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Understand trade implications of unregistered uses

Follow label directions, use only registered pesticides and grow current varieties to protect export markets from trade sanctions.


November 20, 2007
By Bruce Barker

In 2003, a shipment of canola to France had a pesticide detected at higher
levels than allowed under that country's import regulations. For the exporter,
the cost ran into the millions. "Canola trade with France stopped that
day," says Derwyn Hammond, a canola agronomist with the Canola Council
of Canada in Brandon, Manitoba.

More recently, a shipment of Australian canola to Japan had levels of fenitrothion
that exceeded the Maximum Residue Limit (MRL). These types of incidences illustrate
what is at risk in the high-stakes game of international trade. Hammond says
that with 75 percent of the Canadian canola crop exported, growers can no longer
afford to play loose with the rules of the game, namely, the entire industry
has to ensure that export standards are met.

Understanding the MRL
Each country determines maximum residue limits and standards may vary from country
to country. A MRL is the maximum limit at which a pesticide is allowed in a
crop. In some cases, there is a zero-allowable limit, meaning that if the pesticide
is detected at any level, the shipment can be rejected.

Japan has some of the most stringent MRLs in the world, with provisional levels
established for more than 750 pesticides. Fourteen of the MRLs have a zero-allowable
designation. However, not all of those pesticides are used in Canada. Denise
Maurice, technical development manager of crop protection management with Agricore
United, says that of those roughly 750 products, western Canadians use only
69 in wheat and barley.

"Our customers are getting more demanding. They want to know what we are
doing on the farm, and what products we are using," explains Maurice. "If
you want to export to them, the customer is always right."

Hammond says canola growers should be on high alert if malathion was used in
canola storage (not a registered use). He says that the Canadian Grain Commission
(CGC) sees occasional spikes in malathion detection. Hammond says it is related
to farmers spraying malathion in storage bins to control insects.

"If the bins have been treated with malathion in the past six months,
they shouldn't be used to store canola," explains Hammond. To help minimize
insect problems and avoid the use of malathion, he recommends that canola bins
be kept free of chaff, seeds and other foreign material. For long-term storage,
store canola at cool temperatures: below 15 degrees C and at moisture content
of less than eight percent.

The Japanese are also concerned about the detection of animal protein in canola,
including blood meal and bone meal. Growers should also ensure that their bins
are free of mice and rats.

Mike Grenier, an agronomist with the Canadian Wheat Board, compared Canadian
MRLs on wheat to other countries. Of the 69 active ingredients used on wheat,
29 MRLs are equivalent to Japan's and 27 Canadian MRLs are more stringent, while
13 Japanese MRLs are more stringent than Canada's, including one zero-allowable
pesticide MRL for Amitrol. In the case of Amitrol, the Canola Council recommends
growers strictly follow the label rates and use only as a pre-seed application
to ensure that no residues will remain in the harvested canola seed.

Still, Canadians are faring well on the export stage, thanks in part to stringent
testing by the CGC and increasingly, responsible use of products by farmers.
The CGC set up a monitoring system in the 1960s and now monitors for 200 compounds,
20 mycotoxins and heavy metals. Grenier says that only two pesticides ever routinely
show up in samples, glyphosate and malathion, but at levels well below established
MRLs.

Growers are also encouraged to dispose of seed treatments containing lindane.
Lindane is no longer registered or sold in Canada, and old product left on the
farm should not be used. The product, sold under trade names such as Cloak,
Vitavax RS, Foundation, Premiere and IPC Benolin-R Insecticide-Fungicide Dust,
is not registered in the US and no tolerance levels exist for lindane residues
in canola.

Observe labels
Maurice says that growers need to be aware that MRLs are a concern for export
markets in addition to or other export requirements. Although this sounds like
a complex job for grower associations and exporters, the easiest way to manage
MRLs is for growers to follow product labels right down to the fine print –
being especially vigilant of pre-harvest intervals.

Registered products should be used only on registered crops at registered rates.
While the old days of mixing up cocktails on the farm seem to be dying out rapidly,
Maurice says that when pushed into a corner by a pest problem, a grower might
be tempted to try an unregistered product on a crop. She says that can have
negative consequences for the export market. If in doubt, consult an agronomist
for the best recommendations on how to control a pest.

