oversight

Food Safety and Quality: Five Countries' Efforts to Meet U.S. Requirements on Imported Produce

Published by the Government Accountability Office on 1990-03-22.

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

      United States
GAO   General Accounting Offlce
      Washington, D.C. 20548

      Resources, Conununity, and
      Economic Development Division

      B-237768.1

      March 22,1990

      The Honorable Leon E. Panctta
      House of Representatives

      The Honorable Frank Horton
      House of Representatives

      This report responds to your September 3,1987, letter and subsequent discussions with your
      offices requesting information on (1) foreign government and private industry efforts to
      assure that imported produce meets U.S. safety and quality standards and (2) what federal
      agencies are doing to assist foreign countries in meeting U.S. safety requirements. Our review
      focused primarily on government and private sector pesticide controls over exported
      produce in five countries: Chile, Costa Rica, the Dominican Republic, Guatemala, and Mexico.
      We also idi.'ntified efforts by several federal agencies to help foreign countries improve their
      pesticide registration and use practices. In addition, we obtained background information on
      the responsibilities or activities of U.S. agencies, states, and private industry in monitoring
      imported produce.

      As arranged with your offices, 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 send copies to the Director, Office of Management and Budget; the Secretary of
      Agriculture; the Secretary of Health and Hum£m Services; the Administrator, Agency for
      Intemational Development; the Administrator, Environmental Protection Agency; the
      Commissioner, Food and Drug Administration; and other interested parties.

      Major contributors to this report are listed in appendix VI.




      John W. Harman
      Director, Food and
        Agriculture Issues
      Executive Summary


                         With the rapid growth in fruit and vegetable imports during the 1980s,
      Purpose            concern about the safety and quality of imported foods and the presence
                         of pesticide residues has increased. Previous GAO work identified weak-
                         nesses in monitoring imported food and limited information on foreign
                         pesticide use. As a result, Representatives Leon Panetta and Frank Hor-
                         ton asked I;AO to provide information on (1) foreign government and pri-
                         vate industry effoits to ensure that imported fresh produce meets U.S.
                         safety and quality standards, (2) what U.S. agencies are doing to assist
                         foreign countries in meeting U.S. safety requirements, and (3) U.S. agen-
                         cies' responsibilities for safety and quality of imported produce.


                         The r,S, safety and quality network for imported produce involves sev-
      Background         eral r s . agencies, states, and private industry. The Environmental Pro-
                         tection Agency (Ki>,\) registers pesticide products and sets maximum
                         acceptable pesticide residue levels—tolerances—allowed in foods con-
                         siinied in the United States, The Food and Drug Administration (FDA)
                         samples imported foods to identify prohibited substances, including ille-
                         gal pi^sticide residues; and it enforces KI'A standards for all domestic and
                         imported food products, except meat, poultry, and eggs, which the
                         Department of Agriculture (ISDA) monitors. I\SDA also determines if cer-
                         tain imported produce meets minimum quality requirements for size,
                         grade, and maturity. Some states and supermarket chains have produce
                         tested for pesticide residues, (See ch, 1,)

                         Latin American and Caribbean countries supply most U.S. imports of
                         fruits and vegetables—5.5 million metric tons, or 77 percent, in 1988.
                         (;,\() visited five coiintrie.s—Chile, Costa Rica, the Dominican Republic,
                         (luatemala, and Mexico—which accounted for over half of the Latin
                         America Caribbean import volume in 1988.


                         Like the United States, the five countries' governments have not
      Results in Brief   (l(>signed their food safety and quality systems—specifically regarding
                         pestieides—to meet other countries' import requirements but primarily
                         to jiddress domestic needs and issues, liecause each country registers
                         pesticides on the basis of its own climate, crops, and pest probiems, an
                         exporting country faces a mazi>Of pesticide requirements that may dif-
                         ler from -ts own and tiiat may not necessarily be health-related. Some of
                         tlu- live ^oM'niMieiits" pesticide registration practices may affect the
                         le>;;il availability aiul use of certain pesticides and. therefore, the pres-
                         eiK (' and composition of pesticide residues on produce imports from
                         those countries.



                         VHHI-                        (i.\0   R( Kirmr,!) ,S«f^.y «nd Qualit) of Imp<)rtf(l PrtMSuee



itisiiiasii
                                      Executive Suinmary




                                      Some countries' export sectors try, to varying degrees, to use manage-
                                      ment practices that consider U.S. pesticide residue requirements. Where
                                      GAO saw evidence of such practices—by multinational firms in all five
                                      countries and by other growers in Chile and Mexico—growers had
                                      exported produce to the United States for so.ae time and had estab-
                                      lished networks to obtain information and technical assistance—
                                      ihrough cooperative efforts of governments and exporter/growef- orga-
                                      nizations. Where U.S. requirements were not specifically considered in
                                      selecting pesticides for use or- exports—particularly among the less
                                      experienced growers in Costa Rica, the Dominican Republic, and Guate-
                                      mala—growers had not developed networks for obtaining information
                                      on their export markets' pesticide requirements.

                                      The current Uruguay Round of the General Agreement on Tariffs and
                                      Trade has included proposals to harmonize food safety and sanitary
                                      requirements—including pesticide residue standards—as a way to
                                      reduce their use as technical barriers to trade Ilowever, because adop-
                                      tion of international standards for pesticide residues is a slow, delibera-
                                      tive process, information exchange among nations regarding specific
                                      pesticide standards will need to increa.se to ensure that world trade is
                                      facilitated and that consumers are assured that food imports meet their
                                      countries' safety standards,

                                      Se\er ll CS, agencies, as well as international organizations, provide
                                      assistance related to pesticide use to developing countries. The U.S.
                                      agencies include Kr.-\. FDA, ISDA, and the Agency for International Devel-
                                      opment (AID), International organizations include the United Nations'
                                      Food and Agriculture Organizatiim, World Health Organization, and Pan
                                      American Health Organization, UAO did not review t he effectiveness of
                                      the agencies' or organizatiims' assistance.


GAO Analysis

Ciovernnu'iU P r a c t i c e s        (io\ernment piactices tliat may afiect the presence and composition of
T h a t Ma\ .Affect R e s i d u e s   pesticide residues on I'S, imiiorted produce from the five countries
on r , S , i m p o r t s              include ( 1) registering and reregistering pesticides: (2) ccmsidering a pes-
                                      ticide's I VS. status (iuriiig registration: CJ) canceling, restricting, or not
                                      reKisteriiij; pesticides tliat KI'A has canceled or suspended; (4) providing
                                      int'orniation about 1 '.S. staiuiards to export growers; and (5) regi.stering
                                      pesticides thai do not have i;i'.\ tolerances, .Some practices tend to limit


                                      I'uKf :)                      li.\() K( KI) »(>-.').'> Safely and QuaUty of Imported Produce
                            the legal availability of pesticides that are not allowed in the United
                            States, and they help to increase the likelihood that exports to the
                            United States will not contain residues of such pesticides. For example,
                            the 5 governments had prohibited or not registered from 81 percent to
                            94 percent of 52 pesticides who.se registrations KI'A had canceled or sus-
                            pended as of October 25, 1988, including 26 whose registrations had
                            been voluntarily canceled by manufacturers. In addition, two govem-
                            ments—Chile and Mexico—had provided information on U.S. pesticide
                            residue standards to export growers, to a.ssist them in making pesticide
                            decisions for their crops. (See ch. 2.)

                            liAO also identified 110 pesticides registered for use in 1 or more of the 5
                            countries that do not have KI'A tolerances established for a food use in
                            the United States: In some ca.ses, KCA may not have evaluated these pes-
                            ticides or may have denied a U.S. tolerance or registration. Registering
                            pesticides that do not have U.S. registrations pr Ki>A tolerances may be
                            appropriate in a country because of its specific pest problems, crops,
                            and climate: because the pesticides are suitable for nonfood uses; or
                            because exporters need alternative pesticides to be legally available to
                            meet their export markets' differing requirements. While registering
                            such pesticides may be appropriate to a country's needs, using them on
                            exported produce could result in the produce being refused entry to the
                            United States if KOA detects residues, (See ch, 2,)


Export Growers' Pesticide   In the five counrries. the export sectors have assumed responsibility for
Management Practices        ensuring that crops exported to the United States meet U,S. pesticide
                            requirements. Multinational firms and their contract growers in all five
                            countries and experienced export growers in Chil? and Mexico had
                            access to U.S. information and technical iLssistance—through their
                            firms, grower a.ssociations. or other resources—and they generally used
                            management practices that considered U.S, pesticide requirements. The
                            Chilean exporters' associatiim has distributed information on U.S.
                            iTqiiirements for exported fruit to its members since 1980, and it has
                            jirovided pesticide control plans for certain fruits. In Mexico, the Con-
                            federation of Mexican Fruit and Vegetable Growers Associations, with
                            the Ministry of Agriculture, published a comprehensive wall chart in
                            U)H7 showing U.S, pesticide requirements for export crops, and it has
                            distributed p<'stici(le spray schedules to some .Mexican export areas.

                             The less experieiucd. iiopinultinat ional export growers in Costa Rica,
                            the Dominican Repiiblii, and (iiialeniala have nol had ready access to
                            I'S. information or technic;il a,ssistance and have not u.sed management


                            HaKe 4                      (iAO K( KI) HO-.^.'j Safety and Quality of Imported Produce
                         Executive .Summary




                         practices that specifically considered U.S. requirements. The United
                         States does not have tolerances established for pesticides used on some
                         of these countries' export crops—in some cases because the crop is not
                         grown commercially in significant quantities in the United States.
                         Grower/exporter groups in these countries were seeking information on
                         U.S, requirements, and U,S, agencies havc been expanding assistance to
                         them, (Seech, 3,)


U.S. Agency Assistance   KI'A and KDA have provided foreign governments and growers with infor-
                         mation and technical assistance on request, and KPA has implemented
                         regional technical assistance workshops. In addition, AID and EPA are
                         providing Latin American and Caribbean export growers with informa-
                         tion on whal pesticides have U.S. tolerances for specific crops and guid-
                         ance in developing pesticide mcmitoring for exports. These efforts
                         should prove < <'fu\ in (1) decreasing the likelihood that U.S. consumers
                         receive produce grown with pesticides lacking U.S. tolerances, (2) help-
                         ing these countries avoid violations, and (3) preventing economic losses
                         to e: porters and U.S. importers. (See ch. 4.)


                         The extent to which, and in what ways. U.S. agencies should increase
Issues for               their invoKement in establishing tolerances for imported crops and in
Congressional            increasing the flow of information on U.S. food safety and quality stan-
Consideration            dards are issues that will confront the Congress as it deliberates on both
                         food safely and U.S, competitiveness. These issues also have implica-
                         tions regarding U.S, agencies' responsibilities and resources. Such
                         actions could help developing countries provide U.S. consumers with
                         iiuiea.sed assurance about the safety and quaiity of imported foods and
                         incr(>a.se the countries' exports to tho United States. However, these
                         actions could also help foreign growers and exporters compete more
                         diriMtly with US, producers and processors and increase U.S. agencies'
                         resource needs, (See ch, 5,)


                         11,Ml (liscii,s,sed the information contained in a draft ofthis report with
Agency Comments          resporsihie i:i',\, KDA, i SUA, and AID officials. Their comments have been
                         incorpoiated in the report where approi)riate As requested, (iAOdid not
                         obiain official a^t'ii" y comments on the report.




                         I'HtJi-                      <;A( ) K( 'KI)W)-.'>.5 .Safety aiid QuaUty nf Imported Produce
    Contents


    Executive Summary                                                                       2

    Chapter 1                                                                               10
                             Rising Fruit and Vegetable Imports                             11
    Introduction             Concerns About Residues on Imported Produce                    12
                             U.S. Safety and Quality Network for Imported Produce           13
                             International Organizations' Roles in Developing Food          15
                                  Safety Systems
                             Objectives, Scope, and Methodology                             15

    Chapter 2                                                                               20
                             Government Practices That May Affect Residues on I '.S.        21
    Foreign Governments'         Produce Imports
    Efforts to Meet U.S.     Controls Over Pesticide Availability and Use                   35
                             Observations                                                   36
    Safety and Quality
    Requirements on
    Exported Produce
    Chapter 3                                                                               38
                             Export Growers and Their Pesticide Management                  38
    Private Sector Efforts       Practices
    in Five Foreign          Multinational Firms                                            39
    Countries to Meet U.S.   Other Experienced Export Growers
                             Less Experienced Export Growers
                                                                                            41
                                                                                            49
    Safety and Quality       Observations
    Requirements
    Chapter 4                                                                               54
                             Environmental Protection Agency                                54
    U.S. Agencies' Efforts   Food and Drug Administration                                   56
    to Assist Foreign        U.S. Department of Agriculture                                 58
1    Countries in Meeting    Agency for International Development                           58
                             Observations                                                   64
    U.S. Safety
    Requirements




                             Paite n                    l i M t •'Ul'V.lt.an nn « - r . .
m

                           Contents




    Chapter :>                                                                                             66
    Issues f;r             Lack of Established Tolerances                                                  66
                                                                                                           67
                           Information
    Considuration by the   The Challenge                                                                   67
    Congress
    Appendixes             Appendix I: Pesticide Use Per Hectare, by Area or Nation                        70
                           Appendix II: U.S. Produce Imports by Region, 1988                               71
                           .\ppendix 111: Federal Agencies Involved in the U.S.                            72
                               Safety and Quality Network for Imported Produce
                           Appendix IV: International Organizations' Roles in                              78
                               Developing Food Safety Systems
                           Appendix V: Status in Five Countries of Pesticides That                         81
                               Do Not Have EPA Tolerances Established for the
                               Active Ingredients
                           Appendix VI: Mjuor Contributors to This Report                                  85

    Tables                 Table 2.1: Status in Five Countries of Pesticides on EPA's                      26
                               October 25,1988, Revised List of Canceled and/or
                               Suspended Chemicals
                           Table 2.2: Status in Five Countries of Pesticides on EPA's                     28
                               October 25, 1988, Revised List of Voluntarily
                               Canceled Chemicals of Significance
                           Table 2.3: Number of Pesticide Registrations With No                           32
                               EPA Tolerances in Five Countries
                           Table 2.4; Reasons Tor No-Tolerance Pesticide Residue                          35
                               Findings for Imported F<x)ds in Fiscal Year 1986

    Figure                 Figure 2.1: Chilean Pesticide Label                                            31




                           Page?                       UAO RCEn-90-55 Safety and Quality of Imported Produce
 Omtents




Abbreviations

AID         Agency for International Development
 AMS        Agricultural Marketing Service
 Ai'iiis    Animal and Plant Health Inspection Service
(AAP        Private Industrial and Agriculture Council of Costa Rica
c HI        Caribbean Basin Initiative
i It I"     Consortium for International Crop Protection
 ^:l'A      Environmental Protection Agency
 KA()       Food and Agriculture Organization
KDA         Food and Drug Administration
 KKD( A     Federal Food, Drug, and Cosmetic Act
KiKRA       Federal Insecticide, Fungicide, and Rodenticide Act
(iAO        General Accounting Office
(lUK.MiAL   Export Federation Guild of Guatemala
IK A        Inter-American Institute for C(X)peration on Agriculture
IK 4        Inter-Regional Research Project Number 4
 IAI c DK   Joint Agribusiness Coinvestment Council, Inc., of the
                Dominican Republic •
MAK         Nontraditional Agricultural Exports
I )i( I >   Office of International Cooperation and Development
< 'I A       Office of Technology Assessment
rAiio       Pan American Health Organization
1(1 H Al"    Regional Office for Central America/Panama
I \Ki'      United Natitms Environmental Program
I M'll      Confederation of Mexican Fruit and Vegetable Growers
                 .Associations
I :-^i'\    r s . Department of Agriculture
WHO         World liealth Organization


''««•• >*                    GAO, »'<1;ED-90-5I> Safety and QuaUty of Imported Produce
  BLANK PAGE

Page»          ( ; A 0 K('KI>-M.I.? Safely and QuaUty of Imported Pn>1uce
 A rapid increase in fmit and vegetable imports during the 1980s has
 been accompanied by government and public concem about the safety
 and quality of such imports, particularly about the presence of pesticide
 residues. Specifically, questions have been raised about whether resi-
 dues on imported produce exceed U.S. tolerances and if pesticides
 banned in the United States are being used on foods exported to the
 United States.'

Pesticides are chemicals or biological substances used to destroy or con-
trol weeds, insects, fungi, rodents, and bacteria. Pesticides are a mixed
blessing: they enhance agricultural productivity and improve public
health through control of discase-c airy ing pests, but they can adversely
affect people, nontarget organisms such as fish and wildlife, and the
environment.

 Worldwide pesticide sales have dramatically increased: from 1977 to
 1987, the worldwide agricultural chemical market doubled in size to
 more than a $17 billion industry. Developed countries, such as Japan
and the United States, have been using increasing amounts of pesticides,
and developing countries have been importing progressively more pesti-
cides. According to a 1986 United Nations Food and Agriculture Organi-
zation (FAO) publication,- Latin American countries' —m^or fruit and
vegetable producing countries that export to the United States—were
fourth in pesticide amounts used per hectare,^ after Japan, Europe, and
the United States. (See app. I.) The Environmental Protection Agency
(EFA) estimates that about half, and sometimes less than half, of most
Latin American countries' pesticide imports come from the United
States.

While international guidelines on the registration and use of pesticides
on food exist, their adoption by individual countries is voluntary. Each
country sets its own laws for pesticide registration and use, which vary
considerably in sophistication and degree of implementation among

  A iX'stKidi- residue toleranco is the n\a.\inuim legal level of a i)t;stieide residue that may exist in or on
a lixid Aiiording to Environmental Protection .Agency officials, EPA generally st-t.s tolerances so that
lot ill dieting' intake from all cioiw i,s at least KM) tinie.s lower thiin the lowest nontoxic' level observed
III lahoraKin,' exixisure tests of animals and so thai re,sidues will be unlikely to result in human
licallh toxicity pniblcin.s

-lleiigt V llot'.sicn iuiii lieorgc Ek,stioni, editors, Control of I'csiicide ,\|)[)licati(>ns iutd Ki,'sidues in
Kixiil ,\ (iiiitic Hiul Directory— lllftij 11'pl'sala, Sweden: Swi^lish Science Press)

 111 Uiis rciHin, Liilin ,\jMciic a relcrs lo the coujilries nf Ci'Dtriil ami ,Soiilh ,AlTierica.

' I licilaic = J-l" acres.



P^K*- 10                                     CiAO R(Er)9<»r>5 Safety and QuaUty of Imported Produce
 M'jp.V'gliiia!;-".." "




                           Chapter i
                           Iiiitroductidn




                           CoUhtriies. The United States can exercise control over pesticide use in
                           other countries only insofar as it identifies residues on food as it enters
                           the United States.


                           In May 1988 we reported that U.S. agricultural imports had generally
Rising Fruit and           increased from 1980 through 1986 and that fruit and Vegetable imports
Vegetable Imports          had risen more quickly than total agricultural irnportsi'* Specifically, the
                           report stated that, from 1980 to 1986, U.S. fruit imports tripled and veg-
                           etable imports more than doubled in real valiie; In addition, the import
                           share of the U.S. market for major fresh and frozien fruits rose from
                           aboui: 26 percent to about 33 percent; the share for major fresh vegeta-
                           bles rose from about 5 percent to about 7 percent.

                           Most U.S; frtiit and vegetable imports come from Latin America and the
                           Caribbean—5.5:rhiliionmefric tons, or 77 percent of the total U.S.
                           irhports of fruits and vegetables in 1988. (See a:pp. II.) Together, Chile,
                           Costa Rica; the Dorhihicah RepubliCj Gua:temala, and Mexico—the five ,
                           cbuntries bri which this riepdrt focuses—accounted for 59 percent of the
                           U.S. import yolume from Latin American and Caribbean countrieis in
                           1988; Mexico vi^as the principal supplier with 32 percerit of these Latin
                           Ariterican/Caribbeah irnpprts. Other Latin American countries that sup-
                           plied friiits and vegetableistb the Uriited States during 1988 included
                           ColbiribiaiEciiad6r;Horidurias, and Panama.

                           Many cburitries iri the Latin American/Caribbean region have empha-
                           sized diyersif^iciatibri bf their agricultural exports in recerit years as
                           vvbrld prices arid demarid fbr many of their traditional export commodi-
                           ties, siich as sugar arid coffee, have leveled bff or declined. Several of
                           these Cburitries are tryirig to ide'UtifyrieW specialty crops, such as aspar-
                           agus and mielons, to fill riiarket niches. The Agericy for Intemational
                           Developnierit (Alb) is assisting some Of these riatibns in increasing their
                           exports of ribhti'kditibnal fruits and vegetsibles; mostly to the United
                           States;" (See ch; 4.)




                           '^'AurlculturiilTrude: CmiSoo und ltnpttet.s of InereiwotI Entll and VcuelHtile Imrxxts (GAO/
                           ld-!!i5-8fl-(4flBn,MHy 10,1088),                                                      —
                          "Accordlhtl tt) un AID ol'fltiliil, mmirudll.lnnHl fnills tmd vegotubliw uio comimxIltlOM tillier ihan tracil-
                           tlorml pltiiilutlon crtips—coffcx;, collon, cucao, tuid bwf—that ua> pi'odi.it.t'd In vw-y lui^jie volume,
                           NtihtriidllltjriHl crops have been prmliicud In l.ho Uitln Amorlcan/CHi'lbbeim region lor liiiw thtui 16 to
                           20 yuHniigtinurullyln rosponse to Incrutwwi t.'.S. di;intuid for winter produt-o,



                          (*«!(« i I                                 aA6/IUJBIM»0^eiS MCBty lUtd QulOlty «>r tmpttrt«Ml thradue*
                                   Chapter 1
                                   Introduction




                                   Concerns about the safety and quality of imported produce, which focus
            Concerns About         mainly on pesticide residues, have been raised by government agencies,
            Residues on Imported   environmental grcnips, and others. In addition, international organiza-
            Produce                tions and environmental groups have recognized the general need for
                                   improved food safety systems in developing countries, many of which
                                   export fruits and vegetables to the United States and other countries.

                                   In September 198() we reported that the Department of Health and
                                   Human Service's Food and Drug Administration's (FDA) import monitor-
                                   ing program provided limited protection against public exposure to ille-
                                   gal residues in imported food." We said that P'DA sampled less than 1
                                   percent of the approximately 1 million imported food shipments each
                                   year.** In addition, we raised concerns about FDA'S limited information
                                   about what pesticides foreign countries use. In response to our recom-
                                   mendations, KDA has made changes in its sampling program and taken
                                   steps to increase its information on foreign pesticide use. In addition, the
                                   Pesticide Monitoring Improvements Act of 1988 (Subtitle G of Title IV of
                                   the Omnibus Trade and Competitiveness Act of 1988, P.L. 100-418)
                                   required the Secretary of Health and Human Services to improve FDA'S
                                   data collection and management of information related to pesticide resi-
                                   dues in imported and domestically produced foods, including obtaining
                                   information on pesticides used on exported foods destined for U.S.
                                   markets.

                                   In 1988 the Office of Technology Assessment (OTA) reported that limita-
                                   tions in FDA'S analytical methods create problems in enforcing pesticide
                                   t,c)leranc;es on imports becau.se FDA does not test for some pesticides used
                                   in foreign countries that are not approved for use in the United States."
                                   (JIA added that the testing limitations are compounded by FDA'S lack of
                                   information on what pesticides have been used on specific crops, espe-
                                   cially imports.

                                   lOnvironmental grouj;s have also rai.sed questions concerning U.S. knowl-
                                   edge about use of pesticide's on U.S. imports, For example, the Natural
                                   Ri;soiiices Defense C'ouiicil, a national, nonprofit environmental organi-
                                   zation, testified before the Sulicoinmittee on Health and Environment,
                                   I louse Commit (ceOii lOiiergy and C'ommerce, in December 1987(m tho
                                   'IV.sl_iciili's: Heller Saiii|ilin>; and l';iiroh enieiil Needed "'J_ll^[!!;>''i.<''iJ'''_!<'i! (<jA0/H{"MD-8li-y ll>,
                                   s i r i . ^vrroR^Y"                 ~        • "" '"•"'
                                   "A .liil.s li'HIi slall lepoil l)\ Ihe SiihcoininilIce on Oversighl mul liivi'sligiiliiiiisorihe lloiLseCoininit-
                                   lec on i:Merg\ and Coininerce indiciilcd a sampling raleol'nlioiil 2 iH'i'ccnl lor llsciil year I!1H7.

                                   •'I'eslic llic Kcsidiics IM I'oiid: I'ecl   logics lor llelcclion, (flVV, Ocl, IIISH,



                                   Patie I 'i                                       (•AO. KCEI) INI-nn MHfely and QiiHllty of ImiMtrtMl PnMlucf


iteSal^tlttemitsimii
     ryr^,.;




                             Chapter 1
                             Introduction




                             need for more information on foreign pesticide use. The Council stated
                             that foreign growers may legally purchase and use pesticides whose res-
                             idues may be illegal if that product is imported into the United States.

                             Broader food safety concerns about imports from Latin America and the
                             Caribbean were discussed at the August 1985 Inter-American Confer-
                             ence on Fbod Protection, which was convened by the National Academy
                             of Sciences. The conference, which was attended by representatives of
                             North American and most Latin American and Caribbean countries,
                             related to issues concerning the safety of foods both consumed within
                             countries and shipped among countries. The conference report identified
                             several factors that might negatively affect food safety in developing
                             Latin American and Caribbean countries.'" These factors included eco-
                             nomic problems; inadequate government control over food safety; and
                             lack of technical knowledge, advisory services, financial resources, and
                             physical facilities for proper quality assurance. The report concluded
                             that a lack of timely and effective technical and commercial information
                             particularly hinders developing countries' regulatory officials and pri-
                             vate industry in making appropriate choices in food safety and quality
                             decisions.


