UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460      

	OFFICE OF CHEMICAL SAFETY AND

                                                                        
                      POLLUTION PREVENTION

	

  SEQ CHAPTER \h \r 1 MEMORANDUM

  SEQ CHAPTER \h \r 1 

DATE: November 15, 2010

SUBJECT:	ChemSAC Review of the USDA IR-4 Crop Grouping Proposal to Amend
the Tree Nut Crop Group 14, and Analysis of the USDA IR-4 Petition to
Amend the Crop Group Regulation 40 CFR § 180.41 (16) and Commodity
Definitions [40 CFR § 180.1 (g)].

FROM:	Bernard A. Schneider, Ph.D., Senior Plant Physiologist

Chemistry and Exposure Branch  

Health Effects Division (7509P)  

TO:	Michael Doherty, Ph.D. and William Donovan, Ph.D., 

Chairpersons HED Chemistry Science Advisory Council (ChemSAC)

		Jennifer Selwyn, PMRA

		Felix Valera, SAGARPA, Mexico

	Barbara Madden, Minor Use Officer, RD (7505P)

		Laura Nollen, RD (7505P)

cc: 	IR-4 Project, Bill Barney, Jerry Baron, Dan Kunkel, Debbie
Carpenter, Van Starner 

BACKGROUND:

	The current Crop Group 14, Tree Nuts group published in 40 CFR 180.41
(14) includes 12 commodity entries in seven botanical families including
Anacardiaceae, Betulaceae, Fagaceae, Juglandaceae, Lecythidaceae,
Proteaceae, and Rosaceae.  Almond and pecan were selected as
representative commodities for this group.  There have been 55 group
tolerances established on tree nut crop group based on the residue data
generated from the representative crops.  

	Botanically, a nut is a hard indehiscent (not opening at maturity)
one-seeded fruit.  It is also defined as a hard shelled fruit or seed of
which the kernel is eaten by humans.  A nut is the seed of a tree. 
However, a nut in commerce and cuisine has a much less restrictive
definition than a nut in botany.  The term is applied to many seeds that
are not true nuts.  Any large kernel found within a shell and used in
food may be regarded as a nut.  For example, almond is the edible seed
of a drupe, while the Brazil nut is the seed from a capsule.  Candlenut
and cashew nut are seeds.  Pine nut is the seed of several species of
pine, while the pistachio nut is the seed of a thin-shelled drupe. 
Peanuts can be disqualified from “nuts” because peanuts include two
or three seeds in the indehiscent pod and are legume crops. 

	Since the tree nut crop group is a somewhat artificial crop group and
because the various crops within the group come from diverse families,
they are not expected to be susceptible to the same pests and diseases
requiring the same pesticide treatment.  There are 18 different plant
families represented in this proposed tree nut crop group.  However, in
practice, residues (expressed on the edible portion) in tree nuts from
field use are often low or not detectable irrespective of the pesticide
use, so a tree nut group tolerance can be achieved.  Most are grown in
similar orchard or plantations and maintained with similar cultural
practices.  Comparing U.S., Codex, and the EU Tree nut
MRL’s/tolerances based on residue data generated from the
representative crops range from 0.01 to 0.5 ppm with one Codex tolerance
established at 1 ppm for carbaryl.  Most U.S. tolerances for the Tree
Nuts are < 0.2 ppm.

	Since this crop group was established in 1995, more species and
varieties of tree nuts have become popular in commercial production and
some in international trade.  Tree nuts that were previously considered
as orphan crops include tropical almond, betelnut, coconut, ginkgo,
heartnut, bur oak, pili nut, pine nut and pistachio.

