United States
Environmental Protection
Agency
Policy. Planning,
And Evaluation
(PM-221)
21P-2C05
May 1992
&EPA
EPA
21
p_
2006
An Overview of Fruit and
Vegetable Standards Relating
to Cosmetic Appearance and
Pesticide Use
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
U S EPA Headquarters Library
Ma? coo --3?0<
1?00 r'"'"r ^'--"""'la '^'Onue NW
" WHS-.noto.-i ::C 20460
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21P-2006
May 1992
v An Overview of
Fruit and Vegetable
Standards Relating
to Cosmetic Appearance
and Pesticide Use
prepared
by
Office of Policy, Planning, & Evaluation
United States Environmental Protection Agency
U.S. EPA Headquarters Library
Ma;! oxin 3201
1200 f'e-r :?"','C!i'c Avenue MW
Wasr,inc,ion DC 20460
-------
Acknowledgments
This report was prepared by the Agricultural Policy Branch, in the Office of Policy
Analysis, Office of Policy, Planning, and Evaluation, U.S. Environmental Protection Agency,
with the assistance of Doug Koplow and Elaine Haemisegger of die consulting firm of Temple,
Barker, and Sloan, Inc. and Jim Governale and Mark Liniado of The Bruce Company, Inc. The
project officer was Andrew Manale. Several representatives of die agricultural community provided
helpful comments and advice on draft versions. The Agricultural Marketing Service (AMS) of the
United States Department of Agriculture (USDA) and die Center for Food Safety and Applied
Nutrition of die Food and Drug Administration (FDA) were particularly helpful in providing
extensive comments on die entire report.
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Contents
Executive Summary i
Introduction v
Chapter I: Economic Factors Affecting Grower Behavior
Economic Motivations of Growers 1-1
Consumer Preferences and Economic Motivations of Buyers 1-1
Grower Objectives and the Use of Pesticides and Other Agricultural Chemicals 1-2
Efforts on the Part of Growers to Control Pesticide Costs 1-4
Chapter II: Government Programs Affecting Produce Quality and Their
Implications for Pesticide Use
USDA Food Grading Standards 11-1
State Grading Standards II-3
FDA Defect Action Levels 11-4
EPA Pesticide Registration and Special Review 11-5
Federal and State Marketing Orders 11-5
Chapter III: Market-based Factors Affecting Cosmetic Appearance
Contractual Agreements Between Buyers and Sellers 111-1
Industry Concentration and Market Power 111-2
Downgrading Quality Standards Along the Produce-Handling Chain 111-2
Qualitative Measures to Protect the Produce Buyer 111-2
Use of Quality Standards To Control Supply in the Citrus Market 111-3
Contractual Agreements to Reduce Risk to the Buyer 111-3
Retail Chain Produce Contracting and Pesticide Use 111-4
Bank and Crop Insurance Restrictions on Grower Practices III-4
Chapter IV: Case Studies
Fresh Market Tomatoes IV-1
Processing Tomatoes IV-2
Apples IV-4
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Chapter V: Conclusions
Next Steps V-1
Areas of Future Research V-1
Appendix A
Creating or Modifying USDA Grading Standards for Fresh Produce A-l
Creating or Modifying Defect Action Levels A-3
Creating or Modifying Marketing Orders A-4
Appendix B
Food Grading Standards (through Dec. 1991) B-l
Marketing Orders (through Jan. 1992) B-13
Defect Action Levels (as of Jan 1989) B-16
Notes R-1
References R-7
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use
Executive Summary
Industry, state governments, and the federal govern-
ment establish standards that denote attributes of fruit and
vegetable quality relating to the cosmetic appearance of
fruit and vegetables; as stated in the 1990 Farm Bill,
cosmetic appearance refers to external attributes that do
not significantly affect yield, taste, or nutritional value.
To the extent that adoption of more environmentally
benign agricultural practices involving reduced rates of
pesticide application may be hindered by existing stan-
dards, modification of these standards to allow an in-
creased level of cosmetic damage, while still being
acceptable to consumers, have the potential to allay
concerns over the risks of pesticides.