                             The U.S. safety and quality network for imported produce involves sev-
       U.S. Safety and       eral federal agencies, as well as states and private industry. At the fed-
       Quality Network for   eral level, EPA registers pesticides and establishes pesticide residue
       Imported Produce      tolerances that all fresh produce and other foods and feeds—whether
                             domestic or imported—must meet to be legally allowed for U.S. con-
                             sumption. EPA can also establish tolerances—sometimes called import
                             tolerances—foi- pesticides where there is no registration request and the
                             commodity is being treated outside the United States. It can also grant
                             tolerance exemptions when it determines a tolerance is not necessary to
                             protect the public health,

                             KI'A is required to notify foreign countries about (1) U.S. exports of
                             unregistered chemicals to their countries and (2) EI'A actions to cancel or
                             suspend a pesticide's U.S, registraticm. Pesticides used in foreign coun-
                             tries are not required to be registered with EPA, Ilowever, foreign uses of
                             pesticidc^s thai do not have an EPA tolerance or an exemption can result
                             ill a commodity's ri'jection at U.S, entry points if residues are detected.



                              't'otidPioifcllull ill Ihe Aiiierliiisi Wii.shiiigioii D,('.: Niiiloiuil AciultMny Pro.ii, 11)87),



                             Pn|(e IK                                     (jAO/K(;EI)-»onBHafely and Quality of Importml Produm


l^
Chapter 1
Introduction




FDA, which is responsible for protecting the U.S. public from unsafe
foods and other products, enforces the ERA pesticide residue tolerances
for all food products—both domestic and imported—except meat, poul-
try, and eggs, which are monitored for pesticide residues by U.S. Depart-
ment of Agriculture (USDA) agencies, FDA is also re.sponsible for
identifying imported foods that contain chemical contaminants, have
microbial and filth contamination, foreign objects, or that are decompos-
ing. A food shipment is considered adulterated if, among other things, it
contains either (1) a pesticide residue that is not subject to an EPA-
approved tolerance for that food or (2) a pesticide residue in an amount
greater than the EPA tolerance level.

The U.S. Customs Service can deny admission of any food presented for
import if the food is adulterated, and it can assess and collect damages if
adulterated shipments are not reexported or destroyed. In some cases,
previously adulterated food is allowed admission if other action brings it
into compliance with U.S. requirements.

USDA is authorized to inspect imported produce to determine its quality.
 USDA's Agricultural Marketing Service (AMS) administers a mandatory
inspection program for quality standards of size, maturity, and grade
for certain imported commodities covered by domestic marketing
orders." As of March 1988 these commodities were avocados, dates
(except dates for processing), filberts, grapefruit, table grapes, limes,
olives (except Spanish-style olives), onions, oranges, Irish potatoes,
prunes, raisins, tomatoes, and walnuts.'- AMS also administers a volun-
tary inspection program for fresh produce that financially interested
parties can use. USDA'S Animal and Plant Health Inspection Service
(APHIS) inspects produce, animals, and other products at U.S. entry
points (and conducts inspection, survey, and control activities at some
foreign locations) to prevent the introduction of foreign pests and dis-
eases that can hai'm U.S. agriculture.

The federal agencies' activities are discussed in more detail in appendix
III.

 " Markeling (irdtM's iiri.' iniirkotliig pliiiw ik>Migiii<d by KriiwtT.s uiut handli>rt4, und upprovinl by tho
.SiM.'i'trtiiry of Agrli'iiMiire, lo eollocl Ivi'ly work nut NOIUIUUIM lo inarkotliiK pix>bloiiiM. Murkotlng orders
iiri! l,H,Htto(l an I'oilonil rt^KiiliiMoM.s. I liidor soolIon Hu ol' Ilu: Agrli'iillurul Miu'kollng AKn.titnoiil Ai:t. of
 11137, IW iiMiondod (7 W.ti.C (iOHivI), iho min-ktM.limordois govern iho qiiullt.y of iH'Unln lm|M)rn;(l
ooininiitlltlo,<< iliirliig thi< dotTU!,slii! inurkollng .>ttuiiioii,

'-'Ixiglxliilliiii bofiire Iho IOI,sl CoiigrosKdLK, WM, MK, ;mil7, luid H, 17121)) would add .MIIOII ctminuxli-
l.les UM kiwi fruit, lux'tiirliMw, iMipiiyiLM, and plumst lo the Hut of lm|)()i1.od i.'oniiniKilllo,'* ,HUli|oot to mun-
dulory liiM|H.'(;lliin.



Page 14                                        UAO/RCKD-B0-B5 BkfHty and Quality of ImpitrtMl Produce
i   HB(|^jr.^.fliji   IL..IIJHIHI...1




                                        Chapter I
                                        Introduction




                                        Although federal agencies are responsible for ensuring the safety and
                                        quality of the U.S. food supply, some states may set regulations more
                                        stringent than the federal regulations. In addition, some states have
                                        established their own pesticide residue testing programs. In the states
                                        we contacted—California, Florida, and New York—testing primarily
                                        focuses on domestic produce, although imports are also sometimes
                                        tested. According to officials in these states, they use EPA tolerances as
                                        guidance and rely primarily on federal enforcement activities to monitor
                                        pesticide residues on imported fmits and vegetables.

                                        Some supermarket chains and other importers contract for their pro-
                                        duce prior to receipt and may indicate general quality specifications for
                                        the imported produce in the contract. However, officials of many of the
                                        major supermarket chains and other importers with whom we spoke
                                        said that they purchase their imported fresh produce on consignment at
                                        U.S. entry points. According to these importers, regardless of whether
                                        produce is purchased on consignment or under contract, they tend to
                                        rely on FDA to determine whether imported fresh produce meets U.S.
                                        pesticide tolerances. Some supermarket chains, however, have begun
                                        using private testing services to monitor produce for pesticide residues.


                                        Several international organizations play important roles in assisting
             International              developing countries to develop their food safety control systems. These
             Organizations' Roles in    organizations include the U.N. Food and Agriculture Organization; the
             Developing Food            U.N. World Health Organization (WHO); the Codex Alimentarius Commis-
                                        sion, a subsidiary body of FAG and WHO; the Pan American Health Organ-
             Safety Systems             ization (PAHO); and the Inter-American Institute for Cooperation on
                                        Agriculture (IICA). These organizations, whose activities are discussed in
                                        more detail in appendix IV, create model food laws, recommend food
                                        control regulatory policies, set international standards and guidelines
                                        for foods, mobilize resources, and provide technical assistance to indi-
                                        vidual countries upon request.


                                        In a September 3, 1987, letter and subsequent discussions with their
             Objectives, Scope, and     offices, Representative l^eon Panetta, then Chairman, Subcommittee on
             Methodology                Domestic Marketing, Consumer Relations, and Nutrition, House Commit-
                                        tee on Agriculture, and Representative Frank Horton asked us to
                                        (1) obtain information on foreign govemment and private sector efforts
                                        to ensure that imported produce meets U.S. safety and quality standards
                                        and (2) determine what federal agencies are doing to assist foreign coun-
                                        tries in meeting U.S, safety requirements. In addition, they asked us to


                                        Page IS                     OAO/RCKDIM) ss Safety and Quality of tmportfid Produn
Chapter 1
Introduction




discuss federal agencies' responsibilities regarding the safety and qual-
ity of imported produce. As agreed, we focused most of our effort on
safety standards related to pesticide controls.

To respond to the first objective, we visited five countries in Latin
America and the Caribbean between March and October 1988: Chile,
Costa Rica, the Dominican Republic, Guatemala, and Mexico. We
selected these countries for several reasons:

Latin American and Caribbean countries supply most U.S. imports of
fruits and vegetables—77 percent in 1988.
The five countries together contributed over half of the Latin American/
Caribbean volume in 1988.
Mexico provides most of the fresh vegetables, such as tomatoes, cucum-
bers, peppers, eggplant, squash, and asparagus, imported into the
United States.
Mexico and Chile accounted for most of the increased U.S. imports of
fresh tomatoes, broccoli, and table grapes between 1980 and 1986.

In addition, we considered information, obtained from various sources
during preliminary discussions, on the countries' length of experience
with fruit and vegetable exports and their varying levels of sophistica-
tion in government regulatory programs. Most of the U.S. produce
imports from Costa Rica and Guatemala are bananas—about 90 percent
and 80 percent, respectively, in 1988. U.S. imports from Mexico and the
Dominican Republic are mostly vegetables and other fruits, and imports
from Chile are mostly fruit.

In the five countries, we met with government officials responsible for
pesticide standards and food safety monitoring; officials of the Costa
Rican and Mexican national pesticide commissions; repi'esentatives of
regional and international organizations, such as FAG, PAHG, and IICA;
environmentalists and university experts; representatives of grower and
exporter associations; exporters; expoit growers; representatives.of
Chile's Chemical Producers Association; and U.S. embassy officials. We
also met with FAG, PAHO, and IICA representatives in Washington, D.C. We
did not verify all the information obtained from these scnirces or evalu-
ate the adequacy of food safety and quality activities in the five
countries.

For information about the controlf; these coimti'ies' governments use to
help ensure that exported prodiici> destined for the United States ineets
U.S, pesticide tolerances, we intiM'viewed foreign govei'nment officials


Page I«                     U AO/KCEIllM)Bn Safety and Qnnllty of Imported Pniduco
Chapter 1
Introduction




responsible for pesticide registration and use and reviewed applicable
laws and regulations; official government lists of registered chemicals;
and proclamations, statutes, or other documents relating to the use of
pesticides. We also obtained available studies and analyses related to the
use of agricultural chemicals in each country and spoke with laboratory
personnel in Costa Rica and Guatemala.

To determine if pesticides were legally available for use in the five coun-
tries that do not have tolerances established for a food use in the United
States, we compared the official government lists of registered pesti-
cides for each of the five countries with lists of active U.S. pesticide
tolerances in the U.S. Code of Federal Regulations (40 C.F.R. part 180
and 40 C.F.R. part 185, which was formerly 21 C.F.R. part 193) and
information in commercial publications.'' To determine if these countries
had pesticides registered for use, and therefore legally available, that
the United States had canceled or suspended, we compared the coun-
tries' lists of official pesticide registrations with EPA'S Office of Pesticide
Programs' October 25,1988, revised lists of (1) canceled/suspended pes-
ticides and (2) voluntarily canceled chemicals of significance. These lists
include pesticides that ERA has identified as having the mjyority of food
uses withdrawn or canceled but do not include all restricted pesticides.
We did not verify BRA'S definition of the status of these pesticides.

For information on the 5 countries' private sector efforts to meet U.S.
pesticide and quality standards for imported produce, we interviewed
officials of 5 exporter and grower associations; 18 export growers; 9
exporters; and 22 grower/exporters, of which 5 were multinational
firms. We asked about their management practices for determining and
using pesticides and for ensuring quality and reviewed the exporter and
export growers' pesticide use planning documents, such as spray plans,
and pesticide purchase and application records, where available.

The exporters and growers we interviewed produced a variety of fruits
and vegetables for export to the United States, including pineapples,
strawberries, chayote, and yucca in Costa Rica; bananas, broccoli, sugar
peas, and strawberries in Guatemala; tomatoes, strawberries, and


 '•'The lisls lor Chili;, Ihc Doiiiiniciiii Kepulilic, and (iiiiiioiniilii wort; IIIH7 lisl.s, l^islii UleH'solTloliil list
wiLs curitMil as ol our visit in ,limo IHHH, iiccoi'ding lo Ministry of AgiicuUtiro (»fl'k:t«ls. For Moxkti, wi;
i^xaininod two pcsileldo lisls, ono hdin iho Mliil.slry of Agrloulliiro for IHH7 aiul ono dovolo|H;d by
Mexico's Inleriiiinisterial Pe,slicldo(:oinnii,sslon in IHHH. which coniinis,sion officials told us would
siipersode all pit^ious lists of olTicial |)osllcidc I'eglsl nil Ions, In addilion. wooxainiuod the Mlnlsli-y of
Agriculture's osllmule of posllclde colistuupl.tou for lllHK,



Page 17                                       (lAO/KCKI>m)-5n Safety and Quality oflmportedPntdum
Chapter 1
Introduction




watermelon in Mexico; Chinese vegetables, melons, and tomatoes in the
Dominican Republic; and grapes and tree fruit in Chile.

We obtained information on Chilean export growers' pesticide manage-
ment practices primarily from representatives of Chile's exporters' asso-
ciation and from 4 exporters, 16 export growers, and 1 multinational
grower/exporter selected from the association's list of exporters. We col-
lected information on Mexican export growers' pesticide management
practices primarily from representatives of Mexico's Confederation of
Mexican Fruit and Vegetable Growers Associations (UNPH) and from 12
grower/exporters in 4 of Mexico's 5 largest exporting states (Sinaloa,
Sonora, Baja California, Michoacan, and Tamaulipas). These 5 states
produced 84 percent of Mexico's exports to the United States during the
1987-88 growing season, UNPH selected the Mexican exporters and grow-
ers according to our specification of location and crops grown.

In Costa Rica, the Dominican Republic, and Guatemala, we obtained
information on export growers' pesticide managemeni practices from
exporter and grower associations; five exporters; two individual export
growers; nine grower/exporters, of which four were multinational firms;
and, in the Dominican Republic, several export growers in a group. The
associations are the Private Industrial and Agriculture Council of Costa
Rica (GAAP); the Joint Agribusiness Coinvestment Council, Inc., of the
Dominican Republic (.JACC/DR); and the Export Federation Guild of Gua-
temala (GREMiAL). We selected exporters and growers in these countries
with assistance from USDA'S Foreign Agricultural Service agricultural
attaches, APHIS officials, and AID officers in the U.S. embeissies in these
countries.

We analyzed 1986 FDA import violation data to determine the extent and
reasons for pesticide violations on imported produce. We also deter-
mined the proportion of imported fresh produce that was required to
meet minimum quality standards from 1985 through 1987 for each
country. We did not determine what proport,ion of total fresh produce
imported from these countries, and inspected by AMS, was rejected, how-
ever, because the data were not computerized, and inspection certifi-
cates with the re.jection data were grouped by port and importer, rather
than by country.

To determine what federal agencies were doing to assist foreign coun-
tries in meeting U.S safety requirements, we interviewed officials from
EPA, FDA, and AID headquarters; the AID regional office for Central
America and Panama; and AID bilateral missions in Costa Rica, the


Page 18                     (JAO/KCKDiMIr^ Safety and QuaUly «f Imported Produc*
Chapter 1
Introduction




Dominican Republic, and Guatemala. We also reviewed ERA and FDA
international program documents, such as workshop records, foreign
visitor and training records, and special project documents. We did not
verify these activities or evaluate their effectiveness.

To obtain information on federal agencies' responsibilities regarding the
safety and quality of imported produce, we reviewed prior GAG reports
and agency documents and spoke with officials from ERA, FDA, AMS, and
APHIS. APHIS is not directly involved in ensuring the safety or quality of
imported fruits and vegetables, but it conducts inspection and quaran-
tine activities at U.S. entry points (and inspection, survey, and control
activities at some foreign locations) to identify and prevent the intro-
duction of exotic animal and plant diseases and pests that might
threaten U.S. agriculture. We did not verify these agencies' program
activities or evaluate their effectiveness.

For information on what some states and private industry were doing to
monitor pesticide use on imported produce, we spoke with state depart-
ment of agriculture officials and reviewed annual reports and other
related documents from three states—California, Florida, and New
York—and spoke with various importers and supermarket chain
representatives.

For additional background information, we visited FDA offices in Phila-
delphia and Los Angeles and spoke with representatives of the National
Food Processors' Association and NutriClean, a private residue-testing
service.

We did our work primarily between February and December 1988, with
updates as appropriate through February 1990, in Philadelphia, Penn-
sylvania; Washington, D.C; California; Chile; Costa Rica; the Dominican
Republic; Guatemala; and Mexico. We discussed the information con-
tained in a draft of this report with responsible EI'A, FDA, USDA, and AID
officials. Their comments have been incorporated in the report where
appropriate. Ilowever, as requested, we did not obtain official agency
comments on this report.




Page IH                      UAU/HCliUWyan Safety and Quality of Importetl PnMluc<'
Chapter 2
Foreign (jovemments' Efforts to Meet U.S.
Safety and Quality Requirements on
Exported Produce
               Like the United States, the governments in the five countries we visited
               (Chile, Costa Rica, the Dominican Republic, Guatemala, and Mexico) do
               not design their food safety and quality systems—specifically their pes-
               ticide registration and monitoring systems—to meet other countries'
               safety and quality standards, but primarily to address domestic needs
               and issues. Each of the five countries has laws and regulations control-
               ling pesticide availability and use; however, govemment monitoring and
               enforcement activities ,^re generally limited because of a lack of
               resources.

               Each country's need for legally registered pesticides is unique, depend-
               ing on the climate, crops grown, pest problems, and nonfood-use require-
               ments. A country's export markets may have different pesticides
               registered for use on a given crop or they may have the same pesticide
               registered, but for different crops. As a result, an exporting country
               needs to have a range of pesticides available so that export growers can
               meet many export markets' pesticide requirements. In addition, an
               exporting country needs to have information on its export markets' pes-
               ticide requirements and quality standards to ensure successful exporta-
               tion of its produce.

               Although the five countries' regulatory systems are not specifically
               aimed at meeting U.S. import standards, most of the government offi-
               cials told us that they may cancel, restrict, or not register pesticides that
               are canceled, restricted, or suspended in the United States, if the infor-
               mation is known. When pesticides that have been canceled or suspended
               in the United States are prohibited or not registered for use in these
               countries, it helps decrease the legal availability of such pesticides for
               use on exported produce. In addition, two of the governments provide
               information to export growers about U.S. pesticide requirements for spe-
               cific export crops. Because of the variety of pesticides that different
               countries may allow for use on a given crop, providing information to
               export, growers on U.S. requirements increases the likelihood that the
               growr I will be able to meet U.S. requirements for their exported
               produce.

               Conversely, the five governments have registered some pesticides that
               do not have tolerances established in the United States. The legal availa-
               bility of the.se pesticides may increase the possibility of their being used
               on produce exported to the United States, While the reasons these pesti-
               cides do not have U.S, tolerances may be other than health-related,
               imported pi'oduce with residues of these pesticides would be considered
               violative if FDA detects them.


               Page 20                      UAO/KCKD-90-SS Safety and Quality of Imported Produce
                         Chapter 2
                         Foreign Governments' Efforts to Meet U.S.
                         Safety and Quality Requirements on
                         Exported Produce




                         On the matter of quality, government officials in the five countries told
                         us that their governments do not monitor fruits and vegetables to deter-
                         mine whether produce destined for export meets the size, maturity,
                         grade, or other quality standards of their growers' export markets. As
                         with pesticides, exporters are expected to know and meet their export
                         markets' quality requirements.


                         Officials of the five governments we visited told us about a number of
Government Practices     practices that affect the legal availability and use of pesticides in their
That May Affect          countries, and therefore the presence and composition of pesticide resi-
Residues on U.S.         dues on U.S. produce imports from those countries. These practices
                         included (1) registering and reregistering pesticides; (2) considering the
Produce Imports          U.S. status of pesticides before making registration decisions; (3) having
                         canceled, restricted, or not registered pesticides that do not have U.S.
                         registrations or tolerances; (4) providing information about U.S. pesti-
                         cide requirements for export crops to growers; and (5) registering pesti-
                         cides that do not have ERA tolerances.


Registration Practices   Registration procedures are necessary to provide for the proper and
                         safe use of pesticides and to protect people and the environment from
                         ineffective or detrimental chemicals. Each country we visited had estab-
                         lished a pesticide registration system that requires pesticides to be regis-
                         tered before they can be sold or used. With the exception of the
                         Dominican Republic, each country required pesticide registrations to
                         specify crop use.'

                         The five countries' registration processes require registrants (usually
                         chemical manufacturers) to provide much of the same type of informa-
                         tion ERA requires for a U.S. registration: the pesticide's name, chemical
                         composition, and use instructions; health and environmental safety
                         studies; and residue information. All five countries use the international
                         maximum residue limits (tolerances) developed by Codex. In the United
                         States, ERA'S Office of Compliance Monitoring, in cor\junction with FDA,
                         conducts randomly selected inspection audits—usually post-registra-
                         tion—of the laboratory practices used in conducting the scientific stud-
                         ies that support the registration data, according to a former Director of
                         the Registration Division of EI'A'S Office of Pesticide Programs. Ilowever,

                         ''I'lio Diinilnicun Kopiiblit; i<;visotl Ils i)o,sMeido slatuto lu IHHH to inoludo, (UiU)ng ol.h(>r things, a
                         r(.'f|iilr<.>iu(<iil for a pt.'Stloldo rt-glHlralion to IH' orop-,s|)ot:lflo, Al tho llino of our visit, hi)W0V(;r, Iho
                         stuliilo had nol rtH'olvod I'iiial ii|i|ii'oval, Ministry of Agrlctiltiiro ofl'lolals lolil UM lliai. llioy (!X|H!Ot(Ht ll
                         would ho slgiUMi by DocoinlK'r IHHH.



                         Page 21                                        UAO/RCBD-OOSB Safety and QuaUly of Imported Produce
                                             Chapter 2
                                             Foreign Governments' Efforts to Meet IJ.S.
                                             Safety and QuaUty Requirements on
                                             Exported Produce




                                             officials of four of the five countries told us that their governments do
                                             not validate the scientific studies presented by the registrants, generally
                                             because of a lack of scientific and budgetary resources. Mexican govern-
                                             ment officials told us that they validate the scientific studies to a limited
                                             extent.

                                             While the five countries do not generally register pesticides to meet
                                             another country's import requirements, we found that the governments
                                             have prohibited or not registered many pesticides that the United States
                                             has canceled or suspended, usually because of health or environmental
                                             concerns. Canceling registration of, restricting use of, or not registering
                                             pesticides that are canceled or suspended in the United States help to
                                             ensure that these pesticides will not be legally available for use on
                                             export crops.


           Considering U.S. Status of        Foreign government officials told us that, during the regifjtvation pro-
           Pesticides Before Making          cess, they try to determine the pesticide's status in industrialized coun-
                                             tries, including the Llnited States. To do so, they depend primarily on the
           Registration Decisions            registrant's providing a certificate of free sale for the country of ori-
                                             gin—that is, the registrant's certification that the pesticide is legal for
                                             use in the country where it is manufactured. The officials' use of other
                                             sources of U.S. pesticide information provided by ERA and Codex varied
                                             among the five countries, depending on the officials' degree of access to
                                             this information.

                                             Each of the five countries required registrants to submit a certificate of
                                             free sale from the country of origin. The amount of information required
                                             to be submitted with the certificates, however, varied among the coun-
                                             tries. For example, the Dominican Republic requirc\s documentation
                                             from a "competent authority" that indicates the pesticide's name and
                                             formula, registration number, and date of registration, and an indication
                                             of whether tho chemical is unrestricted, prohibited, or manufactured for
                                             export because it has no commercial use in the country of origin.

                                             Similarly, Costa Rica requires "official documentation showing the reg-
                                             i.stralion nuinber, date ol" registration or renewal, type of formula and
                                             coiicentralion." In addition, when a pc'sl.icide is not registered in the
                                             country of origin, Costa liica requires documents from the manufacturer
                                             or "appropriate authorities" indicating (he rea.son. While (locumeiUation
                                             i.ssiied hy a corresponding governmeiU agiMicy or coiupeleiit aulhorily is
                                             rec|uired, veril'it.'atioii by the corresponding govonimeiit agency in th(>



                                             I'age 22                           (•AO.' I{( ElMHI-nn .Safety iind Qunlily of ImiMirted Prudtur



•jjllijU^m^lttUii^tmU^kiikiMm^miiiiimiil^^
Chapter 2
Foreign Governments' EfforU to Meet U.S.
Safety and QuaUty Requirements on
Exported Produce




country of origin was not required in these countries. Mexico's docu-
ments indicated that it would accept certification from a third country.

According to some government officials, the free sale certificate assures
these governments, to some degree, that because the pesticide has been
registered in an industrialized country, the health effects probably have
been independently validated. Because the countries we visited gener-
ally lack the resources to independently validate the studies described in
the chemical companies' application data, govemment officials depend
on these certificates to protect their countries from registration and
indiscriminate sale of untested chemicals or chemicals that have been
proven unsafe. We did not verify the countries' use of these practices.

Officials of the five countries said that they consider other U.S. sources
of information, such as notices under sections 17(a)- and 17(b>' of the
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 U.S.C.
136o(a) and (b)), if available, when making pesticide registration deci-
sions. These notices can be valuable to foreign countries in properly
evaluating the risk of registering or continuing use of a pesticide. Chil-
ean officials also said that they have their embassy staff in the United
States routinely obtain needed information directly from ERA on the U.S.
status of pesticides. Similarly, Costa Rican officials responsible for agri-
cultural pesticide registrations told us that, during the process of mak-
ing registration decisions on a certain group of pesticides, they had
requested and received some additional information from ERA.

