oversight

U.S. Food Exports: Five Countries' Standards and Procedures for Testing Pesticide Residues

Published by the Government Accountability Office on 1990-12-20.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

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                                                     U.S. FOOD EXPORTS
                                                     Five Countries’
                                                     Standards and
                                                     Procedures for Testing
                                                     Pesticide Residues


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                                                                            RELEASED
                                           RESTIUCTED --Not      to be released outside the
                                           General Accounting OBllce unless specifically
                                           approved by the OfTice of Congressional
                                           Belatious.


      GAO/NSIAIHJ              1-!)(I
GAO ::;:;::yD
            c.20648
     6eneral Accountmg Office
                , **

      National Security and
      Interuational Affairs Division

      H-242 180

      December 20, 1990

     The Honorable Pete Wilson
     Ranking Minority Member
     Subcommittee on Agricultural      Research
        and General Legislation
     Committee on Agriculture,
        Nutrition, and Forestry
     I Jnitcd States Senate

     Dear Senator Wilson:

     As you requested, we have provided information on (1) the U.S. government’s efforts to
     prevent or resolve trade disputes that may arise over pesticide use; (2) the specific
     procedures used by foreign governments in selected Pacific Rim countries and Australia to
     set tolerances and test for pesticides on U.S.-exported produce; and (3) the technical
     capabilities of these foreign governments to conduct pesticide testing.

     As agreed with your office, unless you publicly announce its contents earlier, we plan no
     further distribution of this report until 30 days from the date of this letter. At that time, we
     will sand copies to interested parties and make copies available to others upon request.

     Please contact me at (202) 275-4812 if you or your staff have any questions concerning this
     report. The mqjor contributors to this report are listed in appendix I.

     Sincerely yours,




     Allan I. Mendelowitz, Director
     International Trade, Energy, and Finance Issues
1-p




Executive Summ~


                   The controversy in 1989 over Alar, a growth regulator primarily used
Purpose            on apples , heightened public concern about the presence of pesticides
                   and other chemicals on U.S. food. This controversy has also led to con-
                   cerns overseas and to los s e s in U.S. agricultural exports.

                   The Ranking Minority Member, Subcommittee on Agricultural Research
                   and General Legis lation, Senate Committee on Agriculture, Nutrition,
                   and Forestry, asked G A Oto provide information on (1) U.S. government
                   efforts to prevent or resolve trade disputes that may arise over pesticide
                   use; (2) the specific procedures used by foreign governments in selec ted
                   Pacific Rim countries and Australia to set tolerances and tes t for pesti-
                   c ides on U. S. exported produce; and (3) the technical capabilities of
                   these foreign governments to conduct pesticide tes ting. To evaluate pes-
                   tic ide tes ting and technical capabilities , G A Ov is ited Australia, Japan,
                   South Korea, Taiwan, and Thailand.


                   In June 1989 the news media in South Korea and Taiwan reported that
Bac k ground       Alar had been detected on U.S. grapefruit. As a result the market for
                   U.S. grapefruit in both countries was adversely affec ted. The markets
                   for other US. perishable commodities in several Pacific Rim countries
                   were also threatened. Since the Alar inc ident, concern over the presence
                   in food of other chemicals , primarily pesticides, has surfaced as well.

                   The Pesticide Monitoring Improvements Act of 1988 calls for foreign
                   countries to identify pesticides used on food imported into the United
                   States, but does not address the issue of pesticides used on U.S. exported
                   food.


                   The IJnited States is attempting to respond to pesticide residue concerns
Results in Brief   through multilateral, bilateral, and adminis trative efforts. U.S.
                   approaches to deal with pesticide concerns inc lude tak ing a lead position
                   on s trengthening health-related s tandards in the current Uruguay
                   Round of the General Agreement on Tariffs and Trade negotiations ,
                   forming ad hoc technical working groups with several countries, and
                   creating an International Food Safety Task Force. However, govern-
                   ments in the five countries G A Ov is ited have lacked information about
                   which pesticides and other chemicals were being used on U.S. exported
                   produce. Hence, the ris k of exposure to a problem like the South Korean
                   grapefruit scare remains.




                   Page 2                                         GAO/NSLAD91-99 U.S. Food Exports
                         Executive Summary




_----
                         The governments of Australia, Japan, South Korea, Taiwan, and Thai-
                         land have laws, regulations, and government agencies for ensuring the
                         safety of the food supply. They have established import inspection and
                         sampling procedures which include monitoring for pesticides. Each
                         country was at a different stage of registering pesticides, establishing
                         pesticide tolerances, and developing testing standards.

                         Government laboratories in the five countries GAOvisited also had the
                         necessary technical capabilities, including equipment and personnel, to
                         conduct pesticide testing. However, a variety of standards were used in
                         these countries, and the United States and these countries have not
                         agreed on and have not used common standards and testing methods.



Principal Findings

US. Government Efforts   Multilaterally, the United States has taken a leading position in the Gen-
                         era1 Agreement on Tariffs and Trade’s negotiating groups on health-
to Address Pesticide     related measures that can serve as trade barriers. These negotiations are
Disputes                 directed toward making sound scientific evidence and the IJnited
                         Nations’ Codex Alimentarius Commission’s standards central to
                         resolving trade disputes over food safety.

                         Bilaterally, the IJnited States and several countries, such as South Korea
                         and Taiwan, have established certain ad hoc technical working groups
                         to assist in setting standards and sharing information on pesticide toler-
                         ances, sampling, and testing methods.

                         Administratively, the U.S. Department of Agriculture has created an
                         interagency International Food Safety Task Force in response to the
                         1989 South Korean grapefruit scare. The Foreign Agricultural Service
                         chairs this group. The task force promulgates a single U.S. government
                         position on and provides a quick technical response to disputes over
                         food safety concerns. The Department also participates in food safety
                         seminars to share information on international negotiations and on bilat-
                         eral and administrative actions.

