UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Initial
Examination
of
Maximum
Residue
Levels
on
Exported
Fruit
for
Selected
Insecticide
Alternatives
to
Azinphos­
methyl
FROM:
Stephen
Smearman,
Economist
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503P)

Nikhil
Mallampalli,
Biologist
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503P)

THRU:
Arnet
Jones,
Chief
Biological
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503P)

Timothy
Kiely,
Acting
Chief
Economic
Analysis
Branch
Biological
and
Economic
Analysis
Division
(
7503P)

TO:
Diane
Isbell/
Margaret
Rice
Special
Review
&
Reregistration
Division
(
7508P)

Summary
The
Special
Review
and
Reregistration
Division
(
SRRD)
requested
that
BEAD
explore
the
maximum
residue
levels
(
MRL)
allowed
for
export
crops
for
various
alternatives
to
azinphos­
methyl
(
AZM)
if
AZM
is
no
longer
available
to
US
growers.
This
document
presents
a
brief
summary
of
the
export
value
and
the
MRL
status
for
alternatives
for
AZM
for
four
of
the
ten
sites
under
consideration
for
reregistration
in
Group
3.
These
four
are
apples,
pears,
blueberries,
and
cherries.
Also
included
are
tables
for
each
of
these
crops
that
illustrate
the
top
five
export
countries
(
in
terms
of
value)
to
which
these
crops
are
marketed.
BEAD
notes
that
not
all
export
market
countries
have
MRL
values
established.
However,
they
may
follow
the
Codex
Alimentarius
(
an
institution
affiliated
with
the
United
Nations)
or
European
Union
(
EU)
values
for
pesticides
for
which
they
have
not
established
their
own
MRLs.
Some
MRL
values
are
more
restrictive
than
the
US
and
are
shown
in
the
tables
below.
2
Background
There
are
ten
sites
or
uses
in
Group
3
(
as
defined
in
the
Memorandum
of
Agreement
on
AZM,
signed
in
2001
by
EPA
and
the
AZM
registrants).
These
include:
apples/
crabapples,
pears,
blueberries
(
highbush
and
lowbush,
cherries
(
sweet
and
tart),
parsley,
almonds,
pistachios,
walnuts,
Brussels
sprouts
and
nursery
stock.
BEAD
searched
the
USDA
Foreign
Agricultural
Service
(
FAS)
MRL
data
base,
the
Northwest
Horticultural
Council
website
and
other
sources
to
determine
the
MRL
status
for
key
insecticide
alternatives
to
AZM
for
four
crops
within
the
Group
3
crops
that
were
considered
to
have
significant
export
value
to
growers.
These
four
sites
are
apples,
cherries,
pears,
blueberries
(
listed
in
order
of
monetary
value
of
exports).
The
key
AZM
alternatives,
listed
in
the
tables
below,
are
those
that
were
discussed
in
detail
in
BEAD's
2005
assessments
of
AZM
use.
These
assessments
were
released
for
public
comment
in
late
2005
and
are
already
part
of
the
AZM
docket.
The
tables
below
show
MRL
values
(
or
lack
thereof)
separately
for
each
crop,
along
with
summaries
of
export
statistics
for
the
top
5
countries
to
which
each
crop
is
exported
from
the
USA.

In
terms
of
AZM
use
on
crops,
apples
are
a
major
component,
with
76%
of
AZM
total
pounds
applied
allocated
to
apples.
For
all
ten
sites
combined,
the
estimated
value
of
direct
yield
and
quality
losses
if
AZM
is
no
longer
available
is
estimated
to
be
$
71.5
million.
The
total
export
value
for
apples,
cherries,
pears
and
blueberries
is
estimated
to
be
$
560.8
million,
nearly
8
times
the
value
of
the
estimated
direct
yield
and
quality
losses
if
AZM
is
no
longer
available.
If
we
consider
only
those
countries
that
do
not
have
an
MRL
for
all
of
the
listed
alternatives
to
AZM,
the
potential
worst
case
loss
scenario
for
the
export
markets
ranges
from
$
290
million
to
$
333
million
(
this
excludes
Mexico's
imports
of
apples
and
pears,
and
Japan's
imports
of
cherries
since
these
markets
have
MRLs
for
all
key
AZM
alternatives
and
is
dependent
upon
more
restrictive
MRL
assumptions).
Compared
to
the
estimated
direct
yield
and
quality
losses
of
$
71.4
million
in
domestic
markets
if
AZM
is
no
longer
available
(
derived
from
BEAD's
2005
assessments
of
AZM
use),
this
estimated
potential
worst
case
loss
scenario
for
the
export
markets
is
nearly
4
times
the
loss
associated
with
yield
and
quality
on
the
low
end
of
the
range
to
4.6
times
on
the
high
end
of
the
range.