Although government officials in each country except Chile and Mexico
(who said they already received enough information) expressed interest
in consistently obtaining information on U.S. pesticide standards and
changes in pesticide status, this information is not always readily avail-
able. In an April 1989 report,' we said that EI'A had not issued notices to
foreign governments for all pesticides where significant action had been

 'Seel ion 17(a) oslablishes uolification rotiuironiiMil.s foi' l.ho (.'XtKHl of |K>sli(.'id(;s that lU'o iu>t rogis-
lori.'d for (Iomeslic use iu the I iiiitod Stales, In a soi-ios of ,slcps, l.ho foreign piu'chitsor nuisl aokuowl-
edge, and ihe gox'oi'nini.'iil is suhsotiuoutly not.ifiiKl, Ihiit tho po,slleido is uol r<!gi,stoivd aud cauiiol IH'
sold lor \isi> iu tho Diiilod StiUos.
 '.Section I7(hi retiiiiros KI'A to notify I'oiiMgugoveriniu'Ulsaiul appi'oprialo iultMiiatioiuil agoiuws
about, signiricaul cliangos in a (K'slicide's I i,S. status, such lis caiu'olat.lou or su,s|H'U.siou, 'l'lu> nolicos
goiiorully couiiiiii lulorntailou o(\ whon KI'A ViH)k Uio ai'itou, haokgvouiu) ou whal.pvooipllnltMl iho
aciion, an oxiiliiiiaMou of ilio aoi lou, iinil Iho ha.sis EI'A had I'or taking llu> aciion, Thi' nolicos also
IdentHy KI'A conlacis I'roiu which foreign govornmeiils can re<|Uo,sl additional iiiforniation ou Iho
affecli'd iH'sl.icide aiul registered products Ihal. could bo usod lu lieu of l.ho |)esticide.

'I'esllcldos: KxiKirl of I 'urogistorod Pcsl.lcldo.s Is Not Adouiialolv Moulloiod hy KI'A (liAO/
urKn'SfrrsoTS^rrTrwiT.                                             —                       —

Page r.i                                     GAO/RCEI> W) ns Safety and Quality of lni|N>ned Pniduce
                           Chapter 2
                           Foreign Governments' Efforts to Meet U.S.
                           Safety and QuaUty Requirements on
                           Exported Produce




                           taken and that ERA'S 1985 booklet entitled Suspended, Cancelled, and
                           Restricted Pesticides was outdated. We said that the type of information
                           in this booklet, if updated and disseminated, would be sufficient to alert
                           countries using the included pesticides to initiate actions or request
                           additional data as a basis for making their own risk/benefit analysis
                           concerning use. The booklet also serves as a reference document on past
                           U.S. actions.

                           We recommended that ERA (1) develop criteria and procedures for deter-
                           mining whether and when to prepare and issue notices of regulatory
                           action (sec, 17(b) notices); (2) annually update and issue to all concerned
                           parties, including foreign governments, its booklet entitled Suspended,
                           Cancelled, and Restricted Pesticides; and (3) establish guidance on 17(a)
                           transmittal procedures for sending notices to foreign governments and
                           coordinate with the Department of State in updating and sending 17(a)
                           and 17(b) notices to U.S. embassies. We believe that these improvements
                           would enhance foreign governments' efforts to use established informa-
                           tion on pesticides from other countries in making their pesticide use
                           decisions.

                           On February 12, 1990, ERA published a F'ederal Register notice on pro-
                           posed changes to its notification process. The notice cited our report's
                           recommendations and issues discussed during May 1989 hearings on
                           pesticide exports before the House Subcommittee on P^nvironment,
                           f^nergy, and Natural Resources, as reasons for the proposed changes.


Reregistration Practices   l']ach of the live governments' regulations provided for (1) reregistration
                           procedures or reviews and/or (2) procedures for revoking a pesticide's
                           registration when adverse health, safety, or environmental factors
                           become known. These countries—like the United States—do not always
                           remove canceled pesticides from registration lists and commert:e at the
                           time of cancelation. As a result, pesticides that are officially not
                           approved for use in a country may .sometimes be lc?gally found in distri-
                           bution channels,

                           According to the former Director of the Registration Division of I:;PA'S
                           Office of Pesticide I'rograms, I:PA determines how long a pesticide can
                           remain in commerce and use in the United States on a caso-by-case basis
                           as a resiill; of a risk/benefit determination made during the review pro-
                           cess to determine whether a pesticide should be canceled. In most cases,
                           if no immediate health risk exists or if cancelation is due to I'inancial
                           decisions, IOI'A may allow a pesticide to stay in disti'ibution channels for a


                           I'flge 24                         GAO/K<;En W) ns SalVly ami QuaUly of ImiMirtcd l>rt)duc«
                              Chapter 2
                              Foreign Governments' Efforts to Meet U.S.
                              Safety and QuaUty Requirements on
                              Exported Produce




                              specified time. However, if a pesticide's registration is suspended on an
                              emergency basis, ERA prohibits sale or use of the pesticide concurrently
                              with the suspension.

                              The countries we visited handled the availability of recently prohibited
                              pesticides in various ways. For example, some countries' regulations,
                              such as the Dominican Republic's and Costa Rica's, specify that if a
                              chemical is voluntarily canceled by a manufacturer, the registration will
                              be maintained for 2 years until existing stocks are used. In Mexico, when
                              officials determine that a pesticide should be removed from the official
                              pesticide list, it is still legal for use for 2 years, In Guatemala and the
                              Dominican Republic, pesticides that have had their registrations can-
                              celed are allowed to remain in commercial channels for a time to allow
                              existing supplies to be depleted.

                              In Guatemala, for example, 18 pesticides were canceled in 1987. As of
                              May 1988 its list of registrations continued to include several of these
                              chemicals because, according to government officials, they gave the
                              chemical companies 6 months to sell existing stocks, and use of these
                              pesticides was to be allowed to continue until supplies were exhausted.
                              Similarly, the Dominican Republic canceled a series of pesticides during
                              the 1970s; some, however, had not been removed from the government's
                              list of registered products as of October 1988. For example, distribution
                              and sale of the pesticide 2,4,5-T is prohibited; yet the chemical's regis-
                              tration was still listed in 1988.


Canceling or Restricting      In the countries we visited, a number of pesticides that ERA has canceled
Pesticides That Are Illegal   or suspended in the United States, or that chemical manufacturers have
                              voluntarily canceled, have also been prohibited from importation, sale,
in the United States          and use; have had their uses restricted; or are not registered. As a result,
                              the legal availability of such pesticides is limited, decreasing the likeli-
                              hood that they will be used on exported produce.

                              Table 2.1 shows the 1988 registration status in the five countries of 26
                              pesticides who.se U.S. registrations ERA had canceled and/or suspended,
                              for various rea.sons, as of October 25, 1988. As the table shows, the five
                              governments have i)rohibited, restricted, or not registered nuiny ofthe.se
                              pesticides,




                              Page as                           GAO/R( :KI> mvnn Sal\'ty and Quality of Impitrted Produce
                                           Chapter 2
                                           Foreign Governments' Efforts to Meet U.S.
                                           Safety and QuaUty Requirements on
                                           Exported Produce




Table 2.1: Status In Five Countries of Pesticides on EPA's October 25,1988, Revised List of Canceled and/or Suspended
Chemicals
Pesticide                                             Cliile  Costa Rica Dominican Republic            Guatemala                                                    IVIexico
Aldrin^                                                 P/L            P                       P                 P                                                       NR
Aspon                                                   NR            NR                     NR                NR                                                        NR
Brominated salicylanilide                                NR           NR                     NR                NR                                                        NR
Carbophenothion'^                                       NR            NR                       R               NR                                                          R
ChiordaneV Heptachlor'^                                    P           R                     RS''              P/L                                                         R
Cycloheximide^                                          NR            NR                     NR                NR                                                        NR
DBCP
   (dibromochloropropane)                               NR              P                    P/L               P/L                                                       NR
DDD (TDE)
   (1,1-dichloro-2,2 bis [p-chlorophenyl] ethane)       NR            NR                     NR                NR                                                        NR
DDT
   (dichloro diphenyl trichloroethane)                     P           P                     NR                  P
Demeton"                                                NR            NR                     NR                NR                                                        NR
Dialifor'-'                                             NR            NR                     NR                NR                                                        NR
Dieidrin"                                               P/L            P                    P/L                  P                                                       NR
Dinitramine"                                            NR            NR                     NR                NR                                                        NR
Dinoseb"                                                NR             P                     NR                P/L                                                       NR
EDB''
   (ethylene dibromide)                                    P           P                       P                 P                                                        R
Fenaminosulf                                               R           R                     NR                 R                                                        NR
Fluchloralin"                                           NR            NR                       R              NR                                                         NR
Kepone
   (Chlordecono)                                        NR             P                     RS               NR                                                         NR
Mirex                                                   NR            NR                     NR                 R                                                        NR
Monuron TCA
   (tnchloroacetic acid)                                NR            NR                     NR               NR                                                         NR
Perfluidone'                                            NR            NR                     NR               NR                                                         NR
Potassium permanganate                                  NF^           NR                     NR               Nl-I                                                       NR
Silvex"                                                 NR             P                     NR               NR                                                         NR
2.4 5T
   (2.4.5trK;hlorophcnoxyacc-;ticacid)                  NR             P                    P/L               P/L                                                        NR
Thiophanale                                             NR            NR                    NR                NR                                                         NR
ToxaplienR"                                             NR             P                    NR                P/L                                                         R
                                           Loi.ji.Mir.l

                                          Wit = N D I ierji';li.'ii.-il (i.>i iisiv

                                          I ' = I'iiihiriili.Nj (.11 :.ii;.',|.]i.;ii(li.,'il

                                          I'/l    " l'ii:ihi|iili;i| m i l n ' l i n i v i ' i l I m m I;MM:IIIV :• li:,l i.'l ir'psli.Mi.'il |.»;:;lii:ii.li':

                                          II a llijgislfll.vj Int ii'.^i-

                                          MS => llr;",-,lrii:;li.if.l
                                           'I.l'A hi.ir, aclii.'i' >':'.';\:^ { v . : v Lil'li; ,'.' •! n . i t i ' ^ii Im t h i s | .i.'::.lii;irli-,'




                                          I'ngo 2<l                                                              (•AU l« EDIH) nn SulVly nnd Qiuitlly of lin|Mirlod l>nMlu(T
Chapter 2
Foreign Govemmente' Efforte to Meet U.S.
Safety and QuaUty Requirements on
Exported Produce




''EPA has a tolerance(s) tor this pesticide,

'^EPA has tolerances and action levels for this pesticide.
''The Dominican Republic permits use only for termites.

'^Mexico's health ministry uses DDT to control malaria.
Source; EPA's Office of Pesticide Programs' Oct. 25,1988, revised list of canceled and/or suspended
chemicals: olficial pesticide registration documents, statutes, resolutions, and proclamations from five
countries; 40 C.F.R. parts 180 and 185 (revised as of July 1, 1989): and The Pesticide Chemical News
Guide (Washington, D C ; Louis Rothschild, Jr), June 1, 1988.,


Of the 26 pesticides on ERA'S list, 17, or 65 percent, were either prohib-
ited or not registered in all 5 countries. Chile had not registered or had
prohibited use of 25 of the 26 pesticides, or 96 percent; Costa Rica and
Guatemala, 24, or 92 percent; the Dominican Republic, 22, or 85 percent;
and Mexico, 21, or 81 percent.

Among the 5 countries, Mexico had the most pesticides registered of the
26 that had been canceled or suspended in the United States. However,
one of the pesticides, heptachlor, which was previously registered for
use in the Ministry of Agriculture's catalog of approved chemical uses, is
not listed as registered in the new Official Catalog of Registered Chemi-
cals for Mexico, published by the Interministerial Pesticide Commission
in 1988. According to Mexican Ministry of Health officials, the chemical
is no longer going to be allowed to be used in Mexico. However, as men-
tioned earlier, pesticides may still be legally sold and used in Mexico for
2 years after they have been removed from the registration list.

In addition to EI'A'S canceling or suspending registrations because of
health or environmental concerns, registrations may be voluntarily
withdrawn by manufacturers. Table 2.2 shows the 1988 registration sta-
tus in the five countries of 26 pesticides that F.I^A had included on its
October 25,1988, revised list of voluntarily canceled chemicals of signif-
icance.' As the table shows, the five governments have also prohibited
or not registered many of these pestitiides.




'('honiical inaiiiil'iiciurci's cancel chonilcal uses for various i'oa,sou<t, lucluding hoallh luul/or oamomlo
rea,soiis.



Page 27                                   (iAO/RCKDWtnn Saf^'iy and QuaUty of Imported Produce
                                            Chapter 2
                                            Foreign Governments' Efforts to Meet U.S.
                                            Safety and QuaUty Requirements on
                                            Exported Produce




Table 2.2: Status in Five Countries of Pesticides on EPA's October 25,1988, Revised List of Voluntarily Canceled Chemicals of
Significance
Pesticide                                                  Chile         Costa Rica              Dominican Republic                                Guatemala          Mexico
Acrylonltrile                                                  NR                      NR                                     NR                                          NR
Arsenic trioxide                                               NR                     "NR"                                    NR"                         NR              NR
Benzene
  (all pioducts)                                             _NR                       NR                                   _NR                           NR              NR
BHC
  (benzene hexachloride)                                       NR                      NR                                     NR                            P
c"aptafoP~~                                                                                                                                                "R"           __R
Carbon tetrachloride                                           NR                     j^lR                                      "R""                      NR              NR
Chloranil                                                      NR                    "NR"                                    ""NR"                       '"NR"'           N^
Copper acetoarsenite                                          "NR"                   "NR"                                   ""N'R"                        NR             "NR
Copper arsenate
  (basic)                                                      NR                      NR                                    NR                           NR             NR
Cyhexatin^                                                      R                       R                                  ""ISI'R"                      ""NR""""         R
                                                                                                                           •••p7[-
Endrin"                                               "^ '""""P                  "" 'R""                                                                  ""'p'""'"      NR
EPN^
  (0-ethyl 0-p-nilrophenyl
  phenylphosphonothioate)                                      NR                      NR                                      R                            R               R
Erbon                                                          NR                   ""'NR                                   "_N"R""                      '"NR '           NR
Hexachlorobenzene                                              NR           ""        NR                                   ""NR                           "NFI            NR
Lead arsenate"                                                -^p                      NR                                    "NR"                         NR           """N"R
Monuron                                                       "N"R                     "NR"""'                              """NR   "                     NR             NR
Nitrofen
 _(T(DK<^)                                                     NR                        P                                      R                        NR              NR
OMRA"'"""'"
 (Octamethylpyrophosphoramide)                                NR                       NR                                    NR                          NR              NR
Pentachlorophenol
  (some nonwood uses continue)                                NR                      NR                                     NR                          RS               R
Perthane                                                      NR                      NR                                     NR                          NR              NR
Phennrsazine chloride                                         NR                      NR                                     NR                          NR              NR
Ronnel"                                                       NR                      NR                                     NR                          NR              NR
Safrole                                                       NR                      NR                                     NR                          NR              NR
Sodium arsenite'                                              NR                      NR                                     NR                          NR              NR
Strobane                                                      NR                      NR                                     NR                          NR              NR
frysben                                                       NR                      NR                                     NR                          NR              NR
                                           i.oyonrj

                                           NH " Nol it'(.jislrjif:r,l Im ir;,i;:
                                           I-' « I'loliihilud

                                           P/l. " I'luliiljllui:!. nol KMMijvud lioin ijoiinliy ;.; Iiyl i.il ii.:gi;;li.:iixl |.",';:'.liCK.l0!

                                           II • riugisliiiirjil IDI UUU

                                           IIS - llr-'yliictiiiJ




                                           I'age 2N                                               tJAO RCEDIHinn Safety nnd Quality of IniiMtrlod PnMluoe
                           Chapter 2
                           Foreign Governments' Efforts to Meet U.S.
                           Safety and QuaUty Requiremente on
                           Exported Produce




                           *EPA has a lolerance(s) for this pesticide.
                           ''EPA has tolerances and action levels for this pesticide.
                           •^Trade name.
                           Source; EPA's Office of Pesticide Programs' Oct, 25,1988, revised list of volunlarily canceled chemicals
                           of significance: official pesticide registration documents, statutes, resolutions, and proclamations from
                           five countries: 40 CF.R. parts 180 and 185 (revised as of July 1,1989); and The Pesticide Chemical
                           News Guide, June 1,1988.


                           Of the 26 pesticides whose U.S. registrations had been voluntarily can-
                           celed, 18, or 69 percent, were either prohibited or not registered in all 5
                           countries. Chile had not registered or had prohibited use of 24 of the 26
                           pesticides, or 92 percent; Costa Rica and Guatemala, both 23, or 89 per-
                           cent; the Dominican Republic, 22, or 85 percent; and Mexico, 21, or 81
                           percent.


Providing Information on   In each country, government officials emphasized that they believed
U.S. Pesticide             that most export growers, particularly multinational firms and growers
                           affiliated with national grower or exporter associations, independently
Requirements               obtain information on U.S. standards and are therefore unlikely to
                           export produce that does not meet U.S. requirements. According to Chil-
                           ean and Mexican officials, however, their governments also provide
                           information on U.S. pesticide requirements to export growers, which
                           assists them in making decisions about pesticide use on their export
                           crops. The Chilean government, througli pesticide labels, provides infor-
                           mation to its growers on U.S. pesticide tolerances for specific crops. The
                           Mexican government coordinates with a national association to provide
                           U.S. information through a wall chart, which the association distributes
                           to export growers.

                           Government officials in Costa Rica, the Dominican Republic, and Guate-
                           mala said that while they would like to be able to provide information
                           on the United States' and other countries' requirements to their growers,
                           they have not obtained adequate regulatory information on U.S. pesti-
                           cide standards, such as 40 C.F.R. part 180, or other comprehensive com-
                           mercial publications that incorporate U.S. regulations. They also suid
                           that it was primarily the export growers' responsibility to Icnow and
                           meet both the safety and quality requirements of their markets—as it is
                           in tho United States.




                           Page 99                                  (lA<)/H(:Klvm) SB Maftely and Quality of Imported Pmdum
                             Chapter 2
                             Foreign Governments' Efforte to Meet U.S.
                             Safety and QuaUty Requiremente on
                             Exported Produce




Chile Provides Information    To assist its export growers in meeting the United States' and other
on U.S. Pesticide             countries' import requirements, the Chilean government requires infor-
                              mation about major export markets' pesticide requirements, by crop, to
Requirements on Pesticide     be included on pesticide labels. Chilean officials gather information on
Labels                        export market requirements, particularly on tolerances and preharvest
                              intervals,'' as part of the registration process. Chilean regulations
                              require this information to be printed on the label in addition to the
                              standard information on precautions, composition, hazard, and use."
                              Further, Chilean regulations require a change in the pesticide label
                              whenever the listed export markets' registration status changes. Figure
                              2.1 shows the Chilean label for the fungicide Mancozeb 80, with the
                              highlighted portions showing use and tolerance information.




                             ' I ' l e h a r v c s l inlerval is Ihe liiiic i.'i days reijiiired alloi' a|i|>licaliou liohiro an aMriciilluial ci'op ,«ay bo
                             I lai vesled l i i e n s i i i e Ihal resiill Ics lemainiiig are w i l h i n Ic^al toleianccs

                             ' A l l live govcriiinenis•^ M   iul M
                                                                  a <^l
                                                                    siaiiihiidi/.iliou
                                                                        I M I * • I I I • l|r,4 M !• ' I I cfhu'l
                                                                                                           • I |1 >l 1 w    >ti Ml hI I olher
                                                                                                                                        « '1 111 I coi
                                                                                                                                                     1 <'M mli l l lies
                                                                                                                                                                    I I I <^inl i l iho
                                                                                                                                                                                    I il< r(>glon--ai'e
                                                                                                                                                                                            I^K                                 changing
                             llieir
                             llieir label
                                      label rornial
                                            rornial lo
                                                    lo Iry l' o reduce'           Ihe' iiiisiiseor            •' I . . .~ii"••••'•••
                                                                                                .Tl ,,11 1.1 |ieslicitlos
                                                                                                                                              '•'•••'•
                                                                                                                             i \ I . it , 1 . I'.mU
                                                                                                                                                         •' I II Iho
                                                                                                                                                         . •'•''
                                                                                                                                              I 111. i i of               i . F i n n I 'I , •
                                                                                                                                                                     I . counlrit>s          ,T Ilia,s
                                                                                                                                                                                                 i , . i , T iido|ilod
                                                                                                                                                                                                             ii.iir| i l ,            Iho
                             KAO/Wllolalicl Illlliiial. ' " ' In
                                                              ' " which
                                                                  " 'lich Ihc lei          I d I siile of Ihc label lists                  lisls luecaulion.s,
                                                                                                                                                     lU'ecaulion.s, Ihe center               coi... . colli    . . . . . . ia. .ills
                                                                                                                                                                                                                                , . , ^ Inl'oi''
                             iiiiiliuM on llic |iesliciilc's clieiic nil 111' 11 Hllj II isil" illl, anil' a 'l i a / a n l' sign,                 '        and• ,Ibe     • .l i ^.h1l . side       i shows u,sc
                             iMloi'iiialioii




                             I'ngo ;MI                                                                          t i A O K t i;!)IK) nn Safely ami Qniilliy of lin|mrt«><l PriNtuoe
                                                                                  Chapter 2
                                                                                  Foreign Govemmente' EHbrte to Meet U.S.
                                                                                  Safety and QuaUty Requiremente on
                                                                                  Exported Produce




Figure 2.1: Chilean Pesticide Label

                                                                                                                                      Cylli«a                            Ootil I M
                                                                                                                                                   Eirfarmatfad                           ObHmelaiiH
                                                                                                                                                                         Hl,afiit
                                                                                                                                      Duraz noi    Corineo                  180 a         Cominiir tn botAn roiado y npitir cida 7 diai
                                                                                                                                      Nectannet    Pudricion piriia         240 gr.       hiiti U l d i dl piialot. Con pudricldn pirdi
                                                                                                                                      OimsKOf      Roya                                   r«pailr aplicacionii 4 i 6 Hminii m m dt
                                                                                                                                      Almendrot    Cloca                                  coHcha. U w doiii alia contrt cloara an ytma
                                                                                                                                      Ciruelot                                            hinchada. Cirtncia: 14 diit.
                                                                                                                                      Vid          Botrilit                 ISO a         Aplicir intii y dtipuai dt Moracidn, continuan-
                                                                                                                                                                            240 gr        do ctdt 14 di'ai. Canncii: 6 6 d i i i .
                                                                                                                                     Uan/anoE      Veniuna                  160 a         Comtnim tn ytmi hinchtdt cada 6 t 10 dill,
                                                                                                                                     Piralei                                240 gr.       dtpanditndo dt condicionti. Carencit: 21 d i n
                                                                                                                                                                                          manjanoi: 15 di'ai tn ptralti.
                                                                                                                                     Fiuiillai     Mancha                   1,1 a 3,4     Comtniir an broticidn. Aumtniar la dofii a
                                                                                                                                                   Foliar                   Kg./ha.       mftdida qua aumanta al daiarrollo (oliai.
                                                                                                                                                                                          Carancia: 7 iin.
                                                                                                                                     Tabaco        Antracnoiit              tSOgr         El ilmiciQO cidi 3 i 5 dtii. al apittcK (»
                                                                                                                                                   MohD arul                              enltrmadidi Comen/ir cuando lai hojai alcifi'
                                                                                                                                                                                          can 1.5 cm. dadiimiiro.
                                                                                                                                     Remolacha    Virutla                   2,3 a 3,4    Apiicaf cida 7 i 10 diai al apiracer la anfif'
                                                                                                                                                                            Kg./ha.      mtdid. Aplicici6n da alto voluman cubrlendo
                                                                                                                                                                                         homogeneamentt. Caftncia: 14 dial.
                                                                                                                                    Papal         Ti(dn                     1,1 a 2,4    Aumenisr doiit a madidi que ence la planta.
                                                                                                                                                  temprano v                Kg /ha.      Comianca tamprano lai apliciclonai. Sin llmi-
                                                                                                                                                  tardio                                 iaci6n,
                                                                                                                                    Tomate        Tiiond                    I.8>2,e      Comeniaf al iniciai la anleimtdad cada ) a 10
                                                                                                                                    A|.           AnlraconotiE              Kg./ha.      dial, Carancia: 5 diat.
                                                                                                                                    Pimiefito




   T O l i M N C I A l a i M i n i VICENTES EN PAISES 0 AREAS ECONOMICAS QUE SON MERCADO DE EXPORTACIDNES VECETAIES CHILENAS:

   ClIUwl             EE,UU.           Oiatil          AlllMIM           Italia        FAD/WHO             CEE            Cullnii                 EE.UU.              Biaiil            Alananit         ••Ha

   ManiiiMi              7.0             20              2.0              20                                              Ramolacha                2.0                20                  0.2             20
  Prnln                10.0              2.0             2.0              20                                              Papal                    O.i                OOS                 02              20
  Owitnoi               HK                               20               2.0                                                                                                                             2.0
  NNtMlfin
                                          -                               20
                                                                                                                          Tomate                   4.0                10                  10
                                                                                                                                                                                                          2.0
                                                         20                                                               Arvojai                                     0.1                 02
  OMiiKOI
                        »
                        KR
                                          -              2.0              2.0                                             Trigo
                                                                                                                                                    KK

                                                                                                                                                   SO                 0.2                 02              2.0
  Almndroi              KK
                                          -              2.0              20                                              Melonil
                                          -              2.0
                                                                                                                                                   4.0                4.0                 10              2.0
  ClnialM               KK                                                20                                              Citncot
                        7.0                              20
                                                                                                                                                    -                 10                  2.0             20
  VIMi
                                         -                                20
                                          ," Sin inlormaclbn dafinltjva                                                                                KI Sin tolarancia
  I m InlofrTtaciin putrfa lar modificada tn cualqular mominto por lot oiganilmot o autoridadti de lot paiiai o areai economical mancionadat, dablendo lot uiuarloi, conlirmarloi anlai dt axporlar, puti do aiumimBl ratponHbilUid p
  t n u r i t d t infprfflKtonil titnclllminia varlablai. El lilmpo de carancia itiialado no aiegura un retiduo igual o interior a la manor loterancja mdicada.
  h n a l ' M u n i n i y/o marcidoi di a>pDrtaclin, conultanoi.                                                                                                     Santiago, viganiti al I-S-SC




                                                                                  As figure 2.1 shows, the label lists use information to the right of the
                                                                                  name block and the tolerances for specific crops and export markets on
                                                                                  the far right. For example, for the pest, corineo, on peaches (duraznos),
                                                                                  the label recommends 180 units of Mancozeb 80 in 100 liters of water
                                                                                  per hectare, repeated every 7 days. The export market tolerances reveal
                                                                                  that the United States (EE.UU.) has not set a tolerance for Mancozeb 80
                                                                                  on peaches, alerting the Chilean export grower that use on peaches
                                                                                  would be unacceptable if the peaches are intended for the U.S. market.
                                                                                  At the same time, the label shows that Mancozeb 80's use would be
                                                                                  acceptable if the peaches were intended for the German or Italian
                                                                                  market.




