Tea and Pesticides - Toxic Blend

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Subject:  Toxic Blend
 Date:     Wed, 17 Apr 2002 11:34:29 -0400
From:      Stephen Tvedten <steve@getipm.com>
Organization:     Get Set Inc. (www.getipm.com)

To:     Paul Helliker <phelliker@cdpr.ca.gov>
          Director, State of California, Department of Pesticide Regulation 

cc:    Christine Whitman whitman.christine@epa.gov

Amid mounting global concern over pesticide residue levels in tea, safeguards have been erected to weed out the harmful supplies of the beverage. Transparency and scientific observations should ideally be the 1ingredients in the setting of such standards. But when science gives out a political aroma and governments use these benchmarks to camouflage protectionism, there’s trouble brewing

In 1995, Indian exporters got a rude shock when a consignment of Darjeeling tea was rejected by Germany . The reason for this drastic measure: the tea leaves contained excessive pesticide residue levels. The unsavoury incident left a bitter aftertaste in India , but the fact remains that the tea did contain banned toxic substances. It is also true that since then, neither have any domestic standards been set for maximum pesticide residues in tea nor an effort made to curb unscrupulous exporters (some of them are known to give one sample for clearance and another for actual export). This unhealthy blend of inaction and non-implementation has left the country just as susceptible as it was seven years ago to non-tariff trade barriers and unfair practices of developed nations.

Germany had rejected the Darjeeling Gold brand of tea from market leader Teekanne because it contained 0.24 milligrammes (mg) of tetradifon — a pesticide used against mites in horticultural crops, cotton, hops, tea and rice — per kilogramme (kg) of tea. This was 24 times the maximum residue level (MRL) fixed by Germany . MRLs indicate the maximum amount of pesticide levels in foodstuffs allowed by any country.

Indian exporters argued that the tetradifon levels found in Darjeeling tea were within the standards set by the US Environmental Protection Agency (EPA), which then allowed a maximum limit of 8 mg/kg. However, their contention that tea liquor and not tea leaves should be tested for pesticide residue levels did not cut much ice with the Germans. The tea was also found to contain ethion, which is used to control leaf-eating insects and mites, above the stipulated German levels.

Interestingly, the main producer of tetradifon in India was a German manufacturer which sold it under the brand name Tidion. The product was banned in India in 1992. When the controversy erupted, it was believed that the use of leftover stocks had led to the lapse.

Flavoured with politics Over one and a half billion cups of tea are consumed daily all over the world. In fact, tea is said to be the second most consumed beverage after water. With so much at stake, it is not surprising that a North-South divide has emerged where industry lobbies in both the regions exert their influence over key policy matters. Concern has been expressed over the domestic environmental policies of developed nations adversely affecting market access of products from developing countries. These laws are often so stringent that developing countries lack the technical and financial ability to comply with them.

In this context, it is widely believed that the 1995 German ban was protectionist. Veena Jha of UNCTAD (United Nations Conference on Trade and Development) puts the issue into perspective: "Doubts have arisen about the justifiability of the objections about pesticide residue in the European market. The German MRLs were arbitrarily imposed because of lack of data from India on its pesticide safety limits."

Ironically, this was done right under the nose of an international standard-setting body — the Codex Alimentarius Commission (see box: Codex strives for some bite). This global watchdog has been established under the aegis of FAO (Food and Agriculture Organisation) and WHO (World Health Organisation) and is recognised by the WTO (World Trade Organisation) for fixing technical specifications as well as benchmarks for all agricultural commodities including tea. While it cannot impose its standards, countries that adhere to Codex guidelines automatically conform to international trade rules. Significantly, Codex has not set a standard for tetradifon.

T C Choudhary, director of research, Tea Board, Kolkata, optimistically claims that "the problems have been sorted out due to our successful campaign amongst tea growers". His confidence may, however, be misplaced considering the fact that reports of pesticide residues in tea continue to pour in. "That tetradifon was banned in India before it was detected in tea indicates a poor enforcement regime," points out Mohammed Saqib, consultant at the Rajiv Gandhi Institute for Contemporary Studies, Rajiv Gandhi Foundation, New Delhi . The tea producers take the stand that at US $ 200 per sample, the cost of testing for maximum residue levels is prohibitive in Germany and amounts to non-trade barriers.

Biswajit Dhar, senior fellow, Research and Information System For the Non-Aligned and Other Developing Countries, a New Delhi-based ngo (non-governmental organisation), echoes their views: "These regulations have the potential to create barriers to trade, particularly for products exported by developing countries, despite several agreements to safeguard their business interests."

The correct dosage MRL science — meant to protect the health by determining the amount of pesticide residues that can be tolerated by humans — is the key to this business. But it is complicated and takes time, as it involves collection of sufficient data from different agro-ecosystems and quantification of what is known.

The residue data obtained from analysed samples is evaluated by experts, who then recommend an MRL consistent with national good agricultural practices (GAPS). Each country’s authorised safe uses of pesticides under actual conditions necessary for effective pest control are included in their GAPS.

The acceptable daily intake (ADI) is a quantitative expression of acceptable daily amounts of residue that can be ingested on a long-term basis and which is established on the basis of toxicological data from animal studies.

But the lack of sufficient data on pesticide residue and toxicological studies on ADI leads to the setting of MRLs through temporary acceptable daily intake (TADI). A TADI estimated by the joint FAO/WHO meeting on pesticide residues normally involves the application of a safety factor larger than that used in estimating an ADI.

In such cases, Germany applies a default value based on the limit of determination for the pesticide. This translates into the lowest level at which residues of the pesticide can be detected, quantified and confirmed in the product. Such a limit is also referred to as ‘zero’ tolerance. Jha points out that "these levels are impossible to maintain even if a minuscule amount of the pesticide is being used".

Toxic infusions The seasonal appearance of pests during tea cultivation necessitates timely management of the crop through pesticides. However, care has to be taken not to overdose on pesticides because this can lead to a high residue level of toxic substances in tea leaves in excess of the MRL set by importing countries. Consequently, emphasis is laid on striking a balance between pest toxicity and mammalian toxicity.

Pests that commonly attack tea crop include mites, thrips, jassids, helopeltis, mosquitoes, bugs, leaf-eating beetles and defoliating caterpillars. Tetradifon is the most effective pesticide to counter a potent pest — the red spider (Oligonychus coffeae). For other mites, dicofol and ethion are used.

Endosulfan helps tackle pests such as thrips, jassids, aphids, helopeltis and other sap-feeders. Unlike mites, sap-feeders disperse rapidly and can be dealt with by applying pesticides over a large area. Organophosphate insecticides such as quinalphos and phosphamidon are also used to control sap-feeders and leaf-eaters. When conventional chlorinated hydrocarbons like endosulfan fail to control leaf-eating beetles and defoliating caterpillars, synthetic pyrethroides like deltamethrin are applied. On account of the complex pest situation in tea cultivation a total avoidance of pesticides does not appear feasible, say industry observers. It is in this context that MRL assumes importance.

http://www.cseindia.org/html/dte/dte20020415/dte_srep.htm

Well Mr. Helliker, there are safe and far more effective alternatives yet the "industry observers" continue to pretend your "registered" POISONS are the "only answer".  My alternatives work far better, and on Earth Day I will give the people of the world a chance to avoid continued exposure to their pest problems and your "registered" POISONS.

Respectfully,  Stephen L. Tvedten

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