The report describes the economic and regulatory
incentives to use pesticides to enhance the cosmetic
appearance of fruits and vegetables. It summarizes the
findings of avialable literature on the subject. Results are
presented of interviews with key individuals involved in
the production of fruits and vegetables and in the imple-
mentation of federal programs concerning produce qual-
ity. Finally, it discusses where consumer education
concerning trade-offs between pesticide use and cosmetic
appearance could, through different buying patterns,
change the way fruit and vegetables are produced. Fur-
ther research is needed in all these areas to identify and
quantify specific areas of improvement.
Chapter I: Economic Factors Affecting
Grower Behavior
Market forces compel producers to minimize the risk
of cosmetic damage (i.e. damage in terms of cosmetic
appearance). Consumers' perception of fruit and veg-
etable quality is based, in part, on cosmetic quality (i.e.
quality in terms of cosmetic appearance). In the retail
fruit and vegetable markets, fruits and vegetables exhib-
iting the highest levels of cosmetic quality sell at pre-
mium prices. Retailers are interested in selling fruit and
vegetables of high cosmetic quality since the products
sell well at a relatively high margin of profit. In cases
where fruits and vegetables destined for the fresh pro-
duce market exhibit lower levels of cosmetic quality, the
selling price for growers can drop dramatically since
most retailers only buy fruits and vegetables of the
highest cosmetic quality. Producers aim to achieve
standards set by buyers who demand high levels of
cosmetic quality as well as the highest grade as set by
industry, state, or federal government.
To maximize their own profit, producers attempt to
grow, in a cost-effective manner, as many units as
possible ensuring that a high percentage attains the
highest grade and cosmetic quality; they minimise eco-
nomic risk by growing over as long a season as possible.
Techniques used to achieve these goals include the
following: expanding the growing season, extending the
shelf-life and/or shipping distance potential of produce,
improving shipping qualities, improving produce ap-
pearance, reducing per unit costs of production, and
protecting and enhancing yield. Innovations in these
techniques that involve the use of chemical pesticides
have reduced per unit costs, reduced transit losses, and
yielded cosmetically appealing produce. On the other
hand, pesticide use has led to considerable uncertainty
regarding human health and environmental risks.
In recent years, producers have, to varying degrees,
begun to adopt Integrated Pest Management (IPM), a
system of agricultural practices which reduces reliance
on chemical pesticides. Reduced pesticide use in rum
leads to lower levels of pesticide residues in fruits and
vegetables. Nevertheless, many growers have not adopted
IPM, while those that have fully adopted IPM or organic
methods confront difficulty in always meeting demanded
levels of cosmetic quality.
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Executive Summary
Chapter II: Government Programs
Affecting Produce Quality and Their
Implications for Pesticide Use
Government interventions in the fruit and vegetable
market are intended to protect the interests of growers,
intermediaries and consumers. This chapter provides an
overview of some of the major government programs
affecting the fruit and vegetable supply.
USDA food grading standards are voluntary stan-
dards that enhance communication within the market-
place by providing a standard language of trade. Al-
though the standards are voluntary, they are often made
legally binding through marketing orders (MOs) or
marketing agreements (for fruits and vegetables destined
for import or export). Since grading standards do not
provide intermediate handlers or consumers with infor-
mation regarding potential pesticide residues, there is no
standard language of trade between different levels of
pesticide residues on conventionally grown fruits and
vegetables.
Some states establish food grading standards in
addition to, or in the absence of, USDA standards. In
some states the cosmetic attributes included in the
standards may be more stringent than those set by
USDA.
The FDA sets Defect Action Levels (DALs) to
protect consumers from producers selling adulterated
food. Adulteration is generally defined as contamination
by insect fragments, mold, excreta, or rodent hairs, even
at microscopic levels. DALs can be legally binding and
are generally based on unavoidable levels of adultera-
tion. FDA acknowledges that unavoidable defects de-
fined by DALs generally pose no hazard to human
health. In the courts, avoidability is, for most DALs,
determined by the lowest technologically feasible levels
of adulteration. Given that conventional technology
makes the prophylactic use (use in anticipation of pest
infestation) of chemical pesticides, growers have an
economic incentive to apply pesticides to insure they
meet DALs. Further research is needed to determine how
growers practicing IPM are hindered by DALs.