                                                                                  Page a I                                                      UAO/RCBD-VO-55 Saftty and QuaUty of Imported Pradttet
                                          Chapter 2
                                          Foreign Govemmente' Efforte to Meet U.S.
                                          Safety and QuaUty Requiremente on
                                          Exported Produce




Mexico Provides Information on            In 1987 the Mexican Ministry of Agriculture and UNPH—the Confedera-
U.S. Requirements Through a               tion of Mexican Fruit and Vegetable Growers Associations—jointly pub-
Wall Chart                                lished a wall chart for export growers, to provide all chemical/crop
                                          combinations and corresponding U.S. residue tolerances for Mexican
                                          export crops. According to Mexican officials, the chart was the first
                                          comprehensive document of U.S. regulations compiled specifically for
                                          Mexican export growers. As discussed in chapter 3, this chart generally
                                          provides Mexican export growers with the information needed to meet
                                          U.S. pesticide tolerances on their export crops.


Pesticides Registered                     We identified 110 pesticides registered in 1 or more of the 5 countries as
Without EPA Tolerances                    of 1987 or 1988 (see ch. 1, fn. 13) that do not have tolerances estab-
                                          lished for a food use in the United States. In some cases, the countries
                                          may have registered these pesticides (I) because of their specific pest
                                          problems, crops, and overall climatic conditions; (2) because the pesti-
                                          cides are suitable for nonfood uses; and/or (3) because exporters must
                                          have alternative pesticides legally available to them to meet the differ-
                                          ing requirements of their export markets. While registering these pesti-
                                          cides may be appropriate to the countries' needs, use of any of the 110
                                          pesticides on produce destined for export to the United States could
                                          result in no-tolerance violations, and tiie produce could be refused entry
                                          if KDA detects them. In some cases, EPA may not have evaluated these
                                          pesticides or may have denied a U.S. tolerance or registration.

                                          The 110 pesticides we identified are detailed in appendix V. Table 2.3
                                          shows the number of such pesticides for each of the five countries.
Table 2.3: Number of Pesticide
Registrations With No EPA Tolerances in   Country                                                                                                                      Number
Five Countries
                                          Chile "                                                                                                                             "24
                                          Costa Rica                                                                                                                          "42
                                          Dominican Republic                                                                                                                   50
                                          Guatemala''                                                                                                                         "37
                                          Mexico                                                                                                                               35
                                          Total                                                                                                                               188"
                                          •'GuiJlriiiialiin reyisirulioii (lat.:i included nhpiit 7,S inodiicls wlioye aclivi^ ingioclienis woie n,>t iclontitiecl,
                                          llu;ij(.i producls .-iKi uul coiiLiideiud iii Ihib: (;,'ilijiilalioii
                                          ''LteciiiKiii w.iiiii; ijesihcirlc's an.; ii.'tjiatuicil in iiioio lli.iii uno cuiinliy. Ilu.: lolal i;;x(.;i".n.M.l5 110
                                          ;.;oiiir;[i l-Visliciilo lugislialioii iiyls lui (^liilo. ('osla ilici. Ilu..' r..)uiiiiiiiciiii Hi;piililiij. Giialoiiiaia. Miid
                                          Mr.;xii.;(.i                                                                                                     o




                                          Page ;I2                                             GAO lU'EDIHMilVSnroty ami Qunlily oflmiMmed PnMlmv
    mmmw                      Wf*




                                    Clwptef 2
                                    Foreign Govemmente' Efforte to Meet U.S.
                                    Safety and QuaUty Requiremente on
                                    Exported Produce




Most Violations on Imported         According to FDA reports, FDA data have consistently shown that most
ftodiice Are No-Tolerance           pesticide residue violations on imported produce involve no-tolerance
Violations                          violations rather than residue levels that exceed ERA tolerance levels.
                                    No-tolerance violations result when FDA detects residues of pesticides
                                    that do not have U.S. tolerances established for use on a particular crop
                                    in the United States. Over-tolerance violations result when pesticide res-
                                    idues exceed EPA'S established tolerances and most often occur because
                                    of pesticide misuse, unusual weather conditions, or poor agricultural
                                    practice, according to FDA.

                                    Each of the five countries has experienced no-tolerance violations on
                                    produce exported to the United States. In many cases, U.S. tolerances
                                    had not been established for the specific export crop, although a toler-
                                    ance may have been established for a related crop. The effect of not
                                    having tolerances established for certain crops may be particularly
                                    severe for Costa Rica, Guatemala, and the Dominican Republic, which
                                    are trying to improve their economies through increased exports of non-
                                    traditional fmits and vegetables, such as chayote, yucca, and some Chi-
                                    nese vegetables. These commodities either are not grown or are not
                                    grown commercially in significant quantities in the United States and
                                    tend to have few, or no, U.S. tolerances. As a result, these countries'
                                    growers may face rejection of their produce at U.S. entry points because
                                    of potential no-tolerance pesticide violations. The following examples
                                    illustrate what happens when U.S. tolerances have not been established
                                    for specific crops:

                                    A representative of a chayote cooperative in Costa Rica told us that to
                                    control pests on its growers' crops, the cooperative was using a selection
                                    of chemicals that do not have U.S. tolerances for chayote. However, the
                                    chemical companies and the Costa Rican Agriculture Ministry had
                                    assured them these chemicals would break down in 4 days and therefore
                                    not leave residues on their exported chayote. The representative told us
                                    that the cooperative's growers were using these pesticides because EPA
                                    had not registered any chemicals or established any tolerances for any
                                    pesticide's use on chayote, and fungus problems, if not controlled, would
                                    result in severe economic loss.
                                    While EPA has set a tolerance level for permethrin residues on bell pep-
                                    pers, the tolerance does not extend to other specialty peppers. In 1986
                                    Mexico experienced over 30 no-tolerance violations for permethrin resi-
                                    dues that were detected on Mexican serrano, poblano, caribe, and other
                                    peppers. The residue levels were below the tolerance level for bell pep-
                                    pers but were In violation because tolerances had not been set for these
                                    particular specialty peppers.


                                    Page aa                          aA0/RCICD4N>-SS SaflBty and QuaUty of Imporied PftMlUM
    'WW^""""^



                ChapterZ
I               Foieign Govenunents'Efforts to Meet U&
                Safety and QnaUty Requiremente on
                Exported Produce




                The Dominican Republic experienced many no-tolerance violations in
                1987 and 1988 on imported fresh produce, including eggplant, peppers,
                squash, and snow peas. As was the case with the Mexican peppers, U.S.
                tolerances had been established for the pesticides on other food com-
                modities, but not on the foods cited for violation. In December 1988 FDA
                ordered automatic detention of all shipments of long beans, snow peas,
                peppers, and fuzzy squash from the Dominican Republic because of the
                number of no-tolerance violations." In correspondence with Dominican
                Republic govemment officials, FDA officials noted that while the pesti-
                cides identified are not permitted for use in the United States on the
                violative imported crops, most often they are legal in the United States
                for use on other crops.

                FDA import monitoring data show the extent of no-tolerance violations
                on imported produce. In fiscal years 1986 and 1987, FDA'S inspection of
                fresh produce imports found 256 violations out of 5,676 samples, or
                4.6 percent, and 427 violations out of 8,016 samples, or 5.3 percent,
                respectively. Of these violations, 230, or 90 percent, in 1986," and 390,
                or 91 percent, in 1987, occurred because U.S. tolerances had not been
                established for the food commodities sampled. The remainder resulted
                from residues that exceeded established EPA tolerance levels. In 1986
                about two-thirds of the no-tolerance violations involved pesticides that
                had U.S. tolerances for commodities, including fmits and vegetables,
                other than the type cited for violation. (See table 2.4.) We did not make
                a similar analysis for other years.




                '*Undor uuUiniatIo dotuntlon, Miitmuquont. Mhl|:)inonlH ul' doHlgnuliKi |)i-(Klm.'l.s aro nui iNTmlllod lo enter
                thu llnlli'd StuloH iinlvNt) thu tthlpiNir or lmfN>rl,(<r oun piiivtdu a valid ivrtll'loutu of mialyNlN Nhuwing
                that lh(! pnxliicl doeo nut ounluin lllugal ruHlriiiuH uf llio oltud puslluldoM,
                "or thuRu 2311 vIolHllunN, 8 Invutvod 2 or muro rJUHlioldo iimldiiuH making a total of 'MI vtulHllvu
                (joHtluldu runldiiu rindlngN,



                Page 84                                    QAO/RCRD-BO-SS Safety and QuaUty of ImportMd Prwlttce
                                             Chapter 2
                                             Foreign Govemmente' Efforte to Meet U.S.
                                             Safety and QuaUty Requiremente on
                                             Exported Produce




Table 2.4: Reasons for No-Tolerance
Pesticide Residue Findings for Imported                                                                                          Violations
Foods in Fiscal Yea? 1986                    Reason for violation                                                    Number                   Percent
                                             The pesticide had a U.S, tolerance for one or more fruits,
                                               vegetables, and/or other commodities, but not for the
                                               commodity cited for violation                                              155                       64
                                             The pesticide wras not registered for any use in the United
                                               States; or the pesticide was registered, but no tolerances
                                               had been established for a food use application                              72                      30
                                             The pesticide was canceled or severely restricted in the
                                               United States, and previous food use tolerances were
                                               revoked^                                                                     14
                                             TbtaJ                                                                        241                      100
                                             ^For enforcement purposes, EPA has established action levels lor canceled or severely restricted pesti-
                                             cides because several of these chemicals can persist in the environment for many years. Action levels
                                             are regulatory limits at or above which FDA generally can take legal action to remove foods from com-
                                             merce. On Feb. 19, 1988, FDA announced in the Federal Register (53 Fed. Reg. 5043) that, in response
                                             to a court ruling, action levels were not binding on FDA, industry, or the courts, although ihey could be
                                             used as guidelines. In 10 of these 14 cases, the residue levels present in the violative samples w/ere
                                             below action levels for commodities in the same or other lood groups.
                                             Source: Our analysis of FDA fiscal year 1986 import monitoring data.


                                            As table 2.4 shows, almost two-thirds of the no-tolerance residue find-
                                            ings for the import violations in 1986 involved pesticides with U.S. toler-
                                            ances for other commodities, including fruits and vegetables, but not for
                                            the commodities cited for violation. In such cases, the residue findings
                                            may not necessarily be indicative of pesticide misuse or poor agricul-
                                            tural practice. In addition, of the 72 residue findings in the second cate-
                                            gory, 66 involved a single pesticide—procymidone—on grapes from
                                            Chile, Italy, New Zealand, and South Africa.


                                            According to I-^AO guidelines, monitoring and enforcement activities are
Controls Over                               needed to help ensure the integrity of governments' pesticide registra-
Pesticide Availability                      tion systems and to help prevent the illegal use of pesticides and the
and Use                                     resultant risks to health and the environment. The guidelines state that
                                            monitoring and enfoi'cement programs should verify that only legal,
                                            I)roperly registered products or theii* components are imported and that
                                            chemicals offered for sale have the exact formulations indicated on
                                            container labels. In addition, the guidelines spt;cify that after registering
                                            a product, governments should exercise control over residues found in
                                            food for the protection and reassurance of the (.'onsumer and to ensure
                                            the acceptability of agricultural commodities in ti'ado.




                                            Page .'in                                GA(>/H(KI> mi nit Miintty nnd Quaiity of lm|Mirl«>d Produce


                                          a^Miri^^iMiUUi
•j|!<",|i. .1   IPI1««"||"""P_1'1.,«HI' ^, » ^




                                                 Chapter 2
                                                 Foreign Govemmente' Efforte to Meet U.S.
                                                 Safety and QuaUty Requiremente on
                                                 Exported Produce




                                                 Government officials in each of the countries except Chile told us that
                                                 governinent monitoring and enforcement activities, particularly moni-
                                                 toring pesticide availability and field sampling for residue testing, were
                                                 generally limited because of such resource constraints as lack of inspec-
                                                 tors, lack of transportation to monitor distributors and perform field
                                                 sampling, and inadequate residue testing facilities. Subsequent to our
                                                 visit, Chilean officials indicated in an FAG survey that they believed that
                                                 adequate resources were available in their country to effectively man-
                                                 age the availability, distribution, and use of pesticides.'"

                                                 While the officials told us that their countries had few monitoring
                                                 resources, we found that limited residue testing had been done for
                                                 domestic crops in Mexico, Chile, Costa Rica, and Guatemala and that, in
                                                 some cases, university and government laboratories had provided resi-
                                                 due testing to export growers for a fee. Some of the countries were seek-
                                                 ing assistance in improving their laboratory capabilities. For example,
                                                 Costa Rican officials told us that they were seeking FAO funding for
                                                 increased laboratory facilities and that an FDA representative had been
                                                 detailed through PAHO to work with Costa Rica's Ministry of Health to
                                                 improve laboratory testing capabilities. In addition, Mexico informed
                                                 FiaA in May 1988 of plans to establish regional laboratories that will pro-
                                                 vide a variety of analytical services, including pesticide residue testing
                                                 of both imported and exported products.


           Ohsprvations                          Because each country registers pesticides on the basis of its own climate,
                                                 crops, and pest problems, an exporting country faces a maze of pesticide
                                                 requirements that may differ from its own and that may not necessarily
                                                 be health-related. These variations can particularly affect developing
                                                 countries that are trying to increase exports but have few resources
                                                 available to identify the differences between countries' pesticide/crop
                                                 combinations and tolerances. Many countries, such as the United States,
                                                 have complex systems of pesticide registration and tolerance-setting,
                                                 and their tolerances are not always the same as international Codex
                                                 maximum residue limits, which the newer exporting countries we visited
                                                 have adopted. In addition, the exporting countries may have different
                                                 pesticides registered for use on a given crop, or they may have the same
                                                 pesticide registered, but for use on different crops.



                                                 '"KoNpoiiNo toQiiuwtloiinairo tiiliovominoiil.s iiii l.ho Inlonialloiial (,'tKlo of Oimliiol on tlio l.ll.ilrlbullon
                                                 and Uno iif I'uHtluldow, FAQ. Rimio, .lim, llWfl,         '



                                                 Page 80                                      UAO/RCKD-iW-OB Safety and Quality of Imported Pmduce
Chapter 2
Foreign Govemmente' Efforte to Meet U.S.
Safety and QuaUty Requiremente on
Exported Produce




To more effectively compete in world agricultural markets and deal
with the maze of requirements and systems, export growers and export-
ers need to obtain more information on other countries' requirements.
The governments in the countries we visited expect export growers and
exporters to take primary responsibility to know and meet the import-
ing requirements of their export markets. Most of these governments
have resource constraints that affect their ability to obtain and dissemi-
nate information on other countries' requirements and to conduct moni-
toring and enforcement activities relating to pesticide availability and
use.

In most cases, government officials told us that their countries lacked
information about U.S. requirements. However, in two of the five coun-
tries, the governments had taken action to provide their export growers
with information about U.S. pesticide requirements, which assists their
growers in making appropriate decisions on pesticide use for their
export crops. Government officials in the other three countries
expressed interest in obtaining more information on U.S. import require-
ments but, at the time of our review, had not yet established the neces-
sary information networks. U.S. agencies are assisting some countries'
export growers in obtaining information about U.S. pesticide require-
ments. These efforts are discussed in chapter 4.

Despite a general lack of information about U.S. pesticide/crop require-
ments, the countries we visited had prohibited or not registered most of
the 52 pesticides hsted in tables 2.1 and 2.2, which the United States
had canceled or suspended as of October 1988 either through EPA'S regu-
latory action or through voluntary cancelation by chemical manufactur-
ers. While such pesticides are not legally available in these countries,
constraints in monitoring and enforcement capabilities may contribute
to lingering concern that these pesticides, although not legally sanc-
tioned, may be available for use on domestic and exported produce.




Page 87                          GAO/R( :KI) IMI^IIA Salety and Quality of Imported Produce
f(P(MHVJ>^ii«'ai,m. .JM"




                    ter 3

     Private SeetGtt" Efforts in Five BYjreigrt Countries
     to Meet U.S. Safety and Quality Requirements

                            The governments in the five countries do not design food safety and
                            quality systems to ensure that exports meet U.S. safety and quality
                            standards. Moreover, the governments expect growers and exporters to
                            take primary responsibility to know and meet such standards. Exporters
                            and export growers in these countries try, to varying degrees, to ensure
                            that fruit and vegetable exports meet U.S. pesticide residue require-
                            ments. The extent to which the exporters and growers are able to do
                            this, however, generally depends on their length of experience in export-
                            ing produce and on access to information and technical assistance.

                            Multinational firms, their contract growers, and other experienced
                            export growers are more likely than less experienced export growers to
                            use pesticide management practices that consider U.S. pesticide require-
                            ments. Multinational firms' and experienced export growers' practices
                            are most often directed by the policies, information, and technical ser-
                            vices provided by their firms or by older, national exporter/grower
                            associations. The less experienced export growers are generally affili-
                            ated with newer grower/exporter jissociations, which have fewer sup-
                            port services in place to assist export growers in meeting their export
                            markets' pesticide requirements. Growers who produce for domestic
                            consumption are governed by their countries' safety and quality
                            requirements only and do not have an economic incentive to be part of
                            an information network or to develop management practices that ensure
                            compliance with the United States' or other countries' requirements.

                            On the matter of quality, the exporters determine what the quality of
                            exported produce should be largely on the basis of their knowledge of
                            the importing countries' quality requirements and changing market
                            demands. Most of the export growei's and exporters we spoke with were
                            aware of U.S. marketing order lequirements and tended to sort produce
                            for export to the United States according to these minimum require-
                            ments and/or importer specifications—either verbal or written. Repre-
                            .sentatives of multinational firms told us that their companies' standards
                            are fuither dictated by theii* assessment of customei" preferences.


    llxpdrt Growers and     Within the five countries, the export sectors have assumed responsibil-
                            ity for ensuring that their crops exported to the United States meet U.S.
    their Pesticide         pesticide requirements. The fruit and vegetable growers in the export
    Management Practices    sectors include (1) ex|K;rienced multinational firms; (2) other expe-
                            rienced growers affiliated with older, national ox porter/grower associa-
                            tions (Chile and Mexico); or (3) less experienced export growers



                            Page »M                     UAO/RCEDW) DIt Salety and QuaUty of ImpoHed l>rodtte«
                      Chapter 3
                      Private Sector Efforte In Five Foreign
                      Countries to Meet U;S. Safety and
                      QuaUty Requiremente




                      affiliated with newly organized, national associations (Guatemala, Costa
                      Rica, and the Dominican Republic).

                      The export growers we contacted told us of a variety of pesticide man-
                      agement practices that many of them used to help meet U.S. pesticide
                      requirements for fresh fruits and vegetables. These practices included
                      the following:

                      Obtaining available information on ERA pesticide tolerances for produce
                      destined for export to the United States.
                      Developing pest control plans consistent with the information on EPA
                      requirements.
                      Supervising pesticide selection and application and creating and moni-
                      toring crop- or field-specific records of chemicals purchased, received,
                      and used (including pesticide used, field location, dosage, and date).
                      Performing routine or periodic residue testing to ensure that pesticide
                      residues on exported produce do not exceed U.S. tolerances.
                      Enforcing pest control plans.

                      However, not all export growers had used each practice or used specific
                      practices to the same degree. Multinational firms in each country and
                      experienced export growers in Chile tended to have most of these man-
                      agement practices in place. In Mexico, experienced export growers     -
                      varied in terms of the number of practices they used. However, they
                      tended to use practices that were more consistent with U.S. pesticide
                      requirements, while the practices of the less experienced export growers
                      in the other countries—Guatemala, Costa Rica, and the Dominican
                      Republic—usually did not. The following sections discuss, for each type
                      of grower, the extent to which pesticide management practices that con-
                      sider U.S. requirements had been or were being used.


                      According to the five multinational firms we contacted in Chile, Costa
Multihational Firms   Rica, the Dominican Republic, and Guatemala, management practices
                      were in place to help ensure that their exported produce meets U.S.
                      safety and quality standards because U.S. detention of their produce
                      could result in serious revenue loss. The commodities they export, such
                      as bananas, pineapples, melons, apples, grapes, and peaches, are grown
                      either by the firms' employees on company-owned land or by contract
                      growers. These firms generally Implement management practices
                      through internal controls, These controls Include pest control pians
                      based on U.S. pesticide regulatory Information and monitoring practices
                      to ensure compliance with the plans,


                      Page 8»                                     GAO/HCBD-ao-SB Safety and QuaUty of Imported Produc*



                                   i^aaaMtm^tmimmummmmidtMmimmiiiit
                               Chapter 3
                               Private Sector Efforte in Five Foreign
                               Countries to Meet U.S. Safety and
                               QuaUty Requirements




Information on U.S. Import     Each of the five multinational firms had written pest control plans that,
                               according to their officials, were consistent with EPA pesticide standards
Requirements Is Applied in     for commodities exported to the United States. Four of the firms had
Pesticide Management           used U.S. regulatory information on U.S. pesticide requirements, and the
Plans                          fifth had used technical publications, to develop and update their writ-
                               ten plans. These plans, which deal with anticipated pests and disease,
                               cover each crop the firms handle and .specify the chemicals permitted,
                               dosage, frequency of use, and preharvest interval.

                               For example, one multinational firm exporting bananas and pineapples
                               from Guatemala and Costa Rica provides lists of approved chemicals in
                               its operating manual. According to the manual, the lists are beised on
                               EPA'S regulations. The firm requires its technical division in the United
                               States to approve, in advance, all pesticides used, including those used
                               in emergency situations, such as an unanticipated outbreak of a pest or
                               disease. The operating instructions specify how each pesticide should be
                               used for each crop, including dosage and preharvest intervals. Officials
                               of another multinational firm, which also u.ses U.S. pesticide regulatory
                               information, told us that the firm's agronomists, during their twice-
                               weekly monitoring of all growers, specify changes in how pesticides
                               should be used according to the firm's approved list.


Multinationals' Controls       The multinational firms we contacted had controls o\'er acquisition and
Over Pesticide Use             use of pesticides applied to their expoit, crops. Their officials told us
                               that the firms also supply pesticides used by their contract growers,
                               arrange sources of purchase, or apply pesticides for them. Further, they
                               said the firms provide access only to pesticides KVA has approved for use
                               on the export crops and according to the written pest control plans they
                               provide to growers. Tlu^y also employ agronomists to supervise employ-
                               e(>s' and contract growei's' implementation of the approved pest control
                               plans. Additionally, while recoixlkeeping methods (including u.se of
                               votiehois, warehou.se receipts, diary notes based on direct ol)servation,
                               and grower-signed s|)raying receipts) used to monitor pesticide access
                               and use varied among the firms, all met hods tied (he pesticide u.sed to
                               till- crop and application date.


Multinationals' Use of         OITii'iatsol'oiily one iniillinalional firni told us that il regularly te.sis its
Pesticide Re.«5idtie Testing   coiiiniodilics lor pcslieide residues, Ilowever. representalivesof .sonieof
                               I lie ot hers said t hat (heir lii'ius obtain peslicide residue testing under
                               ccrlaiii loiiditioiis, such as when (hey chiinge wrideii p(>s( eoiUrol |)lans,
                               lociisiire Iheir Iresli piodiire meets U,S, pesticide requirements. Overall.


                               I'flgo to                           (•AO K( KniMMlA Snfoly nnd Qiinilty of liniMtrtod l>nMliic<>
                         Chapter 3
                         Private Sector Efforte in Five Foreign
                         Countries to Meet U.S. Safety and
                         QuaUty Requiremente




                         these firms depend on good agricultural practices resulting from their
                         internal controls to ensure that their exports meet U.S. pesticide
                         requirements.

                         However, the representatives told us that when they obtain residue test-
                         ing, they use laboratory services outside the exporting country because
                         expeditious service is unavailable within their countries. Therefore, if
                         residue testing is needed, the produce generally is not tested before ship-
                         ment. For example, the president of one multinational firm in Guatemala
                         told us that the firm cannot get residue testing done in Guatemala in less
                         than 3 weeks. Therefore, when residue testing is necessary, the firm
                         obtains it in the United States after shipment.


Multinationals' Use of   According to their representatives, most of the multinational firms work
Quality Controls         toward quality standards set by the company. The representatives said
                         that these standards were dictated by customer preferences and were
                         related primarily to a commodity's size and appearance.


                         Other experienced export growers that we spoke with were affiliated
Other Experienced        with older, national exporter/grower associations and tended to have
Export Growers           management practices in place that help them meet U.S. safety and
                         quality requirements. We identified these types of growers in Chile and
                         Mexico, where most export growers belong to such associations. How-
                         ever, grower implementation of these practices varied between the two
                         countries and among the growers in Mexico.

                         Like multinational firms, more of these growers (than of the less expe-
                         I'ienced export growers we visited) used management practices that
                         address U.S. safety and quality requirements, primarily because of the
                         economic incentive—52 percent of Chile's and about 90 percent of Mex-
                         ico's produce exp')rts go to U.S. markets. The expoiter/grower associa-
                         tions in Chile and Mexico provide the experienced growers with a
                         variety of services designed to ensure that their members meet their
                         export markets' import I'equirements. These services include
                         (1) obtaining information on I ',S, requirements and (2) providing techni-
                         cal assislance, such as developing i)es( con(rol plans, assisting with resi-
                         due testing, and |>roviding quality inspections.