	The Crop Group 14 proposal was generated at the USDA/IR-4 Crop Grouping
Symposium in Washington, DC, October 2002 by the Temperate Tree and
Small Fruit Workgroup Chaired by Van Starner of USDA, IR-4 and
Co-Chaired by Craig Hunter, Canadian Horticultural Center, Rick
Melnicoe, University of California Department of Environmental
Toxicology, Dr. Richard Loranger and Chris Olinger, EPA, HED and John
Wise, Michigan State University.  It was further discussed and developed
within the Tree Nut Workgroup of the International Crop Grouping
Consulting Committee (ICGCC).  This workgroup consists of 200 crop or
regulatory experts from the US, NAFTA, EU, Asia, Middle East, Africa,
and Latin America regions representing 30 countries.  The Workgroup
discussed and validated each of the existing crop group commodities and
representative commodities.  It was proposed that “Filbert
(hazelnut)” be changed to “Hazelnut (filbert)”.  Additional tree
nuts proposed at the Symposium included guana, nut-o-nogal, cajou,
dalison, okari nut, bunya and candlenut.  These additional tree nuts
were also validated at the Symposium, except it was later determined
that dalison should be considered as part of the tropical fruit group. 
Also, guana was not included in this submission since it apparently only
grows in eastern Cuba and is a threatened species.  It was determined
that nut-o-nogal is a alternative name for black walnut and will be
included in the EPA Food and Feed Commodity Vocabulary as a lookup term.
 

The concept of having separate temperate and tropical/subtropical
subgroups was not validated at the Symposium, so no subgroups are
proposed in this submission.  The Symposium also proposed crop
definitions for the representative crops of almond and pecan, but due to
the previously discussed diverse taxonomic nature of tree nuts, no crop
definitions are proposed in this submission.

	Another important aspect is the harmonization with the Codex crop
classification.  The Codex Classification of foods and animal feeds for
Tree nut Group is also undergoing revision.  The IR-4/EPA Crop Grouping
Working Group and the International Crop Grouping Consulting Committee
(ICGCC) are collaborating with the revision of the Codex crop
classification.  The expanded Tree Nut Group and the representative
commodities proposed in this petition would facilitate the harmonization
of the U.S. and the Codex crop classification systems.  Proposed
additions to the Codex Classification including Brazilian pine,
castanha-do-maranhao, Guiana chestnut and monkey-pot were also included
in the petition.

	Other tree nuts presented to the ICGCC but not validated include the
Australian or Moreton Bay chestnut, canarium nut, shea nut, suari nut,
African walnut and tallow tree.  Two proposed crops, purging nut and
karanj were not accepted because of the poisonous nature of the nut or
bean and because development of these crops is primarily for biofuel. 
One additional proposed crop kalamungay (Moringa oleifera) will be
considered to be added to a future tropical fruit crop group.  Further
work by the ICGCC also identified four more potential commodities to be
proposed for the Tree nut group.  They are the African nut tree
[Ricinodendron heudelotii (Baill.) Heckel], dika nut [Irvingia
gabonensis (Aubry-Lecomte ex O’Rorke) Baill.], mongongo nut
[Schinziophtyon rautanenii (Schinz) Radcl.-Sm.], and the peach palm nut
(Bactris gasipaes Kunth var gasipaes).

The world total hectares for tree nuts (almond, betelnut, brazil nut,
cashew, chestnut, coconut, hazelnut, pistachio, and walnut) reported by
FAO (FAO 2009, have increased from 17,420,730 hectares (ha) in 1997 to
19,961,492 ha in 2007, and the total production of these nuts has
increased from 57,174,933 metric tons in 1997 to 72,519,897 metric tons
in 2007.

Some “minor” tree nut commodities like the chestnut, pili nut, pine
nut, and okari nut are becoming more popular.  Some of these nuts
don’t have large commercial production, and thus have little chance to
be added to pest control products labels unless they are placed in the
tree nut group.  By being excluded from the crop groups, means that
tolerances requested for these commodities would have to be established
based on separate residue studies.  Without a doubt the inclusion of
these commodities in crop groups will benefit growers, consumers, save
time and tax payer’s money on residue studies, save government
agencies time in reviewing residue data, as well as facilitating the
establishment of import tolerances.  Many of these crops are of economic
importance or have a great potential to be grown in larger scale in the
future due to their nutritional value or medicinal value, or the
increased market demand driven by both the growing ethnic populations
and greater awareness of these crops by the non-ethnic population as a
whole.  The American cuisine has a distinct global nature that includes
many orphan crops not yet in a crop group.  