EPA registers pesticide products for use in the
United States under the Federal Insecticide, Fungicide
and Rodenticide Act (FIFRA). A large number of
pesticides currently registered are being reregistered
under more stringent standards.
Marketing orders (MOs) are collective marketing
agreements, which are legally binding on members of the
industry. The goal of a MO is to control market quantity
or quality (varying by commodity) to stabilize grower
prices. Some MOs incorporate cosmetic attributes.
Chapter III: Market-based Factors
Affecting Cosmetic Appearance
The bulk of fresh fruit and vegetables sold in
supermarket chains are produced under long term con-
tracts with growers in a few states. Because growers may
not know where their produce is ultimately destined, all
produce must meet high standards for transportability
and storability. Hence, the relationship between cos-
metic quality and quality necessary for storability and
transportability becomes blurred.
Contractual agreements between buyers and sellers
have the most direct influence on grower behavior in
terms of pesticide use and cosmetic appearance. Gener-
ally, the greater the supply relative to demand, the more
power the buyer has over the seller in setting price and
quality requirements; in the U.S., supply is seldom
scarce giving buyers the edge. Quality stipulations
incorporated into contracts, serve as a way for buyers to
obtain a consistent supply at a given price and quality by
reducing or increasing quality standards to control sup-
ply.
As fruits and vegetables pass from the grower to
intermediate handlers to the retailer and eventually to the
consumer, quality suffers due to long shipping distances,
handling, and time lag. To meet retail market quality
standards, all intermediate handlers require a safety
margin between the actual quality they buy and the
promised quality of the product they deliver.
Buyers use contracts as a way to reduce economic
risk where consumers reject produce because of the
presence of insects or insect damage. Contracts specify
levels of insects and damage thus influencing growing
practices.
Research is needed to determine the extent to which
financial lending practices or crop insurance inhibit the
adoption of IPM techniques.
Chapter IV: Case Studies
Fresh Market Tomatoes
In the fresh tomato market, contractual obligations
enforce standards of cosmetic quality that can drive
pesticide use. are the overriding source of cosmetic
quality standards. USDA grading standards are of sec-
ondary importance to these contractual obligations.
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An Ovarviaw of Fruit and Vagatabla Standards Relating to Coamatic Appaaranca and Paaticida Uaa
The U.S. No. 1 Grade for fresh market tomatoes
allows for up to ten percent of a shipment to contain
defects at the shipping point and fifteen percent to
contain defects en route or at destination. Generally,
packing houses aim for as low as five percent when
making implicit or explicit contracts with growers.
To control defects, growers employ a number of
techniques such as planting disease resistant, tough
skinned tomato strains, and using pesticides to decrease
cosmetic damage. In addition to other post-harvest
innovations, the increased use of pesticides and fungi-
cides have extended shipping distances and shelf-life.
In the fresh tomato market, tomatoes rejected in the
primary retail market must be sold at great loss in
secondary markets. The processing market requires a
specially produced product, different from that produced
for the retail market. As insurance against rejection in the
primary market, growers face the incentive to adopt
prophylactic strategies to control pests.
Professing Tomatoes
In the processing market, tomatoes with few excep-
tions, such as for canned whole tomatoes, are ground up,
with the skins removed. Rarely do the fruits remain
whole. Unlike the fresh market, certain cosmetic at-
tributes do not affect the appearance of the final product.
Nevertheless, there are still stringent cosmetic standards
for processing tomatoes with industry standards domi-
nating. The stringency of the standards, rather
than improving quality can serve to reduce
aggregate supply and provide a way for proces-
sors to reject shipments that exceed their desired
production quantities. Similar to the fresh mar-
ket, the cosmetic standards that groweis must
meet can require an array of chemically-inten-
sive agricultural practices.
Apples
Similar to tomatoes, the operational stan-
dards for apples an set by the wholesale and
retail market rather than the state or federal
government. Unlike tomatoes, however grow-
ers producing for the fresh market have the
option to sell to the processing market, though
at lower profit than in the fresh market. In the
red apple market, the marketplace is extremely
strict with respect to color, retailers believe that
consumer preferences lean toward big, bright
apples. To maximize color and other cosmetic
attributes, growers face incentives to apply
pesticides prophylactically. Socioeconomic research
shows consumers are willing to trade off only minor
cosmetic damage for less pesticide use on apples.