                         Page 41                             (iAO/K( El) Wl nn Mafety and Qunlily of InuMirted Produce
w^
                          Chapters
                          Private Sector Efforte in Five Foreign
                          Countries to Meet U.S. Safety and
                          QuaUty Reqidremente




Most Mexican Export       In Mexico, the government requires its export growers to be members of
Growers Are Assisted by   either UNPH or another exporter organization registered with the Mexi-
                          can government. According to its president, most export growers are
the Confederation of      members of UNPH. UNPH provides its members with many of the
Growers Associations      resources necessary to meet U.S pesticide requirements. According to
                          Mexican government and UNPH officials, the Mexican government relies
                          on UNPH and its regional associations to ensure that export growers meet
                          U.S. pesticide and quality requirements.

                          To help meet this goal, UNPH provides its export growers with services
                          ranging from providing information on which pesticides are legal in the
                          United States on Mexico's export crops; to written pest control plans,
                          such as spray schedules; to monitoring of use through residue testing.
                          UNPH'S level of assistance, however, is not the same across all export-
                          growing areas. For example, it provides written pest control plans and
                          residue testing to areas that have less access to U.S. information and
                          that have experienced export problems. It also provides residue testing
                          in areas that export the most produce.

                          Until sometime in 1988, the Mexican government had assigned UNPH the
                          authority and responsibility for issuing export permits for fruits and
                          vegetables. This authority had allowed UNPH to impose quality and pesti-
                          cide use controls by making adherence to lists of U.S.-approved pesti-
                          cides for use on export crops a condition for issuing an export permit.
                          UNPH and Mexican government officials told us that, given this author-
                          ity, UNPH had controlled about 97 percent of Mexican exports through
                          conditions stated in the export permits.

                          In November 1988, however, UNPH'S president reported at UNPH'S
                          national convention that government policy had shifted from a system
                          with controls and regulatory mechanisms over planting and exports to a
                          more decentralized system. He also reported that the government was
                          no longer requiring the export permits previously required for all
                          exported crops. In July 1989 UNPH'S U.S. manager told us that this policy
                          change had resulted in an increase in "bad produce" being shipped to
                          the United States by small, inexperienced domestic growers, which
                          depressed prices and hurt Mexico's image as a produce exporter.

                          UNI»H also works on the regional level in Mexico tt) solve export prob-
                          lems, It has established regional associations In 24 of the 32 Mexican
                          .states. The 24 regional associations represent 214 local unUms wtth
                          about 20,000 fruit and vegetable export growers.



                          Page 48                             GAO/RCKDIN)B5 Safety and QuaUty of Imported Produce
                                                                                                                          "1


                                Chaptei'3
                                Private Sector Efforts In Five Foreign
                                Countries to Meet U.S. Safety and
                                QuaUty Requiremente




                                UNPH reported that the top five Mexican exporting states (in order of
                                exported volume, Sinaloa in western Mexico, Baja California and Sonora
                                in northwestern Mexico, and Michoacan and Tamaulipas in central and
                                northeastern Mexico) were responsible for over 85 percent of Mexico's
                                fruit and vegetable exports in the 1986-87 growing season, and 84 per-
                                cent in the 1987-88 growing season, with Sinaloa accounting for 48 per-
                                cent and 45 percent, respectively. In addition, according to their regional
                                association, Sinaloa growers produce about half of all vegetables
                                exported to the United States during the winter vegetable season.

                                According to UNPH officials, export growers in the western, northwest-
                                ern, and northeastern states tend to be more sophisticated and well-
                                educated and have large landholdings; export growers in the central
                                state are generally less sophisticated and educated and farm smaller
                                areas of 10 to 20 hectares.


       UNPH Provides            According to its officials, UNPH gathers information on the most current
       Information on U.S.      U.S. pesticide regulations and distributes it to export growers to facili-
                                tate exports and decrease rejections of Mexican produce at the U.S. bor-
       Pesticide Requirements   ders. The officials said that UNPH recognizes that many export growers
                                in northwestern Mexico are physically close to the United States and
                                therefore have easier access to direct sources of information on U.S.
                                requirements. Nevertheless, UNPH supplies information on U.S. stan-
                                dards to all Mexican export growers to ensure that they have access to
                                accurate information. According to the officials, UNPH'S primary source
                                of information on U.S. pesticide requirements is a Washington, D.C.-
                                based industry representative.

                                Regional UNPH associations distribute information on U.S. pesticide
                                requirements to local grower unions and individual growers primarily
                                through the wall chart, mentioned in chapter 2, which details all chemi-
                                cal/crop combinations and corresponding U.S. residue tolerances for
                                Mexican export crops, FDA'S Los Angeles district pesticide coordinator,
                                who examined the chart, told us that the chart is accurate, with one
                                exception: omethoate, which does not have a U.S. registration or toler-
                                ance, was listed as legal on major export crops, such as bell peppers,
                                tomatoes, and cucumbers. i't)A detected illegal omethoate residues on
                                some Mexican shipments sampled at the U.S. border In 1988, ahd many
                                Mexican shipments were refused entry, FDA officials estimated losses to
                                Mexican exporters/growers at over $40 million. Mexican government
                                officials told us that they would seek U.S. tolerances for omethoate and



                                Page 48                             OAO/RCRD-OOSn BafKty and QuaUty of Imported PTOdue*


^.1.
                                 Chapters
                                 Private Sector Efforte in Five Foreign
                                 Countries to Meet U.S. Safety and
                                 QuaUty Reqidremente




                                 other chemicals specifically required for production in the Mexican
                                 environment.

                                 UNPH also distributes information on changes to EPA regulations through
                                 monthly newsletters. For example, UNPH'S January 7,1988, newsletter
                                 announced that a temporary U.S. tolerance of 7 parts per million for
                                 tiodicar (an insecticide) on broccoli became effective in October 1987.

UNPH Provides Sonte Written      In Mexico's more sophisticated export states, such as Sinaloa, Bjya Cali-
Pesst Control Plans              fornia, and Sonora, growers routinely develop their own spray schedules
                                 using the information provided in the wall chart. However, UNPH has
                                 developed and distributed standardized spray plans for its members in
                                 some of Mexico's less sophisticated export states.

                                 For example, the regional UNPH association distributed a spray schedule
                                 for growers in Zamora, Michoacan, who grow strawberries exclusively
                                 for export to the United States. The spray schedule was based on infor-
                                 mation in the wall chart. It detailed the strawberry pest or disease to be
                                 treated with each pesticide, the proper mix, and dosage rate. We found
                                 that the spray schedule's information agreed with U.S. regulations for
                                 strawberries.


UNPH and Mexican Export UNPH officials told us that they do not routinely monitor export growers'
Growers' Controls Over  selection and use of pesticides in Sinaloa, Baja California, and Sonora—
                        except for random field sampling for residue testing in Sinaloa—
Pesticide Use           because growers in these areas are very experienced and have access to
                                 technical assistance needed to meet U.S. requirements. The officials
                                 said, however, that in the central export-growing areas, such as Michoa-
                                 can, where technical assistance is not readily available, the local UNPH
                                 associations provide assistance, such as purchasing pesticides that meet
                                 U.S. requirements and reselling them to export growers, UNPH officials
                                 said that they believe that this assistance provides an economical source
                                 of pesticides for smaller export growers and encourages the use of pesti-
                                 cides that are legal in the United States on Mexican exports, UNPH offi-
                                 cials acknowledged, however, that these growers still have the option of
                                 obtaining pesticides from local suppliers.

                                 Use of pesticide purchase and application records varied among the
                                 export growers we talked with. Export growers in Michoacan and
                                 Tamaulipas tended to not have purchase and application records. UNI»H
                                 grower members in Baja California and Sinaloa, however, told us that


                                 Page 44                             UAU/RCRD-90-B6 Salety and QuaUty of Imported Produce
                                  Chapters
                                  Private Sector Efforte In Five Foreign
                                  Countries to Meet U.S. Safety and
                                  QuaUty Requiremente




                                  they track their pesticide application by using logs and diaries to note
                                  their choice of pesticides and the fields treated.

UNPH's Use of Pesticide Residue   UNPH provides preexport residue testing in two of the four exporting
Testing                           states we visited, Michoacan and Sinaloa. According to UNPH officials,
                                  this testing is provided because Michoacan growers have experienced
                                  pesticide residue problems in the past, and Sinaloa accounts for almost
                                  half of Mexico's exported produce to the United States. The officials
                                  said that growers in other major exporting states, including Bsua Califor-
                                  nia and Tamaulipas, obtain residue testing at their own discretion. Dur-
                                  ing the 1987-88 growing season, UNPH performed about 1,300 preexport
                                  residue tests for strawberry growers in Michoacan and about 1,000 for
                                  growers in Sinaloa.

                                  In Michoacan, where one of the primary export crops is strawberries,
                                  UNPH relies on private laboratories and limits its testing to two pesti-
                                  cides—azodrin and monitor—that it knows growers are likely to use but
                                  that are illegal for use on strawberries in the United States. The local
                                  association president told us that UNPH expelled 12 growers during 1988
                                  because the laboratories found residues of the 2 chemicals, UNPH denied
                                  export permits to these growers for shipments containing violative
                                  residues,

                                  UNPH officials told us that in Sinaloa, Mexico's major exporting state,
                                  UNPH performs a broader range of testing. These officials said that they
                                  try to identify residues of 50 commonly used pesticides using FDA'S
                                  multiresidue method, which identifies a number of pesticide ingredients
                                  in a single procedure, UNPH has a laboratory in Sinaloa dedicated to pes-
                                  ticide residue testing of export crops and staffed by an FDA-trained tech-
                                  nician. The laboratory performs field sampling at harvest and provides
                                  follow-up testing if growers receive FDA violations.

UNPH'S Efforts to a)ntrol         U.S. importers of Mexican produce contract with USDA'S Agricultural
Quality of Mexican Export Crops   Marketing Service to grade UNI'H growers' produce at the U.S. entry
                                  point, primarily in Nogales, Arizona, according to an AMS official. AMS*
                                  district manager in Nogales told us that In recent years UNPH required
                                  that about 80 percent of the produce meet U.S. No. 1 grade require-
                                  ments. According to UNPH'S U.S. manager, the exporters, together with
                                  their U.S. partners, where they exist, determine what the quality of
                                  exported pioduce should be, largely on the basis of their knowledge of
                                  the United States' or other marktHs' quality requirements and changes
                                  in consumer demands.


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                                    Chapters
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                                    QuaUty Reqidremente




                                    In December 1988 USDA reported that the Mexican export licensing
                                    requirement for fresh fruits and vegetables had been dropped, and in
                                    September 1989 UNPH informed AMS' district manager in Nogales that
                                    UNPH would not require minimum inspections for the 1989-90 growing
                                    season, UNPH was previously authorized by the Mexican govemment to
                                    issue export permits for horticultural products. During the time UNPH
                                    had authority to issue export permits, it used the requirements stated in
                                    the permits to control its grower members' attention to quality. Accord-
                                    ing to UNPH'S president, UNPH tried to compensate for the loss of control
                                    over export permits by increasing its physical presence at border cross-
                                    ings with the greatest problems and documenting all export shipments
                                    with a new form.

                                    According to AMS estimates, almost half of the fresh fruit and vegetable
                                    imports from Mexico from 1985 through 1987 were required to meet
                                    minimum quality standards under U.S. marketing order legislation. Most
                                    of the inspected produce was tomatoes—averaging over 810 million
                                    pounds a year. Other AMS-inspected produce included onions, limes, table
                                    grapes, oranges, and grapefruit.


Chilean Export Growers              The Chilean exporters association (Asociacion de Exportadores de Chile
Are Assisted by Their               A.G.) facilitates the export process for Chilean fruit and vegetable
                                    exporters/growers and tries to ensure that Chilean growers use manage-
National Exporters                  ment practices that help them meet their export markets' requirements.
Association                         The association's executive director told us that its members handle
                                    about 95 percent of all Chilean fruit and vegetable exports. The associa-
                                    tion provides information on the import regulations of Chile's export
                                    markets, which augments information exporters have obtained indepen-
                                    dently. The association also provides pest control plans for certain
                                    export fruit crops, such as grapes and tree fruit.

                                    According to government officials, Chilean exporters contract with
                                    growers for production of export commodities and include provisions
                                    for controlling pesticide use in the contracts. The Chilean exporters we
                                    spoke with ahso monitor grower selection and use of pesticides and
                                    arrange residue testing when needed.

Chile's Exporters A.s.s(.)ciation   The Chilean exporters association gathers information on cui'rent U.S.
Provides Information on U.S.        pesticide requirements and distributes it to exporters and export grow-
Requirements                        ers. It also funds I'osearch on pesticidi! use in Chile to determine what
                                    constitutes good agi-icultural praitices in Chile's climate.



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 I!W«S"




                                Chapter 3
                                Private Sector Efforte In Five Foreign
                                Countries to Meet U.S. Safety and
                                QuaUty Requiremente




                                The association obtains information on U.S. regulations from FDA, ERA,
                                the Chilean government, and the Chilean representative to Codex. At a
                                1986 association seminar, for example, FDA and ERA officials presented
                                information on U.S. laws governing pesticides, FDA'S policies and proce-
                                dures for regulating pesticide residues in imported foods, ERA'S registra-
                                tion and tolerance-setting procedures, and steps that Chilean authorities
                                should take to ensure that Chilean produce exports meet U.S. pesticide
                                requirements. According to the Director of FDA'S Contaminants Policy
                                Staff, the Chilean organizations were committed to and had the capabil-
                                ity for ensuring that pesticide use on produce destined for U.S. markets
                                would conform with ERA'S requirements.

                                Since 1980 the association has summarized information on U.S. pesticide
                                requirements and annually published and distributed a manual identify-
                                ing pesticides, residue tolerances, and preharvest intervals allowed on
                                fruit crops exported to the United States. Information on regulations in
                                Chile's other export markets, primarily Europe and Japan, was added in
                                1984. We found that the pesticide recommendations in the 1987-88 man-
                                ual agreed with U.S. tolerances. The manual also indicated available
                                pesticides that are not registered in the United States.

                                Until recently, the association published information needed by fruit
                                exporters only. Association officials told us that the association was
                                planning to expand its programs to serve vegetable growers as well.

                                To further ensure that Chilean exports meet U.S. requirements, the
                                association funded university research to determine if residues resulting
                                from use according to label instructions are the same in Chile as in the
                                United States. The studies showed that several pesticides left residues
                                for longer periods of time when used in Chile. As a result, the associa-
                                tion modified the manual's guidelines for several pesticides, lengthening
                                the preharvest period, to ensure that residues do not exceed U.S.
                                tolerances.

Chile's Exporters Association   The Chilean exporters association contracts with an expert at the Uni-
Develops Pest Control Plans     versify of Chile to develop pest control plans for each of Chile's major
Based on U.S. Standards         export crops destined for the United States, These plans are available to
                                all expoiters and gi'owers free \\\n)n request, At;coi"ding to the five
                                exporting linns we contacted, which accounted for about 42 percent of
                                Cliile's exports in 1987, the fiiins hud received tho information and
                                spray plans from the associatiim and had providtnl their growers with
                                pest control plans that met I ',S. standards for commodities grown for
                                the U.S. iiuuket. In their contracts, tho.se exporters roquli'o growers to


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WWI



                                   Chapter S
                                   Private Sector Efforte In Five Foreign
                                   Countries to Meet U.S. Safety and
                                   QuaUty Requiremente




                                   follow these plans. The pest control plans we reviewed identified the
                                   pest or disease to be treated with each pesticide for each crop and the
                                   dosage rate. The plans also provided alternative treatments that con-
                                   form to U.S. requirements.

Chilean Exporters' Controls Over   Chilean exporting firms told us that they routinely monitor selection
Pesticide Use                      and use of pesticides by their contract growers through their agrono-
                                   mists, who regularly supervise up to 15 growers each. Growers are
                                   required to follow a firm's spray plan unless a substitution is approved
                                   in writing by the agronomist. Records of 16 growers growing for 4 of the
                                   5 firms showed that the firms' agronomists had supervised growers
                                   weekly during the early growing season and more frequently during the
                                   harvest period to ensure implementation of the spray plans. The other
                                   firm, a cooperative, has its agronomists visit its growers about every 2
                                   weeks.

                                   Representatives of Chile's Chemical Producers Association told us that
                                   75 percent of all agricultural pesticides used in Chile are supplied to
                                   growers by exporters. Some of the remaining 25 percent are purchased
                                   directly with growers' own funds; the rest are charged to an exporting
                                   firm's account by its growers. This firm is one of the multinational firms
                                   we contacted. Because growers can charge chemicals only on the firm's
                                   authorized list, they obtain only approved chemicals from this source.

                                   The 21 Chilean export growers whose records we reviewed also kept
                                   records of pesticide purchases and application information. The agrono-
                                   mists told us that they monitor field production, including checking
                                   growers' application records, to ensure that only approved pesticides
                                   are used.

Chilean Exporters' Use of          The Chilean exporting firms told us that they do not routinely test fruit
Pesticide Residue Testing          for residues before export but rely on their other management practices
                                   to ensure that U.S. safety and quality requirements are met. They
                                   arrange pesticide residue testing if they have problems during the grow-
                                   ing season, such as a need for later-than-normal spraying. For example,
                                   the largest fruit exporting firm in Chile told us that it sometimes uses
                                   three laboratories for intermittent testing, SGS and NutriClean in the
                                   United States and Fundacion Chile (a quasi-government institutitm) In
                                   Chile. According to a firm representative, the produce is not shipped if
                                   violative residues are found. The other expoi'ting fii'ms told us they sim-
                                   ilarly arrange residue test ing if n(?edt?d.




                                   Page 48                             (iAO/RCKI) IN) nn Safety and QuaUly of lmp«»rted Produce
                             Chapter 3
                             Private Sector Efforte In Five Foreign
                             Countries to Meet U.S. Safety and
                             QuaUty Requiremente




Chilean EJxporters' Use of   According to Fundacion Chile officials and representatives of the firms
Quality Controls             we spoke with, Chilean growers have a variety of quality controls in
                             place. Fundacion Chile officials told us that Fundacion Chile performs
                             quality control inspections on 10 percent to 12 percent of all Chilean
                             export produce and that Fundacion Chile's standards exceed Chile's
                             domestic quality standards. This produce is marked with a quality certi-
                             fication seal. In addition, an APHIS official in Chile told us that Chilean
                             exporters use AMS' voluntary inspection service during periods when
                             U.S. marketing orders are not in effect.

                             According to AMS estimates, about 19 percent of the fresh fruit and vege-
                             table imports from Chile from 1985 through 1987 were required to meet
                             minimum quality standards under U.S. marketing order legislation. Most
                             of the marketing order-related inspections were for table grapes—aver-
                             aging about 110 million pounds a year—but also included avocados and
                             onions.


                             In Costa Rica, the Dominican Republic, and Guatemala, which have a
Less Experienced             shorter history of exporting fruits and vegetables to the United States
Export Growers               than do Mexico and Chile, most export growers, other than multi-
                             national firms growing traditional high-volume export crops, are new to
                             the export business and are affiliated with relatively new national
                             associations.' These less experienced growers tend not to have manage-
                             ment practices in place that specifically consider U.S. safety and quality
                             requirements for their export crops. They have fewer resources, includ-
                             ing fewer sources of information on U.S. pesticide requirements, and the
                             information they obtain may be inconsistent or inaccurate. The less
                             experienced growers that we contacted in these countries had small
                             farms, usually under 100 acres, and grew lower volume nontraditional
                             and specialty export crops, such as Chinese vegetables, cauliflower,
                             strawberries, melons, and chayote—mostly for the United States.

                             Officials of these countries' grower/exporter associations indicated that
                             they were seeking and developing information on U.S. lequirements to
                             provide to their export growers, in these countries, export growers were
                             experiencing significant difficulty in exporting certain crops to the
                             United States because of a lack of information on U.S. pesticide require-
                             ments and because, in many castas, the United States has not established
                             tolerances for pesticides used on these crops.

                             ' Kor oxaiiiiilo, (iimiomata's iialluiial lowiuiiitkm, tJUl'lMlAI., wa.s oslahUnluHt In tlW2 ami C<wl« Klctt's
                             tAAI'lii IIIHR,



                             Page 4»                                   UA(>/H«'KI> IM) nn SalVty anri Quality of ImpiMled Produce
                            Chapter 3
                            Private Sector Efforte In Five Foreign
                            Countries to Meet U.S. Safety and
                            QuaUty Requiremente




                            According to AID documents, much of these countries' increajjed agricul-
                            tural efforts grew out of Caribbean Basin Initiative (CBi)^ projects to
                            expand the countries' economies by increasing exports of nontraditional
                            fruits and vegetables primarily directed at the U.S. market. In these
                            countries, most export growers are therefore new to the export business.
                            CBi workshop projects have focused on developing and marketing the
                            crops for export and, according to a USDA official, little attention has
                            been given to providing information on pesticide inputs. According to
                            this official, however, the workshop participants have consistently
                            asked for specific information about what pesticides can be used on spe-
                            cific export crops destined for the United States. As discussed in chapter
                            4, new U.S. AID projects are addressing the exporters' need for U.S. pes-
                            ticide information.


Role of National Grower/    According to association officials, the national grower/exporter associa-
                            tions represent about 80 percent of the export growers in Guatemala,
Exporter Associations in    about 60 percent in the Dominican Republic, and almost all the export
Costa Rica, the Dominican   growers in Costa Rica. These associations, which were established to
Republic, and Guatemala     help expand and improve their countries' agricultural export industries,
                            perform a variety of services, such as providing marketing and financ-
                            ing of exports for their members. However, they do not provide informa-
                            tion on their members' export markets' pesticide requirements or
                            technical assistance in pest management. As previously mentioned, each
                            of these associations was seeking information on U.S. pesticide require-
                            ments at the time of our visits.


New Export Growers in       The export growers, exporters, growei/exporters, and exporter associa-
the Three Countries Have    tions we contacted in the three countries said that they had insufficient
                            sources of information on U.S, pesticide requirements. While the Guate-
Limited Information on      malan and Costa Rican as.sociations had some commercial pestit;ide pub-
U.S. Pesticide              lications, only one publication showed U.S. pesticide requirements. None
Requirements                of the associations had official U.S, governmeiU sources of information,
                            such as ERA'S regulations on pesticide tolerances.

                            Most tjxpoit growers we conlai'ted in Guatemala and Costa Rica said
                            that they had received .some information from I I.S. contacts or commer-
                            cial publications; however, none of (he growers said that tliey had

                            •Tho IIIHII Cailhlioaii llaslii I'li.diHtiiiii' Uoonvciy Aoi i IM,. !l8-(i7,117 Slat, ,'.IHI) |irovltlod now t.railo and
                            lux iiioii,siii'o,s to pll IMM lie I'd till Hiiir i'i>viliili/,iiliiiii iind |,\|iiiiiilod pi'lviilo ,Mootoi'(i|i|ioi1uiillloK In Iho
                            (.'ai'llihoiin IIIIMIII rufiimi. AICILS invri'od in lhi,s inii inl ivo iiiilndi.' llir(,'iu'llilioiin tslanil ual IOHN imd
                            (Viitral Aiiioilcn.




                            Pago no                                            (iAO/H( El)(N)nnSnl^'ty ami Qunlily of ImiMirli'd IViNluce
ripp-
                                     Chapters
                                     Private Sector Efforte in Five Foreign
                                     Countries to Meet U.S. Safety and
                                     QuaUty Requiremente




                                     access to official U.S. regulatory sources of information. In the Domini-
                                     can Republic, the growers told us that they did not have information on
                                     U.S. requirements. At the time of our visits, the association in each
                                     country was exploring how export growers and exporters can access
                                     critically needed information on U.S. pesticide requirements.


        New Export Growers Lack      Except for one grower, none of the growers, exporters, grower/export-
        Written Pest Control Plans   ers, or exporter associations we contacted in the three countries had
                                     developed written pest control plans that reflect U.S. pesticide require-
        That Consider U.S.           ments. They said that they lacked information on such requirements.
        Requirements                 However, over half the growers, exporters, and grower/exporters told
                                     us that they used the practice of preplanning what pesticides would be
                                     used on their export crops. Of the 12 growers, exporters, and grower/
                                     exporters we contacted in these countries, 5 had developed plans and 7
                                     had developed lists to guide the selection and use of pesticides. How-
                                     ever, only 1 of the 12, an exporter, had a plan consistent with U.S. pesti-
                                     cide requirements. Others' plans or lists included one or more pesticides
                                     that are not approved for use on the specific crop being grown for
                                     export to the United States.

                                     The exporter associations also had not deveU)ped pest control plans to
                                     improve the use of pesticides by growers of nontraditional export crops.
                                     Nonetheless, officials of the Dominican Republic and Guatemalan
                                     associations told us that they would provide such assistance to their
                                     members if they could obtain official information on U.S. rules.


        New Export, Growers'         Of the 12 groweis, exportei's, and grower/expoiters we contacted in the
        Controls Over Pesticide      3 countries, 8 told us that they monitored pesticide application to some
                                     extent; however, as with the pest control plans di.scusst?d above, they
        Use                          said thai U.S. pesticide requirements did not form the basis of such mon-
                                     itoring. About half the growers we talked with maintained pesdcide
                                     application recoids, inchiding charts, diaries, and agronomists' recom-
                                     mendation records; and about two-thirds of the growers, exporters, and
                                     grower/exporters (old us (hat they were periodically advi.sed by an
                                     agronomist.


