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:  	January 2, 2013

SUBJECT:	Crop Grouping – Follow-up to the Analysis of the USDA IR-4
Petition to Amend the Crop Group Regulation 40 CFR § 180.41 (c) (5)
Crop Group 4 Leafy Vegetables to Add Two Additional Commodities Dillweed
and Dang-gwi. 

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

Chemistry and Exposure Branch  

Health Effects Division (7509P)  

THROUGH:	Donna Davis and Donald Wilbur, Chairpersons

HED Chemistry Science Advisory Council (ChemSAC)

		Health Effects Division (7509P)  

TO:	ChemSAC Members

		Jennifer Selwyn, Monica Le, and Susan Wong, PMRA

		Barbara Madden, Minor Use Officer, Registration Division (7505P)

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

BACKGROUND: 

	Since the HED ChemSAC/PMRA meeting which approved the revisions to
amend the leafy vegetable crop group 4 on November 30, 2011 and was
updated December 23, 2011, it has come to our attention that two more
commodities need to be considered as members to the Leafy vegetable
group 4.  The commodities are dang-gwi, a Korean leafy vegetable and
dillweed, a current member of the herb and spice group which we will
recommend be moved to the leafy vegetable group.  

HED RECOMMENDATIONS:

	I recommend that ChemSAC agree to add dang-gwi and dillweed to the
amended Leafy vegetable crop group 4-13 and Leafy greens subgroup 4A
based on similarities of cultural practices, pest problems and maturity
and harvesting techniques to other members of the Leafy vegetables crop
group.  Since these leafy vegetables are grown in close proximity to
each other by being members of the crop group will avoid inadvertent
residue problems.  The discussion below will further describe why
dang-gwi and dillweed will be added to the Leafy vegetable crop group.

DISCUSSION:

	Each of the two commodities will be discussed separately. 

Dang-gwi:

	The Codex Electronic Crop Grouping Workgroup notified William P.
Barney, Crop Grouping Project Coordinator, USDA Interregional Research
Project No. 4 (IR-4), and leader of the International Crop Grouping
Consulting Committee (ICGCC) that the Korean delegation had requested
that dang-gwi, a leafy vegetable be added to the Leafy vegetable group. 
Dang-gwi (Angelica gigas Nakai family Apiaceae/alt. Umbelliferae) is a
leafy vegetable native to eastern Asia including China, Japan, and
Korea, reaching up to 6.6 ft (2 m) in height.  It has thick, hollow,
ribbed stems, purple in color and broad pinnate leaves (see Figure 1). 
The plant is also currently being grown in the U.S. as an ornamental,
but it is locally grown and/or gathered from the wild as a leaf
vegetable.  It is valued for its young leaves and shoots, which are
edible and used a tender vegetable.  It is also valued for the root,
which is used medicinally.  

	ChemSAC (minutes November 30, 2011) approved several leafy vegetables
similar to dang-gwi which have similar cultural practices, share the
same pest problems, and are members of the same plant family.  They are
used fresh in salads, pickled, or cooked by boiling or frying.  All of
these also have medicinal uses including cham-chwi, cham-na-mul, and
dol-nam-mul.  If approved dang-gwi will also be a member of the amended
Leafy vegetable crop group and the leafy greens subgroup 4A along with
cham-chwi, cham-na-mul, and dol-nam-mul.  The crop group already
includes parsley and cilantro leaves.  Residues based on leaf morphology
and cultural practices for dang-gwi should be similar to leaf lettuce
(Figure 2) the representative commodity for the leafy greens subgroup
4A-13. 

Figure 1.  Picture of Dang-gwi.

 

Figure 2.  Picture of Leaf Lettuce.

 

Dillweed:

Barbara Madden, Minor Use Officer, RD contacted me about a conversation
she had with a grower during the September 2012 IR-4 Food Use Workshop. 
 According to Barbara Madden: “I made a presentation and as part of
the presentation I discussed crop groups and shared with them the plans
to move the Brassica leafy vegetables in with the other leafy vegetables
and to create a new stalk and stem group. I also mentioned during the
presentation that cilantro leaves was going to be included in the
revised leafy vegetable group. I encouraged people to look at these
proposals and to provide us with comments during the process while these
changes are being proposed.  Afterwards Bruce Buurma of Buurma Farms  
HYPERLINK "mailto:bruce@buurmafarms.com"  bruce@buurmafarms.com , who is
also a member of the IR-4 Commodity Liaison Committee, came up to me and
asked if dillweed would also be moved into the leafy vegetables group. 
I checked the ChemSAC write-up and saw no mention of dill leaves. 
According to Mr. Buurma cilantro and dill are grown together and if
cilantro is going to be moved into the revised leafy vegetable group he
recommended that dill be moved as well. 

After receiving Barbara’s email I contacted Mr. Buurma and requested
additional information on grower practices for dillweed and fresh herbs.
 He stated: dillweed (Figure 3) and cilantro (Figure 4) are planted
twice a week starting on April 1st and ending on September 17th.  We
plant the cilantro first and then change seed and continue to plant with
the dill seed so they are literally inches apart.  We plant both herbs
on a 10 inch raised bed with 2 rows 10 inches apart on top of the 20
inch bed, and there are 36 inches between beds.  Both dillweed and
cilantro are harvested when they are approximately 12 - 15 inches tall,
which is right before they go to seed.  Both crops mature in 45 days
depending on the time of year but they both grow about the same. 
Disease and insect pests for both crops are almost identical.  In
summary, dillweed and cilantro are planted at the same time from the
beginning to the end of the season, they are planted by the same
equipment in the same field, both are seeded at 16 - 17 lbs. of seed per
acre, the days to harvest are the same, the harvest size and the
packaging are basically the same, and they share the same insect and
disease problems.  

	As with cilantro leaves and parsley, we find dillweed is grown in very
close proximity with other leafy vegetable crops and to avoid
inadvertent residues it makes sense to move dillweed to the amended
leafy vegetable group, and leafy greens subgroup 4A-13 in which leaf
lettuce is the representative commodity.  Dill seed will remain in the
Herb and spice crop group 19, because it has different cultural
practices and harvesting techniques.

Figure 3.  Dillweed.

 

Figure 4.  Cilantro.

 

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