                         The governments in the five countries GAOvisited had little information
                         on the type and amount of pesticides and other chemicals used and tol-
                         erance levels actually allowed on specific U.S. exported produce. Reg-
                         ular information-sharing between the United States and its trading


                         Page 3                                       GAO/NSIAD-91-90 U.S. Food Exports
                            Executive Summary




                            partners would help reduce the likelihood of future disruptions of U.S.
                            agricultural exports caused by foreign concerns over the use of pesti-
                            cides and other chemicals.


Varying Standards and       The governments of the five countries GAOvisited have set tolerances
Procedures for Monitoring   for a number of pesticides. As of May 1990, Australia had established
                            tolerance levels for 395 pesticides, Japan for 25 pesticides, South Korea
                            for 1’7 pesticides, Taiwan for 127 pesticides, and Thailand for
                            10 pesticides.

                            These countries have conducted pesticide testing less routinely than the
                            IJnited States. Australia and Thailand have not systematically con-
                            ducted pesticide testing on imported produce. Japan has conducted tests
                            on certain products when deemed necessary. And in South Korea and
                            Taiwan, tests have been conducted on selected commodities to detect
                            residues on those pesticides for which tolerance levels have been
                            established.

                            In addition, Australia has deferred to Codex standards or applied a zero
                            tolerance level in evaluating imported produce when established toler-
                            ances did not exist. Japan, Taiwan, and Thailand have allowed flexi-
                            bility in such circumstances and generally have deferred to Codex
                            standards or have accepted the standards of the exporting country
                            when deciding whether to allow the commodity to enter the market.
                            South Korea normally did not have such flexibility.


Testing Is Conducted at     Based on the Federal Drug Administration’s laboratory standards, the
Capable Labs                five countries GAOvisited had government laboratories with adequate
                            pesticide testing equipment. The equipment included gas chro-
                            matographs for multiresidue testing and mass spectrometers for con-
                            ducting pesticide residue confirmation tests. According to laboratory
                            officials, the laboratories were generally well stocked with the solvents
                            and chemicals needed to conduct accurate tests. However, in Thailand,
                            the government was unable to use a U.S. Food and Drug Administration
                            standard method to test for Alar on apples because the laboratory did
                            not have the required solvents,

                            The laboratories employed trained personnel to conduct pesticide res-
                            idue testing and analysis. Scientists and technicians GAOinterviewed
                            were familiar with international and U.S. recommended guidelines for
                            pesticide testing. Laboratory technicians were aware of the procedures


                            Page 4                                       GAO/NSIADQlSO   U.S. Food Exports
                      Executive Summary




                      for cleaning and handling equipment and samples and with other stan-
                      dard scientific practices to ensure the accuracy of the results.

                      However, the five countries have used a variety of testing methods
                      which could contribute to variations in test results. For example, in
                      Japan they were developing and using their own methods, while South
                      Korea has used analytical methods similar to those used in the United
                      States. Thus, technical capability alone has not eliminated the potential
                      for obtaining conflicting test results.


                      To help reduce the likelihood and impact of future disruptions of U.S.
Recommendations       agricultural exports caused by foreign concerns over pesticides, GAOrec-
                      ommends that the Secretary of Agriculture, in cooperation with other
                      federal and state agencies

                  l develop mechanisms for routinely providing foreign trading partners
                    with information on pesticides used on U.S. exported produce and
                  . establish ad hoc technical working groups with more U.S. trading part-
                    ners to address technical problems related to agricultural trade, such as
                    US. pesticide use patterns and tolerances and sampling and testing
                    methods.


                      As requested, GAOdid not obtain official agency comments on this
Agency Comments       report. However, GAOdiscussed the information contained in a draft of
                      this report with officials at the Environmental Protection Agency, the
                      Food and Drug Administration, and the Departments of Agriculture and
                      State. Their comments have been incorporated in the report where
                      appropriate.




                      Page 5                                        GAO/NSIAD-91-90 U.S. Food Exports
Contents


Executive Summary                                                                                      2

Chapter 1                                                                                              8
Introduction             Growth in Fruit and Vegetable Exports and Pesticide Use
                         Objectives, Scope, and Methodology
                                                                                                       9
                                                                                                       9

Chapter 2                                                                                             11
U.S. Government          1J.S.Efforts to Address Food Safety Disputes
                         Potential for Trade Disputes Remains Due to Lack of
                                                                                                      11
                                                                                                      12
Efforts to Address            Information on U.S. Pesticide Use
Trade Disputes Over      Conclusions                                                                  13
                         Recommendations                                                              14
Pesticide Use
Chapter 3                                                                                             15
Five Countries’          Pesticide Residue Monitoring Procedures and Standards
                              Have Varied
                                                                                                      15
Procedures to Monitor
the Safety of Imported
Produce
Chapter 4                                                                                             21
Pesticide Residue        Australia
                         ,Japan
                                                                                                      21
                                                                                                      22
Testing Is Conducted     South Korea                                                                  23
at Technically Capable   Taiwan                                                                       23
                         Thailand                                                                     24
Laboratories
Appendix                 Appendix I: Major Contributors to This Report                                26

Table                    Table 3.1: Five Countries’ Pesticide Allowances                              15




                         Page 0                                       GAO/NSIAB91-99   U.S. Food Exports
tintents




Abbreviations

 1
WA         Environmental Protection Agency
FAS        Foreign Agricultural Service
FDA        Food and Drug Administration
GAO        General Accounting Office
GATT       General Agreement on Tariffs and Trade
IJSDA      1J.S.Department of Agriculture


Page 7                                     GAO/NSIAD-91-90 U.S. Food Exports
Chapter
__      1                                                                                                                        --

Introduction


--_---
                                In June 1989, the news media in South Korea and Taiwan reported that
                                Alar, a growth regulator primarily used on apples, had been detected on
                                U.S. grapefruit, Alar is primarily used on apples to prevent preharvest
                                fruit drop, increase storage life, and promote red color. Evidence of
                                Alar’s carcinogenic activity in animals was discovered in 1977. As a
                                result, the market for U.S. grapefruit sales in both countries dropped
                                substantially. The market for several U.S. perishable commodities in
                                other Pacific Rim countries was also threatened. Since the Alar incident,
                                concern over the presence in food of other chemicals, primarily pesti-
                                cides,’ has emerged.

