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Corrective action if chemical residue is higher than specification?


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#1 foodsafetyAUS

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Posted 08 March 2019 - 09:10 AM

Hi dear members,
What is the corrective actions if one of chemical residues is slightly higher than specifications? We sent few raw materials such as parsley and rocket to the lab for MRL and the results came back with slightly out of specs. Not sure how dangerous is that specific chemical residues. Is there any resource for understanding MRL residues? What are corrective actions?



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#2 pHruit

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Posted 08 March 2019 - 09:20 AM

MRLs are generally set with something of a safety margin, so it's unlikely to pose an actual food safety risk.

Nonetheless it is potentially a regulatory issue - not sure how NZ views it, but in the EU it would not be legal to place the food on the market.

FSANZ will almost certainly publish the risk assessments/decisions that form the basis for MRLs - have a look at some of the links from here for starters: http://www.foodstand...es/default.aspx

MRLs are generally set by considering both the level of a chemical needed to achieve the desired function, and the potential impact of dietary exposure. If you're finding crops with excessive pesticide residues then it suggests that the grower may have applied too much, or may not have adhered to the recommended application timings ahead of harvest - some pesticides require a "break" between final application and harvesting.
 



#3 foodsafetyAUS

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Posted 31 March 2019 - 07:25 AM

MRLs are generally set with something of a safety margin, so it's unlikely to pose an actual food safety risk.
Nonetheless it is potentially a regulatory issue - not sure how NZ views it, but in the EU it would not be legal to place the food on the market.
FSANZ will almost certainly publish the risk assessments/decisions that form the basis for MRLs - have a look at some of the links from here for starters: http://www.foodstand...es/default.aspx
MRLs are generally set by considering both the level of a chemical needed to achieve the desired function, and the potential impact of dietary exposure. If you're finding crops with excessive pesticide residues then it suggests that the grower may have applied too much, or may not have adhered to the recommended application timings ahead of harvest - some pesticides require a "break" between final application and harvesting.


Interestingly we are now in trouble from Aldi that we sent a MRL result from one of our growers that is out of spec for Lead! We do not have procedure to indicate what corrective actions require for out of spec MRL.


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#4 pHruit

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Posted 01 April 2019 - 08:42 AM

You'll probably want to check FSANZ's take on it, but in general I'd expect Pb (and Cd, Hg along with some of the mycotoxins, aflatoxins etc) to be treated slightly differently to the MRLs for agrochemicals, as it's (hopefully!) not something that is intentionally applied to the crop.

My understanding is that the Aus/NZ view is similar to Europe where these would instead be considered as contaminants, but you're probably more familiar with the local regulatory position than I am.

 

Contaminants like Pb can be more tricky to resolve than a "simple" pesticide issue, as they are potentially related more to natural growing conditions, soil composition etc.

Nonetheless, as a start - what was the actual result, how does this compare to regulatory limit, what is the uncertainty in the analytical method etc.?

Is it a grower with whom you've been working for some time, and do you/they have historical data that can be reviewed to see if they have a history of higher (even if not excessive / problematic) levels of Pb in this crop?

Is this a newly introduced crop using land that previously grew something else in which no problems of this type were observed? Some crops pick Pb up from the soil more than others - for example in the EU the limit for e.g. apples is lower than for strawberries, as a reflection of this.



#5 Charles.C

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Posted 01 April 2019 - 09:01 AM

I also anticipate this is going to be a regulatory query,

 

If so the corrective action is presumably self-evident. Unless perhaps sampling is also a  factor.

 

So what are the regulatory MRL / heavy metal limits for Australia for Fresh Produce (i assume) ? Anyone ?


Kind Regards,

 

Charles.C


#6 pHruit

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Posted 01 April 2019 - 09:12 AM

I *think* I've successfully managed to upload a file (never tried before) with the relevant limits: https://www.ifsqn.co...nz-schedule-19/

Obviously we now also need to know what product foodsafetyAUS is looking at.



#7 Charles.C

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Posted 01 April 2019 - 09:29 AM

I *think* I've successfully managed to upload a file (never tried before) with the relevant limits: https://www.ifsqn.co...nz-schedule-19/

Obviously we now also need to know what product foodsafetyAUS is looking at.

 

Hi pHruit,

 

Actually I (after re-reading) deduce from OP that the poster already knows the legal limits.

 

If so, unless there is a n/average or nmMc type scenario involved(?), yr link in Post 3 seems to well answer the OP -

 

A maximum residue limit (MRL) is the highest amount of an agricultural or veterinary (agvet) chemical residue that is legally allowed in a food product sold in Australia whethe​r it is produced domestically or imported.

 

 

PS - yr attachment (thks), other than for Hg, seems to have no sampling procedure. Curious.


Kind Regards,

 

Charles.C





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