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Fodder Industry Practices to Meet Export Market Standards
by J.L Black
June 2008
RIRDC Publication No 08/102 RIRDC Project No JLB-5A
The project considered whether additional research was required in relation to reducing the cost or improving the efficiency of AQIS certification for Annual Ryegrass Toxicity (ARGT). Exporters were also questioned on other potential threats they could envisage for the export fodder industry and whether additional research was required in relation to these threats.
Target audience
The prototype Australian
Fodder Industry Association (AFIA) ChemCheck system developed in this project
is for use by cereal crop growers who supply hay or straw to fodder exporting
companies.
Information generated by the system and, particularly the ‘alerts’ that it produces when an issue in relation to chemical residues is identified, will be available to the cereal grower who recorded the pesticide spray activities and to the exporters for which any specific area of crop is contracted.
Information about chemicals important to the export hay industry that do not have specific Maximum Residue Limit (MRL) values and are considered ‘nil detect’ in Australia, chemicals that are used for oat crops but are not registered for such use, and chemicals used but not registered for oat, barley or wheat crops and the subsequent recommendations are provided for consideration by the Australian Fodder Industry Association and other stakeholders.
The review of the current status of methyl bromide use for Quarantine and Pre-Shipment (QPS) purposes and the availability of possible alternative fumigants and recapture technology for methyl bromide is for consideration by stakeholders.
Background
Total shipments of hay and
straw from Australia to the year ending June 2006 were 730,000 tonnes -
worth approximately $220 million. The majority of the fodder is exported
to Japan with increasing amounts to Korea. Growth in exports over the last
decade has averaged more than 8% per year and this rate of increase is
projected to continue into the future. However, it is critical that this
market and the opportunity for continued expansion is not jeopardised by
prohibitions imposed by importing countries resulting from the supply of
contaminated product.
The Japanese authorities currently undertake a basic screen on a small percentage of imported animal feeds, including hay and straw, for 173 substances covering antimicrobial feed additives, mycotoxins, heavy metals, pesticides, pathogenic micro-organisms, animal protein and genetically modified organisms. Prior to May 2006, there was no legislative power in Japan to act if contaminated products were identified. However, an Ordinance was proclaimed on 29 May 2006 that allowed action against importers and manufacturers of feeds within Japan if a violation was detected where concentrations exceeded MRL values for 60 identified chemicals and Aflotoxin B1. The Australian Government recognises that the Japanese Government retains the right at any time to either officially change the Ordinance or implement unofficial MRLs for additional chemicals.
The most likely scenario is that if residues for any one of the listed compounds in a shipment of Australian oaten hay or straw are found to exceed its MRL, the rate of monitoring of the commodity from Australia will be increased. Discovery of further breaches is likely to result in severe impediment to ongoing shipment of the commodity. Thus, breaches of the MRLs by any one shipment of fodder could have serious economic implications for the whole of the Australian fodder export industry.
In recognition of the potential seriousness of just one detected breach of a MRL, AFIA initiated this project to develop a process that would reduce to a minimum the likelihood of contaminated fodder being exported to Japan or any other country.
Methyl bromide is currently used as the preferred substance to fumigate containers of hay and straw exported from Australia to countries that require fodder to be free from all live insects and other pests.
Methyl bromide is a potent ozone depleting substance. Under the 1987 Montreal Protocol, methyl bromide was to be completely phased out for use in developed countries by January 2005. However, its use for Quarantine and Pre-shipment (QPS) purposes was exempt from the Protocol until January 2015, when phase-out would be considered. There is currently pressure from the European Union to set a cap on the use of methyl bromide for QPS purposes. Furthermore, the United Nations Environment Programme is encouraging parties to the Montreal Protocol to consider alternatives or substitutes for methyl bromide and for its recapture during QPS applications. Consequently, the fodder industry needs to know the likelihood that methyl bromide use for QPS purposes may be phased out earlier than initially stated under the Montreal Protocol and whether there are any effective and economically viable alternatives.
Objectives
The objective for the project
was to ensure as far as possible that shipments of hay or straw from Australia
consistently meet mandatory standards for product purity in importing countries.
The specific aims of the project were:
1. Develop a risk management protocol to reduce as far as possible the chances of Australian hay or straw exported to Japan exceeding the MRL values for the 60 recently prescribed chemicals and contaminants.