REQUEST:

	William P. Barney, Crop Grouping Project Coordinator and Tracey Switek,
USDA Interregional Research Project No. 4 (IR-4), State Agricultural
Experiment Station, Rutgers University has submitted a petition (May 29,
2008) on behalf of the IR-4 Project, and the Tree Nuts Workgroup of the
International Crop Grouping Consulting Committee (ICGCC) to amend the
Crop Group Regulation 40 CFR § 180.41 (c) (16) Crop Group 14, Tree Nut
Group. 

	The above-mentioned Tree nut crop group petition requested the
following four proposals:

IR-4 Proposal 1: “Amend the existing crop group in 40 CFR 180.41 (c)
(14) that consists of following twelve commodity entries:

Almond, Prunus dulcis (Mill.) D.A. Webb (Rosaceae)

Beechnut, Fagus spp. (Fagaceae)

Brazil nut, Bertholletia excelsa Bonpl. (Lecythidaceae)

Butternut, Juglans cinerea L. (Juglandaceae)

Cashew, Anacardium occidentale L. (Anacardiaceae)

Chestnut, Castanea spp. (Fagaceae)

Chinquapin, Castanea pumila (L.) Mill. (Fagaceae) 

Filbert (Hazelnut), Corylus spp. (Betulaceae)

Hickory nut, Carya spp. (Juglandaceae)

Macadamia nut, Macadamia integrifolia Maiden & Betche (Proteaceae) 

Pecan, Carya illinoinensis (Wangenh.) K.Koch (Juglandaceae)

Walnut, black and English, Juglans spp. (Juglandaceae);

To an expanded crop group that consists of following Thirty-two
commodity entries:

Almond, Prunus dulcis (Mill.) D.A. Webb (Rosaceae)

Beechnut, Fagus spp. (Fagaceae)

Betelnut, Areca catechu L. (Arecaceae (Palmae))

Brazil nut, Bertholletia excelsa Bonpl. (Lecythidaceae)

Brazilian pine, Araucaria angustifolia ((Bertol.) Kuntze (Araucariaceae)

Bunya, Araucaria bidwillii Hook. (Araucariaceae) 

Bur oak, Quercus macrocarpa Michx. (Fagaceae)

Butternut, Juglans cinerea L. (Juglandaceae)

Cajou nut, Anacardium giganteum Hancock ex Engl. (Anacardiaceae)

Candlenut, Aleurites moluccanus (L.) Willd. (Euphorbiaceae) 

Cashew, Anacardium occidentale L. (Anacardiaceae)

Castanha-do-maranhao, Pachira glabra Pasq. (Malvaceae)

Chestnut (Chinquapin), Castanea spp. (Fagaceae)

Coconut, Cocos nucifera L. (Arecaceae (Palmae))

Ginkgo, Ginkgo biloba L. (Ginkgoaceae)

Guiana chestnut, Pachira aquatic Aubl. (Malvaceae)

Hazelnut (Filbert), Corylus spp. (Betulaceae)

Heartnut, Juglans ailantifolia var. cordiformis (Makino) Rehder
(Juglandaceae)

Hickory nut, Carya spp. (Juglandaceae)

Japanese horse-chestnut, Aesculus turbinata Blume (Sapindaceae)

Macadamia nut, Macadamia integrifolia Maiden & Betche (Proteaceae) 

Monkey-pot, Lecythis pisonis Cambess. (Lecythidaceae)

Okari nut, Terminalia kaernbachii Warb. (Combretaceae)

Pachira nut, Pachira insignis (Sw.) Savigny (Malvaceae)

Pecan, Carya illinoinensis (Wangenh.) K.Koch (Juglandaceae)

Pequi, Caryocar spp. (Caryocaraceae)

Pili nut, Canarium ovatum Engl. (Bursraceae)

Pine nut, Pinus edulis Engelm. (Pinaceae)

Pistachio, Pistacia vera L. (Anacardiaceae)

Sapucaia nut, Lecythis zabucaja Aubl. (Lecythidaceae)

Tropical almond, Terminalia catappa L. (Combretaceae)

Walnut, black, Juglans spp. (Juglandaceae) and Walnut, English, Juglans
regia L. (Juglandaceae) 

And all edible varieties and/or hybrids of Fagus species, Castanea
species, Corylus species, Carya species, Caryocar species, and Juglans
species.”

