Sometimes a report comes out from FDA that is not very exciting to most of our readers, but often these reports, even if not exciting, are a good reminder of just how good our food safety system is. The recent report about pesticide residues is just such a report. As the report indicates, the food industry is continuing to do a good job preventing pesticide residues in food, according to the latest Pesticide Residue Monitoring Program Pesticide Report from FDA. Summarizing the results of FDA’s pesticide monitoring program for FY 2017, the report states that levels of pesticide residues in the U.S. food supply – both domestic and imported – are well below established safety standards and are consistent with previous years’ findings. While the EPA is responsible for establishing the pesticide tolerances on the amount of a pesticide chemical residue a food can contain, FDA and USDA are responsible for enforcing those tolerances for domestic and imported human and animal foods. Samples are considered violative if they have pesticide chemical residues above the EPA tolerance or pesticide chemical residues for which the EPA has not established a tolerance or a tolerance exemption for the specific pesticide/commodity combination. To determine compliance, FDA conducts an annual pesticide monitoring program, for which the most recent report was published in September for FY 2017. Annual reports have been prepared since 1987 and published from 1993 to the present. FDA employs a three-fold strategy to enforce the pesticide tolerances. In its regulatory pesticide residue monitoring program, FDA selectively monitors a broad range of domestic and import commodities for residues of over 700 different pesticides and selected industrial compounds. FDA may also carry out focused sampling surveys for specific commodities or selected pesticides of special interest. The agency monitors the levels of pesticide chemical residues in prepared foods in its Total Diet Study (TDS), which monitors contaminants and nutrients in the average U.S. diet. For the FY17 pesticide residue report, FDA tested for 761 pesticides and industrial chemicals across 6,504 human and animal food samples, 93% of which were human food. Domestic samples were derived from products of 48 states and Puerto Rico, the imports from 100 countries. Of the 6,069 human food samples (1,799 domestic and 4,270 imports): 96.2% of domestic and 89.6% of import human foods were compliant with federal standards. No pesticide chemical residues were found in 52.5% of the domestic and 50.0% of the import samples that we analyzed. Of the 435 animal food samples (258 domestic and 177 import samples) analyzed: 98.8% of domestic and 94.4% of import samples were compliant with federal standards. No pesticide chemical residues were found in 40.7% of the domestic and 52.0% of the import samples. Most samples were for livestock or poultry; 57 were pet food. For the FY 17 report, FDA also conducted pesticide analyses for two field assignments For animal derived foods, 550 domestic milk, shell eggs, honey, and game meat samples were analyzed. No residues were found in any of the milk or game meat, 87.5% of the egg, or 77.3% of the honey samples. Concluding herbicide assignments begun in FY 16, 879 samples of corn, soy, milk and eggs, the analysis of for glyphosate and glufosinate showed no violative residues of glyphosate or glufosinate detected over the two-year assignment. This testing is now part of the routine pesticide monitoring program. In some human food commodity groups, the violation rate was higher for import samples validating the targeting of import commodities more likely to contain violative pesticide chemical residues, and the countries more likely to export them. Factors considered in targeting import commodities include past problem areas, findings from state and federal monitoring, and foreign pesticide usage data. When a violative sample is identified in an imported food, shipments may be refused entry into U.S. commerce and firms may be listed on an Import Alert. Food also may be subject to Detention Without Physical Examination if there is information that future shipments of the food appear to be violative. When identified in a domestic food, a Warning Letter may be issued to the responsible grower or manufacturer and other actions may be taken, such as seizure to remove the food from commerce, or injunction to correct the cause of the violation. So, my take on this report is that the U.S. food industry is doing a good job at controlling pesticide residues. However, we can predict that even a report as good as this one will be leveraged by some to scare consumers and point out the negative findings while ignoring the positive findings. We often don’t focus on pesticide residues as part of high-level risk control thinking. But this report and the ongoing regulatory vigilance should remind us that pesticide controls are just as important in preventing recalls and import refusals as are pathogens. Accordingly, the food industry needs to stay current on pesticide usage and tolerance levels as well as preventive controls and supplier control programs. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