        New Export Growers' Use      Tlie 12 growei's and ex|»oi'l('rs we contacted in the 3 coimtrii's told us
        of Pesticide Residue         dial they generally had not obtained residue (esi ing before exploiting
                                     (heir crops, primarily because of a lack of timely acivss (,o adequa(ely
        Testing                      eqi;ip|)ed laboratories.


                                     i>Hgoni                             (jAO/KCKti-WinnHnlVty nuriQuaUty of lin|N>rlwd l>nMlttc«
               Chapter 3
               Private Sector Efforte ih Five Foreign
               Countries to Meet U.S. Safety and
               QuaUty Requiremente




               In the Dominican Republic, government officials told us that neither
               government nor private testing laboratories vvere available for export
               growers' use. They said that because of a lack of supplies and equip-
               ment, their government's laboratory had been inoperative since Septem-
               ber 1986.

               In Costa Rica and Guatemala, limited laboratory services were available
               to produce exporters from government or government-sponsored labora-
               tories for residue testing on a fee-for-service basis. However, our discus-
               sions with some laboratory personnel in these countries indicated that a
               small number of tests had been conducted for produce exporters. Offi-
               cials of the National Pesticide Commission in Costa Rica told us that the
               Commission was exploring ways to provide residue testing services for
               exporters and others.


Observations   Multinational firms in the five countries and experienced exporters in
               Mexico and Chile had the most management practices in place that take
               into account U.S. pesticide requirements. Most importantly, these firms
               and exporters had significantly more information available on U.S. pes-
               ticide requirements and had mechanisms in place to ensure that such
               information was updated.

               The export growers in Costa Rica, the Dominican Republic, and Guate-
               mala, except for the multinational firms, are less expeitenced in export-
               ing fruits and vegetables to the United States. While these countries'
               export volumes are expected to increase, they had minimal practices in
               place to ensure that U.S. pesticidt; requirements are met. These export-
               ers had some management practices in place to monitor pesticide use to
               some degree. However, the practices offered little assurance that their
               export crops would meet U.S rt;quirements because, in almost all situa-
               tions, thtjse export growers and exporters lacked information about pes-
               ticides allowed on those fruits and vegetables in the United States.

               Because increased exports of IVuits and vegetables are planned in these
               countries, and as KDA implements provisions of the Pesticide Monitoring
               Improvements Act of 1988, a failure to meet U.S. pesticide requirements
               may jeopardize the ei:onomic growth of these countries and the success
               of U.S. projects planned (o iiicreiise noii(,raditional agricultural exports
               in (hese countries, At (he time of our visits, export growers, exporters,
               and e\f.w»rter ntis<)dnti<ms in these cvutHrios wove .seeking information




               Page H'i                            GAO/KCKI)IHinnSafiMy and Qunlily of lm|M»H«<l VfwWitt,
Chapters
Private Sector Eflbrte in Five Foreign
Countries to Meet U.S. Safety and
QuaUty Requiremente




on U.S. requirements. In addition, U.S. agencies were expanding differ-
ent types of assistance, which should prove timely to these efforts. (See
ch. 4.)

To the extent that export growers and exporters use the pesticide man-
agement practices mentioned in this chapter—particularly obtaining
and following information on pesticides allowed on export crops to the
United States—the United States will be less likely to experience illegal
pesticide residues on fruits and vegetables presented for import from
these five countries. Further, consumers will have better assurance that
only pesticides with approved U.S. tolerances have been used in produc-
ing imported produce.




Page 88                            «AO/RCRI>4)aft8 Safety and QuaUty of Imported Prodttco
    r4

U.S. Agencies' Efforts to Assist Foreign
Countries in Meeting U.S. Safety Requirements

                    Several U.S. agencies have provided or are providing pesticide-related
                    training or technical assistance to developing countries, which could
                    influence their abilities to meet U.S. safety requirements on produce
                    exported to the United States. This chapter discusses the efforts of ERA,
                    FDA, USDA, and AID. We did not verify these efforts or evaluate their
                    effectiveness.


                    ERA offers assistance to developing countries through its Offices of Inter-
Environmental       national Activities and Pesticide Programs, conducting workshops, con-
Protection Agency   sultations, and ad hoc training seminars. One objective of these activities
                    is to improve the developing countries' management of pesticides. These
                    activities indirectly contribute to protecting the health and welfare of
                    U.S. citizens when food is imported from these countries.

                    ERA'S primary effort to assist developing countries with pesticide con-
                    trols has been to implement regional workshops developed in collabora-
                    tion with AID, FDA, and such international and regional organizations as
                    FAO and WHO. The workshops are designed to upgrade the technical skills
                    of regulatory and enforcement officials and scientists in developing
                    countries and to facilitate information exchange about key regulatory
                    issues among countries in the region and between these countries' regu-
                    latory agencies, ERA, and other governments and international organiza-
                    tions. According to the Director of ERA'S Developing Countries Staff, one
                    workshop component has also focused on the need for developing a resi-
                    due testing system for exports to ensure that exported foods do not con-
                    tain pesticide residues that could prevent acceptance by the importing
                    country. In addition, he said that workshop officials have provided
                    sources of information about pesticide use and U.S. government contacts
                    for additional information.

                    One workshop was held for the Asia and Pacific region during 1988,
                    with two follow-up workshops during 1989. A woi'kshop for the Latin
                    American region was held in .lanuary/Februaiy 1990.

                    ERA has also offered ad hoc tiaining seminars, consultations, and train-
                    ing on pesticide residue testing to countri(>s on request and has been
                    involved in ongoing programs (o help iini)rove countries' data bases of
                    pesticide inrormation through (he Uni(ed Nations Environmental Pro-
                    gram (i!Ni;i') and I'AO. In addition, it has worked with international orga-
                    ni/vatioiis in regional and global efforts lo improve pesticide use.




                    Page n4                      GAO/K( El) mi nn Hnfety nnd Quality of lm|Miri«>4l Pntduce
Chapter 4
U.S. Agencies' Efforte to Assist Foreign
Countries in Meeting U.S.
Safety Requiremente




ERA'S records indicate that of the 39 foreign visits to ERA during 1987 and
1988 from the 5 countries we contacted, 3 were related to pesticide
issues. The chief of ERA'S analytical chemistry laboratory told us that no
one from the five countries had participated in ERA'S residue analysis
training over *he past several years.

According to an Office of International Activities' document, since late
1986, ERA has divided its approach in assisting developing countries to
develop or improve their pesticide controls. For the poorer nations, ERA'S
approach has been to emphasize collaboration with, and support for,
existing development assistance agencies, particularly within the frame-
work of U.S. development assistance policy through AID. ERA'S technical
service memorandum of understanding with AID, dated February 1988,
identifies a variety of assistance related to environmental issues that
EPA is to provide AID. In addition, ERA is pursuing closer ties with bilat-
eral donor agencies, the multilateral development banks (the World
Bank and regional development banks), and the United Nations Develop-
ment Program.

For rapidly industrializing developing nations, ERA'S approach has been
to provide more direct assistance, including consulting, training, and
information-sharing, via formal agreements and informal arrangements
between ERA and its foreign counterpart institutions. For example, part
of a cooperative agreement with Mexico specifies that each country's
laws and regulations will be enforced, to the extent possible, regarding
transboundary shipments of hazardous wastes and substances, includ-
ing pesticides. It also provides for notifying each other about regulatory
actions to ban or severely restrict pesticides.

Under FiFitA's sections 17(a) and 17(b), Eiv\ is to notify foreign govern-
ments when U.S. pesticide manufacturers export chemicals to their
countries that are not registered for use in the United States and when
ERA cancels or suspends a pesticide's use(s). When governments are
alerted to unreasonable hazards as.sociated with using particular pesti-
cides, they can act to lessen exposure of their workers and citizens. The
United States can benefit when a foreign government restricts using
these harmful or pt)tentially harmful pesticides on crops that are subse-
quently imported into the United States.

Ilowever, as discussed in chapter 2, we reported in April 1989 that ERA
was not eflectively monitoring compliance with Kii'itA's ex|)oit notifica-
tion retiuirements, and we recommended .several actions to lmpn)ve the



Page KH                             GAO/RCKI) im-nn SalVty and Quaiity «>r lmp«»rted Pntduce
                                                     Chapter 4
                                                     VS. Agencies' Efforte to Assist Foreign
                                                     Countries In Meeting U.S.
                                                     Safety Requiremente




                                                     effectiveness of ERA'S program. At the same time, we reported that for-
                                                     eign govemments rely on the United States for information on pesticides
                                                     (1) that the United States has judged to be hazardous to human health
                                                     or to the environment or (2) for which no hazard assessment has been
                                                     made. We concluded that improyements in U.S. notification require-
                                                     ments could protect U.S. imported products when foreign governments
                                                     receive full information on hazardous unregistered pesticides previously
                                                     used on foods produced in their countries and intended for U.S. markets.


Food and DrilS                                       According to the Director of FDA'S International Affairs Staff, FDA does
 . , . .    . ^                                      not have a formal outreach program to assist foreign countries in meet-
AdminiStratlOn                                       ing U.S. pesticide requirements. However, through the International
                                                     Affairs Staff and often in cooperation and coordination with other agen-
                                                     cies and organizations, FDA has provided technical training and consulta-
                                                     tion activities (including training programs funded through FAO, WHO,
                                                     PAHO, or the training recipient's home country) to its foreign government
                                                     counterparts on request. In addition, FDA has provided direct input to
                                                     countries—through contact with the countries' embassies—on FDA
                                                     detention of food from these countries. According to FDA'S Americas'
                                                     Desk Officer, such contacts have been made to identify and resolve
                                                     problems causing detention and to reduce the countries' pesticide
                                                     violations.

                                                    In a February 1988 report to the House Appropriations Committee, FDA
                                                    stated that it uses the training activities and other contacts to stress the
                                                    need for compliance with existing U.S. requirements and to encourage
                                                    the countries to improve their pesticide regulatory controls, FDA also
                                                    described cooperative activities to resolve pesticide lesidue problems.
                                                    These activities ranged from agreements to investigate the source of a
                                                    residue problem to, less frequently, the establishment of a formal memo-
                                                    randum of understanding between the appropriate foreign government
                                                    entity and FDA.

                                                    Examples of FI:)A a.ssistance activities follow:

                                                  • The International Affairs Staff, under the International Visitors Pro-
                                                    gram, coordinates the scheduling of meetings with other agencies
                                                    throughout the Unified States and (he implementation of training. During
                                                    fiscal year 1989, it coordinaled such activities for over 600 foreign visi-
                                                    tors from over 50 countries, including Mexico and Chile,




                                                    Page M                              GAO/RCEI) Wl nn Safttty and Quality of Imported Produce


           MtoaOaiiiidtiiitdmmtiitiJMagiiimkm^^
Chapter 4
U.S. Agencies' Efforte to Assist Foreign
Countries in Meeting U.S.
Safety Requiremente




 FDA pesticide specialists have traveled to several countries, including
 Mexico and Chile, often under U.N. sponsorship, to train foreign pesti-
 cide analysts in analytical methods and to train administrative staff on
the regulatory aspects of FDA'S pesticide program.
An FDA laboratory analyst has provided Costa Rica's Ministry of Health
 with assistance in (1) setting up government laboratories for assuring
 food safety and (2) getting government and industry to work together
on food safety issues. This project is the result of the August 1985 Inter-
American Conference on Food Protection, discussed in chapter 1, at
 which RAHO and FDA agreed to work together to implement projects that
 assist Latin American governments in upgrading their food protection
systems.
 In 1986, at Chilean request, FDA presented information at Chilean semi-
nars about U.S. pesticide laws and FDA policies and procedures regarding
pesticides on imported food and the steps Chilean authorities should
take to ensure that Chilean produce exports meet U.S. pesticide
requirements.
Mexico has requested more FDA laboratory training to assist it in apply-
ing 10 new regional laboratories to food safety testing, according to the
Director, International Affairs Staff, FDA plans to provide the training at
U.S. laboratories.
In 1988 FDA offered to provide the Dominican Republic with whatever
assistance was necessary to resolve extensive residue violations on
imported produce. In early 1989, FDA officials met with officials of the
Dominican Republic's government and export industry to discuss food
products on countrywide automatic detention from the Dominican
Republic because of pesticide residues. They also met to discuss initia-
tives the Dominican Republic's government was planning to remedy the
situation.
In 1989, according to the Director, Intemational Affairs Staff, FDA
assisted AID'S regional office for Central America and Panama in assess-
ing the extent of Guatemala's and Costa Rica's capabilities to perform
laboratory testing on produce exports and identifying actions needed to
improve such capabilities.

According to FDA'S February 1988 report to the IIou.se Approijriations
Committee, FDA has often been called on to provide input, guidance, and
technical assistance to foreign government counter|«irts, foreign private
.sector organizations, and U.N, and other international organizations.
FDA'S interaction with KAO, WHO, the Codex Alimeiitai'insCommi.ssion,
and UNER has ranged from document review to an aitive l(?adership role




Page 87                             GAO/Ht KDIMVnn Salety and Quality of ImiNirted Ihniduce
                     Chapter 4
                     U.S. Agencies' Efforte to Assist Foreign
                     Countries in Meeting U.S.
                     Safety Requiremente




                     in developing analytical guidelines or regulatory principles. For exam-
                     ple, in its leadership role in ajoint WHO/FAO/UNER Global Monitoring Sys-
                     tem, FDA helped prepare a document that provides guidance, particularly
                     for developing countries, on establishing monitoring programs to esti-
                     mate the dietary intake of selected pesticides and chemical contami-
                     nants. In addition, FDA officials told us that FDA has worked with WHO to
                     help set up an international program for chemical safety that serves as
                     an information source for member governments.

                     Like ERA, FDA has cooperative agreements with Mexico. Cooperative
                     agreements executed in 1988 with the Mexican Ministries of Health and
                     Agriculture emphasize the exchange of information on pesticide regula-
                     tions and detention and collaboration on mutual training projects. One
                     agreement calls for (1) mutually developing programs of technical coop-
                     eration to strengthen Mexican food regulation and (2) discussing the
                     harmonization of specifications for chemicals used in or on food.


U.S. Department of   The Private Sector Relations Division of USDA'S Office of International
                     Cooperation and Development (oiCD), as part of its implementation of CBI
Agriculture          programs, assists countries in understanding U.S. import requirements.
                     Agricultural programs under the CBi initiative are designed to promote
                     economic development, two-way trade, and investment in the Caribbean
                     Basin and Central America, and therefore emphasize marketing.
                     The division's principal means of outreach to CBI countries has been the
                     workshops and seminars it has held in the region annually since 1983,
                     which provide information on U.S. standards and regulations and basic
                     marketing information needed by both U.S. and Caribbean Basin entre-
                     preneurs. The Division has also developed the Agricultural Marketing
                     Handbook for Caribbean Basin Products. The handbook provides infor-
                     mation on most of the key U.S. regulatory agencies' activities and each
                     agency's role over safety and quality of imported food. According to an
                     oicD official, the Division's activities and personnel are funded primarily
                     through AID; however, USDA funds an information center and provides
                     the professional expertise.


Agency for           AID tries to assist growers on pesticide use related to agricultural exports
                     in a variety of ways. Through its Regional Office for Central America/
Intemational         Panama (liocAR), it recently began to directly assist developing Central
Development          American countries in meeting U.S. pesticide requirements by dissemi-
                     nating regulatory information about pesticides legal in the United States


                     Page 88                             UAO/RCEI)-(N)B8 Safety and QuaUty of Imported Produce
BSPPW                                                                                                                                               '^



                          Ciiapter 4
                          U.S. Agencies' Efforte to Assist Foreign
                          Countries In Meeting U.8.
                          Elafety Requiremente




                          on nontraditional export crops from Central America, AID is also assess-
                          ing the feasibility of using the Inter-Regional Research Project Number 4
                          (iR-4) Program,' which supports the development of pesticide tolerances
                          for minor crops in the United States, to establish pesticide tolerances for
                          Central American export crops that do not have U.S. pesticide
                          tolerances.

                          In addition, by carrying out environmental assessments, before
                          approval, of AiD-assisted projects involving pesticides, AID has the
                          opportunity to affect the safety of exported produce resulting from its
                          agricultural export projects. These assessments, which are required by
                          AID'S environmental regulations, are to include, among other things, con-
                          sideration of the EPA status of the proposed pesticides.-


    Nontraditional        ROCAP has provided assistance to export growers and exporters in meet-
    Agricultural Export   ing U.S. pesticide requirements through extension of a regional project,
                          Nontraditional Agricultural Export Support, which started in fiscal year
    Support Project and    1986. The project's primary goal is to facilitate economic growth by
    Subproject            expanding nontraditional agricultural exports, including fruits and veg-
                          etables, for Central America and Panama. The project provides assis-
                          tance to export growers through key private sector exporter
                          associations in several countries, including GREMIAI. in Guatemala and
                          GAAP in Costa Rica. Technical assistance and training is to be provided
                          through these associations to the associations' members; local growers'
                          associations; cooperatives; export brokers and sellers; and, to some
                          extent, public sector export personnel. As discussed in chapter 3,
                          exporter associations in some countries have played key roles in increas-
                          ing export growers' abilities to meet U.S. pesticide requirements on
                          exported crops, and the associations in the countries we visited were
                          seeking information on U.S. pesticide requirements for their members.

                          In 1988 ROCAP began a subproject of the Nontraditional Agricultural
                          Export Support project, under which it plans to (1) distribute regulatory

                           ' IThe IR-4 Rrogram Is a natkinwidu ciHiiM.Ttitivo olTiii'l. aiuonii! IJSIJA's (.jxii.ioi'alivo Slaio l<o,s(uircli
                          .Servloo und Agrloiiltural l<o,suaroh .SOITIOO; EI'A; ,sliilo afiili'iillni'iil o\|.K>rlinoiit ^^laiioivs; and Individ-
                          ual ix'uearcliere, manufaoturerH, and (irowo'r,'*, Tlu; iiatlnnal l'.oad(|iiail<.'f,s, at KiUKors t'nivui'sliy. Now
                          Brunswick, Now Jursuy, primarily as!il,st.,>* in dovolnpliix roNoai'oh •nol.in.'ols and. In i'(Ni|MM-ailim with
                          EPA and the manufHoturer of tho ix'Nt.loldo Invnlvod, In iMKonililiiiM iH'iit.iiuiN I'm' |H>Hlioido M'KlHl.rallon,

                          "The conference report (H, Ropt. llll-,')44)oii ihu l'"iirolKiiO|H;iail(Hi,s, KXIHIII. FliiaiioliiK, and Kolatml
                                                                                                                                      IU
                          Programs Appropriations Aot, l»IH)(IM., 1111-1)17. Nov, 2\. IHSDl ii;i|iili'o,'!i All) in study and ir.       ;|Kllt
                          by April 1, 191)0, on thu foufllblllly and tmlonllal IKMIOIIIS DI Joinl roKoinch and oiliioiiMon, Inohidliig
                          ohumloal, biological, and bliilouhiioloxy I'i.'Koaroli, mi aKi'li.'iilliiriil prodilol.lmi In Iho Cai'thhoan roglon
                          (Including the CBI nutlons and tho U.S. ,'<iiilo'< ahiillliiK 1 IK.- (iiill' nl' MoxInD.



                          Page 89                                      GAO/RCl,a»» nn safety and Quality of lmp«>ried Produce
              Chapter 4
              UJS. Agencies' Efforte to Assist Foreign
              Countries In Meeting U.S.
              Safety Requiremente




              information on U.S. import requirements to private and public sectors in
              Central America and (2) provide training to the nontraditional agricul-
              tural exporter associations on how to interpret basic references on U.S.
              regulatory information. This subproject responds to an urgent need of
              export growers in Guatemala, Costa Rica, and other Central American
              countries that have not had ready access to information on U.S. pesti-
              cide requirements for their export crops and risk rejection at U.S. entry
              points because of the information void. (See ch. 3.)

              The subproject offers a direct opportunity for AID to assist export grow-
              ers in determining which pesticides they will use and to ensure that they
              are applied correctly. According to a ROCAP document, ROCAP'S long-term
              goal for the subproject is to have the exporter associations and public
              sector organizations, through the project training, be able to interpret
              the basic EPA references on pesticide regulations and begin to provide
              similar information and updates to export growers. In addition, ROCAP
              intends to build comparable reference files for Canadian and Codex
              (international) regulations regarding acceptable pesticide use and
              tolerances.

              ROCAP accelerated the subproject's development as a result of our
              review, which revealed that exporters and export growers, many of
              whom were growing export crops under AiD-assisted projects, lacked
              critical information about pesticides legal for use on produce destined
              for the United States, ROCAP'S interest ia accelerating the subproject also
              increased because of anticipated increases in FDA monitoring resulting
              from enactment of the Pesticide Monitoring Improvements Act of 1988.
              ROCAP documents stated concern that the potential for violative levels of
              pesticide residues may jeopardize the success of nontraditional crop
              exports—a cornerstone of AID'S developmental strategy in Central
              America—and result in significant economic losses for Central Ameri-
              can exporters and export growers.

Infonnation   ROCAP intends to purchase, for the nontraditional agricultural exporter
              associations to give to growers and for governments, if appropriate, offi-
              cial U.S. govemment and commercial documents that provide informa-
              tion on pesticides with U.S. tolerances that can be used on
              nontraditional crops exported to the United States, UOCAP also Intends to
              develop a pesticide label library for Ei'A-registered pesticides that are
              commonly used in Central America and maintains a complete file of USDA
              grade standards for all fresh produce products and some frozen
              products.



              Page 60                             UAO/RCKD-W)-88 Safety and QuaUty of Imported Produce
             Chapter 4
             VS. Agencies' Efforts to Assist Foreign
             Countries In Meeting U.S.
             Safety Requiremente




             ROCAP has begun to prepare infonnation bulletins, in Spanish and
             English, summarizing information from official U.S. government sources
             and trade publications on EPA-approved pesticides for use in growing
             and processing nontraditional export crops grown in Central America.
             The bulletins that have been prepared emphasize that all products regis-
             tered with EPA are required by U.S. law to carry the label instmctions;
             and they stress the need for "strict compliance" with EPA, FDA, and USDA
             regulations and for purchasing a pesticide product for use on a crop des-
             tined for export to the United States only if it has EPA-registered label
             instructions. One bulletin, dated November 2,1988, and entitled "Pesti-
             cides Approved by the ERA for Use in Growing and Processing Pea Pods
             (Succulent Green Peas) Sno Peas, Snowpeas, Sugar-Snap Peas," includes
             the following information:^

           • A list of the pesticides ERA has registered for use with pea pods in the
             United States, with the names and numbers under which the pesticides
             are registered and the trade names under which they are sold.
           • ERA residue tolerance levels for products approved by EPA for use with
             pea pods, expressed in parts per miUion.
           • A list of pesticides most commonly available in Central America for use
             on pea pods.

             According to the ROCAP project manager, ROCAP had completed 10 of the
             planned 23 bulletins as of May 1989. He estimated that the 10 bulletins
             provide information on 80 to 90 percent of the nontraditional export
             crops destined for U.S. markets, including melons, asparagus, snow
             peas, raspberries, strawberries, okra, limes, squashes, and broccoli. An
             FDA report showed that it had invoked automatic detentions on several
             of these crops in 1988 for the countries we visited.
             In addition to developing the information on EPA-approved pesticides,
             ROCAP intends to provide information on changes in U.S. regulations and/
             or inspection and administrative procedures. It also plans to provide
             Spanish translations of the legal portions of the USDA quality standards
             for fresh produce exported from Central America and Animal and Plant
             Health Inspection Service lists of admissible fruits and vegetables.
Training     KOCAI' planned to provide training in pesticide use management, begin-
             ning in September 1989. AID environmental regulations (22 C.F.R. part
             216) restrict the u.se of AID funds for procuring pesticides—specifically

             •'Wo did nol vorlfy lt>e aoonraoy of Uw Information IttK'AI' Is duvoloplng In Uils pni)M;l; however,
             aocordliig to tho RIKAR pro,juol manager, AID ooordliialed with ERA In developing tho Infoi-matlon,



             Page 61                                aA0/RCBD(N)-88 Safety and QuaUty of Imported Produce
                         Chapter 4
                         U.S. Agencies' Efforte to Assist Foreign
                         Countries in Meeting U.S.
                         Safety Requiremente




                         those EPA designates as "restricted use"' pesticides on the basis of user
                         hazards—until (1) users are made aware of the risks involved with
                         these products and (2) technical assistance is provided, if necessary, to
                         mitigate these risks.

                         ROCAP plans to base the formal training course, which would be provided
                         by a private organization, on training programs used in the United
                         States. This training would be given to private and public extension
                         agents, agricultural chemical company representatives and salesmen,
                         and pesticide manufacturer representatives who not only sell the prod-
                         ucts but also make technical recommendations on pesticide use. Ulti-
                         mately, ROCAP intends to have the national governments certify the
                         curriculum and examinations and issue licenses to recommend or sell
                         pesticides.

                         The training element will cover general aspects of pesticide use; pesti-
                         cide laws; pest biology and identification; pesticide classification and
                         formulations; label comprehension; personal safety; pesticides and the
                         environment; and issues related to specific aspects of pesticide use in
                         Central America, including integrated pest management and pesticide
                         cost calculations, ROCAP'S plan is to train persons to train 300 to 400
                         others within their respective countries, with the training function ulti-
                         mately becoming a function of the universities.


Assisting Developing     In 1988 the Consortium for International Crop Protection (ciCR)'^'
Countries in Obtaining   reported on a study it had prepared for AID on the feasibility of estab-
                         lishing a program to obtain U.S. tolerances for pesticides used on non-
Pesticide Tolerances     traditional export, crops from Central America. As discussed in chapter
                         2, the lack of such tolerances affects some Central American and Carib-
                         bean exporters' ability to export produce to the United States, and no-
                         tolerance violations at U.S. entry points can result in severe economic
                         loss to exporters and growers.