Chapter V: Conclusions
Government standards establish the language of trade
within the marketplace regarding quality. Industry stan-
dards, in most cases, contain higher quality levels than
government standards and may be the driving force
behind most pesticide use for cosmetic purposes. Stan-
dards on cosmetic attributes are sometimes used to
restrict supply of fresh and processed fruits and veg-
etables. Though it is clear that some pesticides are used
for the purpose of improving or assuring cosmetic
appearance, how much is used is unclear. The dominance
of fresh fruits and vegetables produced in a few states far
from major population areas and hence the need for long
distance transportation and storage blure the distinction
between purely cosmetic attributes and quality require-
ments that assume transport and storage. However, to
the extent to which local producers must meet national
•mi regional standards, such standards are cosmetic and
can affect pesticide use. Nevertheless, in many areas of
the country, growers are currently producing high qual-
ity, cosmetically appealing produce with few or no
pesticides. Much of this produce however, does not enter
conventional distribution channels such as major na-
tional supermarket chains.
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'v Executive Summary
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use
Introduction
Surveys suggest that consumers are concerned about
the health effects from ingestion of pesticide residues in
foods.1 According to the 1990 Farm Bill, 'cosmetic
appearance" is
the exterior appearance of an agricultural commodity,
including changes to that appearance resulting from superficial
damage or other attention that do not significantly affect yield,
taste, or nutritional value.1
There is evidence suggesting that some amount of
pesticide use derives from farmers' attempts to protect or
enhance the "cosmetic appearance" of their produce.1
Though the exact relationship between pesticide use on
fruits and vegetables and the occurrence of residues is
unclear, reducing pesticide use (provided that by so
doing, more toxic pesticides that are used at lower
application rates are not substituted) is likely to lead to
less pesticide residues in foods. It also lowers the
likelihood of ecological damage associated with pesti-
cide use.4 An additional benefit would be the savings to
producers from lowering their input costs. Thus, a win-
win situation can be achieved for producers and consum-
ers if producers can reduce their use of pesticides without
adversely affecting the marketability of the produce as a
consequence of impaired cosmetic appearance.
Industry, state governments, and the federal govern-
ment establish standards that denote attributes of fruit
and vegetable quality relating to the cosmetic appearance
of fresh and processed fruits and vegetables, or to foreign
matter in or on processed fruits and vegetables or fruits
and vegetables dnatined for processing. The United
States Department of Agriculture (USD A) sets voluntary
standards for various attributes of fresh and processed
fruits and vegetables, grains, meat, poultry, dairy prod-
ucts, cotton, and tobacco and assigns grades accordingly
(see Appendix B).1 Though voluntary, they serve the
important role of vocabulary to the producer, wholesale
and retail markets and thus facilitate trade by enhancing
communication and minimi ring cnnfinann Where USDA
or state governments issue marketing orders (MOs)
(legally binding rules for all producers in the production
regions covered by the orders) for certain commodities
which include minimum USDA or state grade require-
ments, the standards relating to cosmetic appearance
incorporated in these grades become mandatory.' The
Food and Drug Administration (FDA) sets compulsory
ftfln/4flfrtff for the ip^xirnvni amounts of foreign materi-
als, such as insect parts, that may be detected in or on
certain items of produce and in processed fruit and
vegetable products, as well as in grains and grain
products and other miscellaneous foods.7 The tolerances
(ie: maximum levels) for pesticide residues in raw
agricultural commodities are set by the Environmental
Protection Agency (EPA) in its pesticide registration
process.1 To the extent that adoption of more environ-
mentally benign agricultural practices involving reduced
rates of pesticide application may be hindered by existing
standards, their modification may allay consumer con-
cerns with residues in foods. An added benefit is a
reduction in the total chemical loading to the environ-
ment with concomitant gains in environmental quality.
Though not now considered in governments' con-
ceptualization of quality, the possible presence of pesti-
cide residues in foods are beginning to be considered by
consumers as a determinant of quality, along with the
more traditional attributes such as sweetness and matu-
rity.' At the present time, information on the existence of
pesticides in foods can be conveyed to assist consumers
in their purchasing decisions only in states or communi-
ties where organic or "pesticide free* certification pro-
grams are in place.
