Some of Pesticides which are approved by pesticide control act could be exempt from the requirement of maximum residue level(MRL) in food by the regulation on the standards and specification of food in the Korean food code if they are applicable following condition. First they are not likely to pose risk to human because they have minimum risk. Second they are not likely to residue in food. Third, they are natural component of food and could not tell from exogenous compound. Fourth, natural plant protection product (including microorganism) which are proved to safe in human. We investigate the exemption regulation on pesticide MRL in United state of America. European Committee, Japan and Codex to suggest more detailed guideline which could be used when regulators determine the exemption of MRL for the pesticide in food items.
In USA, the exemption for pesticide chemical residue in food are described in subpart D and subpart E in 40 CFR part 180 and 40 CFR 180.940 for the active/inert ingredients in antimicrobial products. The total amount of pesticide in/on the food items should not pose any harmful on the public health. Most of them are applicable when they are used under GAP and labeling.
EU has the “guidance document on criteria for the inclusion of active substance into Annex IV (substances are not required the MRL) of regulation (EC) No 396/2005.(SANCO/11188/2013)”. They have 5 criteria for the exemption of MRL. Criterion 1 is the active substance which are approved as basic substance under regulation (EC) No 1107/2009. Criterion 2 is the compound is listed in Annex 1of regulation (EC) No 396/2005. Criterion 3 is the compound which has no identified hazardous properties. Criterion 4 is then natural exposure is higher than the one linked to the use of PPP. Criterion 5 is that no consumer exposure is forecasted linked to the mode of application of the PPP.
establishment of codex maximum residue limit or do not raised to reside as step 4 from 2020”. The draft suggests 4 criteria. Criterion 1 is the basic substances and Active substances without hazardous properties identified (very low or no toxicological concern). Criterion 2 is substances for which it is not possible to differentiate between the exposure associated with its use as pesticide and its other uses in the food chain. Criterion 3 is the substances for which no consumer exposure linked to the mode of application is foreseen
Criterion 4 is the microorganisms which are not pathogenic and do not produce mammalian toxins or other potentially toxic secondary metabolites of human health concern.
Conclusively, most regulatory agency determined the exemption of pesticide MRL requirement during the approval procedure in the case of GAP and indication for use. The criteria include the risk factors (toxicity test data, experience of use), and the possibility of exposure to human (GAP, ADME, stability in the environment) and management option (residue analysis).
This project was carried out by the fund from Ministry of Food Safety (211162농축산371) and we deeply appreciate it.