                          'All EI'A olioi.sirioal.imi, dotorinlnod dinliiK llio roKlstralimi pi'oo(!SH, thai a |M-,>«|.loldo, whi^n appllod in
                         aouirdaiico wilh ltn dlrool.lons Inr U,HO, wiirnlng,s, and oaiii.tmis, or in aoooi'danoo with a wldospn^ad
                         luid ooiriiiiDnly rocogiilzod practloi.', and lur ii,>(o,s I'or whioh II IM I'onislt.'i'od, Ho'tionilly ii.'.siili.s in iiiin>a-
                         Muiiublo advurso olTooln on llio onvli'diimoiil, liioliidliiH li\iury lo Uio applioaliir,
                         '^'CICI' li» a iiiiiiprol'll oiganl/.allon t'ornuid In III7H by a group nl' U.S. iiiilvor.Mlilos and I 'Sl.iA I'or tho
                         prlnolpal piiriniso of iLSNlslIng dovolopliiH nallmiH In n>diiolng I'IHIII oiop IOMMON oaiiMod by |II>MI.!I whilo
                         also saroMiiardliig Iho onvlronniont, CICI>'s bitslo goal Is lo advanoo oi'iinmiiloally olTlolonl and onvl-
                         rmiinoiilally souiid (Top protoollmi priiolloos In dovo'lopliigominlrlos.



                         Page A8                                          GAO/RCKDW)-8n SalVty and Quality of Imporied Pniduce
                          Chapter 4
                          U.S. Agencies' Efforte to Assist Foreign
                          Countries in Meeting U.S.
                          Safety Requiremente




                          In its December 12,1988, report, cicp said that an effort could be made
                          to use the iR-4 Program, AID, or ROCAP as a petitioner for obtaining toler-
                          ances for pesticides used on nontraditional export crops that ERA has
                          already approved for use on other commodities. Usually, the pesticide
                          manufacturer is the petitioner. The iR-4 Program's principal function is
                          to obtain tolerances for minor crops in which the manufacturer is not
                          interested because the research and development costs are greater than
                          the possible return to the manufacturer. However, according to an AID
                          official, the iR-4 process is slow moving, has limited funding and staffing,
                          and depends on release of information from the chemical companies.

                          The Consortium identified three pesticide/crop combinations that it said
                          had the most urgent need to be considered under this proposal. They
                          were methamidophos/snow peas, chlorothalonil/strawberries, and
                          thiabendazole/chayote. As of the time we prepared this report, AID had
                          not determined whether to implement cicp's proposal.


Assessment of Pesticide   According to AID regulations, proposed AID projects involving procure-
                          ment and use of pesticides must generally receive an Initial Environmen-
Use in Projects           tal Examination and, in some cases, an Environmental Assessment.
                          Among the several matters to be assessed for each proposed pesticide
                          are (1) its ERA registration status; (2) the requesting country's ability to
                          regulate or control the pesticide's distribution, storage, use, and dis-
                          posal; and (3) provisions made for monitoring the pesticide's use and
                          effectiveness. Additional justification is required when the proposed
                          pesticide has an ERA restricted use provision based on user hazard. In
                          addition, if the project includes a pesticide against which ERA has initi-
                          ated a regulatory action, the regulations require AID to dLscuss the tech-
                          nical and scientific details with the requesting government.

                          In implementing its regulations, AID can assist export growers in meeting
                          U.S. requirements and affect the safety and quality of exported produce
                          resulting from its projects. However, we noted w were told of several
                          problems concerning the regulations. For example, not ajl AiD-assisted
                          projects are subject to AID'S environmental regulations, and AID officials




                          Page All                            GAO/Rt'EI) IN) nn HiiMy and Quality of Imiiorieii IVoduc*
wiwinfifmirm'Tr''^:- '.'—ri




                              Chapter 4
                              U.S. Agencies' Efforte to Assist Foreign
                              Countries in Meeting U.S.
                              Safety Requiremente




                              and a 1988 report by the Committee on Health and Environment" identi-
                              fied several problems affecting the regulations' implementation. Fur-
                              ther, while the regulations require consideration of a pesticide's ERA
                              status, they do not prohibit the use of pesticides that do not have an ERA
                              tolerance established for use on the particular export crop in the United
                              States.

                              Because our review was not directed at evaluating the effectiveness of
                              the federal agencies' assistance efforts, we did not pursue these matters
                              to the degree needed to fully establish their effect or to determine what
                              steps AID has taken or is planning to improve implementation of its envi-
                              ronmental regulations.


Ohservations                  ^^'^' *''^^' ^^^^' ^"^ ^'^ have carried out a variety of activities to assist
                              foreign countries in increasing their pesticide management capabilities.
                              In particular, AID is currently providing Latin American and Caribbean
                              export growers with information on what pesticides have U.S. toler-
                              ances for specific export crops, and ERA is providing guidance in devel-
                              oping pesticide monitoring for their exports. These efforts should prove
                              u.seful in (1) decreasing the likelihood that U.S. consumers receive pro-
                              duce grown with pesticides lacking EPA tolerances for use on specific
                              crops, (2) helping the.se countries avoid no-tolerance pesticide violations,
                              and (3) preventing economic losses to exporters and U.S. importers.




                              ''Thi'l'miiiiiil.t.or wii,s riii'Miod by All), wilh Ihrl'miNorviitloh l''iiiiiidutii)ti, pursuant to.sorlion ril.llKllol'
                              Iho l''m'ol)(ii A^<slslllll(:o nnd Koliilod rio^rains ApprnprliilimiK AoUil' I!IK7( lOO.Stiii. ;|;|.||-L>:III), 'I'ho
                              ('miMorvallmi iMiiiiidiilimi is ii iimi)(iivi'rnnioiilal onvli'miiiioiitiil Ki'< 11111111111 |K>rroriiis ixilioy analysosol'
                              oiiviniiiiiiciiliil l.sNiios, 't'lic ('nniiiilllrr's ri'|Hiil, llp|iiirliillll.K,s In ,'\SSIM1. I lovt'limlnd ('niintrlos III Iho
                              I'rnprr I iso nl' Agrlriilliiiiil mul liidiisliliil I 'hniili'als, was Issiiiil Kob. liCITWy                        '""



                              Page 84                                          GAO/R( ;Ki) DO nn Nal^ly nnd Qunttty of lm|Mirl«>d IVoduce
Chapter 6

Issues for Consideration by the Congress


                      As world trade has expanded, concerns have emerged about the safety
                      and quality of imported food, and more attention has been given to rec-
                      ognizing and dealing with the different and complex food safety and
                      quality standards among nations—particularly for pesticide residues on
                      food. U.S. government and consumer concerns often focus on the
                      increasing imports of produce from developing countries because the
                      level of development of those countries' controls over food production
                      has not always been perceived as providing sufficient assurance that
                      exported produce will meet U.S. requirements and because U.S. import
                      monitoring systems cannot provide a perfect safety/quality screen.

                      Much of the difficulty the five countries we visited had in considering
                      U.S. pesticide requirements related to the absence of U.S. pesticide toler-
                      ances for certain export crops and incomplete information about what
                      pesticides are acceptable for use on produce destined for the United
                      States. The extent to which, and in what ways, U.S. agencies should
                      increase their involvement in dealing with these matters are issues with
                      implications for food safety, U.S. competitiveness, and U.S. agencies'
                      responsibilities and resources.


                      Latin American and Caribbean countries' ability to meet U.S. pesticide
Lack of Established   requirements is exacerbated because the United States has few or no
Tolerances            tolerances established for pesticides used on some crops grown in these
                      countries—in some cases, because these crops are not grown commer-
                      cially in significant quantities in the United States, and I:RA may not
                      have been petitioned to make a hazard tissessment. When export grow-
                      ers are not aware of a specific country's requirements, they may use a
                      pesticide that is not approved i'or use on a certain crop in the importing
                      country, even though it may be allowed for use on another crop or on
                      the same crop in their own country or another country. As discussed in
                      chapter 2, produce destined for U.S. markets may con.sequently contain
                      residues of pesticides that do not; have ERA tolerances and be rejected at
                      U.S. entry points, with economic loss to the expoiting counti'y, its grow-
                      ers, and the U.S. impor* industry.

                      To try to deal with I his isstit!, AID is a.s.se.ssi!ig (lu' feasibility of using the
                      IU I Program, which suppoits the developmeni of pesticide tolerances
                       for minor crops in the Unili'd Stales, to establish pesticide tolerances for
                      Central American export, croijs that do not yet have U.S, pt.'sticidi! toler-
                      ances, Ilowever, as discussed in chapter 4, an AID official told us that the
                      IK 4 process is slow moving, lias limited riinding and si.iffing, and
                      depends on ri,'leii,se of informaiion from the chemical comimnios.


                      Page (in                         GA0/R<;EI) W) nn Nafoty and Quality of ImiMtrled IVoduce
w.

     Chapter 5
     Issues for Consideration by the Congress




     Another effort to try to deal with this issue is the ongoing discussion
     among ERA, FDA, and USDA on whether to increase acceptance of Codex
     maximum residue limits (tolerances) on imported foods. At the time this
     report was prepared, ERA was considering a proposal that it recommend
     that, except in cases involving safety concerns, FDA and USDA accept
     Codex maximum residue limits for imported foods for which the United
     States does not have a tolerance. According to ERA, in its activities
     related to imported food, it seeks to ensure that food coming from other
     countries does not pose risks to the U.S, consumer while, at the same
     time, it also seeks to ensure that foreign agricultural growers and
     exporters do not have an unfair advantage over U.S. farmers.

     The U.N. organizations—FAO, WHO, and Codex—have developed a multi-
     tude of international guidelines, including the Codex international pesti-
     cide residue standards, which many developing countries, in particular,
     depend on when developing their pesticide use and monitoring systems.
     The United States has been active in developing the Codex international
     guidelines and standards and, during the current Uruguay Round of the
     General Agreement on Tariffs and Trade, it has endorsed global harmo-
     nization of pesticide residue standards, through adopting international
     standards and codes of practice, as a way to eliminate nontariff trade
     barriers and facilitate world trade. However, where countries, such as
     the United States, have sophisticated food safety and quality systems in
     place, full adoption of the Codex international pesticide residue stan-
     dards is complicated by the need to reconcile the international maximum
     residue limits with the countries' existing tolerances.

     Dec:iding on the extent to which, and in what ways, U.S. agencies should
     increase their involvemt;nt in establishing tolerances for crops not
     grown commercially in significant quantities in the United States
     involves consideration of several matters. These matters include the
     degree to which establishing such tolerances will affect the safety of
     imported food; the effect on U.S. competitiveness, including the poten-
     tial for increasing foreign growers' and exporters' ability to compete
     with the U.S. agricultural sector; the extent of the U.S. agencies' respon-
     sibility for taking the actions necessary to establish such tolerances;
     who should provide (he financial and other )-e.sources necessary to
     develop the toxicological and other scientific data needed for establish'
     ing such tolerances; and wliel hei' the use of the ii<-4 Program and the
     broader acceptance of Codex tolerances are appropriate ways of getting
     (iilerances established for additionai import crops.




     Page m                             <MO/R(JKI)-K0A8 SaMy and Quality of Imporied IHt)dttGe
               Chapter 5
               Issues for Consideration by the Congress




               As agricultural exports expand and become more important to an indi-
Information    vidual country's economy, attention to the country's export markets'
               pesticide requirements heightens and systems evolve to obtain needed
               information for successful exports. We saw evidence of this evolution-
               ary process in Chile and Mexico, which have been exporting produce to
               the United States for some time and which had established networks to
               obtain necessary information and technical assistance. This progress
               had occurred through cooperative efforts of these countries' govern-
               ments and private sector exporter associations.

               In the other countries, whose growers were less experienced in export-
               ing fruits and vegetables, officials acknowledged the need to obtain
               more information. However, the necessary information networks had
               not been established.

               While several U.S. agencies have provided pesticide-related training or
               technical assistance to foreign countries and have responded to requests
               for information, few agency resources have been devoted to providing
               information on specific pesticide/crop combinations allowed on
               imported food. Recently, however, greater communication with develop-
               ing Central American countries about specific U.S. pesticide require-
               ments by crop has occurred through AID'S regional agricultural export
               support projects.

               The extent to which, and in what ways, U.S. agencies should increase
               their involvement in providing information to I.I.S, trading iiattners is an
               i,ssue that, like the establishment of additional tolerances, involves ques-
               tions of increa.sed food safety, U.S. agencies' authority and responsibil-
               ity, U.S, competitiveness, and funding sources, Forexample, (o what
               extent would providing information to foreign entities enhance the
               safety of imported foodstuffs'.^ What degree of autliorily and res|)ousi-
               bilit;y do U,S. agencies have for providing information to loieign ijnti-
               Lies? To which foreign countries and entities should inlormation l)e
               provided'.' Would increasing the (low of information enhance Coreign
               growers' and exporters' ability to compete with (he US, agriciilttiral sec-
               tor? And who should provide the I'inancial and other resources needi.>d
               to gath«?r and disseminate the information','


               Greiiler global standardization of pesticide tolerances among count ries
TheChdllenge   Ihfoiugli greater acceptance of international standaids could nilimiu.eiy
               improve di'veloping countries' abilities to export and could l'acilit.aU>
               world trade. However, because adoption of iniernal iomil food sa('e(y and


               Pag«^ (17                          GA(,>/RCKI)W)nn.Safety anil Qiinlli„v of lm|Min«>it ihnMiuiv
Chapter 8
Issues for Consideration by the Congress




quality standards is a slow, deliberative process, information exchange
among countries, regarding specific pesticide/crop combinations, will
need to continue to expand and improve to ensure that world trade is
facilitated and that consumers are assured that food imports meet their
countries' pesticide safety requirements.

The extent to which, and in what ways, U.S. agencies should increase
their involvement in establishing import tolerances for additional crops
and in increasing the flow of information on U.S. food safety and quality
standards are issues that will confront the Congress as it deliberates on
both food safety and U.S. competitiveness. Establishing tolerances for
additional crops and increasing the flow of information could help
increase U.S. consumers' assurance about the safety and quality of
imported foods; help provide U.S. consumers with a larger variety of
foods during a greater part of the year; and help developing countries,
many of which are debtor nations, increase their exports to the United
States. These actions could also, however, increase foreign growers' and
exporters' ability to compete more directly with U.S. producers and pro-
cessors and increase U.S. agencies' resource needs.




Page 88                            GAU/RCBO-gO-nS Safety and Quality of Imported Produce
Bl ANK PAGE


Pag«< «»      GAO/RCED-90-8S Safety and QuaUty of Imported Produce
' -^pp^ridixr

 #isticide Use Per Hectare, by Area or Nation


                                                                            Pesticide use
                 Area/nation                                          (grams per hectare)*                      Rank
                 Japan                                                                 10.790                           1
                 Europe                                                                 1,870                       2
                 United States                                                           1,490                          3
                 Latin America                                                            220                           4
                 Oceania"                                                                 198                           5
                 Africa                                                                   127                       6

                 ^One gram equals about .035 ounce.

                 '^Includes Australia, New Zealand, and various Pacific Ocean islands.
                 Source: Bengt V. Hofsten and George Ekstrom, editors, Control of Pesticide Applications and Residues
                 in Food: A Guide and Directory—1986 (Uppsala, Sweden: Swedish Science Press),




                Page 70                                GAO/RCED-W-SS Saflity and QuaUty of Imported Produce
•   •%~'\



            Appiendix II

            U.S, Produce Imports by Region, 1988


                                                                                                            Percent of total
                                                                           Volume (metric tons)                imports
                           Region/country                                    Country        Region          Country Region
                           Latin America and Caribbean                                   5,541,708                          77
                             Mexico^                                        1,795,540                            25
                             Ecuador                                          797,595                            11
                             Costa Rica^                                      676,269                               9
                             Honduras                                         669,682                               9
                             Colombia                                         514,953                               7
                             Chile^                                           421,709                               6
                             Guatemala^                                       261,789                               4
                             Panama                                           185,752                               3
                             Dominican Republic^                               89,914                               1
                             Brazil                                            42,246                               1
                             Argentina                                         25,759
                             Bahamas                                           13,546
                             Venezuela                                         11,741
                             Jamaica                                           11,459
                             El Salvador                                       10,193
                             Other                                             13,561
                           Asia/Middle East                                                   618,725
                           North America
                             (primarily Canada)                                               556,954
                           Western Europe                                                     387,256
                           Oceania                                                              56,177
                           Eastern Europe                                                      '28^22~
                           Africa                                                             ' 4,57'i
                           Union of Soviet
                             Socialist Republics                                                  203
                           Total                                                            7,193,616                         100
                           Note Data Include fruits, vegetables, bananas, and plantains.
                           ''Chile, Costa Rica, Ihe Dominican Republic, Guatemala, and Mexico accounted for 3.^45,221 metric
                           tons, or 59 percent of US. produce imports Irom Ihe Latin American and Caribbean countries In 1988.
                           ' l e s s than I percent.
                           Source: Foroign Agficultural Trade ol the Uniied Stales, Calendar Year 1988 Supplement, Economic
                           Research Service, USDA




                           Page 71                                (iAO/Ki;KI)-IW-88 Safety and QuaUty of Imported Pradvtce
p
    Appendix III

    Federal Agencies Involved in the U.S. Safety
    and Quality Network for Imported Produce

                               The U.S. safety and quality network for imported produce involves sev-
                               eral federal agencies. The primary ones are EPA, FDA, and USDA. These
                               agencies' safety and quality activities, primarily as they relate to
                               imported produce, are discussed below.


                              EPA is authorized to register pesticides and establish pesticide residue
    Environmental             tolerances that all fresh produce and other foods and feeds must meet to
    Protection Agency         be considered safe for the U.S. market.


    EPA Establishes Residue   Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), as
    Standards                 amended (7 U.S.C. 136 et seq.), ERA is authorized to register and rereg-
                              ister pesticide products, specify the terms and conditions of use, and
                              remove unreasonably hazardous pesticides from the marketplace.' In
                              addition, the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended
                              (21 U.S.C. 301 et seq.), authorizes ERA to establish (1) tolerances under
                              section 408(d) for pesticides undergoing registration under FIFKA and
                              (2) import tolerances under section 408(e) for pesticides where there is
                              no registration request under FIFRA and the commodity is being treated
                              outside thie United States, ERA can also grant exemptions to use unregis-
                              tered pesticides when it determines a tolerance is not necessary to pro-
                              tect the public health.

                              If a pesticide is to be used on food or feed commodities or if its use will
                              lead to residues on these products, FFDCA requires EPA to establish the
                              legal maximum acceptable level of each pesticide residue—tolerance
                              level—allowed on each specific food and animal feed, or a tolerance
                              exemption, for both domestic and imported foods. These tolerance levels
                              are set on the basis of data submitted by the petitioner (usually a chemi-
                              cal manufacturer) who is requesting the residue tolerance. The tolerance
                              data include information on the pesticide's toxicity (potential to cause
                              adverse health effects) and residues (amount which may remain in or on
                              food). Tolerances cannot be legally exceeded and no residue of a pesti-
                              cide! is permitted in or on foods for which an ERA tolerance or exemption
                              has not been established.



                               ' I indor l.ho 11171:! FIFRA ainondiiiontH. Iho ('iiii)trosN iiiaiidiit(>(l thai ERA assoss tho sat'oty of all \n-nU-
                              ridos tliiii had IK.'OII provloiisly roglslorod by I'odcral and sliilo govorninonlH, Wo ii'iKirtitl In llWtl
                              l(iA()/l«'ED-H7-7, Ool, 27, IIIHll) thai KI'A had nnl yoi ooinplolod a final ioaj««>ssinoni on any |H«M||-
                              oldo aot Ivo liigrodloiil, 'I'liidiigh Uio I HHH KIKRA aiMonilnioni.s, tho ('ongivss gavo ICRA adilllloiial
                              riiiulliig (ur ooniliiotliig (lio,<<o IMM'NSIIIOIII.S I'or flio apiiioxlnialoly 4^,111111 piiMJiiois that havo nol IMVII
                              ansi^ssod al oiirroiil sianiliirds, and aboiii I) yoars for I'oinplollng Iho la.sk.




                              Page 7a                                       OAO/RrRI>-»0-88 ftafBty and QuaUty of Imported Pntduce
                         Appendix UI
                         Federal Agencies Involved In the U.S. Safety
                         and QiuUty Network for Imported Produce




                         The registration data, which are required for each pesticide use when
                         applying for domestic pesticide registration, include product chemistry,
                         residue chemistry, environmental fate, and toxicology data. According
                         to ERA officials, a pesticide registration for use on a food crop must be
                         accompanied by the establishment of a tolerance or an exemption from
                         the requirement of a tolerance. Most of the data used in making a toler-
                         ance decision are also considered in deciding whether to register a pesti-
                         cide product.

                         FIFRA also includes export notification provisions for pesticides intended
                         solely for export. Section 17(a) requires that before an unregistered pes-
                         ticide is exported, the foreign purchaser has signed a statement
                         acknowledging an awareness that the pesticide is not registered and can-
                         not be sold for use in the United States, ERA requires that the exporter/
                         manufacturer transmit the foreign purchaser acknowledgment to EPA
                         and certify to ERA that the shipment did not occur before receiving the
                         foreign purchaser statement, ERA sends copies of these statements to
                         U.S. embassies in the importing countries, which then forward the state-
                         ments to the appropriate government official in the importing country.
                         ERA requires these statements for the first shipment of each unregistered
                         product to a particular purchaser for each importing country, annually.

                         Section 17(b) requires ERA to notify foreign governments and appropri-
                         ate international agencies regarding its actions to cancel or suspend a
                         pesticide's U.S. registration. The notifications under section 17(b) bene-
                         fit both the United States and the foreign governments. Foreign govern-
                         ments benefit because they are alerted to unreasonable hazards
                         associated with using particular pesticides and can act to lessen expo-
                         sure of their workers and citizens. The United States can benefit when a
                         foreign government restricts using these harmful and potentially harm-
                         ful pesticides on crops that are subsequently imported into the United
                         States. As discussed in chapter 2, we reported in April 1989 that ERA did
                         not have an effective program to determine whether these notification
                         requirements were being met, and we made .several recommendations to
                         ERA to improve its notification program.'


EPA Establishes Import   Pesticides iistul in foreign countiit^s ure not I'equired to be registered
Tolerances               with ERA. Ilowever, foreign uses of pesticides thut do not havo an EPA
                         tolerance or an exemption can result in a commodity's rejection at the

                         -'I'oslloldos: Kxixirl of I 'nroglslorod I'o.silrlilrs Is Nnl Ailoiiiiatoly Mmillnrod by EI'A tUAO/
                         ticKD-m-12frK]¥^n^.imr)7                                       —                    '—

                         Page 78                                   (ilAO,/R(y.l> IN) ns Mainly and Quality of Imported Produce
                 Appendix in
                 Federal Agencies Involved In the U.8. Safety
                 and QuaUty Network for Imported Produce




                 U.S. entry point as a no-tolerance violation if residues are detected, ERA
                 is authorized under FFDCA'S section 408(e) to establish tolerances—
                 sometimes called import tolerances—on its own initiative, or at the
                 request of interested parties, when petitioners are not seeking tolerances
                 under section 408(d) as a part of obtaining a U.S. registration under
                 FIFRA. Pesticides used to produce food in the United States, however,
                 must have both U.S. registrations and tolerances—if not exempted—for
                 the pesticides' use. According to ERA'S Chief, Policy and Special Projects
                 Staff, Office of Pesticide Programs, import tolerances for pesticides that
                 do not have U.S. registrations may be necessary because foreign coun-
                 tries (1) grow crops that are not grown in the United States and (2) have
                 different pest and disease problems because of different climates.

                 To obtain an import tolerance under section 408(e), a petitioner must
                 submit some of the same types of data required for petitions submitted
                 under section 408(d)—product chemistry, residue chemistry, and toxi-
                 cological data for pesticide use on each specific crop for which a toler-
                 ance is requested. Environmental fate data are not required for
                 establishing import tolerances because the pesticides are applied in for-
                 eign countries and do not affect the environment of the United States.
                 When pesticides are already registered in the United States, EPA may
                 require only residue chemistry data for each new foreign crop use. In
                 addition, the petitioner must discuss any controls regulating pesticides
                 in the host country in which the pesticide will be used and provide some
                 evidence that requirements for use in the host country have been met.

                 EPA does not maintain data that readily show the number of existing
                 import tolerances established under FFDCA'S section 408(e) provisions.
                 However, ERA'S Office of Pesticide Programs was able to identify several
                 pesticides with tolerances that have been established or kept primarily
                 for import purposes. According to the Chief of the Office of Pesticide
                 Programs' Policy and Special Projects Staff, import tolerance petitions
                 represent a small percentage of all tolerances approved by ERA. AS of
                 December 1988, 52 petitions were in active status. Of these, 47 had been
                 reviewed and returned to the petitioner due to data deficiencies, and 5
                 were under review by ERA.


                 FDA Is responsible for enforcing ERA'S pesticide residue tolerances for all
Food and Drug    food products—both domestic and Imported—except meat, poultry, and
Administration   eggs, which are monitored for pesticide residues by USDA. FDA also sam-
                 ples food offered for import for other adulterating conditions, such as
                 microbial and filth contamination, foreign objects, and decomposition.