BEAD
cautions
the
reader
that
this
document
is
an
initial
examination
of
the
MRLs
for
AZM
alternatives,
which
is
based
on
a
few
prominent
information
sources.
Further,
MRLs
change
over
time
at
different
paces
in
different
countries,
and
individual
nations
provide
varying
levels
of
access
to
specific
MRLs
they
currently
use.
Therefore,
the
information
in
this
document
is
subject
to
change,
and
BEAD
welcomes
any
verifiable
corrections
regarding
MRLs.

Apples
Apples
are
the
most
valuable
export
crop
of
the
Group
3
crops.
Apple
exports
for
the
top
five
countries
are
valued
at
$
289.1
million
or
approximately
16
percent
of
total
US
apple
production
value.
Table
1
shows
the
MRL
status
of
key
AZM
alternatives
for
the
top
5
apple
export
market
nations.
Table
2
below
illustrates
the
top
five
export
market
countries
in
terms
of
export
value,
export
value
as
percent
of
total
exports,
and
as
a
percent
of
total
US
production
value.
Apple
exports
to
the
top
five
countries
out
of
105
reported
export
countries
(
listed
in
the
USDA
MRL
database)
account
for
59
percent
of
the
total
apple
export
market.
3
Table
1.
Apples:
Availability
of
MRLs
for
selected
alternatives
to
AZM
*
AZM
alternatives
discussed
in
detail
in
BEAD's
2005
AZM
reassessments
Country
Phosmet
Acetamiprid
Novaluron
Thiacloprid
Mexico
10
1
2
0.3
Canada
10
1
a
proposed
­
­
Taiwan
2a
1
a
­
­
Hong
Kong
10
­
­
­
Malaysia
10
a
­
­
­

US
10
1
2
0.3
Codex
c
10
­
{
3}
b
­
Sources:
USDA
Foreign
Agricultural
Services
(
FAS),
Agricultural
and
Tropical
Products
Division
(
www.
mrldatabase.
com);
Northwest
Horticultural
Council
(
www.
nwhort.
org).
Notes:
a
From
Northwest
Horticultural
website.
b
Proposed
as
per
the
Canadian
PMRA
Website
http://
www.
pmra­
arla.
gc.
ca/
english/
legis/
max­
re­
e.
html.
c
From
the
Codex
Alimentarius
website:
http://
www.
codexalimentarius.
net/
mrls/
pestdes/
jsp/
pest_
q­
e.
jsp.
{}
=
under
development
according
to
the
Report
of
the
Thirty
Eighth
Session
of
the
Codex
Committee
on
Pesticide
Residues,
Fortaleza
Brazil,
3­
8
April,
2006.
Available
at
http://
www.
codexalimentarius.
net.
­
=
MRL
not
listed.
*
MRL
figures
shown
are
in
parts
per
million
(
ppm),
except
for
Codex
values,
which
are
in
mg/
kg.

Table
2.
Apples:
Top
5
Export
Countries
in
Term
of
Value
for
US
Fresh
Apple
Producers
2005*

Country
Export
Value
($
1,000)**
As
%
of
Total
US
Exports
Export
Value
as
a
%
of
US
Production
Value
by
Country
of
Destination
1.
Mexico
99,651
20
5.6
2.
Canada
92,716
19
5.2
3.
Taiwan
44,231
9
2.5
4.
Hong
Kong
27,235
6
1.5
5.
Malaysia
25,306
5
1.4
Total
(
Top
5)
289,139
59%
16.2%
Total
Export
Value
as
a
Percent
of
Total
US
Production
Value:
28%
Export
Quantity
of
Crop
as
a
Percent
of
Total
US
Production:
20%

Sources:
US
Department
of
Commerce,
US
Census
Bureau,
Foreign
Trade
Statistics;
USDA
NASS
Agricultural
Statistics,
2005;
www.
fas.
usda.
gov/
ustrdscripts/
USReport.
exe,
US
Apple
2006.
Notes:
*
Top
5
destinations
out
of
105
reported
countries.

