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Pundit Mailbag —
Hurdles To GlobalGAP

Jim Prevor’s Perishable Pundit, September 28, 2007

Our piece, EurepGAp Becomes GlobalGAP… When Will We Have An AmeriGAP, brought this critique from New Zealand:

As a New Zealand producer who has been subject to EurepGAP for a long period, I would have this to say:

Good agricultural practice is, of course, a ‘must have’ these days and a plethora of certifications is time wasting, expensive and very difficult for a producer-supplier to multiple markets to comply with all.

In my opinion, there are two major hurdles to the GlobalGAP system:

  1. Chemical residue requirements.
    These are non-standard between the receiver countries and make it impossible for growers to manage their production for all markets adding to costs greatly and weakening suppliers’ marketing positions.

    For example, Zespri was hurt badly recently by the removal of an insecticide in Europe making it impossible for growers to meet an insect-free requirement in Korea.

The requirements also enforce residue standards at 0.01 ppm (parts per million), which the evidence would suggest is below any laboratory equipment’s testing ability. When labs are forcing the withdrawal of product for negligible chemical residues below 0.02 ppm, it becomes farcical.

The same labs will not stand behind clear tests at these levels and, as you have recently demonstrated, leads to false positives.

Japan also has totally inconsistent residue standards between fruit products in their positive list. A chemical can have 0.5 ppm on a Japanese Strawberry but less than 0.01 on an imported lemon. Japan also allows older chemical groups favoured by Japanese growers but will not recognize new softer chemicals.

The U.S now works on a food basket approach, allowing a chemical such as mancozeb on a limited range of products while not allowing it on others. This says to consumers that some products may poison you and others may not. Clearly this is ridiculous.

  1. The ethical side of the GlobalGAP system is regulated by whom? As growers we all respect the need to have minimal residues or biotoxins in our products and that the customer has a right to know what they are ingesting.

    However when, for example, the NZ Food Safety Authority makes a call on a chemical product and allows a spray residue for lemons at one level and for mandarins at a much lower level on the basis that in their opinion the chemical is not as required for mandarins, this is nonsense.

Grower/suppliers are now heading into an abyss of nonsense with no scientific backing to regulation. Sounds like the global warming dialogue you are also engaged in.

— Alan Thompson
Managing Director
Kerifresh
Kerikeri, New Zealand

We appreciate this revelatory letter. It brings to mind several important points:

  1. While the whole industry has been focused on pathogens, in many parts of the world authorities and buyers have been tightening up on pesticide regulations both prohibiting the use of more pesticides and restricting the allowable residue levels. In Pundit sister publication, PRODUCE BUSINESS, Mark DeNaeyer of Trofi made the same point in regard to German discounters which you can read about here.

  2. In many, perhaps most, of these cases, there is no scientific evidence at all that these new residue levels and new pesticide restrictions are important.
  3. The problem with certification bodies is that some board or panel winds up making decisions. On issues such as pesticides, they are already making subjective judgments but, at least here, there is a theoretical scientific discipline.
  4. When certification bodies get into social responsibility issues, there is no proper way to make decision. These are purely subjective judgments. A true GlobalGAP would probably be unacceptable to Europe, for example, because it is doubtful that China, India, Brazil… not to mention the United States… would vote for the same standards Europeans want for product sold in Europe. Put another way, the purpose of EurepGAP was to impose European standards on the world for product that would be sold in Europe. What is the purpose of a true GlobalGAP?
  5. With all the problems on imports of food from China, we desperately need certification standards. We know we can’t inspect food safety into food products at the border. Even if we could somehow overcome the problem of corruption that Devon Zagory of NSF Davis Fresh pointed to in our piece, that still leaves the question of what standard we are looking to certify against. Because this question remains unanswered, producers that export to many markets and even to many customers in the same market often struggle with multiple audits and the need for multiple certifications.

Many thanks to Alan for bringing these important issues to the forefront of our industry discussion.

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