US Environmental Protection Agency Reviews Maximum Residue Level of Thiram in Avocadoes

Regulation of 40 CFR 180.132 has been amended to establish a revised tolerance level for thiram in, or on, avocadoes.

The change on maximum residue level of thiram in / on avocadoes entered into force on 19 June 2015. Objections and requests for hearing must be received by addressing the docket with ID number EPA-HQ-OPP-2014-2049 before 18 August 2015.

What Is Thiram?

Thiram (tetramethylthiuram dissulfide) belongs to a group of dithiocarbamate fungicides. It is used as a seed protectant and foliar treatment on fruits, vegetables, ornamentals and turf crops to control a number of fungal diseases, as well as to protect harvested crops from deterioration by fungal infection during storage and transport.  

Tolerance on Maximum Residue Level of Thiram 

To ensure human health and food safety, the FFDCA allows the Environmental Protection Agency to establish tolerances that represent the maximum residue anticipated from the legal use of the pesticides on commodities. At tolerance levels, consumers should not be at risk of harm, especially to infants and children, through dietary exposure, drinking water and in a residential setting. However, occupational exposure is not included for consideration.

In making their tolerance decisions, the EPA tries to harmonize US tolerances with international standards, with particular reference to Codex Alimentarius Commission (CAC), according to FFDCA requirements. Unfortunately, the CAC has not set a MRL for thiram in any food. Therefore, in December 2014, the EPA accepted the proposed tolerance level, without full toxicological evaluation of thiram from petitioner, in or on avocadoes at the concentration of 8 ppm. Based on the Tolerance Calculation Procedures defined by the Organization for Economic Cooperation and Development (OECD), the EPA has evaluated the risk posed by thiram to human health and finally set a new and proper maximum residue level for this substance. As a result, the tolerance level for thiram in or on avocadoes has been increased from 8 ppm to 15 ppm. This amendment becomes the default safety guideline for crop production, animal production, food manufacturing and pesticide manufacturing to regulate growers, food processors, food handlers and food retailers.

Thiram Testing with the Spectrophotometry Technique

Regarding analytical methodology for dithiocarbamate residues in fruits and vegetables, these compounds are easily decomposed into carbon disulphite (CS2) by using hot acid-digestion. The formation of CS2 is collected for its determination by spectrophotometry or gas chromatography (GC). To comply with US regulations, the spectrophotometry technique is used to enforce the tolerance express of thiram.

Tolerance level for Thiram in or on avocado: 15 ppm.

What Do the Changes Mean?

This update has the potential to affect agricultural producers, food manufacturers, and pesticide manufacturers. All avocadoes destined for the US must, with effect from 19 June, meet the new MRL, as listed in Table 1. As the MRLs have been increased, this should have no immediate impact, but if in doubt, food producers and manufacturers should seek professional advice.

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