Results of Targeted AgChem Residue Program (TARP) 2015–2019

Summary of Targeted AgChem Residue Program (TARP) – July 2015 to June 2019

The annual Australian Total Diet Study (ATDS) conducted by Food Standards Australia and New Zealand (FSANZ) examines the dietary exposure of the Australian population to a range of agricultural and veterinary chemical chemicals (as well as other possible contaminants). The ATDS consistently finds that estimated dietary exposures are all below the relevant reference health standards for agricultural and veterinary (agvet) chemicals. The annual results of the Commonwealth Government’s National Residue Survey (NRS) also support Australia’s status as a producer of clean food.

Agriculture Victoria’s TARP results are consistent with these programs and indicate that the level of agriculture chemicals in Australian foods are very low, and generally consistent with chemical residue regulatory standards.

Summary

Agriculture Victoria undertakes a Targeted AgChem Residue Program (TARP) on a yearly basis. The testing program measures chemical residues against maximum residue limits (MRL) to assist in verifying if agricultural and veterinary chemical products are being used appropriately.

In the project years 2015–2019 TARP found 94.4 per cent of the samples collected were compliant with residue standards. Of the 1008 samples collected, 54 contained unacceptable residues. Cross-contamination from on-farm or packing shed equipment was the most common confirmed cause of unacceptable residues.

Detections above the MRLs are considered unacceptable under Victorian legislation, but unacceptable residues are not a direct indication that produce is unsafe to consume. MRLs have substantial human health safety margins built into them. MRL breaches can indicate poor chemical use practices.

TARP utilises a range of intelligence sources to identify and target commodities where unacceptable residues may highlight suspected chemical misuse within an industry.

When unacceptable residues are identified, Agriculture Victoria conducts a traceback investigation to identify the cause of the residue and then implements the most appropriate regulatory outcome.

Why does Agriculture Victoria test for chemical residues in fresh produce?

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), and 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.

How does Agriculture Victoria test for chemical residues in fresh produce?

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.

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.

How does Agriculture Victoria regulate agricultural and veterinary chemicals?

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.

What are maximum residue limits?

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, and 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.

How are commodities selected?

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, which may need an increased compliance focus to demonstrate appropriate chemical use.

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.

How are the samples analysed?

All samples are analysed by a contracted laboratory 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.

Summary of TARP 2015–2019

In the four years from July 2015 to June 2019, there were 1008 samples collected for analysis. All samples were collected over the commodity’s growing season. Samples were delivered to the laboratory contracted by Agriculture Victoria to undertake the residue analysis.

94.4 per cent of the samples were compliant with residue standards.

Unacceptable residues were detected in 56 (5.6 per cent) of the samples analysed. Seven of the samples had two unacceptable residues and two of the samples had three unacceptable residues. The other 47 samples only had one unacceptable residue detected in each of them. This resulted in the detection of 67 unacceptable residues being detected in 56 samples.

Of the 67 unacceptable residues, 23 (34.3 per cent) were considered unacceptable as there was no relevant APVMA or FSANZ MRL. Forty-four (65.7 per cent) of the residues were considered unacceptable as they were above one or both of the MRL standards.

Table 1. Summary of commodities analysed for TARP Jul 2015 – Jun 2019

Produce Category

Produce Group

Number samples with unacceptable residues#

Number unacceptable residues

Total samples analysed

Fruit

Tropical and sub-tropical fruit

15

23

90

Fruit

Pome fruit

5

6

77

Fruit

Stone fruit

4

4

99

Fruit

Citrus

3

3

18

Fruit

Berries and other small fruits

1

1

223

Fruit

Melons

0

0

7

Vegetables

Brassica (cole or cabbage) vegetables

1

1

132

Vegetables

Leafy vegetables (including brassica leafy vegetables)

9

10

85

Vegetables

Fruiting vegetables

6

6

121

Vegetables

Legume vegetable

1

1

17

Vegetables

Root and tuber

5

6

58

Nuts

Tree nuts

0

0

35

Grain

Oilseed and cereal

6

6

46

Notes: # Please note that some samples contain more than one unacceptable residue.

