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ContentsSUBCHAPTER 570 - PESTICIDES570 - PESTICIDE INSPECTIONS 571 - CURRENT PRACTICES 572 - GROWERS 573 - PACKERS AND SHIPPERS 574 - PESTICIDE SUPPLIERS 575 - PESTICIDE APPLICATORS 576 - SAMPLE COLLECTIONS SUBCHAPTER 570 - PESTICIDES570 - PESTICIDE INSPECTIONSThe objective of a Pesticide Inspection is to determine the likelihood of excessive residues of significant pesticides in or on products in consumer channels, and to develop sources of information for uncovering improper use of pesticide chemicals. This requires directing coverage to two major areas:
Pesticide coverage must be provided during all food establishment inspections. Coverage of raw agricultural products will generally be on a growing-area basis. Problem areas include:
571 - CURRENT PRACTICESCooperative Activities - important sources of information relative to evaluating the "Pesticide Environment" include:
NOTE: The U.S. Department of Agriculture has a Pesticide Data Program (PDP), which provides data on pesticide use and residue detection. This program helps form the basis for conducting realistic dietary risk assessments and evaluating pesticide tolerances. Coordination of this program is multi-departmental, involving USDA, EPA and FDA, covered by a MOU (Federal Cooperative Agreements Manual). As a part of this program USDA collects data on agricultural chemical usage, and factors influencing chemical use, and collects pesticide residue data through cooperation with nine participating states. USDA provides this data to EPA, FDA and the public. Several USDA publications are listed below as reference material. The contact point at USDA for pesticide residue matters is: Martha Lamont, Chief
Reference materials - the following reference materials provide background and data necessary or helpful in evaluating current practices. This material should be available at the District office.
572 - GROWERSPreliminary investigation of growing areas at the start of the season will provide data necessary for district work planning including production schedules, types and acreage of crops, pesticides used and the names and addresses of growers and shippers. Growing Dates - The significant growing dates relative to pesticide usage are as follows:
Harvest Dates - The dates of the anticipated harvest season will provide planning information relative to pre-harvest application and shipping. Acreage - This will provide volume information for work planning. Pesticide Application - ascertain the actual pesticide application pattern for each crop. Look for objective evidence to document actual grower practice. Check the grower's supply of pesticide chemicals, look for used pesticide containers, visit his source of supply, etc. Check spraying and dusting practices. Establish if pesticide chemicals are used in such a manner that excessive residues might result. The following information provides a basis for evaluating pesticide usage:
Pesticide Misuse/Drift/Soil Contamination - Pesticide residues, which exceed established tolerances, action levels, or "regulatory analytical limits" may be caused by pesticide misuse which can include:
Other conditions, which may cause illegal residues, include spray drift and soil contamination. Drift may be documented by determining which crops and pesticides have been grown/used in fields adjacent to those sampled. Determine direction of prevailing winds and wind condition on the day of spraying. Selective sampling will aid in determining if drift occurred. Compliance Samples collected to document pesticide drift should be Flagged and noted in block 16 of the CR as "Drift Sample - Maintain as Individual Subs". Soil contamination by compounds, which are relatively stable in the environment, may cause systemic uptake of the compounds by growing crops. Follow-up investigations to violative samples may, in some limited cases, include soil samples as an attempt to determine the source of the contaminant. Do not routinely collect soil samples. 573 - PACKERS AND SHIPPERS
Follow the same general procedure as in IOM 572. Observe and report the following:
574 - PESTICIDE SUPPLIERSPesticide suppliers should be visited routinely during growing-area coverage. They may provide valuable information about pesticides being used on various crops in the growing area. Some suppliers may suggest spray schedules or advise growers about pesticide usage. Determine what representations were made by the manufacturer of pesticide chemicals for which there is only a temporary tolerance or experimental permit. Get copies of any correspondence relating to sale and use of these products. Obtain names of growers to whom sales are made if such sale was not for use on acreage assigned under the experimental permit. Collect Official Samples of any crops treated with the pesticide. 575 - PESTICIDE APPLICATORSPesticide applicators may provide valuable information about pesticides being used on various crops in the growing area. Interview several pesticide applicators, particularly those using airborne equipment. Determine the pesticide chemicals, their formulation, and on what crops they are currently being applied. Determine who supplies the pesticides and how they are prepared to assure proper concentration. If state law requires the applicator to keep a record of each spray application, request permission to review such records. Determine what steps are taken to assure drift on adjoining crops does not result in violative residues. Where there is likelihood of drift, collect Selective Samples from adjoining fields. 576 - SAMPLE COLLECTIONS
See IOM Sample Schedule Chart 3 - Pesticides.
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