Contents

5.8 - PESTICIDES

5.8.1 - PESTICIDE INSPECTIONS

The objective of a Pesticide Inspection is to determine the likelihood of excessive residues of significant pesticides in or on products in consumer channels, and to develop sources of information for uncovering improper use of pesticide chemicals.

This requires directing coverage to two major areas:

1. Pesticide practices in the production and processing of field crops.
2. Application of pesticide chemicals in establishments storing and processing raw agricultural products.

Pesticide coverage must be provided during all food establishment inspections. Coverage of raw agricultural products will generally be on a growing-area basis.

Problem areas include:

1. Improper use of pesticides around animals - gross misuse of sprays and dips in animal husbandry may result in pesticide residues in foods.
2. Use of contaminated animal feeds - waste and spent materials from processing operations may contain heavy concentrations of pesticide residues, which were present in the original commodity. See Compliance Policy Guide 575.100. 
3. Past pesticide usage - past pesticide practices on growing fields. Past use of persistent pesticides may result in excessive residues in the current food crop. You may need to check on pesticide usage for several years prior to an incident to ensure you gather enough information. Some pesticides last for many years in the environment.

5.8.2 - CURRENT PRACTICES

Cooperative Activities - important sources of information relative to evaluating the "Pesticide Environment" include:

1. At the start of the growing season, spray schedules recommended for each crop by county agents, state experiment stations, large pesticide dealers, farmers cooperatives, et al should be obtained.
2. Visits to agricultural advisors may provide information relative to heavy infestation of insect pests and fungal infections on specific crops in specific areas.
3. Daily radio broadcasts in most agricultural areas may provide information on spray schedules, insect pests, harvesting and shipping locations, etc.
4. Field employees of fruit and vegetable canning and freezing plants usually recommend spray schedules, pesticides, and harvesting schedules for products produced by contract growers.
5. United States Weather Bureau Offices and their reports will provide data on weather conditions, which may effect insect growth and their development, size of fruit or leaf growth, and dissipation of pesticide chemicals.
6. USDA Market News Service daily price quotations, and weekly quotations in trade magazines provide information regarding harvesting schedules since market prices are indicators of how quickly a crop will be harvested in a given area. Growers who have the opportunity to obtain high prices may harvest their crops without regard to recommended pre-harvest intervals.
7. State Colleges of Agriculture seminars or short courses on food and vegetable production may alert you to significant departures from usual agricultural practices. Prior approval to attend such meetings should be secured from your supervisor.
8. Pesticide suppliers and distributors may provide information on spray practices, schedules, and the name and address of growers, etc.

NOTE: The U.S. Department of Agriculture has a Pesticide Data Program (PDP), which provides data on pesticide use and residue detection. This program helps form the basis for conducting realistic dietary risk assessments and evaluating pesticide tolerances. Coordination of this program is multi-departmental, involving USDA, EPA and FDA, covered by a MOU (Federal Cooperative Agreements Manual). As a part of this program USDA collects data on agricultural chemical usage, and factors influencing chemical use, and collects pesticide residue data through cooperation with nine participating states. USDA provides this data to EPA, FDA and the public. Several USDA publications are listed below as reference material.

The contact point at USDA for pesticide residue matters is:

Martha Lamont, Chief
Residue Branch, Science Division
Agricultural Marketing Service, USDA
8700 Centreville Road, Suite 200
Manassas, VA 221110
703-330-2300

Reference materials - the following reference materials provide background and data necessary or helpful in evaluating current practices. This material should be available at the District office.

1. Pesticide Chemicals - Regulations under the Federal Food, Drug and Cosmetic Act on tolerances for pesticides in food administered by the Environmental Protection Agency (EPA). (See 40 CFR 185)
2. EPA's Pesticide Regulations - Tolerances for Raw Agriculture Products. (See 40 CFR 180)
3. EPA's Rebuttable Presumption Against Registration (RPAR) List.
4. Pesticide Index. - By William J. Wiswesser. A publication containing information on trade names, composition and uses of commercial pesticide formulations.
5. The Daily Summary or Weekly Summary. News releases and reports from USDA.
6. USDA's Weekly Summary Shipments-Unloads.
7. Agricultural Economic Report No. 717 Pesticide and Fertilizer Use and Trends in U.S Agriculture (May 1995)
8. Annual Pesticide Data Summary
9. Reports from USDA's Crop Reporting Board.
10. USDA's Pesticide Assessment Reports.

5.8.3 - GROWERS

Preliminary investigation of growing areas at the start of the season will provide data necessary for district work planning including production schedules, types and acreage of crops, pesticides used and the names and addresses of growers and shippers.

