Maintaining an Export-Ready Crop:The Importance of MRLs

Agronomy Update 2020, Red Deer

January 7, 2020

Greg Bartley, Pulse Canada

Outline

• Importance of market access to Canadian agriculture

• Overview of Maximum Residue Limits (MRLs)

• Trade risks and concerns of crop protection products and MRLs

• Current approach to managing MRL risks

Importance of Market Access to Canadian Agriculture

Over 90% of its canola

Over 80% of its wheat

Over 80% of its pulses

• Canada’s crop production far exceeds our domestic demand for food

• The continued success of Canadian agriculture is reliant on our export market

• Canada exports:

What’s the issue?

• Canada’s exports must meet the

needs of our customers - which

are not always the same as

Canadian regulations

• Canada’s reputation as a safe,

reliable supplier is valuable

• We must continue to meet the

needs of our customers

Customers Have their Own Requirements

• Customer requirements are becoming more complex

• Countries regulate food to protect plant, animal, human and environmental health

• Close attention is required for:

• Pesticides and their residues

• Seed technology, such as biotechnology

• Plant diseases like blackleg and fusarium

Meeting Pesticide Residue Requirements

“An MRL represents the maximum amount of pesticide residues that are expected to remain on a food product when the pesticide is used according to label directions.” – Health Canada, 2018

Source: “Pesticide use and food safety,” European Crop Protection Association

• Not a measure of food safety

• Used primarily for trade purposes

• Canadian Crops must meet the MRLs set by the destination country in order to avoid trade disruptions.

MRL = Maximum Residue Limit

The Trading Environment is Shifting

1. More missing MRLs as fewer countries are using international standards (Codex MRLs)

2. Residue testing is more sensitive

3. Heightened monitoring and testing of residues

4. Hazard-based MRLs vs. risk-based MRLs

5. Increased sensitivity to public attitude towards pesticides

Other

National, Codex

NationalEU Deferral

Codex and Codex

Recommended

Importer Use of MRLs by Source:

Export Destinations – 105 Countries

Exports Have Been Impacted

• High profile noncompliance in early 2011

• EU second largest market for pulses

Costs Actions

• Rejected cargo

• Product recall

• Reselling distressed cargo

• Demurrage, interest

• Handling and segregation

programs

• Rapid testing tool for industry

• Grower communication

PULSE – Glyphosate on Lentils in European Union

Exports Have Been Impacted

PULSE – Glyphosate on Lentils in European Union

• 0.1 ppm default MRL, later revised by EFSA by a factor of 100 to 10 ppm

• Lesson Learned: a non food safety issue can be treated as a serious food safety issue with serious disruption to trade, threat of retail shelf recalls

Crop EU Canada US

------------- ppm-------------

Lentils 0.1 (10) 4 5

Peas 10 5 8

Beans 2 4 5

Canola 10 20 20

Wheat 20 5 30

Barley 20 10 30

What are we Doing?

Managing Risk of Non-Compliance

• Short term: ensure no unacceptable level of trade risk

– Balance, not eliminate, trade risk

– Keep it Clean! Program

• Medium term: work to attain the required MRL (if possible)

– Communication with product registrants

• Longer term: broader, multi-commodity, multi-country efforts to advocate for harmonization of MRLs through Codex Alimentarius, regulatory cooperation, trade agreements, etc.

– Canada Grains Council

Keep it Clean! Program

• Collaborative effort to inform producers from cereals sector (Cereals Canada, Barley Council of Canada and Prairie Oat Growers Association), Canola Council of Canada and Pulse Canada

• Lists potential market access issues arising from specific herbicides, fungicides and insecticides (including bin treatments)

• Highlight beneficial management practices to keep markets open

Source of market access information for farmers, agri-retailers and agronomists

www.keepingitclean.ca

Keep it Clean! Campaigns

• Follow the Label

• Pre-Harvest Glyphosate

• Five Simple Tips

• Pulse MRL Advisory

• Pre-Harvest Interval/Spray to Swath Calculator

Tip #1: Use Acceptable Pesticides Only

• Only use pesticide that are both registered for use on you crop in Canada and won’t create trade concerns.

• Talk to your grain buyer to ensure products you are using are acceptable to both domestic and export customers

Keep It Clean! Pulses –2019 Grower AdvisoryMarket considerations for use of pulse crop protection

products

Green = no regulatory issues

Yellow = talk to your buyer. There is at least on market where

MRLs are not established

Red = Not registered – do not use

https://keepingitclean.ca/pulses

Tip #2: Always Read and Follow the Label

• Follow the label for rate, timing and pre-harvest interval (PHI) to ensure residues in the treated product will not exceed the MRL.

“Pre-harvest interval (PHI) is the minimum amount of time between the last application of a pesticide and when the crop can be harvested. Harvest is the cutting of the crop or removal of the produce from the plant.” –Health Canada, 2018

Market Considerations for Pre-Harvest Glyphosate

• Glyphosate remains highly scrutinized both domestically and in the global market place.

• The use of pre-harvest glyphosate is restricted on some crops

• Often not a regulatory issue… a consumer perception issue!

Pre-Harvest Glyphosate

• Glyphosate is registered for pre-harvest perennial weed control and is NOT to be used as a desiccant.

• Pre-harvest glyphosate should only be applied when seed moisture content is LESS THAN 30% in the LEAST MATURE part of the field.

• What does 30% seed moisture content look like?

https://keepingitclean.ca/images/pdf/pre-harvest-glyphosate-staging-guide.pdf

Summary

• MRLs are used primarily for trade purposes

• We will continue to hear more about MRLs

• Ongoing efforts to get in front of the problem– Annual MRL advisory and value chain working groups

– International coalition work

• Balance, not eliminate trade risk so farmers maintain access to products

• Need to pay attention to labels, especially with politically sensitive active ingredients

• Talk to your buyer before using crop protection products that may pose a market access risk

Questions?

Greg Bartley MSc, P.Ag., CCADirector, Crop Protection & Crop QualityPulse CanadaOffice: 204-925-3788Email: gbartley@pulsecanada.com