Note by the Secretariat:
The following document is a summary of the Manual on the Safe Use of Pesticides in Cocoa Growing prepared by Dr. Roy Bateman, Expert at the International Pesticide Application Research Centre (IPARC) and ICCO Consultant on pesticide matters. The complete document can be downloaded here.
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Manual on the safe use of pesticides in cocoa growing
The new European Union (EU) Regulation on Maximum Residue Limits on Pesticides (MRLs), EC No. 149/2008 dated 29 January 2008, came into force in the European Union on 2 September 2008. This regulation amended regulation EC No. 396/2005 dated 23 February 2005. The new legislation harmonizes the different regulations that applied in the individual Member States of the European Union and sets maximum levels on the amount of pesticides allowed on imported foods including cocoa beans.
Specific MRLs already established in the EU are listed in Annex II of the legislation. Annex III is split into two parts: Part IIIA contains all temporary MRLs for substances still undergoing approval for use at EU level or no longer approved for use in the EU, while Annex IIIB contains temporary MRLs for all active substances for new commodities (including cocoa) based on national MRLs, where risk assessment has been performed by the European Food Safety Authority (EFSA). Annex IV contains products already assessed at EU level for which MRLs are not necessary.
In September 2005, the ICCO Executive Committee adopted an Action Programme on Pesticides in a drive to ensure that the new EU legislation on MRLs introduced in February 2005 would not unduly affect the cocoa sector by the imposition of unreasonable MRLs for cocoa beans. In the framework of the Action Programme, the ICCO Secretariat compiled comprehensive information on the types of pesticides used on cocoa in producing Member countries. The information received was subsequently sent to an expert on pesticide matters for comparison with the EU Positive List. The expert provided the ICCO with a comprehensive report which was presented at the 132nd meeting of the Executive Committee in March 2007. The resulting technical advice was directly passed on to the countries concerned.
It was further suggested to all producing countries to carry out a pesticide audit, prioritizing the issues. As an example, it was thought that many residues originating from the treatment of cocoa beans in storage constituted the highest risk group, followed by insecticides applied in the field, fungicides and herbicides.The expert on pesticide matters was subsequently requested to produce a Manual on the Safe Use of Pesticides in Cocoa Growing to provide the necessary guidance to the relevant stakeholders. An outline of the first draft of the Manual was presented to the Executive Committee at its 136th meeting in May 2008. The completed document is now available and has been placed on the ICCO website. The ICCO Secretariat hereby presents a summary covering the salient points of the Manual (www.icco.org).C
Contents of the Document
In the first and introductory section, the document provides a list of the most common constraints (pests and diseases) faced by cocoa, their geographical distribution in the world and the frequency of pesticide use to control them. It also reviews the main categories of stakeholders in the debate on pesticides, each with their separate agendas:
The Agrochemical (now often called Life Sciences) industry: principally the half dozen multinational companies which have made considerable investment in new technologies and wish to protect their interests with patents and confidentiality;
Companies producing “generic” products: they benefit farmers by pushing down the prices of agrochemical products when patents expire (“off-patent” compounds);
Consumer groups and activists: they voice concerns on the safety and/or usefulness of pesticides which are often shared by the general public. It is also argued that these groups need regular exposure to maintain their profile and to justify their existence;
Media: they are interested in selling newspapers and/or in viewer ratings, so sometimes they give priority to colourful and sensational stories. They are not really interested in an objective debate;
National Governments and, increasingly, international bodies: these bodies have to balance the various interests at hand and establish an appropriate framework for the players involved to act in a fair and efficient manner; and
Research Scientists: they seek research grants to continue to remain in employment and may be tempted to influence research funding bodies by carefully timed and purpose-designed press releases more for their own benefit than for that of the general public. They may also over-emphasize a safety concern in order to secure funding.
After reviewing the stakeholders involved in the pesticides debate, the document examines the main issues associated with chemical control. These include:
Safety aspects including real and potential risks to growers and consumers;
Cost-effectiveness, perhaps of greatest interest to farmers;
Technical problems with pesticide applications, including development of resistance and resurgence and;
Other sustainability concerns including general impact on the environment.
The document then provides an overview on the importance of pesticide registration and adherence to measures and regulations published mainly by the Food and Agriculture Organization (FAO), the World Health Organization (WHO), the Codex Alimentarius Commission, the European Union, the US Environment Protection Agency, the Food Sanitation Law in Japan and other leading agencies in the world.
Finally, the concept of Integrated Crop Management is reviewed, with its components (cultural methods, clonal selection and other genetic methods, the preservation and/or manipulation of biological agents and the application of chemical pesticides in a sensible way) and that of Rational Pesticide Use (RPU) as a component of Good Agricultural Practice (GAP).
In the second section of the document, the term “pesticide” is explained and the meaning of the names and composition of pesticides is reviewed as well as their biological activity, application rate, types of control, mode of action and technical problems encountered. Finally bio pesticides, organic production and the search for alternative viable solutions are examined.
In the third section, the hazards of unsafe use of pesticides are reviewed and the concept of Maximum Residue Limits (MRLs) for cocoa, the safe use (Acceptable Daily Intake) and the biodegradation of pesticides explained. Information is also provided on how MRLs for cocoa are assessed in practice and what can be done to mitigate the residue problems.
In the fourth section, Good Agricultural Practices (GAPs) are reviewed, including matters to think about before picking up a sprayer, Pesticide selection, Personal Protective Equipment (PPE), Maintenance of equipment, How to spray cocoa, Containers and Hygiene and finally Post-spray Evaluation.
In the fifth section, good practices in crop storage are examined, including the main pests associated with storage and the importance of non-chemical controls, the application and timing of insecticide treatments in storage, pesticide selection, inspection, sampling and documentation/traceability.
In the sixth section, general and region-specific recommendations are given as well as the need for focussed, practical research on pesticide application and on strategic cocoa pesticides.
In the annexes, some technical terms and abbreviations used in pesticide science are presented, followed by the classification of acute toxicity and the list of pesticides that must be avoided in cocoa.
Finally, a list of websites of organizations that can provide further information on the subject is given.
Since publication of the Manual in June 2008, new information has come to light in relation to two products, Metalaxyl and pirimiphos-methyl, listed in Appendix 3. Regarding Metalaxyl, Regulation EC No. 1313/2007 dated 8 November 2007 allowed its use up to the end of the year 2010. Metalaxyl must therefore be removed from Appendix 3B (pesticides that must be avoided) and included in Appendix 3A (pesticides authorized for use in cocoa).
Concerning pirimiphos-methyl, the ICCO has been informed by Syngenta, manufacturer of the chemical compound, that products containing this active ingredient should not be used on cocoa, whether in the field, in post harvest treatment or in storage areas for cocoa, as this could result in residues above the EU MRL of 0.05 mg/kg. Pesticides containing pirimiphos-methyl, such as Cocostar and Actellic, should be avoided on cocoa. Existing stocks should be disposed of safely or used on crops for which it is officially approved. Pirimiphos-methyl should therefore be considered as included in Appendix 3B (pesticides that must be avoided on cocoa).
The issue of pesticide residues is kept under constant review, following decisions on MRLs for active substances taken by the European Food Safety Authority (EFSA) and other leading international agencies. In addition, new developments such as the issues described in paragraphs 18-20 may come to light from time to time. Hence the ICCO is presently making arrangements for the Manual on the Safe Use of Pesticides to undergo periodic updates. The first update is due to take place towards the end of the current year and a revised version of the Manual is to be placed on the ICCO website in the first quarter of 2009.