2. Identify all chemicals that may either directly or indirectly be applied to Australian hay or straw destined for export and develop a risk management protocol to reduce as far as possible the chances of these chemicals exceeding concentrations that may adversely affect export markets.
3. Identify research needed for annual ryegrass toxicity (ARGT) testing and control that would benefit the Australian fodder export industry.
4. Review the likely need to replace methyl bromide as a pre-shipment fumigant, assess the costeffectiveness of alternative procedures and recommend future research if replacement of methylbromide is considered necessary.
5. Identify and prioritise for action other issues that could endanger access to overseas markets of Australian hay or straw.
Methods
Assessment of risks
The chemicals included in
the Japanese Ordinance as well as chemicals in products registered in Australia
for use on oat, barley or wheat crops were identified. A Preliminary Risk
Assessment was conducted for each chemical and chemical combination. Scores
ranged from 0 to a maximum of 25 and those with chemicals with scores of
8 or greater were considered to be of potential risk.
Chemicals and combinations that had a high risk for contamination of hay and straw were noted.
Over 260 hay and straw samples were collected from the 2006-07 harvest through exporting companies and 164 chosen from spray diary records for analysis of chemical residues. Residues were tested for over 70 chemicals including 42 that are in the Japanese Ordinance. Results from the preliminary risk assessment, evaluation of grower spray diaries, chemical residue analyses and a comparison of Australian and Japanese MRL values were used to identify chemicals or chemical combinations that could have changes made to their registration status to better match their use by industry.
Development of a risk
management protocol
Several meetings were held
with the AFIA registered hay exporting companies to consider the most appropriate
system that could reduce to a minimum the chances of contaminated hay being
exported from Australia. The AFIA ChemCheck system was chosen as the basis
for developing a prototype for testing by the Australian fodder industry.
The system was based on a similar system adopted by the Australian wine
industry to ensure contaminated product was not exported. The project Principal
Investigator and the Executive Officer of AFIA worked with Graeme Forsythe
and Associates (GFA) to develop the system for the fodder industry.
ARGT, replacement of methyl bromide and other issues that may impinge on the export hay industry Decisions about ARGT, replacement of methyl bromide and other issues that may impinge on the export hay industry and the need for further research were made largely from consultation with the fodder industry, commercial companies, regulating authorities and literature review.
Major Findings
Assessment of risks
Twenty of the 60 chemicals
listed in the Japanese Ordinance were considered to be relevant to the
Australian fodder industry. Twelve of these were given a Preliminary Risk
Assessment of 8 or greater. Diquat and paraquat were given maximum scores
of 25, whereas glyphosate, bromoxynil, cyhalothrin and permethrin were
each given scores of 12. These chemicals were considered to be of potential
high risk to the export industry. Twelve of the 20 chemicals relevant to
the Australian fodder industry did not have Australian fodder specific
MRL values and were classified as ‘Nil Detect’. This classification in
Australia means that no detectible residue is permitted in hay or straw
in this country.
Another three of the 20 chemicals, atrazine, cyfluthrin, and paraquat have lower MRL values in Japan than in Australia.
Fifty of the 152 chemicals or chemical combinations registered in Australia for cereal crops were given a preliminary risk assessment score of 8 or greater and 28 were given a score of 12 or more.
Most of the highest risk chemicals with scores of 12 or more are fungicides and insecticides that can be used late in the season to control plant diseases and pests. However, the herbicides, 2,4-D + picloram, bromoxynil, clopyralid, diquat, glyphosate, flumetsulam, fluroxypyr, paraquat and terbutryn were all given high preliminary risk assessment scores of 12 or more and are considered to be a potential risk to the fodder export trade.
Several chemicals or chemical combinations potentially important for the export fodder industry are registered for use on barley and wheat crops, but not on oat crops. Some of these compounds are toxic to oats and are used to control wild oats in other cereal crops. However, azoxystrobin + cyproconazole, bifenthrin, bromoxynil + diflufenican, cyfluthrin, dicamba + metsulfuron, metsulfuron, epoxiconazole, fluquinconazole, metalaxyl, metsulfuron, triadimefon and trifluralin were considered important for registration for use on oat crops.
Three chemicals, chlorothalonil, fludioxonil and pyridalyl, were identified from spray diaries as being used, but are not registered for oat, barley or wheat crops. Further investigation may be warranted into the extent of their use on crops destined for export from Australia and whether they should be registered for cereal crops.