                                As it happened, reports of Alar detection on U.S. grapefruit resulted
                                from misinterpreted test results. However, since the South Korean gov-
                                ernment was unaware that Alar is not used on citrus, it was not able to
                                respond immediately to media claims of Alar discovery. Because the
                                U.S. and South Korean governments were not able to quickly resolve the
                                misunderstanding, several US. grapefruit shipments perished before
                                reaching the market. According to our estimates, U.S. grapefruit sales to
                                South Korea would have been $2.4 million to $10.6 million higher over
                                the period July to December 1989 if the Alar incident not occurred.

                                Before the grapefruit scare, news media reports of Alar on U.S. apples
                                led to consumer concerns in Taiwan and Thailand. These press reports
                                also caused losses for importers of U.S. apples and threatened to affect
                                cherries. For example, Taiwan importers reported a 40 percent drop in
                                U.S. apple sales from February to July 1989.

                                The Pesticide Monitoring Improvements Act of 1988 requires the
                                Department of Health and Human Services to enter into cooperative
                                agreements with countries which are the major source of food imports
                                to provide information on the pesticides used in the production, trans-
                                portation, and storage of food products imported from production
                                regions of such countries into the United States. However, the act does
                                not address the issue of routinely providing U.S. trading partners infor-
                                mation on pesticides being used in the production of U.S. exported food.




                                ‘Pesticides are chemical or biological substances used to destroy or control weeds, insects, fungi,
                                rodents, and bacteria.



                                Page 8                                                          GAO/NSIAD-91-90 U.S. Food Exports


            -.   .   If..   -
_.__..
  __ .~   _..   _--.-.~.-_ .
                               Chapter 1
                               Introduction




                               IJS. fresh fruit and vegetable exports to the Pacific Rim countries and
Growth in Fruit and            Australia increased by 82 percent from 1985 through 1989. In 1989,1J.S.
Vegetable EXpOdS and           fresh fruit and vegetable exports amounted to 2,479,678 metric tons.
Pesticide Use                  Australia, Japan, South Korea, Taiwan, and Thailand-the      five coun-
                               tries on which this report focuses-accounted for 31 percent of this
                               volume.

                               In March 1990 we reported that worldwide pesticide sales had increased
                               dramatically.2 The report stated that from 1977 to 1987 the worldwide
                               agricultural chemical market doubled in size to more than $17 billion. It
                               pointed out that developed countries, such as Japan and the United
                               States, have been using greater amounts of pesticides, and developing
                               countries have been importing progressively more pesticides.


                               Senator Pete Wilson, Ranking Minority Member, Subcommittee on Agri-
Objectives, Scope, and         cultural Research and General Legislation, Senate Committee on Agricul-
Methodology                    ture, Nutrition, and Forestry, asked us to provide information on (1)
                               U.S. government efforts to prevent or resolve trade disputes that may
                               arise over the presence of pesticides in U.S exported produce; (2) the
                               specific procedures used by foreign governments in selected Pacific Rim
                               countries and Australia to set tolerances and test for pesticides on
                               imported fruits and vegetables; and (3) the technical capabilities of
                               these selected countries’ governments to conduct pesticide testing.

                               To obtain information on U.S. government efforts to prevent or resolve
                               trade disputes, we interviewed officials from the Environmental Protec-
                               tion Agency (EPA), the Food and Drug Administration (FDA), the Depart-
                               ments of Agriculture and State, and the state agriculture departments of
                               California, Florida, and Oregon. In the private sector, we spoke with
                               exporters, growers, and agricultural chemical producer associations. We
                               also interviewed a liaison to the General Agreement on Tariffs and
                               Trade (GATT) negotiations, committee members of the United Nations
                               Codex Alimentarius Commission,3 and participants in the U.S.-South
                               Korea ad hoc technical working group.



                               ‘Food Safet and Quality: Five Countries’ Efforts to Meet U.S. Requirements on Imported Produce
                               (d-90-55,         Mar. 22, 1990).
                               :‘The Commission was established in 1962 to encourage fair international trade in food and promote
                               consumer health and economic interest. It is an international organization made up of representatives
                               from 136 countries, including the United States and four of the countries we visited-Australia,
                               Japan, South Korea, and Thailand. Taiwan uses the Codex as a reference but is not a member.



                               Page 9                                                        GAO/NSIAD-91-99 U.S. Food Exports
--


         Chapter 1
         Introduction




         T o r e s p o n d to th e s e c o n dobjective, w e visited five c o u n tries: A u s tralia,
         J a p a n , S o u th K o r e a , T a i w a n , a n d Thailand. W e selectedth e s e c o u n tries
         for th e following reasons:

     . S o u th K o r e a , < J a p a na, n d T a i w a n , b y dollar value, imported 4 4 p e r c e n t
       o f their fresh fruits a n d v e g e ta b l e sfrom th e United S ta te s in 1 9 8 9 ;
     . T h e five c o u n tries represent increasing m a r k e ts for U .S . fresh fruits a n d
       v e g e tables;a n d
     l T h e c o n c e r n s th a t l e d to th e S u b c o m m i tte e ’sinterest w e r e first raised b y
       th e Pacific R i m c o u n tries.