IR-4 Proposal 2:  Representative Commodities: 

IR-4 recommends that the following commodities, 

Almond and pecan remain as representative commodities for the expanded
group.

IR-4 Proposal 3. Crop Subgroups: 

No crop subgroups are proposed for the Tree Nuts crop group.  

IR-4 Proposal 4. Crop Definitions: 

No commodity definitions for the Tree Nuts are proposed or were
recommended at this time.

HED RECOMMENDATIONS:

	Each of the proposals and recommendations will be discussed below,
followed by a series of other recommendations on terminology, database
development, and harmonization with Codex.  The EPA would like to
commend the valuable and high quality input of the ICGCC, all its
members, and the Committee Chairperson Bill Barney, USDA IR-4, as well
as Dr. Yuen-Shaung Ng, Biologist, HED, Doug Dotson, Chemist, Susan
Stanton, Roger Chesser, Andy Ertman, and Laura Nollen, Biologists, RD,
EPA for their input and development of various databases in this report
and Dr. Paul Schwartz, USDA, Office of Minor Use Pesticides for his
advice and peer review of the analysis.

IR-4 Proposal 1:

1. “Amend the existing crop group that consists of twelve commodity
entries 40 CFR 180.41 (c) (14)”

To an expanded crop group that consists of following thirty-eight
commodity entries: 

Tree Nut Commodities

African nut tree	Hazelnut (Filbert)

Almond	Heartnut

Beechnut	Hickory Nut

Betelnut	Japanese horse-chestnut

Brazil nut	Macadamia nut

Brazilian pine	Monkey-pot

Bunya	Mongongo nut

Bur oak	Okari nut

Butternut	Pachira nut

Cajou nut	Peach palm nut

Candlenut	Pecan

Cashew	Pequi

Castanha-do-maranhao	Pili nut

Chestnut	Pine nut

Chinquapin	Pistachio

Coconut	Sapucaia nuts

Dika nut	Tropical almond

Ginkgo	Walnut, black

Guiana chestnut	Walnut, English

And all edible varieties and/or hybrids of Fagus species, Castanea
species, Corylus species, Carya species, Caryocar species, and Juglans
species.”

HED Recommendations for Proposal 1:

	Based on similarities of the comparison of tree nuts cultural
practices, edible food and animal feed items, residue levels,
geographical locations, processing, established tolerances, and for
international harmonization purposes, I recommend that ChemSAC concur to
amend the Tree Nut Crop Group 14 from twelve commodities to thirty –
nine commodities (See Table 1).  There are 18 different plant families
represented in this proposed tree nut crop group.  Since the tree nut
crop group is a somewhat artificial crop group and because the various
crops within the group come from diverse families, and they are all not
expected to be susceptible to the same pests and diseases requiring the
same pesticide treatment, but their harvesting, processing (hulling,
drying), marketing, uses, and nutritional value are very similar. Also,
in practice, residues (expressed on the edible portion) in tree nuts
from field use are often low or not detectable irrespective of the
pesticide use, so a tree nut group tolerance can be achieved, and most
are grown in similar orchard or plantations and maintained with similar
cultural practices.   The members of this crop group have similar uses,
and all are consumed after maturity or consumed cooked or roasted in
various recipes including salads, meats, and cookies.  Some of these
tree nuts also have medicinal properties.  Many of the tree nuts from
the same botanical family with similar biological and cultural aspects
suggests they should also encounter similar pest problems and hence have
similar needs for pest control products in similar use patterns.  All of
these commodities except for betelnut were found to have similar
characteristics and uses to become a member of the Tree nut group.  