**
Total
Value
of
US
Apple
Exports
in
2005:
$
492.7
million.
Total
Value
of
US
Apple
Production
in
2004:
$
1.758
Billion.

Cherries
(
sweet)

Sweet
cherries
are
the
second
most
valuable
export
crop,
after
apples.
Tart
cherries
are
4
also
exported
for
processing
but
are
a
fraction
of
the
sweet
cherry
market
value.
Table
3
shows
the
MRL
status
of
key
AZM
alternatives
for
the
top
5
cherry
export
market
nations.
Table
4
illustrates
the
top
five
export
market
countries
in
terms
of
export
value
and
export
value
as
percent
of
total
exports
and
total
US
production
value.
Cherry
exports
for
the
top
five
countries
are
valued
at
$
167.7
million
or
approximately
38
percent
of
total
US
sweet
cherry
production
value.
Sweet
cherry
exports
to
the
top
five
out
of
56
reported
export
countries
listed
in
the
USDA
MRL
data
base
account
for
90
percent
of
the
total
sweet
cherry
export
market.

Table
3.
Cherries
(
sweet
and
tart):
Availability
of
MRLs
for
selected
alternatives
to
AZM
*
AZM
alternatives
discussed
in
detail
in
BEAD's
2005
AZM
reassessments
Country
Phosmet
Lambda
Cyhalothrin
Imidacloprid
Spinosad
Thiamethoxam
Japan
0.1
0.5
3
0.2
5
Canada
7
­
3
0.1b
0.02b
Taiwan
2
a
­
­
­
­
UK
2d
­
­
0.2
a
­
Australia
1
a
0.1
0.5
a
1.0a
­

US
10
0.5
3
0.2
0.5
Codex
c
10
­
{
0.5}
0.2
Sources:
USDA
Foreign
Agricultural
Services
(
FAS),
Agricultural
and
Tropical
Products
Division
(
www.
mrldatabase.
com);
Northwest
Horticultural
Council
(
www.
nwhort.
org).
Notes:
a
From
Northwest
Horticultural
website
only.
b
Proposed
per
PMRA
Website
http://
www.
pmra­
arla.
gc.
ca/
english/
legis/
max­
re­
e.
html.
c
From
the
Codex
Alimentarius
website:
http://
www.
codexalimentarius.
net/
mrls/
pestdes/
jsp/
pest_
q­
e.
jsp.
d
EU
MRL
{}
=
under
development
according
to
the
Report
of
the
Thirty
Eighth
Session
of
the
Codex
Committee
on
Pesticide
Residues,
Fortaleza
Brazil,
3­
8
April,
2006.
Available
at
http://
www.
codexalimentarius.
net.
­
=
MRL
not
listed
in
the
databases
examined.
*
MRL
figures
shown
are
in
parts
per
million
(
ppm),
except
for
Codex
values,
which
are
in
mg/
kg.

Table
4.
Cherries:
Top
5
Export
Countries
in
Terms
of
Value
for
US
Sweet
Cherries
Producers
2004*

Country
Export
Value
($
1,000)**
As
%
of
Total
US
Exports
Export
Value
as
a
%
of
US
Production
Value
by
Country
of
Destination
1.
Japan
$
82,605
46
18.9
2.
Canada
$
44,398
25
10
3.
Taiwan
$
19,503
11
4.5
4.
UK
$
10,856
6
2.4
5.
Australia
$
10,402
5.8
2.3
Total
(
Top
5)
$
167,764
89.7%
38.1%
Total
Export
Value
as
a
Percent
of
Total
US
Production
Value:
43%
Export
Quantity
of
Crop
as
a
Percent
of
Total
US
Production:
10%
Sources:
US
Department
of
Commerce,
US
Census
Bureau,
Foreign
Trade
Statistics;
USDA
NASS
Agricultural
Statistics,
2005;
www.
fas.
usda.
gov/
ustrdscripts/
USReport.
exe.
*
Top
5
destinations
out
of
56
reported
countries.
5
**
Total
Value
of
US
Fresh
and
Processed
Cherry
Exports
in
2004:
$
186.8
million.
Total
Value
of
US
Sweet
Cherry
Production
in
2004:
$
435.7
million.