         For information o n th e five c o u n tries’specific p r o c e d u r e s to set toler-
         a n c e s a n d test for p e s ticide residues, w e m e t with g o v e r n m e n t o fficials
         responsiblefor establishing p e s ticide standards, tolerances, a n d fo o d
         safety; with importers o f U .S . fresh fruits a n d v e g e tables;a n d with 1J.S.
         e m b a s s y o fficials. In th r e e c o u n tries ( S o u th K o r e a , T a i w a n , a n d J a p a n )
         w e visited ports o f e n try, p r o d u c e c o n ta i n m e n t yards, a n d w h o l e s a l e
         a n d retail m a r k e ts to o b ta i n information o n s a m p l i n g a n d o th e r tests
         th a t a r e d o n e b e fo r e th e fo o d e n ters th e m a r k e t.

         T o o b ta i n information o n th e c o u n tries’technical capabilities to c o n d u c t
         p e s ticide testing, w e interviewed laboratory p e r s o n n e l a n d c o m p a r e d
         their laboratory conditions a n d practices with th e F o o d a n d D r u g
         A d m inistration’s laboratory standards for establishing quality c o n trols
         a n d m a i n ta i n i n g generally a c c e p te d laboratory practices.

         A s r e q u e s te d ,w e d i d n o t o b ta i n o fficial a g e n c y c o m m e n ts o n this report.
         W e discussedth e information c o n ta i n e d in a draft o f this report with
         responsibleE P A F, D A ,lJ.S . D e p a r tm e n t o f Agriculture (IJS D A ) a, n d D e p a r t,-
         m e n t o f S ta te o fficials. Their c o m m e n ts h a v e b e e n incorporated in th e
         report w h e r e appropriate.

         W e c o n d u c te d o u r work primarily b e t w e e n -Januarya n d O c to b e r 1 9 9 0 in
         a c c o r d a n c ewith generally a c c e p te dg o v e r n m e n t a u d i tin g standards.




         Page 10                                                         G A O / N S I A D - 9 1 - 9 0U.S. F o o d Exports
Chanter 2

U.S. Government Efforts to Address Trade
Disputes Over Pesticide Use

                      The IJnited States has undertaken multilateral, bilateral, and adminis-
                      trative efforts to reduce the adverse impact of disputes about food
                      safety that may arise over the presence of pesticides on imported pro-
                      duce. However, the potential for disputes remains, because, for at least
                      the five countries we visited, no mechanism has existed to routinely pro-
                      vide U.S. trading partners with information on pesticides being used on
                      U.S. exported produce.


                      Recognizing adverse effects that food safety barriers, including pesticide
U.S. Efforts to       issues, can have on agricultural trade, the (Jnited States has taken a lead
Address Food Safety   role at the multilateral IJruguay Round negotiations of the General
Disputes              Agreement on Tariffs and Trade to strengthen the rules on health-
                      related regulations that affect agricultural trade. A major objective of
                      the negotiations was to stiffen the procedures for dispute settlement and
                      to require that countries base health-related regulations on sound scien-
                      tific evidence.

                      The U.S. Foreign Agricultural Service (FAS) trade policy officials are pro-
                      posing an information system that would provide the GATTmember
                      nations with advance notice of a country’s intent to adopt or change
                      health-related measures and allow a reasonable time for comment. This
                      system would be similar to and facilitate the operation of the informa-
                      tion system already in place under the GATT'SStandards Code, an agree-
                      ment covering both agricultural and industrial technical barriers to
                      trade. The IJSDA'STechnical Office and Office of Food Safety and Tech-
                      nical Services serves as a U.S. inquiry point for the Standards Code on
                      agricultural measures. However, none of the five countries’ governments
                      has used the GATTStandards Code in an information-sharing system.

                      Also under negotiation is a proposal that encourages GATTcooperation
                      with the United Nations’ Codex Alimentarius Commission to facilitate
                      the harmonization of sanitary standards. The proposal would increase
                      the influence of the Codex because GATTdispute panels would look to
                      the Codex standards for guidance when resolving food safety trade
                      disputes.

                      Bilaterally, the FAShas established ad hoc technical working groups with
                      several other countries, such as South Korea and Taiwan. The U.S. par-
                      ticipants in these ad hoc working groups include representatives from
                      IJSDA,EPA, FDA, and the Office of the U.S. Trade Representative. Their
                      objective is to improve bilateral relations by addressing technical issues



                      Page   11                                     GAO/NSUUTSl-99 U.S. Food Exports
        _--
                         Chapter 2
                         U.S. Government Efforts to Address Trade
                         Disputes Over Pesticide Use




                         related to agricultural trade (i.e., food safety concerns, pesticide resi-
                         dues, and so forth) and resolving disputes over differences in standards
                         and testing procedures. They provide U.S. assistance in setting stan-
                         dards and sharing information on pesticide tolerances, sampling, and
                         pesticide residue testing methods.

                         In South Korea, the technical ad hoc working group has been used as a
                         forum to (1) discuss ways in which the two governments might work
                         together to avoid future trade disputes; (2) share information on U.S.
                         pesticide and tolerance levels; and (3) discuss provisions for certifying
                         foreign laboratories for pretesting agricultural exports.

                         The IJnited States has also taken administrative action designed to
                         address food safety issues. In 1989, IJSDAestablished an International
                         J?oodSafety Task Force in response to the Alar grapefruit scare. The
                         Task Force includes technical representatives from IJSDA;FDA; the WA;
                         the Department of State; the Department of Justice’s Bureau of Alcohol,
                         Tobacco and Firearms; and the 1J.S.Trade Representative. It does not
                         have a policy development orientation but rather it is designed to pro-
                         vide a quick, coordinated 7J.S.government technical response to food
                         safety concerns as they arise to (1) prevent or resolve trade disruption
                         and (2) limit U.S. exporters’ and importers’ losses, especially for perish-
                         able fresh fruits and vegetables, due to trade disputes.

                         In addition, IJSDAhas actively participated in food safety seminars with
                         state agriculture departments and industry representatives. These semi-
                         nars discuss food safety issues and provide information on the current
                         status of the international negotiations and bilateral and administrative
                         actions related to food safety.


