Mackenzie 2001). The total market was estimated at over $1,600m in 1999 of which herbicides made up $800m, insecticides $500m and fungicides $200m (Radcliffe 2002). The largest single product was the knockdown herbicide glyphosate of which tonnes was consumed. This was followed by the selective herbicides: atrazine and simazine of which 3000 tonnes was used. Of the other herbicides over 1000 tonnes of phenoxy and similar products (of which and are the major products) and another 1000 tonnes of paraquat and diquat were used. For insecticides there was 5000 tonnes of organophosphate and 3000 tonnes of carbamates used. The most used organophosphates were chlorpyrifos followed by parathion, dimethoate, propenfos and diazinon. The most used carbamate was metham sodium. Over 3000 tonnes of fungicides were used, of which mancozeb was the largest followed by captan. There was 500 tonnes of plant growth regulators used, dominated by ethephon. 6

13 The above figures indicate the vast quantities of active ingredients being applied annually to crops in Australia and indicate the potential for MRLs to be exceeded, especially where these are nondetectable limits. 1.4 Trends in product registrations Over the last 5 years there has been a proliferation in the number of products registered and used on fodder crops. There are 505 chemical products currently registered for use on oats, 398 on lucerne and 776 on pastures. It has become very hard for fodder growers and their advisers to determine which products have MRLs for use in fodder and whether the products they use are registered for the purpose. 1.5 Trends in MRLs Many of the products registered for use on fodder crops were released in the 1960s, 70s and early 80s. At that time the minimum level of detection of residues was greater than 10 part per million and more commonly 50 ppm. For these products the MRLs were generally set at below the limit of detection. This meant that providing no measurable amount of the product was detected in the fodder it could be sold. Since then advances in analytical chemistry has reduced the level of detection to as low as 0.01 ppm for many chemicals, thereby greatly increasing the chances of detecting residues at extremely low levels even though these residues pose no health risk. For many of these products the work required to justify retaining the MRL at the originally intended level of >10 ppm has never been undertaken as the chemical industry view the fodder crop market as too small to warrant the investment required. Consequently it is likely that chemicals for which there are no MRLs can be detected in fodder crops. This is despite the fact that these chemicals may pose no risk at these levels and may have had much higher MRLs determined as safe in similar crops such as grain crops. The requirements and criteria for the setting of MRLs have been amended over time in Australia and the consequent discrepancy in crop definitions can cause confusion. For example fodder crops are now categorised as Primary Feed Commodities but have previously been categorised in other ways. For instance does an MRL for legume animal feed suffice for lucerne hay or cereal fodder for sorghum? Since the 1990s the APVMA has moved to a system where MRLs for minor crops can be set on commodity groups, providing these commodities have a similar use pattern. This can greatly reduce the cost of obtaining data for these smaller crops. These are known as Group MRLs. Group 20 is Cereal Grains and data collected on wheat and barley can be extrapolated to oats and from wheat to sorghum and millet (NRA 2000). Despite this more than half of the product registered for use on fodder still have no established MRLs. 7

