Overview
Title
Emamectin Benzoate; Pesticide Tolerances
Agencies
ELI5 AI
The EPA has decided that it's safe for a tiny amount of a pesticide called emamectin benzoate to be on tea leaves, just like in Japan, so people, including kids, can drink tea without worries.
Summary AI
The Environmental Protection Agency (EPA) has issued a final rule establishing tolerances for residues of the pesticide emamectin benzoate on tea commodities. These tolerances were requested by Syngenta Crop Protection, LLC under the Federal Food, Drug, and Cosmetic Act. The tolerances for dried and instant tea are set at 0.5 parts per million (ppm) to align with Japanese standards. The rule ensures that the level of pesticide residue in tea is safe for the general population, including infants and children.
Abstract
This regulation establishes tolerances for residues of emamectin benzoate in or on tea commodities. Syngenta Crop Protection, LLC requested these tolerances under the Federal Food, Drug, and Cosmetic Act (FFDCA).
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AnalysisAI
Summary of the Document
The document issued by the Environmental Protection Agency (EPA) formalizes the establishment of tolerances for residues of the pesticide emamectin benzoate in tea commodities, specifically dried and instant tea. These tolerances, set at 0.5 parts per million (ppm), align with the standards set by Japan. This is in response to a request made by Syngenta Crop Protection, LLC under the Federal Food, Drug, and Cosmetic Act. The regulation aims to ensure that the amount of pesticide residue in tea is safe for everyone, including vulnerable groups like infants and children.
Significant Issues and Concerns
Several issues emerge from this regulation:
Lack of Alternatives and Environmental Assessment: The document does not address the availability of alternatives to the use of emamectin benzoate, raising concerns about potential environmental impacts. For stakeholders interested in sustainable practices, this omission suggests a potential gap in the evaluation of environmental consequences.
Harmonization Decisions: The adjustment of tolerance levels from 0.2 ppm to 0.5 ppm to align with Japanese standards is not thoroughly justified. This choice, without explanation, may lead to questions about why Japanese standards were prioritized over other international guidelines, creating speculation about the criteria used to make this decision.
Complex Risk Assessment: The language used to describe the risk assessment is intricate and could be challenging for those without a technical background. This complexity might lead to misunderstandings about the safety assurances provided by the EPA.
Reference to External Materials: The document frequently references previous rulemakings and sections not included within the current text. This reliance on external documents makes it difficult to fully understand the rule without additional resources, potentially frustrating those trying to grasp the regulation's complete context.
Potential Conflict of Interest: The key role played by Syngenta Crop Protection, LLC in petitioning for these tolerances may raise concerns about a potential conflict of interest, given the company's commercial interests in emamectin benzoate.
Absence of a Codex Standard: Notably absent is a Maximum Residue Limit (MRL) by the Codex Alimentarius for emamectin benzoate, serving as a point of concern. The document does not explain how this absence impacts the U.S. decision-making process.
Enforcement and Monitoring: The document falls short of detailing how the set tolerances will be monitored and enforced to ensure compliance and safeguard consumer safety, leaving an important aspect of regulatory practice unaddressed.
Impact on the Public and Stakeholders
This regulation potentially impacts the public by establishing a benchmark for pesticide safety in tea, contributing to consumer confidence. Assurance that emamectin benzoate residue levels are safe might alleviate public concerns about pesticide consumption through daily dietary intake.
However, specific stakeholders might experience varied impacts:
Agricultural Producers may benefit from standardized tolerances, which could assist in trade negotiations and compliance. Yet, the lack of exploration into pesticide alternatives could limit options for farms focused on ecological farming practices.
Health and Environmental Advocates might express caution due to the absence of comprehensive environmental impact assessments and thorough justifications for tolerance levels. Their interests in rigorous health standards and sustainable practices could feel inadequately represented.
International Trade Partners can view the alignment with Japanese standards as a positive step towards harmonized trade regulations, facilitating smoother trade dealings with countries adhering to similar standards.
In conclusion, while the regulation primarily aims to ensure the safety of tea products in the U.S., the document raises broader questions about environmental considerations and regulatory transparency, warranting close scrutiny by all interested parties.
Issues
• The regulation allows for the establishment of tolerances for residues of emamectin benzoate in or on tea commodities, but there is no discussion of potential alternatives to the pesticide or assessment of environmental impact, which might be considered in terms of wasteful spending or unnecessary environmental harm.
• The change in the tolerance level from 0.2 ppm to 0.5 ppm to align with Japanese MRL standards is mentioned, but there's no detailed explanation or justification for why the EPA chose to harmonize specifically with the Japanese standard rather than any other international standard.
• While the document states that no harm will result from aggregate exposure, the complexity of the risk assessment language may be difficult for a layperson to understand, potentially leading to misinterpretation of the safety determination.
• The document references various sections and previous rulemakings without providing detailed summaries within the document, which might be seen as overly complex or difficult to navigate without access to the referenced materials.
• Potential conflict of interest or favoritism concern arises from the close involvement of Syngenta Crop Protection, LLC in petitioning for these tolerances, especially if they stand to benefit commercially from this regulation.
• The absence of a Codex MRL for emamectin benzoate is noted, but the document fails to provide a rationale or significance of this absence in relation to the U.S. decision to establish a specific tolerance.
• There is a lack of detail on the measures for enforcement or monitoring of the emamectin benzoate tolerances once these are established, which could be seen as a gap in ensuring compliance and consumer safety.