                         The governments in the five countries we visited had little information
Potential for Trade      on the type and amount of pesticides used and tolerance levels actually
Disputes Remains Due     allowed for specific 1J.S.exported produce. Australian officials stated
to Lack of Information   that, they had obtained some information on US. standards through an
                         informal network of contacts in the U.S. government. None of the five
on U.S. Pesticide Use    countries’ governments has used a formal information-sharing system.

                         Government officials in the countries we visited have obtained pesticide
                         use and tolerance information from various sources, including interna-
                         tional organizations, U.S. federal and state agencies, published sources,
                         and data on residues found as a result of previous laboratory tests.
                         IIowcver, these government officials stated that all of these sources


                         Page 12                                       GAO/NSIAD-91-90 U.S. Food Exports
              Chapter 2
              U.S. Government Efforts to Address Trade
              Disputes Over Pesticide Use




              combined have provided little information on specific pesticide/com-
              modity combinations used in the United States. Thus, the risk of a trade
              dispute over an incident such as the South Korean grapefruit scare
              remains.

              According to U.S. and foreign government program officials, regular
              sharing of information on US. pesticide and other chemical usage would
              help relieve the potential for trade disputes over food safety. South
              Korean government officials told us that the Alar dispute might have
              been avoided if they had known what pesticides and other chemicals
              had been used on U.S. grapefruit. A South Korean official from the labo-
              ratory that initially conducted the Alar tests on U.S. grapefruit stated
              that the laboratory would have been in a better position to advise the
              South Korean consumer if it had prior knowledge of the chemicals used
              in the production of US. grapefruit and if it had known that Alar is not
              used on citrus in the United States.

              In addition, Thailand government officials stated that they needed more
              information on U.S. pesticide testing methods. According to these gov-
              ernment officials, the Thailand laboratory that tested lJ.S. apples for
              Alar was unable to use the FDAstandard analytical method to test for
              Alar because it did not have the solvents necessary to conduct the
              appropriate confirmation test. The initial testing method used by the
              laboratory detected Alar residues that far exceeded the U.S. tolerance
              for apples. It was only after several communications between Thailand’s
              Department of Medical Sciences and US. officials that the Thailand lab-
              oratory was able to obtain the necessary solvents and conduct the
              proper confirmation test. The test indicated that the Alar levels on the
              imported apples were below U.S. tolerances.


              The five countries we visited had little information on the pesticides and
Conclusions   other chemicals actually used on specific U.S. exported fruits and vege-
              tables. Better information on pesticides and other chemicals used on U.S.
              exported produce could be obtained from improved information-sharing
              between the United States and its trading partners, Such information
              would help reduce the likelihood of future disruptions of 1J.S.agricul-
              tural exports caused by foreign concerns over pesticide and other chem-
              ical use on exported produce.




              Page 13                                      GAO/NSIAD-91-90 U.S. Food Exports
                    Chapter 2
                    U.S. Government Efforts to Address Trade
                    Disputes Over Pesticide Use




                    To help reduce the likelihood and impact of future disruptions of U.S.
Recommendations     agricultural exports caused by foreign concerns over pesticides, we rec-
                    ommend that the Secretary of Agriculture

                  . develop mechanisms for routinely providing U.S. trading partners with
                    information on pesticides used on U.S. exported produce. Such informa-
                    tion should include lJ.S. pesticide use patterns, tolerances, and sampling
                    and residue testing methods and
                  . establish ad hoc technical working groups with more U.S. trading part-
                    ners to address technical problems related to agricultural trade, such as
                    pesticide usage, and to resolve disputes over differences in standards
                    and testing procedures.




                    Page 14                                       GAO/NSIAD81-90 U.S. Food Exports
Five Countries’Procedures to Monitm the
Safety of Imported Produce

                                       The governments in the five countries we visited have laws, regulations,
                                       and government agencies for ensuring the safety of the food supply.
                                       They have established import inspection and sampling procedures
                                       which include pesticide monitoring. However, government pesticide res-
                                       idue monitoring procedures have varied because each country was at a
                                       different stage in designing its food safety standards. In addition,
                                       although the government laboratories in the five countries had the nec-
                                       essary technical capabilities to conduct pesticide residue testing, the
                                       United States and these countries have not agreed on and have not used
                                       common standards and testing methods.


                      The responsible agencies in the five countries have registered and set
Pesticide Residue     tolerances for a number of pesticides used on both imported and
Monitoring Procedures domestic produce. Each country has established import inspection pro-
and Standards Have    cedures for all fruits and vegetables that include document and food
                      safety inspections. However, the governments in the five countries have
Varied                conducted pesticide residue testing less routinely than the United States,
                                       where sampling and testing is conducted on imported fruits and vegeta-
                                       bles based on a national sampling plan. Neither Australia nor Thailand
                                       has systematically conducted pesticide residue testing on imported
                                       fruits and vegetables. Japan has conducted tests on certain products
                                       when deemed necessary. And in South Korea and Taiwan, pesticide res-
                                       idue testing has been conducted on selected imported commodities.

                                       Each country we visited was at a different stage of registering pesti-
                                       cides, establishing tolerances and procedural standards, and developing
                                       testing methodologies for sampling and monitoring pesticide residues on
                                       food. The five countries have registered and set tolerances for pesti-
                                       cides, as shown in table 3.1.

Table 3.1: Five Countries’ Pesticide
Allowances                             Country                                        Number of pesticides   allowed
                                       Australia                                                                  395
                                       Japan                                                                       25
                                       South Korea                                                                 17
                                       Taiwan                                                                     127
                                       Thailand                                                                    10


                                       Australia, South Korea, Taiwan, and Thailand have used internationally
                                       recommended guidelines for pesticide residue testing, while *Japan has
                                       been developing its own testing methods,



                                       Page 16                                     GAO/NSIAD-91-90 U.S. Food Exports
            Chapter 3
            Five Countries’ Procedures to Monitor the
            Safety of Imported Produce




Australia   Australia has not used the pesticide residue limits of foreign countries
            when it has not established a residue limit for a particular pesticide.
            Rather, Australian officials said they would elect to use either the
            United Nations’ Codex standards or, if no Codex standard existed, to
            adopt a tolerance level of zero.

