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early o n e - h a l f o f a l l fresh and frozen produce exported to the United States comes from Mexico. U S . imports of Mexican fruit went UD $100 million in 1990 over 1989 i d . u p $200 million for vegetables, according to U.S. Department of Agriculture lUSDAl data cited in the re cent U.S.'Gener.h Accounting Of :e (GAO) report "Pesticides: Comp ison of U S . and Mexican Pesti Standards and Enforcement" (I) In the United States, three cies-EPA, the Food and Administration (FDA), and US share the responsibility of re ing pesticides to protect hu health and the environment. In both countries one govern body-EPA in the United States i d CICOPLAFEST (the Intersecreta 31 Commission for the Control of tk Production and Use of Pesticide-, Fertilizers, and Toxic Substances) in Mexico-uses an application process that reviews data as the basis for granting or denying a pesticide registration and setting tolerances. CICOPLAFEST, created in 1987,coordinates and makes all scientific and regulatory decisions on
BY STANTON S. MILLER especially data generate< by the United States to as review process. lown the The GAC Wf-u..uuo he United States and Mexico 1
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Pesticide standards play an important role in free trade discussions because the importation of produce from Mexico is big business.
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gorie 'hat have mces ries but have Mexican tolerances for some commodities without comparable U S . tolerances; pesticides that have tolerances in Mexico but not in the United States; and pesticides that have tolerances in both
a higher volume and a wider variety of peppers (e.g., serrano, jalapeno, and chili) than U.S. farmers do. Although CICOPLAFEST frequently uses EPA reviews of data for setting tolerances, it may also use reviews from Codex or from other developed countries. [In 1962,Codex (the LCodex Alimentarius Commission) i created under the auspices of United Nations to establish iniational standards, codes of k!ice, and guidelines for differI and for food quality and ocerns, including pesticide Lodex standards are voluntary mly enforceable if adopted and as national regulations. Pestibtolerances are expressed by Coas a maximum residue limit and similar in meanine to EPA's defion of a to1erance.T Appendix I of the GAO report lists the 58 uesticides and the commodities t h k have Mexican tolerances without comparable U S . tolerances. Appendix 111 lists the five pesticides that have never had EPA registrations and tolerances for food commodities: azocyclotin, bitertanol, carbendazim, omethoate, and propamocarb hydrochloride. These
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W.S. AND uesticides, fertilizers, and toxic substances. Basicallv. reeistrations are li" censes for specific pesticide use that state the terms, conditions, and cautions of these uses. In other words, a pesticide registered for use only on tomatoes cannot be used on strawberries unless another registration is obtained to use the pesticide on strawberries. d
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Tolerances Tolerances are the maximum limits of pesticide residues that are allowed in or on foods. Both EPA and CICOPLAFEST register pesticides and assess tolerances by reviewing pesticide registration applications and data. EPA does not rely on the results of data reviews generated by other nations in its review of a registration application, whereas CICOPLAFEST uses such information,
countries for the same commodities, but the tolerances are set at different levels. Fifty-eight pesticides have tolerances for produce in both countries, but not necessarily the same commodity ( I ) . Tolerances between the two countries differ. For example, Mexico has set tolerances for broccoli and cabbage and the United States has not. In addition, 17 pesticides with Mexican tolerances have no U.S. tolerances: the pesticide azocyclotin, for example, has Mexican tolerances for apples, avocados, beans, and peaches. Several factors account for tolerance differences, such as climate, soil composition, and kinds of pests. Therefore Mexico has different pesticide needs and crop-growing patterns than does the United States. For example, the GAO report observes that Mexican farmers grow
IS00 Environ. Sci. Technol., VoI. 26, No. 10, 1992
pesticides have tolerances in Mexico for produce that the United States generally imports in large quantities from Mexico, such as avocados, beans, melons, and strawberries. Monitoring The United States and Mexico differ in the way they monitor for safe levels of pesticide residues on Mexican produce entering t h e United States. FJJA has a sampling program to monitor imports and a special program to test Mexican produce for pesticide residues. In contrast, the Mexican government generally has limited monitoring capabilities for exported produce. Instead, the private sector has assumed responsibility for monitoring exports. However, these private entities test their food when they see fit to do so. A new government
0013-936W92/0926-1900$03.00/0 0 1992 American Chemical Society
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MEX ICAN PESTICIDE STANDARDS Similarities and Differences program to establish a network of residue-testing laboratories may help the government strengthen its role in monitoring residues on exported produce, When Mexican food is found in violation of U.S. tolerances, it is either sent back to Mexico or destroyed. What's new The United States, Mexico, and Canada are now negotiating a North American Free Trade Agreement (NAFTA). Pesticide standards play an important role in free trade discussions because the importation of
fruits and vegetables to this country from Mexico is big business. The NAFTA negotiations have brought to light many environmental issues as they relate to international trade policy. To work out the NAFTA details, the negotiators have set up 18 working groups with representatives from Canada, Mexico, and the United States. In May 1991 a working group of U S . and Mexican officials was established to discuss options for resolving differences between the two countries. Altogether 487 pesticides have tolerances i n the United
States, in Mexico, and in both countries. It is in each country's best interest to work together to minimize the number of differences. Reference [ I ) "Pesticides: Comparison of U S . and
Mexican Pesticide Standards and Enforcement": U. S. General Accounting Office: Gaithersburg, MD. J u n e 1992; GAOlRCEDP32-140. IAvailable from the U.S. General Accounting Office, P.O. Box 6015, Gaithersburg. MD 20877; (202) 275-6241,]
Stonton S . Miller is the managing editor ofES&T.
Enviran. Sci. Technol.. Val. 26, No. 10. 1992 1901
