Results of Targeted AgChem Residue Program (TARP)

Agriculture Victoria is responsible for regulating the use of agricultural and veterinary (agvet) chemicals in partnership with the Commonwealth and other states and territories as part of the National Registration Scheme for Agricultural and Veterinary Chemicals.

Testing for residues in produce and measuring the residues against maximum residue limits (MRLs) is an efficient and effective means to verify if agvet chemical products are being used according to label directions and Good Agricultural Practice (GAP). Testing helps identify industry-wide chemical use issues that may be causing residue detections above the MRL. Upon detection of any issues, Agriculture Victoria can then work with individuals and industry to resolve them.

Agriculture Victoria undertakes a yearly residue testing program – the Targeted AgChem Residue Program (TARP). The annual program operates on a financial year basis and samples are collected throughout the relevant commodity’s growing season.

TARP targets commodities where intelligence suggests produce may be at high risk of pesticide misuse. This approach is different from randomised industry or quality assurance residue monitoring programs. Due to the targeted approach of the program, it is expected that unacceptable residues will be detected in this program.

The main objectives of TARP are to:

• determine the nature and concentration of any unacceptable pesticide residues in the commodities sampled
• determine the cause of any unacceptable residues
• report the summary findings of the program to relevant industry bodies in order to support good agricultural practice and prevent the recurrence of unacceptable residues in a given commodity group.

The main stages of the program are:

1. Planning
2. Sample collection
3. Sample analysis
4. Traceback investigations
5. Reporting to industry and other relevant agencies
6. Evaluation

TARP also has the ability to react to issues identified during a growing season that will not be addressed through the initial sampling plan. This allows Agriculture Victoria to adjust the sample plan according to seasonal conditions, unprecedented pest pressures and any other unexpected events that may call for the sampling plan to be modified.

The Commonwealth Government regulates agvet chemicals up to and including point of retail sale. This includes the role of the Australian Pesticides and Veterinary Medicines Authority (APVMA) to register and approve a chemical product for use if, after a scientific evaluation, it is satisfied the product works and is safe to human health, the environment, animal or crop safety, or trade, when used in accordance with the label directions.

In Victoria, the main controls on the use of agvet chemicals is via the Agricultural and Veterinary Chemicals (Control of Use) Act 1992, which is regulated by Agriculture Victoria. These controls include requiring chemicals to be used in accordance with aspects of the product label, the training and licensing of persons using certain chemicals, and other restrictions on how particular chemicals can be used.

Agriculture Victoria regulates chemical users through education, monitoring of chemical use practices, investigating reports of non-compliance and enforcement of misuse.

In addition to TARP, Agriculture Victoria responds to referrals from other states and territories, and reports from members of the public and other agencies alleging chemical misuse.

A maximum residue limit (MRL) is the highest amount of an agvet chemical residue that is expected (and legally allowed) in produce when a chemical product is used in accordance with its label.

A residue detected in agricultural produce, which fails to meet the MRL is considered unacceptable under the Agriculture and Veterinary Chemicals (Control of Use) Act 1992 (the Act).

MRLs are set by the Commonwealth Government agencies – the Australian Pesticides and Veterinary Medicines Authority (APVMA) and Food Standards Australia New Zealand (FSANZ).

More information on how MRLs are set is available from the APVMA website.

Unacceptable residues are not a direct indication that produce is unsafe to consume

Human health risks are factored in when setting MRLs as part of the dietary exposure evaluation. MRLs are set well below concentrations which are known to have any adverse health effects and have substantial safety margins built into them. MRLs are set at a concentration based on how much of the chemical is needed to control pests and/or diseases and are not likely to be exceeded if used in accordance with directions on the label.

When considering if a residue is unacceptable, the result is compared to the MRLs set by both the APVMA and FSANZ. Where there is no MRL set for the chemical/commodity combination, any detectable residue is considered unacceptable. Where there may be a difference between the two MRL standards, the higher MRL is accepted when determining if a residue is unacceptable.

Codex guidelines

When interpreting residue data, it is important to understand the way in which produce is tested. The Codex Alimentarius is a collection of standards, guidelines and codes of practice that form a central part of the joint Food and Agriculture Organisation of the United Nations and World Health Organisation Food Standards Program. It was established to protect consumer health and promote fair practices in food trade.

Codex guideline CXG 41-1993 outlines the portion of a commodity to which an MRL applies. This guideline determines how produce is analysed to set an MRL and may be different to how that produce is traditionally consumed. For example, MRLs in avocados apply to the whole fruit (including the skin) with the seed removed, and pineapple MRLs are set based on analysis of the whole fruit (including skin) once the crown is removed. Watermelons and pumpkins are also analysed with their skin on.

This guideline further demonstrates that residues in produce do not automatically constitute a food safety risk. Once the skin is removed or the produce is washed, there may be a reduction in the residue profile of that produce.

TARP targets commodities where a potential risk of unacceptable residues has been identified for a given year. Agriculture Victoria uses several sources of information to determine where the risks lie.

The Commonwealth conducts a residue testing program via the National Residue Survey (NRS). The aims of the NRS are to demonstrate high levels of compliance with Australian and international food standards and help Australian agricultural industries to gain a commercial advantage from marketing ‘clean and green’ produce. If a commodity-specific issue is highlighted via the NRS and the risks cannot be managed within the structure of the NRS program, Agriculture Victoria will consider including that commodity in TARP. This ensures full traceability to the grower and helps establish a use pattern associated with the residue, which provides more clarity on how the issue can be managed by the industry.