                 Page 74                            QAO/RCBIMIO-aB Safety and QuaUty of Imported Pr«>dM«
W'.
                                Appendix m
                                Federal Agencies Involved in the U.S. Safety
                                and QuaUty Network for Imported Produce




      FDA Enforces EPA          Under FFDCA, FDA is responsible for protecting the U.S. public from
      Pesticide Standards       unsafe foods and other products, FDA is authorized to examine samples
                                of foods being offered for import into the United States. A food ship-
                                ment is considered adulterated if it contains, among other things, either
                                (1) a pesticide residue that is not subject to an EPA-approved tolerance
                                for that food or (2) a pesticide residue in an amount greater than the ERA
                                tolerance level. In monitoring the entry of imported foods and removing
                                adulterated products from the marketplace, FDA works in cooperation
                                with the U.S. Customs Service, Department of the Treasury. Customs is
                                responsible for (I) notifying FDA of all formal entries subject to FDA juris-
                                diction, (2) requiring importers to post a bond on imported food distrib-
                                uted to owners or consignees pending FDA approval for release into U.S.
                                commerce, (3) ordering and supervising the export or destruction of
                                foods FDA identifies as adulterated, and (4) imposing and collecting liqui-
                                dated damages against importers who fail to export or destroy adulter-
                                ated shipments.''


      FDA's Import Monitoring   Of FDA'S 21 district offices, 20 selectively sample imported foods on the
      Program                   basis of various data and historical information on imports.^ Our 1986
                                report on monitoring and enforcement activities for pesticide residues in
                                imported foods recommended, among other things, that (I) FDA increase
                                its sampling coverage of imported food to a wider range of imported
                                foods and countries and (2) consider several options for obtaining addi-
                                tional information on pesticides actually used in foreign food produc-
                                tion. As a result, FDA has expanded its guidance to field offices on
                                criteria and additional data to be used in determining what countries
                                and commodities to sample."

                                In addition, according to its program documents, FDA performs (1) head-
                                quarters-initiated sampling to help ensure adequate national coverage of
                                pesticides and (2) special emphasis surveys in each district on import
                                sampling for country/commodity combinations not covered by a dis-
                                trict's past monitoring. The district offices also conduct special surveys

                                ''Wo diw!UHiM.'d the uduquacy of FDA's und Custom's monitoring imd oMfortvmunl uoUvltluin In Pratl-
                                otdow; lletU-T Sampling and Enforcement Needed on Imported Food (GA0/RCED-8«-219, SepHHT
                                 I98d),

                                'KDA'H N«>wurl< District Office docs not have any responitlblllty for Imixirt IniiikH itona.

                                ^'Aooordlng tu FDA, It uses data purchased from the commercially prodiiuxl ilHttoIlK World
                                AgruchemlcHl Databanlt to obtain infonnation on what pesticides ure being used on dlffbrvnt crupn tn
                                countries and regions of the world. According to FDA, the databank pnivldcs Infonnatton on pctitl-
                                vIdcH used on selected crops in about 26 to 30 countries that generally rcprcncnt the |M>iit and vltmale
                                oondltliins In various regions of the world.



                                PigeTt                                   QAO/ICIIIVMM         liflity iM ijlliiiity of tinpttHid   Ihalkm
                           Appendix in
                           Federal Agencies Involved in the U.8. Safety
                           and QuaUty Network for Imported Produce




                           when information on foreign pesticide use indicates the use of pesticides
                           that are not allowed for use on food in the United States. A new plan-
                           ning process, initiated in fiscal year 1988, was designed to require the
                           district offices to document their annual pesticide sampling decisions for
                           imported foods, FDA officials told us, however, that they expect it will
                           take several years to fully achieve satisfactory district sampling plans
                           and follow-up.


FDA Enforcement            FDA can request Customs to detain imported food that FDA suspects,
                           either from past experience or initial sampling results, contains illegal
                           pesticide residues. According to FDA'S Regulatory Procedures Manual,
                           when FDA suspects that a product may be violative given its past viola-
                           tive history and/or other information, it can invoke automatic detention,
                           which requires that, until the automatic detention is removed, the
                           importer provide certification from a private laboratory that shows
                           each subsequent shipment is free of violative levels of the pesticide in
                           question. According to FDA, it reviews the certifications to ensure their
                           adequacy. For fresh produce, automatic detention remains in effect for
                           all subsequent lots of the same produce for the rest of the growing sea-
                           son unless the grower/shipper demonstrates that the residue problem no
                           longer exists or that the produce to be shipped originated in fields that
                           were not treated with the pesticide in question.

                           FDA program documents indicated that, as of April 1988, FDA districts
                           could recommend placing shippers under automatic detention after one
                           violation; under prior practice, FDA did not recommend automatic deten-
                           tion with laboratory certification requirements for future shipments
                           until two violations had occurred. Program documents also state that
                           when illegal pesticide residues are found to be widespread on a particu-
                           lar commodity within a country, FDA can require certification from all
                           shippers of that commodity in the country.


                           Two USDA agencies, the Agricultural Marketing Service (AMS) and the
U.S. Department of         Animal and Plant Health inspection Service (ARIIIS), carry out inspec-
Agriculture                tions of imported produce.


AMS Inspects for           AMS assesses the quality of some Imported produce through mandatory
Ccmipliance With Quality   and voluntary quality ln.spectlons thut ure paid for by the Importer. Sec-
                           tion 8e of the Agricultural Marketing Agreement Act of 1937, as
itfindards                 amended (7 U.S.C. 608e-l), mandates that certain Imported commodities


                           Page 78                            UAO/RCRD-MM SAfety ind QuiJlty of linttoitiitf f r t i ^
                            Appendix m
                            Federal Agencies Involved In the U.S. Safety
                            and QuaUty Network for Imported Produce




                            meet minimum quality requirements during the effective dates of the
                            applicable federal marketing orders. As of March 1988 the imported
                            commodities covered by section 8e were avocados, dates (except dates
                            for processing), filberts, grapefmit, table grapes, limes, olives (except
                            Spanish-style onions), onions, oranges, Irish potatoes, prunes, raisins,
                            tomatoes, and walnuts.'' Section 8e requirements help keep inferior
                            grades of a commodity from depressing the market for an entire crop.
                            Because weather significantly influences crop production, requirements
                            may change from season to season, as supply and demand change.
                            According to an AMS official, when imported fresh produce does not pass
                            mandatory inspections for quality, AMS permits the importer to
                            (1) recondition the produce, (2) reship the produce, or (3) destroy the
                            shipment.

                            Voluntary inspections are authorized by the Agricultural Marketing Act
                            of 1946 (7 U.S.C. 1621 et seq.). These quality inspections evaluate the
                            imported produce usually according to USDA'S grade standards and/or
                            other contract specifications. Importers and others use quality inspec-
                            tions (I) as a basis for determining the value of fresh produce in price
                            determinations; (2) as evidence of compliance with contract specifica-
                            tions; (3) to enable appropriate labeling to be printed; and (4) in general,
                            to facilitate the trade in fresh produce in both domestic and interna-
                            tional markets. According to an AMS official, even when the mandatory
                            import inspections do not apply, importers usually still want to have
                            voluntary inspections to determine the quality of their product, AMS per-
                            forms mandatory import inspections at the Customs control points at
                            U.S. entry points. Voluntary inspections are conducted by AMS, either by
                            itself or in cooperation with the states.


APHIS Conducts              APHIS is not directly involved in ensuring the safety or quality of
Inspection and Quarantine   imported fruits and vegetables. However, it conducts inspection and
                            quarantine activities at U.S. entry points (and inspection, survey, and
Activities                  control activities at some foreign locations) to identify and prevent the
                            introduction of exotic animal and plant diseases and pests that might
                            threaten U.S, agriculture, APHIS develops and conducts precloarance pro-
                            grams, which include such activities as inspecting the products and
                            determining what type of treatment is necessary to make the product
                            post-free for the United States.

                            "liOglMlatloii boloro Iho llllsl OmgtvsM (IIR, 2II2II, IIR, .'inil?, and S, I72II) would add mu.b ooinmodi-
                            HON aa kiwi trull, noolarlnos, papayaa, and plums to tho llsl id" liu|x)il,iHt ain\m«Htlt.l<;H Mil\|i>ol. (« rnftH-
                            dalory limixiollnii.



                            Page 77                                    (MO/RCKD-80-88 (teftety and QuiUty of Imphned PMdttce
       Appendix IV

       International Organizations' Roles in Developing
       Food Safety Systems
i:.t


                            Several international organizations play important roles in assisting
                            developing countries to develop their food safety control systems. These
                            organizations, whose activities are discussed below, include the U.N.
                            Food and Agriculture Organization (FAO), U.N. World Health Organiza-
                            tion (WHO), Codex Alimentarius Commission, Pan American Health
                            Organization (PAHO), and Inter-American Institute for Cooperation on
                            Agriculture (IICA).


                            FAO adopted an International Code of Conduct on the Distribution and
       U.N. Food and        Use of Pesticides in 1985, and it has published guidelines to assist gov-
       Agriculture          ernments and industries in implementing the code. The FAO code and
                            guidelines provide a framework for developing or improving pesticide
       Organization         control laws and regulations. As of January 1990, all of FAO'S 158 mem-
                            ber countries, including the United States, had endorsed the FAO code of
                            conduct. A January 1989 FAO survey of governments on implementation
                            of the code of conduct showed that many developing countries, includ-
                            ing Latin American and Caribbean countries, were observing the code to
                            varying degrees. However, the survey report also stated that developing
                            countries reported that they generally have problems with the quality
                            of pesticide formulations, packaging, and receiving technical assistance.


                            WHO has developed a pesticide hazard classification system that classi-
       U.N. World Health    fies pesticides into one of four hazard levels. The hazard level is deter-
       Organization         mined according to the acute risk to health by single or multiple
                            exposures to the pesticide over a short period of time. The system forms
                            the basis of a harmonized pesticide labeling format recently adopted by
                            many Central and South American countries. (See ch. 2.)


                            Codex, a subsidiary body of FAO and WHO, was established in 1963 to set
       Codex Alimentarius   international food standards to protect the health of consumers and to
       Commission           facilitate international trade in food through these harmonized stan-
                            dards. Codex has published international standards for the hygienic and
                            nutritional quality of food; food additives; pesticide residues, including
                            maximum residue limits (tolerance levels); contaminants; labeling and
                            presentation; and methods of analysis and sampling. Member govern-
                            ments are encouraged to accept and Incorporate the food standards and
                            guidelines, which are developed by Codex working committees, Into
                            national legislation and regulations.




                            Page 78                     UAO/RCBI>IN)>55 BsfiBty and Quality of Imported Product
   ^yi^uiiy.Hii,ij




                              Appendix IV
                              Intemational Organizations' Roles In
                              Developing Food Safety Systems




                              Developing countries that lack the research capabilities to indepen-
                              dently develop food standards are able to adopt Codex international
                              standards for domestic and exported foods. However, according to a
                              Codex document, full acceptance of Codex standards is a slow process
                              because governments must reconcile the continuing development of
                              Codex standards with their changing national food laws, which reflect
                              each country's own domestic health issues, environment, and consumer
                              and industry concerns. The United States accepts Codex standards when
                              the Codex tolerance is the same as the ERA tolerance for that pesticide/
                              comiHodity combination. In some cases, ERA will revise its tolerance to
                              match the Codex tolerance, such as when ERA has determined that the
                              Codex tolerance is similar to the ERA tolerance and it does not compro-
                              mise the U.S. consumers' safety.

                              FDA and USDA'S Food Safety and Inspection Service have supported a pro-
                              posal that ERA recommend that FDA and the Service use Codex standards
                              for imported foods for which ERA does not have a tolerance. The pro-
                              posed regulation states that this acceptance would not apply in cases
                              where (1) ERA has canceled or suspended pesticides, (2) ERA has new tox-
                              icological information of concern, or (3) ERA questions the safety of diet-
                              ary exposure to residues of the pesticide, ERA had not taken a position on
                              the proposal at the time of this review.

                              Codex's Committee on Pesticide Residues has formed an ad hoc working
                              group for pesticide residue problems in developing countries. The work-
                              ing group considers such matters as implementing the FAO International
                              Code of Conduct on the Distribution and Use of Pesticides in developing
                              countries, pesticide training activities, and the need for better pesticide
                              residue data as a means of helping developing countries move towards
                              better national pesticide control systems.


                              PAIR) is a member of the U.N. vsystem of international agencies and, by
        Pan American Health   agreement, an advisor to the Organization of American States regarding
        Organization          health-related matters, PAHO'S membership includtis countries in North,
                              Central, and South America and in the Caribbean. Its objective Is to gen-
                              erally promote und coordinate the efforts of tliese t:ountries in combat-
                              ing disease, prolonging life, and promoting the physical and mental
                              health of its peoples.




I.:.:                         Page 70                           UA()/KCBI)-MK88 Safety and QuaUty of lmpoit«id ProdMt
*???"• "^WI^-WT




                  Appendix IV
                  Intemational Organizations' Roles in
                  Developing Food Safety Systems




                  RAHO works cooperatively with other organizations in providing broad
                  assistance to Latin American and Caribbean countries, including partici-
                  pation in regional conferences, training, mobilizing resources, and pro-
                  viding technical assistance. For example, as a result of the August 1985
                  Inter-American Conference on Food Protection, PAHO and FAO developed
                  a 5-year regional program to strengthen the food safety and quality con-
                  trol programs in Latin American and Caribbean countries, PAHO is also
                  working with FDA to develop a model of technical cooperation for devel-
                  oping fdod safety systems in Latin America and the Caribbean. The
                  agencies chose Costa Rica in Central America and Jamaica in the Carib-
                  bean as countries on which to base the models.


                  IICA was founded in 1942 as an institution for agricultural research and
Inter-American    graduate training in tropical agriculture. It gradually evolved into an
Institute for     intergovernmental technical organization designed to encourage,
Cooperation on    promote, and support the efforts of its 31 member nations to achieve
                  agricultural development and rural well-being, IICA focuses its resources
Agriculture       and technical capacity on modernizing agricultural technology and
                  strengthening regional integration.

                  IICA helped to develop harmonized pesticide labeling and registration
                  regulations, based on FAO/WHO guidelines, for Latin American countries.
                  Beginning in 1981, it supported a series of regional meetings between
                  government and agrochemical industry representatives to develop har-
                  monized pesticide regulations, IICA encouraged ministries of agriculture
                  in member countries to implement the standardized labeling and regis-
                  tration regulations. As of June 1988 many Central and South American
                  countries had adopted a standard label format for pesticides sold in
                  their countries.




                  Page 80                            UAU/RCMIMN)'8IS Safiity ahd <)uaUty of llhpoiried PttMlMt
   Appendix V

   Status in Five Countries of Pesticides That Do
   Not Have EPA Tolerances Established for the
   Active Ingredients

       Pesticide                              Chile    C o s t a Rica   Dominican Republic              Guatemala           (Mexico
       Alachlor" + Nudolin                      NR               NR                        R                " NR                 NR
       Aldri'n''                                 R'              NR                       NR                     NR              NR
       Amitrole                                 NR               NR                        R                     NR               NR
       Azamethiphos                             NR               NR                       NR                     NR               R
       Azinphos-ethyl                            R               NR                        R                     NR              NR
       Azocyclotin"                              R               NR                       NR                     NR              NR
       BHC"         '
          (benzene hexachloride)'               NR               NR                       NR                     NR               R
       Bioallethrin                             NR                R                       NR                     NR              NR
       Bitertanoi"                               R               NR                       NR                     NR               R
       Blasticidin-S                            NR                R                        F^                    NR              NR
       BPMC
          (Fenotaucarb)                        NR                 R                       NR                     NR              NR
       Brodifacoum                             NR                 R                       NR                      R               R
   Bromadiolone                                NR                NR                       NR                     NR               R
   Bupirimate                                   R                NR                       NR                     NR              NR
   Buprolezin                                  NR                NR                       NR                      R              NR
   Buthidazole                                 NR                NR                         R                     R              NR
   Butocarboxim                                NR                NR                       NR                      R              NR
   Caldo Bordeles + Cufraneb                   NR                NR                         R                    NR              NR
   Captan + Metoxicloro                        NR                NR                         R                    NR              NR
   Carbaxim + Captan'                          NR               ,NR                         R                    NR              NR
   Cartap                                      NR                 R                       NR                     NR              NR
   Chlordane'-'                                NR                 R                         R                     R'              R
   Chlordane" + Pentad                         NR                 R                       NR                     NR              NR
   Chlorophacinone                             NR                 R                        R                     NR              NR
   Chlofololuron                               NR'               NR                       NR                     NR               R
   Ciomelrinilo                                NR                 R                       NR                    NI-l             NR
   Citrolina                                   NR                NR                       NR                    NR                R
   Colecalcileioi                              NH                Nl-i                     NR                    NR                R
   Coumachior                                   Nl-^            NR                        NR                    NR                R
   Coumachlor + SuHarnilfimide                 NR               NR                         f?                   NR               NR
   Coumaletralyi                               NR                R                         R                     R                R
   CyflOKylale                                 NR               NR                         R                    Nr<              NR
   Cymoxanil + fv/lancozeb'                    Nl-t             NR                         I'l                  NR               NR
   6¥cp
                                               ^\\              NR                        \-\                    R'             NR
     (dibtomochloropfopane)
                                                 1^              1-^                      R                      R               R
   Demeion-(bor S)meihyi
                                                 R               R                       NR                      11             NR
   OfeHiofluanicI"
                                               Nil              NR                        R'                    NR              NR
                                                                                                                        (cootinuod)




                                    Page NI                             (iA< VH('>KI)4N>4IA Hgfety and QualU,y ttf ImpitriMl PntdtMi*

It:.
 W^¥



                                   Appendix V
                                   SutuB Ul Five Countries of Pesticides That
                                   Do Not Have EPA Tolerances EsUblished for
                                   the Active Ingredients




   Pesticide                                Chile     Costa Rica   Dominican Republic         Guatemala                  Mexico
   Dienochlor                                   R             R                     R                        R                R
   DIetanolamina                              NR              R                    NR                  NR                    NR
   DIfenacoum                                 NR             NR                     R                  NR                    NR
   Dimethirimol                               NR             NR                     R                  NR                    NR
   Dimethylamine                               NR             R                    NR                        R               NR
   Dimethyl urea                               NR            NR                     R                        R               NR
   Dinobuton                                  NR             NR                     R                  NR                    NR
   Dioctil Sulfosun.                          NR              R                    NR                  NR                    NR
   Diphacinone                                NR             NR                     R                       R                 R
   Dodemorph                                  NR              R                     R                       R                 R
   Edifenphos<^                               NR              R                     R                       R                 R
   Epibloc                                    NR             NR                    NR                       R                NR
   Ethidimuron                                NR             NR                    NR                  NR                     R
   Ethiotencarb"                                R            NR                    NR                  NR                    NR
   Fenaminosulf                                 R              R                   NR                       R                NR
   Fentin acetate                               R              R                    R                       R                 R
   Flamprop-mefhyl                            NR             NR                    NR                  NR                      R
   Flocoumafen                                NR             NR                    NR                      R                 NR
   Flubenzimine                                 R            NR"                   NR                 NR                     NR
                                                             NR




                                                                                                     z z z z
                                                                                                         DC
   Flumetrina                                 NR                                   NR                                         R




                                                                                                         DC DC IDC
   Fluorodifen                                NR             NR                     R                                        NR
   Fluosilicato                               NR             NR                     R                                        NR




                                                                                                                 i
   Flutriafol                                   R            NR                    NR                                        NR
   Fonofos                                    NR             NR                     R                 NR                     NR
   Glufosinate                                NR             NR                    NR                 NR                       R
   Guazatine"                                 NR           "'NR                     R                 NR                     NR
   Hexaconazole                               NR             NR                    NR                     R                  NR
   IBP
     (Iprobenfos)                             NR              H                    NR                 NR                     NR
   loxynil + 2,4-D'                           NR    ""'       R                    NR              """'NR                    NR
   loxynil octanoafe                          NR             NR                    R                 NR                      NR
   Isazofos                                   NR              R                    R                  R                      NR
   Isoforona                                  NR              R                   NR                 NR                      NR
   l»oproturon                                NR             NR                   NR                 NR                       R
   Kasugamycin                                 R              R                    R                  R                       R
   MAFA                                       NR              R                   NR                  R                      NR
   MCCEP                                      NR             NR                    R                 NR                      NR
   Mephotfolan                                NR              R                    R                  R                      NR
   MetaMehyde" -»- Tri Arsenate               NR             NR                    R                 NR                      NR
   Melhibonzlhlazufon + Amitrole              NR              R                   NR                 NR                      NR
   Methamtodium                               NR.            NR                    R                  R                       R
                                                                                                                     (continued)




                                   Pagtil                           QAO/RCBD^OM Itafkty and QuaUty of Immrtiid
ii!ieMt&
                                       Appendix V
                                       Status in Five Countries of Pesticides That
                                       Do Not Have EPA Tolerances Esteblished for
                                       the Active Ingredients




    Pesticide                                    Chile   Costa Rica     Dominican Republic           Guatemala                Mexico
    Methyl isothiocyanate                          NR           NR                     NR                  NR                      R
    Mirex                                          NR           NR                     NR                    R                    NR
    Naptalam                                       NR           NR                                            NR                  NR
    Nitrofen
      (DCP)                                        NR             NR                                          NR                 NR
    Ofurace                                        NR                                       NR                NR                 NR
    Omethoate^                                                    NR                        NR                NR
    Oxycarboxin                                    NR
    Penconazole                                    NR             NR                        NR                                   NR
    Penconazole + Mancozeb'                                       NR                        NR                NR                 NR
    Pentachlorophenol                              NR             NR                        NR
    Phenothiol                                     NR                                       NR               NR                  NR
    Phenothrin'                                    NR                                       NR               NR                  NR
    Phenthoate^                                                   NR                                          R
    Phoxim'^                                                                                                ""R""
    Piperophos + Dimethametryn                     NR                                                       "ji"
                                                                                                            ... ^...             NR
    Pirimicarb''                                                                            NR
    Pirimidil                                      NR             NR                                         NR                  NR
    Propamocarb''                                  NR             NR                                        ' R" "               NR
    Profhiofos                                                                              NR                  Fl"'             NR
    Prothoate                                      NR             NR                                        ~NR""                N_R
    Pyracarbolid                                   NR             NR                        NR                 'R'              "NR
    Pyrazophos                                                                                              "NR"                 "R
    Quinalphos                                                    NR                        NR              'NR                _ NR
    Sal Sodio Disp                                 NR                                       NR               'NR"      ''"•    ""NR
    Sal So^io Natl.                                NR                                       NR               NR"                NR
    Tetracioruro de Cjrbono + Acrylo               NR             NR                    '    'R'            "NR            " " NR
    Tetramethrin                                  'NR'                                   NR"                 "NR            ' "' R
    thiometon"                                    '"R"            NR                    "NR                  NR"        '""'"   NR
    Tlocarbazi]                                   'NR'           "NR"                       ~R               NR         ""      NR
    Tolclofos-methyl                              'NR'            'R'                   "NR                  NFI "             ~"NR
                                                                                                                       (continued)




f                                      Page S8                           OAO/RCBD-W>4S Safety and <)ttaUty of Impoited PieriMt
              Appendix V
              Status in Five Countries of Pesticides That
              Do Not Have EPA Tolerances Established for
              the Active Ingredients




Pesticide                Chile       Costa Rica        Dominican Republic                   Guatemala          Mexico
Triazophos                   NR'               NR                  "    R"
Triflumuron                   R                NR                           "NR"                          NR
Xiligen                     "NR                 R                          "'NR~                          NR         NR
              Legend

              NR = Not registered lor use

              R = Registered lor use
              •'EPA has tolerances (or this chemical, but not lor combination shown.
              '"EPA has action levels and Codex has maximum residue limits (MRLs) for this chemical.
               This pesticide is on the country's registration list but has been olliciaily prohibited.

              'Codex has MRLs lor this chemical.

              '•EPA has action levels for this chemical

              'EPA has tolerances and Codex has t^RLs lor this chemical.

              •EPA has action levels and Codex has extraneous residue limits for this chemical
              ''40 C F R. 185 4025 aliows preharvest use ol ihis chemical on strawberries, but sets a zero tolerance lor
              residues

               Codex has temporary MRLs for this chemical.
              Source Government pesticide registration lists tor Chile, Costa Rica, Ihe Dominican Republic, Guate-
              mala, and Mexico for 1987 or 1988 (See ch 1. fn. 13 ) EPA verified in 1989 that, according to its records,
              the pesticides (except as shown in the lootnotes) do not have tolerances established lor any lood use in
              the United States Where possible. English spellings and olher information on chemicals were obtained
              from the Code ol Federal Regulations, title 40 parts 180 and 185 (revised as ol July 1, 1989); Farm
              Chemicals Handbook (Willoughby. Ohio: Meister Publishing Co.), 1987; Glossary ot Pgslicide Chemicals,
              FDA. Sept 1988: Guide to Codex Maximum Limits tor Pesticide Residues, Part 2, CAC/PR 2 - 1986, Apr.
              1988, issued by The Netherlands: The Pesticide Chemical News Guide, Reo, P.O.. and M.B Duggan,
              eds (Washington. DC LOUIS Rothschild Jr). June 1, 1988: and The Pesticide Manual, A World Com-
              pendium Sth ed , C R Worthing, ed (Thorton Heath The British Crop Protection Council), 1987.




              Page N4                                     tiAO/KCKIMNIDS SalVly and guallty of imported Produce
Appendix VI

M^'or Contributors to This Report


                        William K, (ialir. Associate Director
Resources,              .lerilynii B, Hoy, ,-\ssignment .Manager
Community, and          Kaieii S, Sa\ ia. Kvaliiator-iii-("harge
                        lf\iM T, Williams, Kvaluator
Economic                .Nam \ .\, Hoaidinaii, Kvaluator
Development Division    ("ami Ilnrnstadt SlutlMiaii, Kepori.s .-\nalyst
Washington, D.C.

                        ,\ll)i'ft T. Vdi'is, Senior Kvaluator
San Francisco           Kt'n'\- (i. Diiiiii, K\';iltiator
Regional Office




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