Introduction

Section 408 of the Federal Food, Drug, and Cosmetic Act (FFDCA) authorizes EPA to set tolerances, or maximum residue limits, for pesticide residues on foods. Under FFDCA, FDA has the responsibility to enforce EPA-established pesticide tolerances in foods imported into the U.S. and domestic foods shipped in interstate commerce (with the exception of meat, poultry, and certain egg products regulated by the Food Safety Inspection Service (FSIS) of the U.S. Department of Agriculture (USDA). To accomplish this task both the Center for Food Safety and Applied Nutrition (CFSAN) and the Center for Veterinary Medicine (CVM) manage a Pesticide Residue Monitoring Program. Each year FDA investigators collect a variety of animal food samples as part of CVM’s Feed Contaminants Compliance Program (71003A) and send them to the Office of Regulatory Affair’s (ORA) laboratories for pesticide analysis. This program allows FDA both to regulate animal foods and food ingredients introduced into U.S. commerce and to gather information on pesticide residues in animal foods and food ingredients; thereby protecting both human and animal health.

In this report we summarize the findings of this monitoring program for samples analyzed during fiscal year 2015 (October 1, 2014 – September 30, 2015).

In the following report, a pesticide chemical residue is considered violative if it is found at a level that exceeds either an EPA tolerance published in Title 40 of the Code of Federal Regulations part 180, or an FDA Action Level (Compliance Policy Guide Sec. 575.100 Pesticide Residues in Food and Feed - Enforcement Criteria); or, a residue found at a level of regulatory significance for which no tolerance has been established in the sampled food.

Report of Pesticide Findings in FY 2015

In FY 2015, a total of 417 animal food samples were analyzed for pesticides by the FDA. This is slightly below the 550 samples (250 domestic and 300 import), projected in the FY 2015 ORA Workplan, but 51 samples more than the 366 samples collected during the prior year.

Of the 417 animal food samples analyzed in 2015, 215 were domestic and 202 were imports. Of the 215 domestic surveillance samples, 111 (51.6%) contained no detectable residues, 104 (48.4%) contained one or more residues, of which 4 (1.9% of the positive samples) were violative. Of the 202 import samples, 117 (57.9%) contained no detectable residues, 85 (42.1%) contained one or more residues, 8 of which (4.0% of the positive) were violative.

The four domestic samples found to contain one or more violative residues were from different commodities. Wheat middlings from Iowa contained 0.022 ppm chlorpropham which has tolerances only for potatoes and potato products. A sample of cottonseed from Utah was found to contain 0.037 ppm permethrin; no tolerance is listed for permethrin in cotton or cottonseed. Cubed alfalfa hay from Kansas contained 0.025 ppm propargite for which no tolerance is listed for the commodity. Barley from Virginia was found to contain 0.734 ppm chlorpyrifos, which has no tolerance established for this commodity.

The eight import samples that were found to contain one or more violative residues were from several countries: two each from Canada, United Kingdom and China and one each from India and France. Flax meal and quinoa imported from Canada were found to contain imidacloprid at 1.05 ppm and chlorpyrifos at 0.417 ppm, respectively. Imidacloprid is only allowed up to 0.05 ppm on flax seed, and there is no tolerance for chlorpyrifos in quinoa. Two herbal products from the United Kingdom each contained multiple violative pesticide residues for which no tolerances are established: a sample of raspberry leaves contained mepanipyrim, and difenconazole; and a mixed botanical product intended for horses was found to contain chlorpyrifos, carbendazim, bromuconazole, difenconazole, dinicoazole, triadimenol, and phorate.

A sample of pelleted sweet potato flour and another of dried distiller’s grain from China each contained a pesticide residue for which no tolerance is listed. The sweet potato contained carbendazim and the dried distiller’s grain contained fenitrothion. A sample of biocholine powder from India was found to contain carbendazim which is not registered in the US. An alfalfa nutrient concentrate sample from France contained propamocarb for which no tolerance is established in alfalfa.

The breakdown of data by the number of positive and violative samples by commodity type and origin is shown in Table 1. For FY 2015, a total of 64 different pesticides were found in the various animal foods tested. A breakdown of the data by the pesticide detected is shown in Table 2, which lists the 40 pesticides detected in at least two samples; 24 other pesticides were found in only one sample each, and are not shown in the table. Of the 417 samples analyzed, 189 were found to contain at least one pesticide (both violative and non-violative samples), 104 in domestic samples and 85 in imported samples. A total of 363 residues were detected in all samples, 207 in domestic samples and 156 in import samples. For all samples, ethoxyquin and malathion were the most frequently found pesticides and together accounted for 37.6 % of all residues detected (Table 2). Piperonyl butoxide was the third most commonly detected residue contributing 6.7 % to the total.

Summary

For FY 2015, a total of 417 animal food samples were analyzed for pesticides by the FDA. This is slightly below the 550 samples (250 domestic and 300 import), projected in the FY 2015 ORA Workplan, but 51 samples more than the 366 samples collected during the prior year.

• Ethoxyquin, malathion, piperonyl butoxide and chlorpyrifos methyl are four pesticides that regularly appeared among the top five most frequently detected pesticides in animal food. For the past three years, the top three residues remain the same: ethoxyquin, malathion, and piperonyl butoxide. Ethoxyquin, although approved for use as a pesticide on pears, is used as an antioxidant in animal food, hence its frequent appearance on this list. Malathion and piperonyl butoxide are the top two most often detected pesticides, reflecting their widespread use.
• During the past three years, approximately half of the samples tested had no detectable residues and violation rates remain low. Violative results are twice as common among imported samples as domestic ones.

Overall, results in this report demonstrate that levels of pesticide residues measured by FDA in animal food and ingredients are generally in compliance with the U.S. Environmental Protection Agency’s (EPA’s) permitted pesticide tolerances. However, we recommend continued monitoring of pesticide residues in animal food and animal food ingredients to help protect both human and animal health.

Table 1. Summary of Animal Foods Analyzed for Pesticides

†Percentage of the number of samples analyzed per commodity type

Table 2. Pesticides Most Commonly Reported in Samples of Foods for Animals

 *64 different pesticides were found in foods for animals. The 40 pesticides with frequency of finding in at least 2 samples are listed. 24 additional pesticides were identified in a single sample only and were not presented in this table.
†Number of samples in which the residue was found with percentage () of all 417 samples tested
††Median level determination includes trace levels