The Australian Chamber of Fruit and Vegetable Industries trading as Fresh Market Australia (FMA) is the national industry body representing wholesalers and supporting business in Australia’s six central fruit and vegetable markets. FreshTest is an initiative of FMA to provide low-cost residue testing on behalf of its members. The de-identified results of this testing, which remain the intellectual property of FreshTest, are available for purchase as part of a subscription. Agriculture Victoria purchases this data and incorporates the trends or issues it identifies into the planning process for selecting commodities for a focus in TARP.

Many industries also participate in quality assurance programs, which are mandated by the produce outlets they supply. One aspect of quality assurance programs is being able to demonstrate that the produce being supplied meets MRLs. Producers may send their produce to interstate laboratories for analysis. In some states, it is mandatory to notify the state from which the produce originates when there is a residue breach in a sample.

Agriculture Victoria also works with the Australian Pesticides and Veterinary Medicines Authority (APVMA) to identify changes to label registrations or MRLs. Data generated from TARP may be used when considering these changes.

As TARP is non-voluntary, Agriculture Victoria also utilises other intelligence sources in the planning of TARP.

It is important to note that the commodities and produce sampled in the TARP is a small, targeted representation of the commodities and produce and does not represent the industry as a whole.

All samples are analysed by a contracted laboratories using analytical methods accredited to ISO/IEC 17025 standards which provides assurance that the tests will be undertaken to the necessary level of competence. Agriculture Victoria contracts laboratories that can analyse for multiple residues in each test, or screen. These screens provide an economical option for having samples analysed for a wide range of analytes.

The detection of an unacceptable residue is an indication that a chemical has not been used in accordance with GAP. It does not necessarily mean that there are health risks associated with the consumption of the food in which the residue was detected.

When an unacceptable residue is identified, Agriculture Victoria conducts a traceback investigation to determine the likely cause of the residue and highlight the importance of good agricultural practice (GAP) with the producer. Tracebacks investigations were conducted for 110 of the samples with unacceptable residues. For 2 samples, tracebacks were not initiated as the residue detected is the result of a naturally occurring compound in the produce.

Each traceback investigation is assessed for the most appropriate regulatory outcome, ranging from voluntary compliance and education to warning letters and fines and potentially prosecution. For all the tracebacks conducted in 2019-2024, letters of advice were issued to all growers. Letters of advice provide information that is designed to assist a grower prevent an MRL being exceeded in the future.  One, Contaminated Produce Notice was issued requiring the producer to keep the produce on-farm until it could be demonstrated that the residue had fallen below the MRL. The notice was removed prior to the conclusion of the investigation.

Once all yearly traceback investigations are completed, Agriculture Victoria may report consolidated findings to the industry body and relevant government authorities such as the APVMA.

Traceback investigations aim to determine the cause of an unacceptable residue. Common findings from traceback investigations (when the cause of a residue can be confirmed) are detailed below.

The table below summarises the causes identified for the 133 unacceptable residues detected.

Table 3. Summary of traceback findings

• Cross-contamination: Cross-contamination from on-farm or packing shed equipment is a common cause of unacceptable residues. This is evident when two or more commodities that had different post-harvest chemical treatments were being packed in the same facility. It is also known that some of the more volatile post-harvest chemicals can be absorbed by the surfaces of cool rooms. The chemical can then later be reabsorbed onto fruit stored in the cool room, resulting in unintended residues. Cross contamination occurred when bins were shared between two different industries that had very different chemical use practices.
• Off-label use: Both permitted off-label and illegal off-label chemical use has the potential to cause unexpected unacceptable residues. When chemicals are used in a permitted off-label manner, the producer may fail to verify that the manner in which the chemicals were being used did not result in unacceptable residues. In situations where a chemical is used illegally off-label, the evidence may identify that the chemical had either been used contrary to a DO NOT statement on the label or at a rate greater than the permitted application rate on the label.
• Internal farm spray drift: Internal farm spray drift may cause unacceptable residues when different crops are grown in rows adjacent to another and there is no physical barrier to prevent the chemical applied to one crop from drifting directly onto the neighbouring crop.
• Uptake of residual chemical: Some herbicide products have statements relating to plant back periods after they have been used. In most cases, these statements relate to preventing damage to following crops, but there is also a chance that the chemical can be bind to the soil and then be available to be taken up by following crops. Historical use of persistent chemicals that are no longer registered for use in Australia can also be taken up by some crops.

In addition to compliance action taken by Agriculture Victoria if chemicals are found to be used incorrectly, data from TARP is also used by:

• agencies such as the APVMA to review the MRLs set for chemical/commodity combinations. It is also used to identify trends in chemical use practices in the horticulture industries.
• peak industry bodies to help them affect change within their industry. The data provides evidence of the outcomes of chemicals being used in a particular manner.

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Table 1. Summary of commodities analysed for TARP July 2019 – June 2024

Table 2. Unacceptable residues detected for TARP July 2019 – June 2020

Notes: * denotes MRL set at or about the analytical limit of reporting (LOR).

T denotes temporary MRL set.

Table 3. Unacceptable residues detected for TARP July 2020 – June 2021

Notes: * denotes MRL set at or about the analytical limit of reporting (LOR).

T denotes temporary MRL set.

Table 4. Unacceptable residues detected for TARP July 2021 – June 2022

Notes: * denotes MRL set at or about the analytical limit of reporting (LOR).

T denotes temporary MRL set.

Table 5. Unacceptable residues detected for TARP July 2022 – June 2023

Notes: * denotes MRL set at or about the analytical limit of reporting (LOR).

T denotes temporary MRL set.

Table 6. Unacceptable residues detected for TARP July 2023 – June 2024

Notes: * denotes MRL set at or about the analytical limit of reporting (LOR).

T denotes temporary MRL set.