14 2. Crops 2.1 Lucerne In 2004 there are 398 product currently registered for use on lucerne. These products are made up from 53 active ingredients. Of these 53 active ingredients only 12 (or 23%) have an established MRL that directly relates to lucerne fodder or hay (Table 2). That is these MRLs are for primary feed commodities and lucerne fodder. These MRLs range from 0.1 mg/kg or 0.1 part per million to 500 parts per million. There are an additional eight active ingredients (15% of 53 active ingredients) that have MRLs for similar categories that should suffice for lucerne fodder. These categories are: legume animal feed and miscellaneous fodder. This brings the total number of active ingredients with satisfactory MRLs to 20 or 38% of the total registered. One active ingredient, quizalofop, has an MRLs for numerous other legume fodder crops but does not specify lucerne. There are three active ingredients that have MRLs on legume pastures which would not cover lucerne fodder but may be suitable indicators. Table 2. Active ingredients registered for use on lucerne that have an MRL for a lucerne hay or a similar category. Primary feed commodities Lucerne fodder Legume animal feed Legume pasture Miscellaneous fodder Bifenthrin Butroxdim Beta cyflurthrin Omethoate Atrazine Fenitrothion Diflufenicam Flumetsulam gamma Diquat Haloxyfop cyhalothrin Imidacloprid Imazamox Imazethapyr Pendimethalin Iprodione Paraquat Propaquizafop Pirimicarb Sethoxydim Active ingredients without MRLs There are 29 active ingredient registered (and an additional three with MRLs on legume pasture only) on lucerne for which the MRL is beneath the level of detection (Table 3). With the exception of Bacillius thuringiensis which is exempt from the requirements of an MRL, the effective MRLs for these active ingredients is less than 0.01 ppm. This is a tenth of the lowest MRL for the chemicals in Table 2 and less than one percent for most ingredients in that Table. Table 3. Active ingredients registered for use in lucerne for which the MRL is non-detectable Carbaryl Fluroxypyr Propyzamide B Lamba cyhalothrin Simazine 2,2-DPA Chlorthal Maldison Terbacil Asulam Diazinon Metalaxyl Trichlorfon Asulox Methabenzthiazuron Trifluralin Bacillius thuringiensis Disulfoton Methidathion Bendiocarb EPTC Methomyl Bromoxynil Fluazifop Phosmet Comparison between for fodder and food requirements Of the active ingredients registered for use on lucerne all but two, 2,2-DPA and asulox (Bacillius thuringiensis is exempt from an MRL on food also), have MRLs on food. These MRLs on food are all obviously above the limit of detection. A list of MRLs for foods that might be expected to have MRLs lower or similar to fodder crops is listed (Table 4). These food MRLs range from 0.01 ppm to 5 ppm with most being more than 0.5 ppm. It is important to note that there are chemicals that have MRLs for fodder and for human foods. The food MRLs are almost always much lower than those for animal fodder. 8

15 Table 4. Active ingredients registered for use in lucerne for which the MRL is non-detectable and their MRL on food commodities. Active ingredient MRL on food commodity Designated food commodity 0.02 Cereal grain B 0.02 Cereal grain Asulam 0.4 Potatoes Bendiocarb 0.02 Banana Bromoxynil 0.02 Cereal grain Carbaryl 5 Cereal grains 0.1 Cereal grains Chlorthal 5 Vegetables Diazinon 0.1 Cereal grains 0.05 Cereal grains Disulfoton 0.05 Vegetables EPTC 0.04 Cereal Grains Fluazifop 0.5 Pulses Fluroxypyr 0.2 Cereal grains Lamba cyhalothrin 0.2 Barley Maldison 8 Cereal grain Metalaxyl 0.05 Cereal grains Methabenzthiazuron 0.05 Cereal grains Methidathion 0.01 Cereal grain Methomyl 0.1 Cereal grains Phosmet 0.05 Cereal grains Propyzamide 1 Lettuce Simazine 0.01 Beans Terbacil 0.5 Almonds Trichlorfon 0.1 Cereal grains Trifluralin 0.05 Cereal grains A comparison of the MRLs, of the 20 active ingredients that are registered for use in lucerne, that are allowed and human foods and animal fodder shows that the MRLs are far higher in fodder than for food in all but two chemicals (Table 5). The exceptions were bifenthrin and fenitrothion. There are 18 active ingredients for which the MRL is higher in fodder than human food. On average the MRL in fodder is more than 800 times that of food but this is somewhat distorted by paraquat where the difference is a factor of 10,000. The median difference is the MRL of fodder being 50 times that for the same chemical in food. Table 5. Comparison of the MRLs in human foods and animal feed for active ingredients registered for use in lucerne. Active ingredient Animal feed/fodder Food MRL Food Commodity MRL (ppm) (ppm) alpha cypermethrin 5 1 Cereal Grains Atrazine Maize Bifenthrin Cereal Grains Diflufenicam Pulses Diquat Wheat Cereal Grains Fenitrothion 5 10 Cereal Grains Flumetsulam Wheat gamma cyhalothrin Wheat Wheat Imazethapyr Pulses Imidacloprid Cereal Grains Iprodione Lupin 9