Results from chemical
assays
The 2006-07 hay production
season was unusual because it finished early in all districts and the crops
generally had low yields. These low yields meant that residues would have
been more concentrated than in a normal year. However, many commonly used
fungicides and insecticides were not used during the later stages of crop
growth because of the short, dry season. Most samples were not collected
for analysis until April or May the following year, which would have reduced
the concentration of residues compared with recently harvested hay.
Twelve chemicals were used that do not have an Australian MRL for cereal hay or straw and are therefore classified as ‘Nil detect’. These chemicals are trilfuralin, dimethoate, chlorpyrifos, pendimethalin, piperonyl-butoxide, phosmet, cyhalothrin, permethrin, bromoxynil, 2,4-D, MCPA and dicamba. Residues were found for seven of these chemicals (dimethoate, piperonyl-butoxide, permethrin, bromoxynil, 2,4-D, MCPA and dicamba).
A most significant finding was that 131 residues were found for chemicals that were not recorded in spray diary records as having been applied to the crop from which the hay or straw was made.
There were 47 recorded residues for bromoxynil and all except four exceeded the Japanese MRL of 0.1 mg/kg and all exceeded the ‘Nil detect’ value for Australia. However, the majority of these residues (38) were from samples taken from the Department of Agriculture trials in Western Australia where two applications of bromoxynil were used pre-sowing as Buctril MA at 1.4 L/ha and four weeks later as Bromocide 200 at a rate of 2 L/ha.
Although 103 residues for clopyralid were found, the highest was only 2.10 mg/kg compared with the Australian MRL of 10 mg/kg. Nevertheless, these residues were identified in 70% of the samples to which it was applied and another 22 samples for which there was no record of application. These findings could be serious for Australian export hay trade because Japanese traders do not accept any fodder containing clopyralid.
There were few residues in samples of hay to which glyphosate had been applied, presumably because glyphosate is generally applied pre-sowing. One application on 18 May 2006 of 1200 ml/ha of glyphosate resulted in a residue of 0.22 mg/kg in hay harvested on 14 October 2006. This residue is far below the Australian MRL of 150 mg/kg. However, another glyphosate residue was recorded at 128 mg/kg from a sample of hay that was sprayed with glyphosate while in the windrow post cutting.
This extreme treatment did not exceed the Australian MRL, but did exceed the Japanese MRL of 120 mg/kg. This result emphasises the importance of not allowing glyphosate applications to drift onto windrows or baled hay.
Issues relating to chemical use on hay crops
Following the Preliminary Risk Assessments, evaluation of grower spray diaries and assays for chemical residues in hay and straw, four issues of concern relating to the use of chemicals on cereal crops were identified:
1. Chemicals used on cereal crops - do not have an Australian MRL, are therefore considered ‘Nil detect’ and residues are not permitted in Australia 2. Chemicals considered relevant to hay and straw destined for export - the Japanese either do not have an MRL value for the chemical or the Japanese MRL is higher than the Australian MRL.
3. Chemicals or chemical combinations that are registered for use on barley and/or wheat crops, but are not registered for oat crops.
4. Chemicals that from spray diary records are used on oat, barley or wheat crops, but are not registered for use on these cereal crops in Australia.
Potential solutions for these issues are covered in the Recommendation section of the report.
A Risk Assessment Procedure
for the Australian Fodder Industry
The AFIA ChemCheck system,
which is web-based for grower input of spray records, has been developed
to the prototype stage. It contains a near complete database of all products
registered for use on oat, barley and wheat crops in Australia. An interface
to accept records from spray equipment is being developed. The prototype
has been tested using 26 spray diary records. Further refinement of the
database is required, particularly the immediate incorporation of all new
products registered and on-going monitoring of the system use. Effort is
also required to ensure adoption of the system across the hay exporting
companies and their growers. A Preliminary Research Proposal has been submitted
to RIRDC for funds for one year to complete the adoption phase. However,
on-going commitment from the fodder industry is required for the risk control
procedure to continue to be effective into the future.
Methyl bromide alternatives
Australian hay and straw
that is exported to a country requiring a government authorised Phytosanitary
Certificate is covered under the Montreal Protocol QPS exemption. QPS uses
of methyl bromide are currently exempt from control under the Montreal
Protocol and there is currently no cap on its use for these purposes. There
is no indication that this situation is about to change until the review
date of 1 January 2015.
