These guidelines form part of a food safety series aimed mainly at food suppliers, manufacturers and retailers, for reducing physical hazards in the food chain and risks to their business. The aim of this guide is to help food companies understand regulatory requirements and voluntary controls on pesticide use and to ensure well structured assessment of risks in their supply chain. The objective is primarily to equip companies with knowledge of how and why hazards and risks may occur, so that they can organise their supply chain practices and documentation for quality assurance and adequate defence under UK ‘due diligence’ legal requirements for contamination risk, mainly residue exceedance. The guide also recognises the increasing concerns and demands from retail customers and consumers for reduced residues. It gives a useful overview of UK and European legislation and voluntary schemes related to different aspects of pesticide use, with website addresses. PAN UK and Friends of the Earth are both listed under a section ‘Influence of lobbying organisations, customers and consumers’ but unhelpfully, no web addresses are given for these NGOs or for individual retailer pesticide policies. Five main hazards for food companies are discussed, the most significant being the legal offence of supplying food containing residues above MRL. The others are residue contamination by pesticides not included in the customer specification (in voluntary schemes), causing environmental contamination or operator exposure above safety levels, or jeopardising business success by adverse publicity on its pesticide practice. Possible causes for each hazard are examined, with examples given of incidents in which residues were detected above MRL in produce sold in the UK. Some were due to suppliers in exporting countries failing to anticipate changes in MRLs. For example, methamidophos was detected above MRL in grapes from Greece in 2000, after a UK MRL was set at 0.01mg/kg in August 1999. Previously sales in the UK had only to comply with the Codex MRL of 1.0mg/kg. Contamination of packing lines and storage was responsible for some exceedance cases, while disposable latex gloves used to handle fruit were thought to account for some dithiocarbamate exceedances as this compound is also used in manufacture of rubber products like gloves. Inorganic bromide exceedances in 8% sampled UK winter lettuce in 2003 were due to residues from soil sterilisation using methyl bromide in glasshouses. Sources of information on good practice are listed and pesticide and risk management strategies outlined for food companies, from supplier approval criteria to production specifications; training, record-keeping and audits at different stages in the supply chain; to product traceability and testing for residues, with possible corrective actions. Two useful appendices present recent residue monitoring data from private companies and the UK government testing. The food industry data for 2002-04 shows residues were found in 48% of 29 types of fruit and vegetables tested, with at least 69% of citrus, grapes, strawberry, banana and apple contaminated. The five most frequently occurring pesticides were: iprodione; chlorpyrifos; procymidone; imazalil and dithiocarbamates. A summary table for government test results 2000-2005 gives a visual display of residue occurrence, showing which compounds were detected in which crops in which years. The government data shows a similar top five offending compounds to the company data, except that carbendazim is the second most frequently detected, while imazalil ranks only eleventh. Apples, pears, grapes, citrus, strawberry, tomato and lettuce all had residues reported more than 20 times in the relevant year(s) of surveillance. This guide gives food chain actors a good idea of how pesticide hazards to their business are likely to occur and in which fresh produce crops but it does not question the dependency on pesticides as the dominant means of pest management nor give companies much guidance on how to reduce this dependency.

Managing pesticides in the food chain. Guideline no. 19. Campden & Chorleywood Food Research Association Group (CCFRA), Chipping Campden, UK, 2006.