            In Australia, the federal and state governments have shared responsi-
            bility for regulating pesticide residues on food. The National Health and
            Medical Research Council has established pesticide residue limits while
            the Department of Primary Industries has conducted food safety inspec-
            tions at the ports of entry. State governments have taken enforcement
            action against food importers that were cited for violating Australian
            food safety laws.

            As of May 1990, the National Health and Medical Research Council had
            established residue tolerance levels for 395 pesticides.’ According to
            Australian officials, the Council has attempted to set pesticide residue
            tolerance levels at the same level established by the Codex standards.

            In *July 1990, Australia implemented the Imported Food Inspection Pro-
            gram to inspect imported foods for various health hazards, including
            pcsticidc residues. Under this program, an Imported Food Risk Advisory
            Committee has categorized imported food into low-, medium-, and high-
            risk groups, The higher the risk, the more rigorous the inspection. The
            laboratory analysis under this program will be done by government
            laboratories.

            The inspections under the Imported Food Inspection Program have con-
            centrated on detecting microbiological and heavy metal hazards in
            various foods, including prawns, oysters, fish, and cheese. Australian
            officials stated that fruits and vegetables have not yet been targeted for
            inspection for excessive pesticide residues. They noted that concern
            over pesticides was growing in Australia, and the Risk Advisory Com-
            mittee may in the future recommend pesticide testing for specific
            imported fruits and vegetables.


Japan       ,Japan has allowed imported produce to contain residues of chemicals
            that have no set tolerances if these residues were not over the tolerance
            level set by the exporting country. For example, U.S. exports to Japan

            ‘Australia’s list of 395 regulated residues included pesticides, agricultural chemicals, feed additives,
            wtcsrinary mcdicincs, and noxious substances.



            Page 16                                                         GAO/NSLAD-91-90 U.S. Food Exports
Chapter 3
Five Countries’ Procedures to Monitor the
Safety of Imported Produce




containing chemicals that did not have tolerances established in Japan
could be accepted if they met EPA standards.

In Japan, three agencies-the Ministry of Agriculture, Forestry, and
Fisheries; the Ministry of Health and Welfare; and the Environmental
Agency-share responsibility for establishing pesticide regulations and
tolerance levels for pesticide residues allowed on food. The Ministry of
Agriculture, Forestry, and Fisheries also registers and approves all
pesticides.

As of May 1990, Japan had set tolerance levels for 25 pesticides
approved for use on 57 commodities. In Japan, setting pesticide residue
tolerance levels has been an ongoing process in which experts have ana-
lyzed methodologies and evaluated the results of studies to determine
whether more pesticides should be added to the current list. .Japan was
in the process of expanding the number of established tolerances to 27
or 28 pesticides.

In Japan, all imported fresh produce has been subjected to a document
and phytosanitary inspection for specific diseases and pests. The Min-
istry of Agriculture, Forestry, and Fisheries has an agricultural chemical
inspection station and plant quarantine testing laboratories at all ports
of entry. These entities are responsible for conducting pesticide residue
testing on commodities which are new to the Japanese market place or
when a particular concern has been identified. Japan’s testing proce-
dures have required importers to select samples based on the number of
cartons in a shipment. For example, if a shipment contained 1,200 car-
tons of grapefruit, the importer could randomly select 9 cartons and test
1 grapefruit from each carton. Ministry officials told us that the Min-
istry has tested approximately 4 percent of all imported food for
pesticides.

The Ministry of IIealth and Welfare supervises the pesticide residue
testing conducted at the local level on most imported and domestically
grown agricultural products. Such testing is conducted by local laborato-
ries in each .Japanesemunicipality. The samples are gathered at the
retail level for testing. The Ministry’s main focus is research, conducted
by local laboratories, on what pesticides are used on the produce. The
research results are used to establish tolerances and methods for residue
testing.




Page 17                                      GAO/NSIAD-91-90 U.S. Food Exports
                    Chapter 3
                    Five Countries’ Procedures to Monitor the
                    Safety of Imported Produce




South Korea         South Korea has set tolerance levels and has been conducting pesticide
                    residue testing for 17 pesticides used on the 28 agricultural products for
                    which it has established tolerances, Quarantine inspectors collect
                    random samples at ports of entry for the 28 commodities that are
                    required to undergo analysis. Inspectors may also collect samples at the
                    wholesale market where South Korea sells 50 percent of its fresh fruit
                    imports.

                    South Korea has subjected other imported produce only to a phytosani-
                    tary inspection for the prevalence of specific diseases and pests and has
                    allowed the produce to enter the market after passing inspection. South
                    Korea may test such produce if it has originated from a country in
                    which a contamination problem has occurred or if the produce has expe-
                    rienced prior problems during import inspection or after distribution,

                     In South Korea, the Ministry of Health and Social Affairs is responsible
                     for establishing pesticide residue tolerances for imported and domestic
                    produce. The Ministry of Agriculture, Forestry, and Fisheries handles
                    the registration of all pesticides. The Ministry of Health and Social
                    Affairs was in the process of establishing tolerances for 19 more pesti-
                    cides. Fresh fruits and vegetables imported into South Korea were sub-
                    jected to a document and phytosanitary inspection for specific diseases
                     and pests, and selected products underwent a pesticide residue test. At
                    ports of entry, quarantine inspection offices have conducted the docu-
                    ment and phytosanitary inspections for diseases and pests. In cities and
                    provinces, the Ministry of Health and Social Affairs has designated spe-
                    cific laboratories (such as the Institute of Health and Environment, the
                    Korean Food Industry Association, and the National Institute of Health)
                    to perform the pesticide residue tests.