	While USDA IR-4 also recommended adding betelnut to the Tree nut group,
however, after analysis of this crop, I recommend ChemSAC concur not to
add this commodity to this crop group.  Betelnut is used mostly as a
stimulant crop and is chewed during the day, so it does not share the
traditional uses of the tree nut crops.  Also, I recommend deleting
Castanha-do-maranhao (Pachira glabra Pasq), because it is limited to
Brazil, endangered, and appears at this timing to have limited chance of
further expansion.

	There were no crop subgroups proposed by IR-4 for this crop group.  HED
is also recommending adding three other commodities that meet the tree
nut criteria to the group.  The three commodities are: coquito nut,
monkey puzzle nut, and yellowhorn.  These three nuts are available to
grow in the U.S. and coquito nut is already available in the marketplace
and in commercial nursery catalogs.  Therefore, the recommended Tree nut
crop group 14 -10 or 14-11 commodities are listed in Table 1 below and
include their appropriate scientific names.  Table 2 contains a
comparison between the current Tree Nut Crop Group and the recommended
changes to the proposed Tree Nut Crop Group 14-10 or 14-11.

“HED Recommended Tree Nut Crop Group 14 – 10 or 14-11”.

Commodities

African nut tree, Ricinodendron heudelotii (Baill.) Heckel

Almond, Prunus dulcis (Mill.) D.A. Webb

Beechnut, Fagus grandifolia Ehrh., F. sylvatica L., F. sylvatica L.
subsp. sylvatica  

Brazil nut, Bertholletia excelsa Humb. & Bonpl.

Brazilian pine, Araucaria angustifolia (Bertol.) Kuntze

Bunya, Araucaria bidwillii Hook.

Bur Oak, Quercus macrocarpa Michx.

Butternut, Juglans cinerea L.

Cajou nut, Anacardium giganteum Hance ex Engl.

Candlenut, Aleurites moluccanus (L.) Willd.

Cashew, Anacardium occidentale L.

Chestnut, Castanea crenata Siebold & Zucc., C. dentata (Marshall)
Borkh., C. mollissima Blume, C. sativa Mill.

Chinquapin, Castanea pumila (L.) Mill., Castanea ozarkensis Ashe

Coconut, Cocos nucifera L.

Coquito nut, Jubaea chilensis (Molina) Baill.

Dika nut, Irvingia gabonensis (Aubry-Lecomte ex O’Rorke) Baill.

Ginkgo, Ginkgo biloba L.

Guiana chestnut, Pachira aquatica Aubl.

Hazelnut (Filbert), Corylus americana Marshall, C. avellana L., C.
californica (A. DC.) Rose, C. chinensis Franch.

Heartnut, Juglans ailantifolia Carrière var. cordiformis (Makino)
Rehder, Juglans ailantifolia Carrière

Hickory nut, Carya cathayensis Sarg., C. glabra (Mill.) Sweet, C.
laciniosa (F. Michx.) W. P. C. Barton, C. myristiciformis (F. Michx.)
Elliott, .C. ovata (Mill.) K. Koch, C. tomentosa (Lam.) Nutt.

Japanese horse-chestnut, Aesculus turbinata Blume

Macadamia nut, Macadamia integrifolia Maiden & Betche, Macadamia
tetraphylla L.A.S. Johnson

Mongongo nut, Schinziophyton rautanenii (Schinz) Radcl.-Sm.

Monkey-pot, Lecythis pisonis Cambess.

Monkey puzzle nut, Araucaria araucana (Molina) K. Koch

Okari nut, Terminalia kaernbachii Warb.

Pachira nut, Pachira insignis (Sw.) Savigny

Peach palm nut, Bactris gasipaes Kunth var. gasipaes

Pecan, Carya illinoinensis (Wangenh.) K.Koch

Pequi, Caryocar brasiliense Cambess., C. villosum (Aubl.) Pers, Caryocar
nuciferum L.