Pears
Pear
exports
for
the
top
five
countries
are
valued
at
$
95.9
million
or
approximately
33
percent
of
total
US
pear
production
value.
Pear
exports
to
the
top
five
out
of
60
export
countries
account
for
83
percent
of
the
total
pear
exports.
Table
5
shows
the
MRL
status
of
key
AZM
alternatives
for
the
top
5
pear
export
market
nations.
Table
6
illustrates
the
top
five
countries
in
terms
of
export
value
and
export
value
as
percent
of
total
exports
and
total
US
production
value.

Table
5.
Pears:
Availability
of
MRLs
for
selected
alternatives
to
AZM
*
AZM
alternatives
discussed
in
detail
in
BEAD's
2005
AZM
reassessments
Country
Phosmet
Acetamiprid
Novaluron
Methoxyfenozide
Mexico
10
1
2
1.5
Canada
10
1
a
proposed
­
1.5
Brazil
­
­
­
­
Sweden
2c
­
­
­
Russia
­
­
­
­

US
10
1
2
1.5
Codex
b
10
­
{
3}
d
2
Sources:
USDA
Foreign
Agricultural
Services
(
FAS),
Agricultural
and
Tropical
Products
Division
(
www.
mrldatabase.
com);
Northwest
Horticultural
Council
(
www.
nwhort.
org).
Notes:
a
From
Northwest
Horticultural
website
only.
b
From
the
Codex
Alimentarius
website:
http://
www.
codexalimentarius.
net/
mrls/
pestdes/
jsp/
pest_
q­
e.
jsp.
c
EU
MRL
d
Proposed
per
PMRA
Website
http://
www.
pmra­
arla.
gc.
ca/
english/
legis/
max­
re­
e.
html
{}
=
under
development
according
to
the
Report
of
the
Thirty
Eighth
Session
of
the
Codex
Committee
on
Pesticide
Residues,
Fortaleza
Brazil,
3­
8
April,
2006.
Available
at
http://
www.
codexalimentarius.
net.
­
=
MRL
not
listed.
*
MRL
figures
shown
are
in
parts
per
million
(
ppm),
except
for
Codex
values,
which
are
in
mg/
kg.

Table
6.
Pears:
Top
5
Export
Countries
in
Terms
of
Value
for
US
Fresh
Pear
Producers
2004*

Country
Export
Value
($
1,000)**
As
%
of
Total
US
Exports
Export
Value
as
a
%
of
US
Production
Value
by
Country
of
Destination
1.
Mexico
$
44,967
40
16
2.
Canada
$
41,480
35
15
3.
Brazil
$
3,940
3.4
1.3
4.
Sweden
$
3,006
2.6
1.0
5.
Russian
(
fed)
$
2,558
2.2
0.009
Total
(
Top
5)
$
95,951
83%
33.3%
Total
Export
Value
as
a
Percent
of
Total
US
Production
Value:
40%
Export
Quantity
of
Crop
as
a
Percent
of
Total
US
Production:
10%
Sources:
US
Department
of
Commerce,
US
Census
Bureau,
Foreign
Trade
Statistics;
USDA
NASS
Agricultural
Statistics,
2005;
www.
fas.
usda.
gov/
ustrdscripts/
USReport.
exe;
USAPears.
com
2006.
6
*
Top
5
destinations
out
of
60
reported
countries.

**
Total
Value
of
US
Pear
Exports
in
2004:
$
115.3million.
Total
Value
of
US
Pear
Production
in
2004:
$
282.1
million
Blueberries
Of
the
Group
3
uses,
fresh,
frozen
blueberries
are
the
fourth
most
valuable
export
crop.
Blueberry
exports
for
the
top
five
countries
are
valued
at
$
8
million
or
approximately
2.5
percent
of
total
US
blueberry
production
value.
Blueberry
exports
to
the
top
five
out
of
26
reported
export
countries
listed
in
the
USDA
MRL
data
base
account
for
94
percent
of
the
total
blueberry
export
market.
Table
7
shows
the
MRL
status
of
key
AZM
alternatives
for
the
top
5
blueberry
export
market
nations.
Table
8
illustrates
the
top
five
export
market
countries
in
terms
of
export
value
and
export
value
as
percent
of
total
exports
and
total
US
production
value.