Growing Dates - The significant growing dates relative to pesticide usage are as follows:

1. Planting date,
2. Date of full bloom, and
3. Date of edible parts formation.

Harvest Dates - The dates of the anticipated harvest season will provide planning information relative to pre-harvest application and shipping.

Acreage - This will provide volume information for work planning.

5.8.3.1 - Pesticide Application

Ascertain the actual pesticide application pattern for each crop. Look for objective evidence to document actual grower practice. Check the grower's supply of pesticide chemicals, look for used pesticide containers, visit his source of supply, etc. Check spraying and dusting practices. Establish if pesticide chemicals are used in such a manner that excessive residues might result.

The following information provides a basis for evaluating pesticide usage:

1. Pesticide Chemical Applied - List the common name if there is no doubt as to the chemical identity of the pesticide. Include labeling indications and instructions.
2. Method of Application - Describe the method of application i.e., ground rig, airplane, greenhouse aerosol, hand, etc.
3. Formulation - Describe the formulation i.e., wettable powder, emulsifiable concentrate, dust, granules, aerosol, etc. Express as pounds of active ingredient per gallon or percent wettable powder.
4. Number of Applications and Dates.
5. Rate of Last Application - Calculate the amount of active ingredient per acre.
6. Pre-Harvest Interval (PHI) - Calculate the number of days between the day of the last application of pesticide and the harvest date or anticipated harvest date. Compare to the PHI.
7. Visible residue on grower's crop.
8. Summary of Usage - Determine the USDA Summary Limitations and evaluate the responsible usage.

5.8.3.2 - Pesticide Misuse/Drift/Soil Contamination

Pesticide residues, which exceed established tolerances, action levels, or "regulatory analytical limits" may be caused by pesticide misuse which can include:

1. Excessive application of a chemical on a permitted crop.
2. Failure to follow labeled time intervals between the last pesticide application and harvest.
3. Use of a non-approved pesticide on a crop.
4. Failure to wash a crop when pesticide labeling requires it (e.g., for certain EBDC's).

Other conditions, which may cause illegal residues, include spray drift and soil contamination.

Drift may be documented by determining which crops and pesticides have been grown/used in fields adjacent to those sampled. Determine direction of prevailing winds and wind condition on the day of spraying. Selective sampling will aid in determining if drift occurred. Compliance Samples collected to document pesticide drift should be Flagged and noted in block 16 of the CR as "Drift Sample - Maintain as Individual Subs".

Soil contamination by compounds, which are relatively stable in the environment, may cause systemic uptake of the compounds by growing crops. Follow-up investigations to violative samples may, in some limited cases, include soil samples as an attempt to determine the source of the contaminant. Do not routinely collect soil samples.

5.8.4 - PACKERS AND SHIPPERS

Follow the same general procedure as in IOM 5.8.3. Observe and report the following:

1. Treatment Before Shipping - This may include stripping of leaves, washing, vacuum cooling, application of post-harvest preservative chemicals, use of cartons with mold-inhibiting chemicals, waxes, colors, fumigation, etc.
2. Identification of Growers' Lots - Determine procedure or methods used to maintain the identity of each grower's lot. Provide the code and key if any.
3. Labeling - Quote labeling or brand names.
4. Responsibility - Determine whether the packer or shipper knows what sprays have been used on the products shipped.

5.8.5 - PESTICIDE SUPPLIERS

Pesticide suppliers should be visited routinely during growing-area coverage. They may provide valuable information about pesticides being used on various crops in the growing area. Some suppliers may suggest spray schedules or advise growers about pesticide usage.

Determine what representations were made by the manufacturer of pesticide chemicals for which there is only a temporary tolerance or experimental permit. Get copies of any correspondence relating to sale and use of these products. Obtain names of growers to whom sales are made if such sale was not for use on acreage assigned under the experimental permit. Collect Official Samples of any crops treated with the pesticide.

5.8.6 - PESTICIDE APPLICATORS

Pesticide applicators may provide valuable information about pesticides being used on various crops in the growing area. Interview several pesticide applicators, particularly those using airborne equipment. Determine the pesticide chemicals, their formulation, and on what crops they are currently being applied. Determine who supplies the pesticides and how they are prepared to assure proper concentration. If state law requires the applicator to keep a record of each spray application, request permission to review such records. Determine what steps are taken to assure drift on adjoining crops does not result in violative residues. Where there is likelihood of drift, collect Selective Samples from adjoining fields.

5.8.7 - SAMPLE COLLECTIONS

See IOM Sample Schedule Chart 3 - Pesticides.

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