Table 2. Unacceptable residues detected for TARP Jul 2015 – Jun 2019

TARP Year

Produce Group

Produce Type

Chemical Detected

Residue Concentration (mg/kg)

FSANZ MRL (mg/kg)

APVMA MRL (mg/kg)

2015/16

Tropical and sub-tropical fruit

Avocado

imazalil

0.033

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Avocado

imazalil

0.21

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Avocado

thiabendazole

1.1

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Avocado

imazalil

2.1

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Avocado

thiabendazole

2.0

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Avocado

fludioxonil

0.29

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Avocado

imazalil

0.094

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Avocado

thiabendazole

0.021

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Fig

bifenthrin

0.014

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Fig

thiacloprid

0.015

No MRL

No MRL

2015/16

Tropical and sub-tropical fruit

Fig

bifenthrin

0.096

No MRL

No MRL

2017/18

Tropical and sub-tropical fruit

Avocado

thiabendazole

0.12

0.03

No MRL

2017/18

Tropical and sub-tropical fruit

Avocado

imazalil

0.24

No MRL

No MRL

2017/18

Tropical and sub-tropical fruit

Avocado

thiabendazole

0.067

0.03

No MRL

2017/18

Tropical and sub-tropical fruit

Feijoa

iprodione

0.64

0.1

No MRL

2017/18

Tropical and sub-tropical fruit

Persimmon

iprodione

0.14

0.1

No MRL

2017/18

Tropical and sub-tropical fruit

Persimmon

fludioxonil

0.11

0.02

No MRL

2017/18

Tropical and sub-tropical fruit

Persimmon

diphenylamine

0.75

No MRL

No MRL

2017/18

Tropical and sub-tropical fruit

Persimmon

propargite

0.028

No MRL

No MRL

2017/18

Tropical and sub-tropical fruit

Persimmon

bifenthrin

0.045

0.03

No MRL

2017/18

Tropical and sub-tropical fruit

Persimmon

iprodione

0.36

0.1

No MRL

2017/18

Tropical and sub-tropical fruit

Persimmon

iprodione

0.40

0.1

No MRL

2017/18

Tropical and sub-tropical fruit

Pomegranate

imazalil

0.068

No MRL

No MRL

2015/16

Pome fruit

Pear

fenvalerate

0.23

No MRL

No MRL

2015/16

Pome fruit

Quince

diphenylamine

0.18

No MRL

No MRL

2015/16

Pome fruit

Quince

diphenylamine

0.010

No MRL

No MRL

2015/16

Pome fruit

Quince

diphenylamine

0.31

No MRL

No MRL

2015/16

Pome fruit

Quince

thiabendazole

0.030

No MRL

No MRL

2017/18

Pome fruit

Pear

iprodione

3.6

3

3

2017/18

Stone fruit

Apricot

diphenylamine

0.016

No MRL

No MRL

2017/18

Stone fruit

Apricot

diphenylamine

0.035

No MRL

No MRL

2018/19

Stone fruit

Plum

imazalil

0.71

0.05

No MRL

2018/19

Stone fruit

Plum

carbendazim

0.015

No MRL

No MRL

2017/18

Citrus

Lemon

diphenylamine

0.055

No MRL

No MRL

2017/18

Citrus

Lemon

iprodione

0.30

0.1

No MRL

2017/18

Citrus

Lemon

diphenylamine

0.20

No MRL

No MRL

2018/19

Berries and other small fruits

Table grapes

carbaryl

0.011

*0.01

*0.01

2015/16

Brassica (cole or cabbage) vegetables

Broccoli

dithiocarbmates

3.3

2

2

2015/16

Leafy vegetable (including brassica leafy vegetables)

Kale

oxadixyl

0.012

No MRL

No MRL

2015/16

Leafy vegetable (including brassica leafy vegetables)

Kale

oxadixyl

0.021

No MRL

No MRL

2016/17

Leafy vegetable (including brassica leafy vegetables)

Kale

clothianidin

0.034

No MRL

No MRL

2016/17

Leafy vegetable (including brassica leafy vegetables)

Kale

cyazofamid

0.81

No MRL

No MRL

2016/17

Leafy vegetable (including brassica leafy vegetables)