Table
7.
Blueberries
(
lowbush
and
highbush):
Availability
of
MRLs
for
selected
alternatives
to
AZM
*
AZM
alternatives
discussed
in
detail
in
BEAD's
2005
AZM
re­
assessments
Country
Phosmet
Esfenvalerate
Tebufenozide
Japan
10
­
3
Canada
5
­
­
Australia
­
­
­
Korea
­
­
­
UK
­
­
­

US
10
3b
3
Codex
a
10
1c
3
Sources:
USDA
Foreign
Agricultural
Services
(
FAS),
Agricultural
and
Tropical
Products
Division
(
www.
mrldatabase.
com).
Notes:
UK
defers
to
EU
MRL
levels
for
pesticides
if
the
country
has
not
set
its
own
MRL.
In
the
same
context,
Korea
defers
to
CODEX
MRL
levels.
Australia
follows
only
its
own
MRL
levels.
­
=
MRL
not
listed.
a
From
the
Codex
Alimentarius
website:
http://
www.
codexalimentarius.
net/
mrls/
pestdes/
jsp/
pest_
q­
e.
jsp.
b
Listed
in
CFR
but
not
in
FAS.
c
Expressed
as
fenvalerate
in
CODEX
database.
*
MRL
figures
shown
are
in
parts
per
million
(
ppm),
except
for
Codex
values,
which
are
in
mg/
kg.
7
Table
8.
Blueberries,
Cultivated,
Frozen:
Top
5
Export
Countries
in
Terms
of
Value
for
US
Blueberry
Producers
2004*

Country
Export
Value
($
1,000)**
As
%
of
Total
US
Exports
Export
Value
as
a
%
of
US
Total
Production
Value
by
Country
of
Destination
1.
Japan
$
3,860
45
1.3
2.
Canada
$
2,790
33
1.0
3.
Australia
$
652
7.6
0.002
4.
Korea
$
380
4.4
0.001
5.
UK
$
327
3.8
0.001
Total
(
Top
5)
$
8,009
94%
2.9%
Total
Export
Value
as
a
Percent
of
Total
US
Production
Value:
3%
Export
Quantity
of
Crop
as
a
Percent
of
Total
US
Production:
n/
a
Sources:
US
Department
of
Commerce,
US
Census
Bureau,
Foreign
Trade
Statistics;
USDA
NASS
Agricultural
Statistics,
2005;
www.
fas.
usda.
gov/
ustrdscripts/
USReport.
exe
*
Top
5
destinations
out
of
26
reported
countries.

**
Total
Value
of
US
Cultivated
Blueberry
Exports
in
2004:
$
8.5
million.
Total
Value
of
US
Cultivated
Blueberry
Production
in
2004:
$
275.9
million.

Total
Value
of
Apple,
Cherries,
Pears
and
Blueberry
Exports
for
the
Top
Five
Selected
Countries
for
Each
Site
The
total
value
for
the
apple,
cherries,
pears
and
blueberry
exports
for
the
top
five
countries
for
each
site
as
listed
above
is
$
560.8
million.
Table
9
below
shows
the
summary
value
of
total
exports
for
apples,
cherries,
pears
and
blueberries,
based
on
data
presented
in
Tables
2,
4,
6,
and
8.

While
it
is
difficult
and
speculative
to
predict
a
worst­
case
loss
scenario
for
the
export
market
in
the
absence
of
AZM,
looking
at
those
circumstances
where
relatively
few
alternatives
exist
with
an
MRL
in
the
export
country,
can
provide
some
sense
of
what
a
potential
worst­
case
scenario
might
look
like
were
AZM
not
available.
In
the
absence
of
AZM,
the
export
market
for
certain
crops
in
certain
countries
could
be
lost
if
MRLs
have
not
been
established
for
sufficient
alternative
pesticides
to
AZM.
While
MRLs
have
been
established
for
phosmet
for
most
of
the
Group
3
crops
in
most
of
the
major
export
countries
listed
above,
the
same
cannot
be
said
for
many
of
the
newer
alternatives
to
AZM
listed
in
the
tables
above.
This
will
likely
change
in
the
coming
years
as
MRLs
are
established
for
many
of
the
newer
pesticides.