16 Active ingredient Animal feed/fodder Food MRL Food Commodity MRL (ppm) (ppm) Omethoate Cereal Grains Paraquat Cereal Grains Pendimethalin Wheat Pirimicarb Cereal Grains Propaquizafop Pulses Quizalofop Beans Sethoxydim Beans If the fodder industry were able to get these food MRLs as temporary MRLs for fodder this would greatly reduce the risk of contravention of MRLs. A list of all current MRLs for registered products is provided (Appendix I). A list of all registered products is provided in alphabetical order of product (Appendix II) and in alphabetical order for active ingredient (Appendix III). These lists will allow farmers and advisers to readily confirm whether the product they are using is registered, what active ingredient is in a product and at what concentration its MRLs are set. 2.2 Oats There are 505 product currently registered for use on oats. These products contain 53 active ingredients and of these only 25 have an established MRL that directly relates to oaten fodder or hay (Table 6). These MRLs are for primary feed commodities, cereal fodder and oat fodder. These MRLs range from 0.05 mg/kg or 0.05 part per million to 500 ppm. Table 6. Active ingredients registered for use on oats that have an MRL for oaten hay or a similar category. Primary feed commodities Cereal fodder Oat fodder Beta cypermethrin Beta cyflurthrin Flumetsulam Chlorsulfuron Carfentrazone Cypermethrin Clopyralid Deltamethrin Diflufenicam Metolachlor Fenitrothion Metribuzin Fluroxypyr Paraquat Flutriafol Tebuconazole Metosulam Triasulfuron Omethoate Propiconazole Terbutryn triflumuron Triticonazole There are 28 active ingredient registered on oats for which the MRL in fodder is beneath the level of detection (Table 7). The effective MRLs for these active ingredients is less than 0.01 ppm. This is less than one percent for most of the MRLS for these chemicals on food. 10

17 Table 7. Active ingredients registered for use in oat crops for which the MRL is non-detectable in fodder Dicamba Phosphide B MCPB Picloram Bromoxynil Diquat Methabenzthiazuron Procymidone Carbaryl Esfenvalerte Methiocarb Tebuthiuron Carboxin Linuron Methomyl Thiram Malathion Methoprene Triadimenol Diazinon Maldison Permethrin Trichlorfon Of the active ingredients registered for use on oats only thiram had no MRL on food. As with lucerne these MRLs on food are above the limit of detection and normally MRLs for human foods are much lower than for animal fodder. Consequently, it is most unlikely that these chemicals pose such a high risk to foods that their MRLs should be beneath the level of detection. A list of all MRLs for registered products is provided (Appendix IV). A list of all registered products is provided in alphabetical order of product (Appendix V) and in alphabetical order for active ingredient (Appendix VI). This will allow farmers and advisers to readily confirm whether the product they are using is registered, what active ingredient is in a product and at what concentration its MRLs are set. 2.3 Pasture There are 765 product currently registered for use on pastures. These products contain 76 active ingredients. Of these 76 active ingredients only 12 products have MRLs defined in a way to definitely include pasture based fodder (primary feed commodities and legume fodder and grass hay) but there are an additional 13 active ingredients that have MRLs that could be sufficient to cover pasture fodder. These categories are: legume animal feeds, legume fodder and grass fodder and miscellaneous fodder. There are eight active ingredients that have MRLs for pasture forage which may act as an indicator of the risk associated with fodder based on these pastures (Table 8). Table 8. Active ingredients registered for use on pasture that have an MRL for pasture hay or other relevant categories. Primary feed commodities Legume fodder & grass hay Legume animal feed, legume fodder & grass fodder 11 Pasture forage Miscellaneous fodder alpha cypermethrin Fenitrothion Butroxydim Beta cyflurthrin Omethoate Atrazine Prometryne Carbendazim Clopyralid Beta cypermethrin Diflufenicam Fipronil Diquat Flumetsulam Fluroxypyr gamma Haloxyfop cyhalothrin Imazamox Imidacloprid Imazethapyr lamba Metsulfuron cyhalothrin Metolachlor Pendimethalin Phosphorous acid Paraquat Propaquizafop Pirimicarb Quizalofop Sethoxydim Terbutryn There are 41 active ingredient registered on pastures for which the MRL is beneath the level of detection, although some have MRLs on other crops that may be useful indicators (Table 9). For these the effective MRLs are less than 0.01 ppm.

