Challenges in meeting growing MRL restrictions

Nov. 2, 2023 | 5 Min read
Domestic and export grain markets continue to revise their chemical regulations and maximum residue limits (MRLs) on grain that Australia supplies, writes Gerard McMullen.

Domestic and export grain markets continue to revise their chemical regulations and maximum residue limits (MRLs) on grain that Australia supplies, writes Gerard McMullen*.

As chair of the National Working Party on Grain Protection (NWPGP), I am responsible to the grain industry to provide information on the impact of using chemicals on market access.

Governments around the world are responsible for ensuring food for their consumers is safe to eat. Each country has chemical legislation based on their specific consumption patterns. Hence, different MRLs for the same chemical and commodity can apply in different markets.

There is a trend towards requiring lower (or nil) residues on grain supplied. Generally, markets with more sophisticated regulations alter MRLs frequently, whereas other markets may only alter their MRLs every few years. Despite this variance, markets are increasing their level of monitoring of imported grain to check compliance.

The challenge is that even if growers apply a chemical as per label directions, the resulting grain residue may not meet those market requirements. Growers generally don’t know the destination before applying a chemical. Nor may the storage agent receiving that grain or marketer when buying the grain from the grower.

All in the supply chain have a responsibility to understand the impacts of their operation in meeting these market requirements.

An example of the need for a whole of supply chain approach to managing chemical usage and residues is haloxyfop use on canola. The European Union (EU) banned its use in 2020. As per their normal practice, they recently announced their intention to reduce the MRL to a level of 0.05mg/kg.

At this level, the post-farm sector cannot mitigate the risks of residues arising above the proposed MRL through the usual management practices of seeking CVDs from growers of chemical use, segregation of treated canola, sampling and testing of canola and stock selection. Hence, the industry agreed on a strategy that to maintain market access, it was essential to provide growers with a recommendation that haloxyfop no longer be used on canola.

While some alternative chemistry is available, haloxyfop is a key tool for some growers. In the industry notice, growers were urged that where haloxyfop is used, to advise their marketer via a CVD. Growers are encouraged to truthfully declare use of a chemical where required, so that the post farmgate are aware of the risk of residues arising and can implement the necessary strategies to comply with the market requirement.

The above is one example where forward advice of a change in regulations was provided by the market. In other instances, little forewarning may be provided. Increasingly, key chemistry is not being supported by chemical registrants when being reviewed by markets or at international forums such as Codex Alimentarius which sets MRLs adopted by many of our key export grain markets.

There continues to be a focus on the needs for consumer views to be considered when marketing grain. Social licence, sustainability and traceability are all being spoken about for not just the grain we supply and food we eat, but also how that food is produced. In many instances, these terms have a different meaning to each consumer and government regulator, adding complexity.

In Australia, the APVMA is responsible for setting an MRL for that chemical and crop commodity combination when registering a chemical. They also review the ongoing use of a chemical and have recently been requested to “fast-track” the review of several chemicals, some of which such as the desiccants and rodenticides are used extensively by growers.

The challenge to produce a quality product that meets market requirements for grain quality, food safety and quarantine aspects will continue. Without access to those chemicals, or a whole of industry approach to managing any residues that may arise through use of those chemicals, we face a risk of losing market access to our competitors. Further advocacy is still needed to ensure the pre-farm and post-farmgate sectors understand their role in meeting consumer expectations in this rapidly changing environment.

As chair of NWPGP it is my role to work with industry and regulators to provide that guidance.

*As chair of the National Working Party on Grain Protection, Gerard McMullen provides information to the grain industry on the implications of chemical use on market access, domestic and export market requirements and chemical regulations. Email: 

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