If
we
consider
only
those
countries
that
do
not
have
an
MRL
for
all
of
the
listed
alternatives
to
AZM,
the
potential
worst
case
loss
scenario
for
the
export
markets
ranges
from
$
290
million
to
$
333
million
(
this
excludes
Mexico's
imports
of
apples
and
pears,
and
Japan's
imports
of
cherries
since
these
markets
have
MRLs
for
all
key
AZM
alternatives
and
is
dependent
upon
more
restrictive
MRL
assumptions
such
as
Canada's
cherry
MRL
levels).
Compared
to
the
estimated
direct
yield
and
quality
losses
of
$
71.4
million
in
domestic
markets
if
AZM
is
no
longer
available
(
derived
from
BEAD's
2005
assessments
of
AZM
use),
this
8
estimated
potential
worst
case
loss
scenario
for
the
export
markets
rnages
from
nearly
4
times
the
loss
associated
with
yield
and
quality
on
the
low
end
to
4.6
times
on
the
high
end
of
the
range.

In
the
short
term,
while
BEAD
expects
that
in
most
cases
phosmet
will
still
be
an
available,
efficacious
alternative
to
AZM
for
most
of
these
crops,
the
loss
of
AZM
would
leave
phosmet
as
the
single
cost­
effective
alternative
pest
control
option
for
some
crops
intended
for
certain
export
markets.
That
scenario
presents
a
risk
that
an
export
market
could
largely
be
lost
should
phosmet
become
unavailable.
These
concerns
existed
for
the
domestic
market
at
the
time
EPA
issued
the
2001
AZM
IRED
(
and
led
in
part
to
EPA's
time­
limited
determination
that
the
benefits
at
that
time
outweighed
the
risks)
and
they
appear
to
remain
to
some
degree
for
the
export
market
today.

However,
several
important
caveats
to
the
above
theoretical
worst
case
loss
scenarios
must
be
kept
in
mind.
The
amount
of
export
value
is
dependent
upon
the
number
of
crops
a
particular
country
imports
and
the
relative
value
of
those
crops.
The
estimated
impacts
may
be
higher
if
all
export
countries
were
included
in
this
analysis.
This
analysis
assumes
an
upperbound
loss
and
that
100%
of
the
export
market
in
some
of
these
countries
for
some
of
the
Group
3
crops
would
be
lost,
as
a
worst­
case
scenario
in
which
no
fruit
treated
with
AZM
alternatives
can
be
exported.
However,
as
described
in
the
tables
above,
most
export
market
countries
have
appear
to
have
MRLs
for
at
least
one
of
the
alternatives
listed.
Furthermore,
some
countries
use
EU,
CODEX,
or
US
MRLs
as
default
values
for
some
pesticides
and
many
MRLs
are
under
development.
Therefore,
it
is
highly
unlikely
that
the
entire
export
market
value
for
these
crops
in
the
circumstances
described
above
would
be
lost
if
AZM
alternatives
are
used.

Table
9.
Summary
of
the
Total
Export
Value
for
Apple,
Pear,
Cherry
and
Blueberries
by
Country
and
Comparison
to
AZM
Yield
and
Quality
Losses.
Top
10
Countries
Rank
in
$
Export
Value*
Total
Value
of
Exports
($
1,000)

1.
Australia
8
11,054
2.
Brazil
9
3,940
3.
Canada
1
181,384
4.
Hong
Kong
5
27,235
5.
Japan
3
86,465
6.
Korea
12
380
7.
Malaysia
6
25,306
8.
Mexico
2
144,618
9.
Russian
Fed
11
2,558
10.
Sweden
10
3,006
11.
Taiwan
4
63,734
12.
UK
7
11,183
Estimated
total
value
of
US
exports:
$
560,863,000
 
Rank
is
for
illustration
purposes
and
applies
only
to
this
analysis.