18 Table 9. Active ingredients registered for use in pastures for which the MRL is non-detectable Dicamba MCPB Picloram B Diclofop Mesurol Simazine 2,2-DPA Metalaxyl Sulfometuron Asulam Disulfoton Metarhizium Anisopliae Tebuthiuron Asulox Ethofumesate Methabenzthiazuron Terbacil Bacillius thuringiensis Fluazifop Methidathion Thiobencarb Bromoxynil Flupopanate Methomyl Tribenuron Carbaryl Hexazinone Molinate Trichlorfon Imazapic Permethrin Trifluralin Chlorthal Maldison Phosmet Diazinon Phosphide Of the active ingredients registered for use on pastures almost all have MRLs on food. As with the other fodder crops the limits in food could be expected to be far lower than for fodder. A list of all MRLs for registered products is provided (Appendix VII). A list of all products registered for use on pasture is provided in alphabetical order of product (Appendix VIII) and in alphabetical order for active ingredient (Appendix IX). 12

19 3. Major fodder trading partners 3.1 Japan Japan is the destination of approximately 80% of Australia s fodder exports (Colin Peace pers. comm.). In the past, when Japan has not had a MRL for a particular active ingredient (it has very few for fodder) it has accepted Codex MRLs. Japan is now changing the way in which it establishes residues standards. In 2003, the Ministry of Health, Labour and Welfare revised the Food Sanitation Law in respect to chemical residues in products entering Japan (MHLW 2003a). It is in the process of drafting provisional MRLs for many agricultural chemicals in food products. Until 2006 Japan will continue to use its past system but after this its provisional MRL list will come into force. Any MRL that is not on the provisional list or previously approved will become illegal. Any import that is found to have detectable levels of active ingredients that are not on the provisional MRL list will be rejected. This has grave implications for the Australian fodder export industry unless MRLs are established for products used in Australia. There is a list of 66 active ingredients for which MRLs have been established previously in Japan and these are not affected by the changes (MHLW 2003b). However only four of these are used on fodder crops in Australia. Therefore the great majority of products used in Australia are involved in the changes. Japan s preliminary MRLs are set for each crop and there are almost no fodder products on the list. It is unclear what will happen to MRLs in fodder at this stage. However the law gives indications of how residues in fodder are likely to be treated. A flowchart has been made of the decision making process (MHLW 2003a). Where there are standards available in the Codex these are used. Where there are no Codex standards and no Japanese standards then a mean of these foreign countries MRLs will be used. These MRLs are on a crop by crop basis ie MRLs will need to be determined separately for oaten, lucerne, grass or pasture fodder. 3.2 Major fodder competitors Australia competes with numerous other suppliers into the international fodder market. The greatest competition into major markets comes from the USA, Canada and China USA The USA has MRLs for a far more extensive range of active ingredients than is available in Australia or in importing countries. The regulating body in the USA, the US EPA, allows MRLs for some Crop Groups. Where an active ingredient is not absorbed into the plant it is possible to share MRLs between similar crop species (US EPA 2004). Some of these groups are of interest to the fodder industry. Group 16 consists of the Forage, Fodder and Straw of the Cereal Grain Group. These cereals include: barley (Hordeum spp.), buckwheat (Fagopyrum esculentum), corn (Zea mays), millet, pearl (Pennisetum glaucum), millet, proso (Panicum milliaceum), oats (Avena spp.), popcorn (Zea mays var. everta), rice (Oryza sativa), rye (Secale cereale), sorghum (milo) (Sorghum spp.), teosinte (Euchlaena mexicana), triticale (Triticum-Secale hybrids), wheat (Triticum spp.) and wild rice (Zizania aquatica). Group 17 consists of the Grass Forage, Fodder and Hay Group. This group includes: any grass, Gramineae family (either green or cured) except sugarcane and those included in the cereal grains group above, that will be fed to or grazed by livestock, all pasture and range grasses and grasses grown for hay or silage. Group 18 consists of Nongrass Animal Feeds (Forage, Fodder, Straw, and Hay). This group includes: alfalfa or lucerne (Medicago sativa subsp. sativa), Bean, velvet (Mucuna pruriens var. utilis), clover (Trifolium spp., Melilotus spp.), kudzu (Pueraria lobata), lespedeza 13

