How to Establish A Risk-based Pesticide Residue Monitoring Plan

How to Establish A Risk-based Pesticide Residue Monitoring Plan

YY TSANG

(CMA Testing and Certification Laboratories)

As mentioned in the previous article, the food trade needs to consider “prevalence history of pesticide residues in food” when he/she formulates a “risk-based” pesticide residue monitoring plan. Indeed, several other factors should also be considered when the trade prioritizes which pesticide to test first.

Factor # 1 – Prevalence of Pesticide Residue

The trade must check and analyse pesticide residue monitoring data of each food commodity and relevant news reported in the past few years. For example, number of MRL/EMRL violations, detection of illegal pesticides, levels of pesticide residues in different foods, trends of detection, etc.

(EFSA, 2014)

If a pesticide is recently detected, implicated in several MRL/EMRL violations, illegal for use, frequently found in different foods or its residue level increases in consecutive years, the pesticide should be ranked and tested first.

Factor # 2 – Health Risk

Many countries have established “Acceptable Daily Intake (ADI) ” for some pesticides, in accordance with their toxicities. ADI tells us the amount of a pesticide residue in food that can be ingested daily over a lifetime without appreciable health risk.

Based on the level of a pesticide residue detected in a food and the amount of the food we eat daily, we can determine whether our dietary intake exceeds ADI set for that particular pesticide or not. There’s no doubt that a pesticide residue implicated in exceedance of an ADI should be ranked and tested first.

Factor # 3 – Supplier Conformity Guarantee

The likelihood of detecting a pesticide residue in food also depends on the quality of food suppliers. The trade has to check whether food is produced in accordance with a food safety management system (e.g. farmers adopt Good Agricultural Practice (GAP) and food manufacturers obtain ISO 22000 certification). In addition, food importers and distributors obtain and keep conformity evidences for their foods like pesticide residue analysis reports, official certificates issued by food safety authorities of exporting countries, etc.

(ISO, 2014; AVA, 2015)

Food from suppliers with a known poor compliance history, without track record for evaluation (e.g. new suppliers) or lack of conformity evidence, should be sampled at a higher intensity and the testing should involve more test items.

Factor # 4 – Country / Territory of Origin

Same type of food from different countries / territories shall contain different types & amounts of pesticide residues, and thereby different compliance percentages. For example, EU countries are usually performing better compared to developing countries.

As such, before importing food, the trade should find out historical data concerning non-conforming foods from the exporting country / territory.This helps to determine the possibility of a pesticide residue present in different foods.

Moreover, the food trade should ensure the food inspection and certification system in the exporting country / territory is internationally recognized (e.g. equivalent to Codex standards).

If an exporting country / territory has a known poor compliance history, or not in line with the international practice, her exported food should be tested frequently and the testing should involve more test items.

(PT, 2011)

Factor # 5 – Food Preparation / Processing

For fresh produce, food preparation or processing activities like peeling / washing fruit before consumption may lower the pesticide residue level in food surface and thereby reducing the consumer risk.

Therefore, when the trade establishes a risk-based pesticide residue monitoring plan for a food, he/she should also consider the extent and nature of any further preparation / processing of the food.

Factor # 6 – Cross-Contamination

Recently, some researchers raise the possibility of transferring pesticide residues to a food commodity from packaging materials, transport lines, etc.

Although the risk of such a cross contamination in practice may be low, it cannot be ruled out completely. As such, the possible risk should also be considered when the trade decides the type and frequency of pesticide residue testing.

Factor # 7 – Uniqueness

Pesticide use patterns for a food produce can be affected by several factors e.g. geographical location, pesticide price, market availability, farmers’ preference, seasonality, pest resistance of crops, etc.

By conducting literature review and data analysis, we can predict the likelihood of detecting a pesticide residue in a certain food from a particular country / territory during a specified period.

Compulsory Test Item and Elective Test Item

Factors mentioned above contribute at different extents to the “total risk” of a pesticide residue. A food safety expert can help the trade to weigh the importance of each factor and calculate the “total risk score”.

If the total risk score of a pesticide is high (say ≧ 75), then the trade can prioritize the pesticide as a “compulsory test item” (i.e. high risk item), which must be frequently tested e.g. testing of every imported shipment. On the other hand, a pesticide with a low score (say ≦ 36) can be classified as an “elective test item” (i.e. lower risk item), which can be tested less frequently e.g. test once for three consecutive imports.

However, it should be emphasized that “lower risk” pesticide is not equivalent to “no risk” pesticide. Therefore, the trade still needs to test “lower risk pesticide” from time to time. Otherwise, a risk-based testing will be compromised. The trade will still be prosecuted if his/her food is found by the government containing “lower risk pesticide” and exceeding the relevant legal tolerance level i.e. MRL/EMRL.

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