6 replies to this topic

[mind over matter]

Customer requires our subsidiary a pesticide residue analysis from our suppliers (small farmers). Our subsidiary thinks that this requirement is only applicable to the big suppliers and not to farmers. They cannot expect farmers to provide residue analysis. Besides, they said that their small farmers didn’t use pesticides.

What would you advice?

If the standard says so, I would appreciate anyone could provide a sample of pesticide residue analysis whether in a form of procedure, instruction or a log sheet.

Thanks a lot.

[Tony-C]

Customer requires our subsidiary a pesticide residue analysis from our suppliers (small farmers). Our subsidiary thinks that this requirement is only applicable to the big suppliers and not to farmers. They cannot expect farmers to provide residue analysis. Besides, they said that their small farmers didn’t use pesticides.

What would you advice?

If the standard says so, I would appreciate anyone could provide a sample of pesticide residue analysis whether in a form of procedure, instruction or a log sheet.

Thanks a lot.

Responsibility for residue testing should be agreed in supply contracts. Either way you or your suppliers should arrange to conduct periodic surveys on pesticide levels to demonstrate due diligence.

[Charles.C]

Dear MOM,

I agree with Tony's Policy / Procedural statement. Verification is surely an integral part of due diligence.

A few hopefully pragmatic thoughts (done before I saw Tony's post) –

Various (unknown) local factors are possibly involved.

I presume you hv a mutually agreed supplier specification which includes a pesticide statement which covers yr customers requirements, eg no use of pesticides or an equivalent regulatory wording.
I presume there is no requirement in the supplier specification which includes COAs and that supplier is not prepared to pay for same.
I presume customer will not proceed without COA
I presume you are in principle willing to pay for COA ( )

Would appear that only way to proceed with business is to either find another compliant supplier or arrange for appropriate COA yourself. Some suggested aspects for latter -

1. Possible risk / benefit evaluation - Yr estimate of “Value” of Customer/Business vs Yr estimate of cost of COA
2. Yr Estimate of reliability of COA / the estimated risk of any claim/loss of reputation etc should the result subsequently be found incorrect.

The risk of error in COA is typically dependent on the cost outlay.

Of course, some local knowledge may simplify the decision, eg if it is common knowledge that all suppliers are using pesticides indiscriminatively.

Rgds / Charles.C

[mind over matter]

Thanks Tony C and Charles C,

I was thinking the following:

Option 1) Including in the criteria of evaluating suppliers lines something like

“Do you use chemical pesticides?”
[ ] Yes - if yes, state the pesticides and attached pesticide residue analysis.
[ ] No

Since they don’t use pesticides, they will just check the “No” checkbox. Do you think it will suffice?

Option 2) Certification stating that suppliers (farmers) didn’t use pesticides in farming. Since they cannot expect farmers to provide residue analysis, supporting papers, etc, can our subsidiary provide certification so suppliers will just sign said certificate? If somebody is doing that method, I would very much appreciate if you could share sample certificate or sample wordings I can use as a guide as I am really swamped with documentation right now but will try to write my own.

Please let me know your thoughts on this. Thanks a lot.

[Charles.C]

Dear MOM,

I deduce from yr post that the existing agreed specification does not cover the use of and/or acceptable levels of "pesticides" in the product.
Yr option 2 is basically therefore revising the specification. This is a possible procedure but presumably will not affect the existing request for a COA (which provides ongoing "verification".)
Any comment regarding contaminants in product specifications is usually required by the customer to, at a minimum, include compliance with importing countries regulatory requirements plus maybe specific additional requirements also. On occasions, the latter require further discussion. Sometimes agreement is simply impossible.

Tony's first post is a representative statement of fact. Naturally suppliers prefer to minimise their expenditure on such issues (or prefer not to know )

Rgds / Charles.C

[mind over matter]

I suggested that farmers to sign a form signifying that they did not use pesticide. If they did, they need to provide a list of pesticide use and the amount then the company can do the analysis. Or the company can require specific pesticide to use something that the company has already done analysis with. Am I on the right track? Did i advice them correctly?

[Anish]

MOM,

Just wants to share my previous experiences as a EU chilli & spice exporter from India. We were having a contract cultivation programme with the farmers from whom we purchase the RM's. We guide the farmers from the beginning of planting stage till the end for pesticide application - what kind of pesticide can be used and in what level based on EU MRL's. And we have strict monitoring in the farming level through regular supervision and labortory testing (in our factory through GC-MS with GC-NPD, ECD & FID testing) during the cropping period till the harvesting, storage and when it reaches the factory for production. If we find any farmer violating our rules - that if he uses any other pesticide apart from our listing - we will suspend him from the programme.

Its a very tedious job as it involves total dedication from farming, training of the farmer groups and periodical discussion with the farmer groups to understand growth of the plant and pest problems.

Sampling is also very important - to ensure the laboratory results. We also send our samples regularly to EUROFINS and other laboratories and we do participate in FAPAS to prove our laboratory accuracy by cross checking.

And FYI, even if the farmer is not using the pesticide - you will get residue of some other pesticides - which was used earlier or which is used in the neighbouring farms. So, its very important to choose the farmer based on his land location.

And very important things to share for your knowledge about pesticide is some items in the name of organic / natural pesticide in the market is not really a organic pesticide and it contains the synthetic pesticide. So, if the farmer brings any pesticide as organic - we test it and then suggest for further use.

I dont think any farmer will agree to provide COA as the testing is very expensive and they don't know how to do sampling and where to send.

If your company wants to establish the testing facility - it needs lots of investment and skilled people - specialized in pesticide residue analysis. You will get the procedure for analysis from US FDA PAM and MRL details from EUROPA website.

If you need more info regarding this please let me know.

Regards,
anish

I suggested that farmers to sign a form signifying that they did not use pesticide. If they did, they need to provide a list of pesticide use and the amount then the company can do the analysis. Or the company can require specific pesticide to use something that the company has already done analysis with. Am I on the right track? Did i advice them correctly?