  _.. _   ._...-.
Taiwan              The Taiwan government has allowed flexibility in cases where the
                    exporting country has used either a nonregistered pesticide or a pesti-
                    cide for which Taiwan has not established a tolerance level. According
                    to Taiwan government officials, in such cases the Taiwan Advisory
                    Committee for Food Safety, which is in the Health Department, can eval-
                    uate the pesticide to decide whether to accept the tolerance level set by
                    the exporting country.

                    In Taiwan, the Department of Health establishes and manages food sani-
                    tation standards, including setting tolerance levels for pesticides that
                    are used on domestic and imported produce. The Council of Agriculture
                    registers and approves pesticides used in Taiwan.


                    Page 18                                      GAO/N&W-91-90   U.S. Food Exports
                                       Chapter 3
                                       Five Countries’ Procedures to Monitor the
                                       Safety of Imported Produce




                                       The Department of Health has set tolerance levels for 127 pesticides
                                       which have been registered by the Council of Agriculture for use on
                                       imported fruits and vegetables.

                                       Like South Korea, Taiwan also has inspected and tested imported fresh
                                       produce. The Bureau of Commodity Inspection and Quarantine is the
                                       Taiwan national agency responsible for conducting document and
                                       phytosanitary inspections for specific diseases and pests on imported
                                       commodities. The Bureau conducts pesticide residue testing at its own
                                       laboratories located in the capital, Taipei. The Taiwan Institute of Agri-
                                       cultural Chemicals and Toxic Substances Research has tested imported
                                       products for pesticide residues when requested by the government to
                                       address special concerns, such as occurred in the Alar grapefruit scare.

                                       For the Department of Health’s list of 127 pesticides which have estab-
                                       lished tolerances, the Taiwan government has set up a pesticide residue
                                       testing program to detect residues on selected produce. The Bureau
                                       decides which type of produce is to be selected based on the crop season,
                                       import statistics, and past experiences. In May 1990, the Rureau
                                       selected grapefruits and cherries for testing.

                                       The Bureau has collected between 1 to 2 kilograms of a product from
                                       five shipments for pesticide residue testing about 5 times a month. The
                                       Bureau then has conducted tests at its laboratories. In cases where the
                                       Institute has conducted the tests, the samples were provided by Rureau
                                       inspectors.

          . . ~~--.-.---   ---_____.
Thailkd                                In Thailand, the Ministry of Public Health has been able to accept inter-
                                       national standards or adopt the standards of the exporting countries
                                       when determining whether to allow imported foods into the country.
                                       The Ministry is responsible for establishing standards and testing for
                                       pesticide residues on domestic and imported foods. The Ministry has
                                       established tolerances for 10 pesticides, by crop group, and was consid-
                                       ering expanding the list.

                                       The Ministries of Public Health and Agriculture are responsible for con-
                                       ducting food safety inspections and pesticide residue tests on imported
                                       fresh fruits and vegetables. The government of Thailand has not sys-
                                       tematically sampled imported produce for pesticide residues. Rather,
                                       such testing has generally been done when a problem has been sus-
                                       pected. For example, Thailand tested U.S. apples for Alar residues due
                                       to reports about concern over Alar in the United States.


                                       Page 19                                       GAO/NSLAD-91-90 U.S. Food Exports
--~   ..-- ...--.---   . . _-.--_- ..-_                                                                                    ,
                                          Chapter 3
                                          Five Countries’ Procedures to Monitor the
                                          Safety of Imported Produce




                                          Each year, Thailand has prepared a master sampling plan for testing
                                          domestic food products. This plan has detailed how many food samples
                                          would be selected for testing.




                                          Page 20                                     GAO/NSIAD91-90   U.S. Food Exports
i:haJ$“r    4 ..--_- -
-__-- - .-...._

Pesticide Residue Testing Is Conducted at
Technically Capable Laboratories

                         Government laboratories in the five countries we visited appeared to
                         have the necessary technical capabilities, including equipment and per-
                         sonnel, to conduct pesticide residue testing. We compared their labora-
                         tory practices with the FDA'S laboratory standards for establishing
                         quality controls and maintaining generally accepted laboratory
                         practices.

                         According to FDA officials, technical capability is defined as having the
                         proper equipment, maintaining adequately trained personnel and appro-
                         priate laboratory supplies, and using approved testing methods and pro-
                         cedures. These officials stated that having technical capability alone did
                         not eliminate the potential for producing conflicting test results.

                         We observed that the laboratories we visited were equipped with pesti-
                         cide residue testing equipment. The equipment used to detect and quan-
                         tify pesticide levels in food included gas chromatographs for
                         multiresidue testing, mass spectrometers, and high performance liquid
                         chromatographs. The laboratories were stocked with the solvents and
                         other chemicals needed to conduct accurate pesticide residue tests. How-
                         ever, in Thailand, the government was unable to use the FDA standard
                         analytical method to test for Alar on apples because the laboratory did
                         not have the required solvents. In each country, the laboratories we vis-
                         ited employed personnel with the technical education necessary to con-
                         duct pesticide analyses. According to the laboratory technicians, they
                         were aware of procedures for cleaning and handling equipment and pro-
                         ducing samples and using other standard scientific practices to ensure
                         the accuracy of test results. The laboratory scientists and technicians we
                         interviewed in the five countries were familiar with Codex- and FDA-rec-
                         ommended pesticide residue testing methods.

                         However, the five countries have applied a variety of analytical
                         methods that could contribute to variations in test results. For example,
                         the pesticide residue testing method used in South Korea and Taiwan to
                         test for Alar on grapefruit was developed for apples. In addition,
                         according to U.S. and foreign officials, the United States and these five
                         countries have not reached agreement on which analytical methods to
                         use for pesticide residue testing.


                         The Australian Government Analytical Laboratory in South Australia
Australia y              (one of five government laboratories) has specialized in conducting res-
                         idue analysis. This laboratory has developed analytic methods based on,
                         among other things, guidelines from the international Association of


                         Page21                                       GAO/NSIAD-91-9OU.S.FoodExports
        Chapter 4
        Pesticide Residue Testing Is Conducted at
        Technically Capable Laboratories




        Analytical Chemists. If the laboratory has not established a testing
        method for detecting a particular pesticide, laboratory scientists have
        used a generally recognized method, such as multiresidue testing.