However the United Nations Environment Programme (UNEP), which monitors and reports on the Montreal Protocol, have encouraged parties to the Protocol to consider alternatives or substitutes and, where this is not feasible, to consider recapture of methyl bromide used for QPS purposes. Belgium has since July 2007 made the recapture of methyl bromide mandatory and similar legislation is being considered by other European countries. The European Union has promoted the application of a cap on the use of methyl bromide for QPS purposes, but as yet has not submitted a formal application to regulating authorities.
The review presented suggests that although a ban on the use of methyl bromide for QPS uses is unlikely to occur in the near future under the Montreal Protocol, pressure could be exerted from various sources, including importing countries, to reduce the loss of methane to the atmosphere. A small number of experiments have been conducted to investigate alternatives to methyl bromide for fumigation of exported hay.
Carbonyl sulphide, although highly effective as a fumigant, needs a longer fumigation time than methyl bromide of 2-5 days depending on temperature and leaves a sulphurous odour on hay for several weeks after treatment. The effect of this sulphurous odour on the palatability of hay by animals would need to be thoroughly investigated. Carbonyl sulphide is price competitive with methyl bromide for fumigation of hay.
Sulfuryl fluoride is effective against adult insects, but less effective than methyl bromide against insect larvae and eggs. A product containing sulfuryl fluoride, ProFume, has been registered in Australia for use on hay. Sulfuryl fluoride needs a longer fumigation time than methyl bromide of 2-5 days depending on temperature and the product is not registered for use at temperatures below 5ºC.
ProFume currently costs $50-$60 more than methyl bromide to fumigate a 40 foot container of hay.
Ethyl formate in liquid CO2 has been incorporated into a product called Vapormate. The product is highly toxic to all stages of insects. A fumigation period of 24 hours is recommended for stored grains, but few experiments have been conducted with hay. More thorough testing of Vapormate as a fumigant for hay is required. Vapormate is not yet registered for use in Australia and is estimated to be 3-4 times more expensive than methyl bromide for the fumigation of hay.
Procedures are commercially available in Australia for recapture of methyl bromide when applied to shipping containers. The release of methyl bromide to the atmosphere can be reduced to 20% of the amount applied, with the cost of recapture approximately 25% higher than for non-capture of methyl bromide for a 40 foot container.
Further research needed
for ARGT
The conclusion following
several meetings with hay exporters was that no further research is warranted
into testing export hay for ARGT.
Other issues that could
endanger access to export markets
The conclusion following
several meetings with hay exporters was that there are not currently any
additional issues that may potentially endanger access to hay export markets
that required research.
Implications
Several chemicals considered
important for cereal crops destined for export hay or straw either do not
have Australian MRL values and residues are not permitted or are not registered
for use on specific crops. Identification of residues for these chemicals
in hay or straw samples could lead to financial penalties for growers.
Residues for clopyralid were found in a large number of the hay and straw
samples analysed, but this compound is not acceptable to importers in Japan.
Care is needed by hay exporters to ensure crops destined for export to
Japan are not sprayed with clopyralid.
Recommendations
1. AFIA to work with the Grains Research and Development Corporation (GRDC) project, “Pathways to Registration – improving pesticide research outcomes”, product manufacturers and Australian Pesticides and Veterinary Medicines Authority (APVMA) to have Australian MRL values established for hay and straw for the following chemicals:
2. AFIA to work with
the GRDC project, “Pathways to Registration – improving pesticide research
outcomes”, product manufacturers and APVMA to have the following chemicals
and chemical combinations registered for oat crops:
3. AFIA to review the
efficacy of fludioxonil and pyridalyl for cereal crops potentially destined
for export hay or straw and, if they are considered to be of value, ask
the manufacturing companies to register them in Australia for use on cereal
crops.
4. Hay exporting companies through AFIA to continue to fund the on-going development, maintenance and use of the AFIA ChemCheck system as a risk control strategy to minimise the chances of contaminated fodder being exported from Australia. The on-going cost for the system is $50,000 annually in 2007 dollars.
5. A decision needs to be made by the export fodder industry representatives whether GFA and/or AFIA executives are informed of every ‘alert’ generated by the AFIA ChemCheck system to ensure that appropriate actions are taken by all cereal fodder growers and exporters.
6. Although methyl bromide is unlikely to be banned for QPS use in the near future unless specified by an importing country, AFIA and the export fodder industry should consider whether, in the interest of the environment and community perception, methyl bromide recapture technology is implemented.
 
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