20 (Lespedeza spp.), lupin (Lupinus spp.), sainfoin (Onobrychis viciifolia), trefoil (Lotus spp.), vetch (Vicia spp.), vetch, crown (Coronilla varia) and vetch, milk (Astragalus spp). This process has greatly reduced the number of individual crops for which MRLs need to be determined and aided the establishment of MRLs in these fodder crops. Table 10. Active ingredients registered on oats in Australia, for which there is no MRLs but where MRLs are defined in Group 16 in the USA for hay or straw or for forage. Active ingredient Hay or Straw Commodity MRL (ppm) Millet straw 20 Bromoxynil Oats 0.1 Carboxin oat straw 0.2 wheat straw 6 Dicamba Oats 20 wheat 2 Methomyl oats 10 Picloram oat straw 1 Active Ingredient Forage MRL (ppm) Diazinon Sorghum 10 Diquat Grass 0.1 Esfenvalerte sorghum 10 Malathion Sorghum 135 Permethrin Grass range 15 Table 11. Active ingredients registered on lucerne in Australia for which no MRLs but where MRLs are defined in Group 18 in the USA for hay or straw. Active ingredient Hay or Straw Commodity MRL (ppm) Bacillius thuringiensis Exempt Exempt Carbaryl lucerne 100 lucerne 13 Diazinon lucerne 10 lucerne 2 Iprodione bean hay 90 lamba cyhalothrin lucerne 6 Metalaxyl lucerne 20 Methidathion lucerne 12 Methomyl lucerne 10 Simazine lucerne 15 Terbacil lucerne 2 Trifluralin lucerne 0.2 NB There were no active ingredients with MRLs on forage that did not have an MRL on hay. There are eight active ingredients in oat hay and 12 in lucerne hay that have MRLs in the USA but do not have MRLs in Australia. 14

21 3.2.2 CANADA Canada has MRLs defined for almost no fodder commodities, far fewer than does the USA, or even Australia. MRLs are set by the Canadian Pest Management Regulatory Authority. Although there is a comprehensive list of MRLs for food commodities, including cereal grains (Pest Management Regulatory Authority 2004) there is no mention of hay, fodder or forage. That some MRLs for fodder do exits in Canada is supported by the fact that conflicts between US MRLs and Canadian MRLs for fodder are acknowledged by groups working with the North America Free Trade Agreement. CropLife Canada, is a trade association representing the manufacturers, developers and distributors of plant science innovations - pest control products and plant biotechnology - for use in agriculture, urban and public health settings (CropLife 2004). There were very few active ingredients with MRLs for fodder commodities (Table 12). Table 12. The number of active ingredients that have MRLs on fodder commodities in Canada. Commodity Active ingredients with MRLs Lucerne hay 3 Lucerne forage 1 Oaten hay 1 Clover hay 2 Wheaten hay 2 Barley straw 3 Oaten straw 2 Wheat straw CHINA The authors were unable to locate MRL data for fodder in China. 15