MRL Pesticides

Below is a decision tree explaining when in the context of Article 19 of Regulation 178/2002 an exceedance of the maximum residue limit (MRL) for residues must or must not be reported to the Dutch Food Authority, taking into account the measurement uncertainty (to be found on the certificate of , max. 50%). MRLs can be found in the pesticide database of the European Commission ((EU Pesticides Database (europa.eu))

Decision tree

There is a health is determined by testing against the health-related limit value:- the Acute Reference Dose (ARfD)* of the active substance, or, if there is none, the Acceptable Daily Intake (ADI)** of the active substance. If both health-related limit values are not exceeded, it has yet to be determined whether the substance is a CMR (carcinogenic – mutagenic – reproduction toxic) substance. When testing whether there is a health risk, the measurement uncertainty should not be taken into account, and the analysis result should therefore be used. For the practical elaboration of the above, see the decision tree ‘assessment of health risk’ on the next page.

ARfD

*The ARfD is the amount of a substance that you can get in 1x without there being a health risk. The ARfD is therefore a health-related limit value for acute intake and not a standard. The ARfD can be found in the pesticide database.

ADI

**The ADI is the health-related limit value for long-term exposure. This is the amount of a substance that you can ingest daily for a long period of time without there being a health risk. The ADI can also be found in the MRL pesticide database.

Decision tree health risk assessment

Below is which steps must be taken when assessing whether there is a health risk and when it should or should not be reported. The Pesticide database is used for this and the EFSA Primo model (Pesticide residue intake model 3.1). In the decision tree below are the steps that must be followed to properly carry out the test whether there is a health risk. On the last page, a number of examples are given.

*CMR substances: carcinogenic, mutagenic and reproductively toxic substances. If a substance is a CMR substance, this is indicated in the EU Database for the active substance in question under the heading ‘classification’. Only if the indication 1a and/or 1b must be reported.

Examples

Intended in the that the analytical result for pesticide residues is higher than the MRL, but with deduction of measurement, uncertainty falls below or equal to the MRL.

Reference ValuesSourceReport status
Has no ARfD been established because it does not apply and does it say: “not applicable”? >> yesfluodioxinilADI : 0.37 mg/kg bw/dayARfD : N/ADR07/76DR07/76Do not report
Has an acute reference dose (ARfD) been established for the active substance? >> yesmetalaxylADI : 0.02 mg/kg bw/dayARfD : 0.5 mg/kg bw2010/28/EU 2010/28/EUReport if ingestion in PRIMO >100% of the ARfD
Has an Acceptable daily intake (ADI) been established but no ARfD? >> yespyrazophosADI : 0.004 mg/kg bw/dayARfD :IMPR 1993Report if ingestion in PRIMO >100% of the ARfD
Is the active substance a CMR* substance (1a or 1b)? >> yesanthraquinone (Classification Reg. 1272/2008-Carc 1B-H350)ADI :ARfD :

 Reporting (See Classification)
Has no ARfD been established due to insufficient data? It says: “not set due to insufficient data” >> yeschlorpyrifosADI : Not set due insufficient dataARfD : Not set due insufficient dataReg (EU) 2020/18 Reg (EU) 2020/18Report

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