Pili nut, Canarium ovatum Engl., Canarium vulgare Leenh. Canarium
indicum L.

Pine nut, Pinus edulis Engelm., P. koraiensis Siebold & Zucc., P.
sibirica Du Tour, P. pumila (Pall.) Regel, P. gerardiana Wall. ex D.
Don, P.  monophylla Torr. & Frém., P. quadrifolia Parl. ex Sudw. P.
pinea L.

Pistachio, Pistacia vera L.

Sapucaia nut, Lecythis zabucaja Aubl.

Tropical almond, Terminalia catappa L.

Walnut, black, Juglans hindsii Jeps. ex R. E. Sm., J. microcarpa
Berland., J. nigra L.

Walnut, English, Juglans regia L.

Yellowhorn, Xanthoceras sorbifolium Bunge

Cultivars, varieties, and/or hybrids of these commodities 



HED Additional Recommendation for Proposal 1:

HED also recommends that in the crop group table the term “all edible
varieties and/or hybrids of Fagus species, Castanea species, Corylus
species, Carya species, Caryocar species, and Juglans species varieties
and/or hybrids of these” should be changed to, “Cultivars,
varieties, and hybrids, of these commodities” will avoid all confusion
with terminology regarding whether they are cultivars, varieties, or
hybrids of the any tree nut commodities.  This is also consistent with
the other revised crop groups completed to date.

HED also recommends changing the preferred commodity name for filbert to
hazelnut, since hazelnut is the commodity term used in international
trade and the U.S. Hazelnut Growers Marketing Board since 1981 has
changed their name from filbert to hazelnut even though filbert is the
correct name for the tree and nut.  The name is of French origin and the
tree was likely first introduced into Oregon by early French settlers. 
Hazelnut is the name coined by the English and it was applied to the
native species by early settlers.  The EPA Food and Feed Commodity
Vocabulary (http://www.epa.gov/pesticides/foodfeed) for filbert will be
changed to hazelnut as the preferred commodity term in the next
vocabulary update.

Table 2.  EPA Crop Group Proposals Comparison of the Current Established
EPA Tree Nut Crop Group 14 with the Proposal Recommendations to ChemSAC
to the Amended 2010 Tree Nut Crop Group 14-11.

Regulation	Current Tree Nut Crop Group 14

(May 17, 1995).	2010 Proposed Tree Nut Crop Group 14-10 for ChemSAC
Approval

Name of the Crop Group	Tree Nut Group 14	Tree Nut Group 14-11 hopefully.

Representative Crops	Two:

Almond and 

Pecan	Two:

Almond and

Pecan same commodities

Subgroup(s)	None	None

Commodities included	12 (Almond, Beechnut, Brazil nut, Butternut,
Cashew, Chestnut, Chinquapin, Filbert (Hazelnut), Hickory nut ,
Macadamia nut, Pecan, Walnut, black and English)	39 (African tree nut,
Almond, Beechnut, Brazil nut, Brazilian pine, Bunya, Bur oak, Butternut,
Cajou nut, Candlenut, Cashew, Chestnut, Chinquapin, Coconut, Coquito
nut, Dika nut, Ginkgo, Guiana chestnut, Hazelnut (Filbert), Heartnut,
Hickory nut, Japanese horse-chestnut, Macadamia nut, Mongongo nut,
Monkey pot, Monkey puzzle nut, Okari nut, Pachira nut, Peach palm nut,
Pecan, Pequi, Pili nut, Pine nut, Pistachio, Sapucaia nut, Tropical
almond, Walnut, black, Walnut, English, and Yellowhorn, cultivars,
varieties, and/or hybrids of these).

Commodity Definitions 180.1(g).	None were proposed.	None



IR-4 Proposal 2:

“The following commodities, Almond and Pecan, should remain as
representative commodities for the expanded group.