        The South Australian Laboratory was well equipped with pesticide res-
        idue testing equipment. Gas and high performance liquid chro-
        matographs were used for pesticide residue testing and confirmation
        tests. A mass spectrometer located at the Sydney Laboratory was used
        to identify unknown pesticides. Test results were fed directly into an
        automated system and analyzed by computer programs and laboratory
        technicians.

        The minimum educational requirement for laboratory technicians was a
        bachelor of science degree or equivalent. Laboratory technicians also
        received on-the-job and external training in pesticide residue testing.
        The South Australian Laboratory ensures quality control through set-
        ting education requirements, devising a written quality control manual,
        requiring routine calibration of equipment, and prescribing independent
        laboratory accreditation.


        In ,Japan, the Ministry of Agriculture, Forestry, and Fisheries and the
Japan   Tokyo Metropolitan Research Laboratory of Public Health have
        employed their own methods for conducting pesticide residue testing.
        IJsing internationally accepted analytical guidelines, Japan was in the
        process of developing its own testing methods as laboratories continue
        to conduct agricultural chemical research.

        The equipment used by the inspection stations and the Tokyo Metropol-
        itan Research Laboratory included the mass spectrometer, the gas chro-
        matograph, and the high performance liquid chromatograph. The
        Japanese laboratories we visited contained new pesticide residue testing
        equipment which were linked with a computer for automated data
        processing to support research efforts.

        Japanese law specifies the educational requirements for technical per-
        sonnel. In accordance with Japanese law, the Ministry of Agriculture,
        Forestry, and Fisheries has required that its technicians have a bach-
        elor’s degree in such areas as medicine, science, veterinary, or pharma-
        ceutical science.




        Page 22                                      GAO/NSLAD-91-90 U.S. Food Exports
              Chapter 4
              Pesticide Residue Testing Is Conducted   at
              Technically Capable Laboratories




              South Korea’s National Institute of Health laboratory has applied mul-
South Korea   tiresidue testing methods to detect pesticide residues. The South Korean
              laboratories were equipped with gas chromatographs and high perform-
              ance liquid chromatographs. The laboratories also had a spectrophoto-
              meter for conducting confirmation of tests. According to South Korean
              officials, most technical personnel who had conducted pesticide residue
              tests had at least a master’s degree in food chemistry or pharmaceutical
              science.

              According to laboratory officials, when the technicians have prepared
              samples for pesticide residue tests, the grinders and blenders were thor-
              oughly cleaned as required before sample preparation was begun. Other
              supplies, such as syringes, were also thoroughly cleaned. In addition, the
              technicians have followed standard scientific practices to ensure the
              accuracy of the results, such as conducting standard tests and deter-
              mining recovery rates, before conducting the actual test.


              In Taiwan, the Bureau of Commodity Inspection and Quarantine and the
Taiwan        Institute of Agricultural Chemical and Toxic Substances Research labo-
              ratories used multiresidue testing methods, since specific testing
              methods did not exist for all pesticides. The Bureau laboratory also used
              other analytical methods to detect pesticide residues,

              The Bureau and Institute laboratories were equipped with the required
              pesticide residue testing equipment-gas chromatographs, high per-
              formance liquid chromatographs, and mass spectrometers. Their labora-
              tory personnel practiced quality controls to ensure that equipment and
              supplies were thoroughly cleaned before conducting pesticide residue
              tests. Other standard scientific practices were followed to ensure the
              accuracy of test results.

              According to Taiwan officials, the minimum degree required for labora-
              tory technicians employed by the Bureau was a bachelor of science
              degree in chemistry or pharmaceutical science. They stated that the
              Institute required that the technicians who prepare samples must have
              graduated from an agricultural vocational school and that those who
              operated the equipment and analyzed test results must have had at least
              a bachelor’s degree in a science-related field.




              Page 23                                       GAO/NSLAD-91-90 US. Food Exports
           Chapter 4
           Pesticide Residue Testing Is Conducted at
           Technically Capable Laboratories




           In Thailand, the Ministries of Public Health and Agriculture laboratories
Thailand   generally have applied the multiresidue testing method for pesticide res-
           idue analysis. Laboratory technicians were familiar with FDAtesting
           methods. The laboratories had gas chromatographs, a liquid chro-
           matograph, and a mass spectrometer to conduct pesticide residue tests.

           According to Ministry officials, the laboratory technicians had bach-
           elor’s degrees in the general sciences and had received the necessary on-
           the-job laboratory training to conduct pesticide residue tests. The labo-
           ratory we visited had participated in quality assurance programs,
           including engaging in regular collaborative testing programs with other
           laboratories, to ensure the accuracy of its test results. The quality con-
           trols practiced by the laboratory technicians were in accordance with
           standard analytical guidelines for sample preparation and equipment
           cleaning.




           Page 24                                      GAO/NSIAD-91-90 U.S. Food Exports
Page 26   GAO/NSIAD-91-90 U.S. Food Exports
Appendix I

Major Contributors to This Report


                        Elliott C. Smith, Assistant Director
National Security and
International Affairs
Division, Washington,
D.C.
                                                                  -
                        Patrick F. Gormley, Evaluator-in-Charge
Los Angeles Regional    Thomas W. Zingale, Site Supervisor
Office                  Rodina U. Sanchez, Evaluator
                        Lisa C. Dobson, Evaluator


                        Peter Konjevich, Assignment Manager
Far East Office         David Trimble, Site Supervisor
                        Shari Eubank, Evaluator


                        Raymond J. Wyrsch, Attorney
Office of the General
Counsel




(41)3542)               rage 26                                       GAO/NW091-90   U.S. Food Exports
“^..-__.._._ ~.--..-.--__-_--