Kale

fipronil

0.040

No MRL

No MRL

2016/17

Leafy vegetable (including brassica leafy vegetables)

Spinach

flutriafol

0.030

No MRL

No MRL

2016/17

Leafy vegetable (including brassica leafy vegetables)

Spinach

oxadixyl

0.027

No MRL

No MRL

2016/17

Leafy vegetable (including brassica leafy vegetables)

Spinach

oxadixyl

0.044

No MRL

No MRL

2016/17

Leafy vegetable (including brassica leafy vegetables)

Spinach

dithiocarbamates

7.2

5

5

2017/18

Leafy vegetable (including brassica leafy vegetables)

Chinese cabbage

Cyhalothrin

0.015

No MRL

No MRL

2015/16

Fruiting vegetables

Chilli

simazine

0.011

No MRL

No MRL

2015/16

Fruiting vegetables

Chilli

cyfluthrin

0.032

No MRL

No MRL

2015/16

Fruiting vegetables

Chilli

cypermethrin

0.064

*0.01

*0.01

2016/17

Fruiting vegetables

Cherry tomato

fluazinam

0.021

No MRL

No MRL

2016/17

Fruiting vegetables

Cherry tomato

fipronil

0.036

No MRL

No MRL

2017/18

Fruiting vegetables

Cucumber

imidacloprid

0.204

0.2

0.2

2017/18

Legume vegetable

Snow peas

chlorpyrifos

0.018

T*0.01

T*0.01

2018/19

Root and tuber vegetables

Turnip

dithiocarbamates

1.0

No MRL

No MRL

2018/19

Root and tuber vegetables

Turnip

azoxystrobin

0.013

No MRL

No MRL

2018/19

Root and tuber vegetables

Turnip

dithiocarbamates

0.86

No MRL

No MRL

2018/19

Root and tuber vegetables

Turnip

dithiocarbamates

1.0

No MRL

No MRL

2018/19

Root and tuber vegetables

Turnip

dithiocarbamates

1.8

No MRL

No MRL

2018/19

Root and tuber vegetables

Turnip

dithiocarbamates

2.5

No MRL

No MRL

2017/18

Grain

Canola

haloxyfop

0.19

0.1

0.1

2017/18

Grain

Canola

haloxyfop

0.12

0.1

0.1

2017/18

Grain

Canola

haloxyfop

0.13

0.1

0.1

2017/18

Grain

Canola

haloxyfop

0.27

0.1

0.1

2017/18

Grain

Canola

haloxyfop

0.18

0.1

0.1

2017/18

Grain

Wheat

thiamethoxam

0.06

*0.01

*0.01

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

T denotes temporary MRL set.

What does Agriculture Victoria do when unacceptable residues are detected?

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 with the producer. Tracebacks investigations were conducted for 54 of the samples with unacceptable residues. For two 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 2015-2019, 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.

The table below summarises the causes identified for the 67 unacceptable residues detected.

Table 3. Summary of traceback findings

Identified cause

Percentage of the unacceptable residues

Cross-contamination

31%

Unable to be confirmed

34%

Off-label use (permitted and illegal)

15%

Internal spray drift

12%

Uptake of residual chemical in soil

3%

Other

1%

Not conducted

3%

What are the common causes of unacceptable residues?

  • 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.
  • Unable to be confirmed: In some cases, the cause of unacceptable residue cannot be confirmed due to limited evidence to support the suspected cause. In some cases, a possible cause, such as internal or neighbouring spray drift was identified, but could not be confirmed.
  • Off-label use: Both permitted off-label use 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 evidence 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: Three per cent of the residues related to chemicals being persistent in soils and then being taken up by produce. 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.
  • Other causes: In one specific sample, clothianidin was detected but its use could not be confirmed. The grower’s chemical use records indicated that a product containing thiamethoxam had been used on the crop. It is known that thiamethoxam can break down and result in false clothianidin detections. In order to address this, the APVMA has since established an ‘All other foods’ MRL for clothianidin. This MRL ensures that when products containing thiamethoxam are used according to the label, the resulting clothianidin detections will not affect the residue status of the produce.
Page last updated: 22 Sep 2021