HED Recommendation for Proposal 2:

	I recommend ChemSAC concur to retain almond and pecan, as
representative commodities for the amended Tree Nut Crop Group 14. 
These representative commodities account for > 74 % of the harvested
acres for the members of the amended Tree Nut Group, and are the two
most widely grown tree nuts in the U.S. with the largest acreages and
geographical distribution.  The representative commodities are based on
similarities in fruit (nut) and cultural practices and geographical
locations, as well as their high production (both acres and yield) and
consumption.  A comparison of established tolerances on tree nut
commodities also supports that residue levels will be similar between
members of the crop group.  

IR-4 Proposal 3: “No subgroups are proposed for the Tree Nuts crop
group.”  

HED Recommendation for Proposal 3:

	I agree that the Tree nut crop group will not benefit from establishing
any crop subgroup.

IR-4 Proposal 4: “No Tree Nut crop definitions are proposed.”  

HED Recommendation for Proposal 4 Commodity Definition for Tree Nuts:

	I agree that commodity definitions are not needed for the tree nuts.

Additional HED Recommendations/Conclusions:

HED Recommendation 5:

	Another important aspect of crop grouping is the harmonization effort
with the Codex Classification of Foods and Animal Feeds.  The current
EPA crop group for Tree nut group 14 is very similar to the
corresponding Codex Group 022, Tree Nuts, which consists of nineteen
commodities including matches to the all the twenty-four commodities in
the proposed amended EPA crop group 14.  The differences are because
several of the Codex commodities refer to another commodity in a similar
manner to the EPA Food and Feed Commodity Vocabulary Lookup to Preferred
Tolerance Terms, such as “Pignolia”, see Pine nuts.  Several Codex
names are equivalent to lookup terms in the EPA Food and Feed Commodity
Vocabulary like filberts is hazelnuts.  The thirty commodities listed by
Codex are really nineteen individual commodities.  The U.S. is proposing
to add the following commodities: African tree nut, betelnut, Brazilian
pine, bunya, bur oak, cajou, candlenut, castanha–do-maranhao,
chinquapin, dika nut, ginkgo, Guiana chestnut, heartnut, monkey pot,
monkey puzzle nut, okari nut, pachira nut, and pequi, that are not yet
in the Codex system.  

	Recently, Codex has been reviewing the list of commodities in a revised
Tree nut group 022 (Secretariat, 2010) derived from the USDA IR-4
proposal.

	Note that the current Codex crop group does not have representative
commodities.  A revision of the Codex Classification is underway with
consideration to include adding new commodities, creating subgroups, and
selecting representative commodities.  The expanded Tree nut group and
the representative commodities proposed in this petition would
facilitate the harmonization of the U.S. and the Codex crop
classification systems.  

HED Recommendation 6:

	The Health Effects Division Dry Matter database was updated by Dr’s.
NG and Schneider to include newer tree and presented in the Analysis of
the Tree Nut Crop Group Petition, Table 40 Part I Analysis.

HED Recommendation 7:

Guidance for HED SOP 99.6 -  SEQ CHAPTER \h \r 1  “Classification of
Food Forms with Respect to Level of Blending” issued August 20, 1999,
and HED SOP 2000.1 – “  SEQ CHAPTER \h \r 1 Guidance for Translation
of Field Trial Data from Representative Commodities in the Crop Group
Regulation to Other Commodities in Each Crop Group/Subgroup” issued
September 12, 2000 can be updated to reflect the amendment to the Tree
nut group 14.

HED Recommendation 8:

Guidance on expressing tolerance terminology for the Tree nut crop group
14 is discussed under the “Tolerance expression guidance section of
this analysis.

HED Recommendation 9: 

New lookup and preferred EPA terms for the members of the Tree Nut Crop
Group are listed in the EPA Food and Feed Commodity Vocabulary section
of this report and these terms will be to the updated EPA Food and Feed
Commodity Vocabulary website (  HYPERLINK
"http://www.epa.gov/pesticides/foodfeed" 
http://www.epa.gov/pesticides/foodfeed ) when it is updated. 

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