The other important pesticide consideration is to ensure that a pesticide is
not applied after the pre-harvest interval. For example, Lorsban should not
be applied for the control of lygus bug in canola within 21 days of harvest.
Pre-harvest interval refers to the number of days that must pass between application
of the pesticide and cutting of the crop (swathing or straight combining, not
harvesting the swaths). Applications after the pre-harvest interval can mean
residues greater than allowable MRLs. These guidelines apply to every crop and
pesticide registered for sale in Canada.

Requirements go beyond MRLs
Export quality goes well beyond MRLs, though. In addition to increasingly tough
MRLs for pesticides, Grenier says end users also test for mycotoxins and heavy
metals. Examples include DON for fusarium infected cereals and heavy metals
such as cadmium in durum wheat. "Customers want to know how our crops are
being produced," says Grenier, echoing Maurice's comments.

Surprisingly, even old varieties may cause trade problems due to adventiscious
presence issues. Some buyers are now demanding to know what variety of canola
is being delivered. The varieties, such as Roundup Ready HySyn 101, several
bromoxynil tolerant varieties and several Liberty Link varieties, are no longer
commercially available through the seed industry, but old seed left on farms
can be hazardous to the trade if grown and sold into the crush or export market.

The bromoxynil tolerant varieties were never approved in South Korea, and Hammond
says that it appears that European regulators will only approve new GMO events
in Liberty Link varieties, not the old ones that have been discontinued.

Grenier says that customers are increasingly asking how crops are grown on
the farm, especially as it relates to how pesticides are used. They want to
know the level of pesticide applicator training, the dose and frequency of pesticide
use, the observance of pre-harvest intervals, and the degree of documentation
and testing. They are also recommending the use of Decisions Support Systems
that use trained 'experts' and integrated pest management approaches, both which
minimize the environmental impact.

"We get customer questionnaires that have numerous and detailed questions
on them," says Grenier. "We place a high priority on explaining what
our growers do to try to address their concerns."

Maurice says it is important for exporters, agronomists and farmers to work
together to preserve CanadaÕs nearly flawless export record. She says various
end users have established their own MRLs, which can be more stringent than
those set out by our own country. This requirement is usually determined by
the use of the export product. For example, Quaker Oats has higher MRL standards
on some pesticides than Canada's MRLs. In addition, Sapporo Breweries of Japan
is asking to look at growers' production records as a way of tracking cropping
practices.

"All of these issues are now becoming more of a part of normal trade,"
explains Maurice. "It is up to grain marketers to educate our growers,
because what happens on the farm affects our markets globally." One example
of a program to inform growers of potential trade issues is the Canola Council
of Canada's 'Canola Export Ready Program' found at www.canola-council.org -30-

Do not grow these canola varieties
HySyn 101 Roundup Ready
A Roundup Ready Polish type variety that was sold on a limited basis and deregulated
in 2003. Japan will not accept this variety and is developing a test to detect
it.

Examples of pre-harvest intervals
for pesticides used in canola.
Product name Pre-harvest
interval (days)
Quadris 30
Lance 21
Furadan 60
Lorsban 21
Matador 7
Ripcord/
Cymbush
30
Decis 7
Rovral Flo 38
Malathion 7
Monitor 10
Lannate 8
Tilt 250E;
Bumper 418 EC
60
Dylox 21
Ronilan EG 40
Source:
Canola Council of Canada 2006.

295BX, Cartier BX, Zodiac BX, Renegade BX
Bromoxynil tolerant varieties that were not sold after 1999 and de-registered
in 2004. South Korea never approved the varieties and Europe will not allow
them under new importation rules.

Exceed, 2631 LL, Swallow, SW Legion LL, SW Flare LL,
LBD 2393 LL

Old Liberty Link varieties no longer sold or registered in Canada. These seeds
contain the genetic transformation event T45, which is not approved in the EU
for food or seed and may not be approved in the future.

3850, 2153, 3640, 2063
Old Liberty Link varieties no longer sold or registered in Canada. These varieties
contain event MS1RF1, which is currently approved in export markets, but may
not be supported in the future.

3880, 2163, 2273
Old Liberty Link varieties no longer sold or registered in Canada. These varieties
contain event MS1RF2 which is currently approved in export markets, but may
not be supported in the future.

Innovator, Independence, HCN 14, Phoenix
Old Liberty Link varieties no longer sold or registered in Canada. These varieties
contain event Topas 19/2 which is currently approved in export markets, but
may not be supported in the future. If growers have seed from these varieties,
the advice is to talk with their local canola agronomists to determine the best
way to dispose of the seed. -30-
Source: Canola Council of Canada, Export Ready Program.