This report provides an overview of what is known
about the economic and regulatory incentives to use
pesticides to enhance the cosmetic appearance of fruits
and vegetables. In particular, it describes the institu-
tional process and context in which quality standards for
fruits and vegetables are set. In discussing how they are
used in the market, this report assesses the potential for
cosmetic criteria to lead to pesticide use. Areas are
identified where intervention in the system could reduce
the economic incentives to use chemical pesticides be-
yond what is necessary for nutritiousness and market-
ability. This report should be seen as complementary to
U.S EPA Headquarters Library
iv;?:! code 3^0!
1200 P-jT'Sy.v'ariia Avenue NW
Vv3ShK-oton DC 20460
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Introduction
further research on consumer attitudes towards pesticide
use and cosmetic appearance of fruits and vegetables.10
Chapter I is a discussion of the economic
motivations of farmers and growers. Chapter n outlines
the major regulatory interventions governing fruit and
vegetable quality. Chapter in depicts the relationship
between major institutional factors and grower behavior
as regards food quality, including stipulations written
into farm loans and contractual agreements between
buyers and sellers. To demonstrate the interplay between
these several forces, Chapter IV presents case studies for
apples and tomatoes grown for the fresh and processed
market. Chapter V presents the major conclusions of this
report. Appendix A contains procedures by which food
grading standards, federal marketing orders, and defect
action levels may be modified; Appendix B contains a
recent listing of these standards.
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use I • 1
Chapter I
Economic Factors Effecting Grower Behavior
Economic Motivations of Growers
In 1987, 3.5 million acres of vegetables and 4.6
million acres of orchards and vineyards were commer-
cially harvested in the United States.1 Out of a total of
282.2 million acres of harvested cropland across the
country, fruits and vegetables accounted for only a small
percentage of total land. But production on this land is
generally intensive, especially in California and Florida
where the longer growing season permits multiple har-
vests.2 While a large percentage of total production
occurs in these two states, significant areas of fruit or
vegetable production can be found in many other states
(for example, potatoes in Idaho and Maine, apples in
Washington, Pennsylvania and the New England states,
and grapes in New York).
It is commonplace to say that most formers operate
with a narrow profit margin. A farmer's fixed costs
might include land rental or mortgage, equipment rental,
construction loans, and property taxes. Operating costs
encompass labor, seeds, agrichemical inputs such as
fertilizers and pesticides, fuel, and equipment mainte-
nance and repair costs. Labor costs to growers of fruits
and vegetables are relatively high, since hand-picking is
often required. Typically, fruits and vegetables require
greater amounts of nutrient and are more susceptible to
ruin from pest infestation than field crops (such as com
and soybeans), making their production more costly due
to pesticide and fertilizer expenses. As high value crops,
the economic value of an acre of fruits and vegetables far
exceeds the value of an acre of cash grains. The loss of
the production from a small number of acres through pest
infestation can translate into significant revenue losses.
With high overhead, the grower strives to maximize
yield in an economically efficient manner by selling as
much as possible, at the highest selling price possible.
Under the current market structure, enhanced cosmetic
appearance can significantly increase the selling prices
for growers, with chemical use minimi ring the risk of
cosmetic damage. The market forces which compel
growers to meet high levels of cosmetic quality are
discussed in depth throughout this report.
Consumer Preferences and
Economic Motivations of Buyers
External characteristics perceived by the senses such
as sight, touch, and smell are important in consumers'
purchasing decisions, while internal characteristics per-
ceived by taste (such as sweetness, juiciness, texture, and
flavor) are important in determining acceptability and
repurchase. Less-tangible characteristics such as nutri-
tional value, health risk, and environmental risk also
factor into consumer demand based on their perceived
importance and the availability of information for deci-
sion making.1 Cosmetic quality encompasses only a
portion of the characteristics which form consumer
perceptions of quality, but "because what constitutes
fruit [and vegetable] quality is a subjective decision,
produce purchased in the retail marketplace reflects the
preferences of not only the consumer, but the grower,
shipper, and distributor as well."4 Hence, the consum-
ers' perception of quality must be weighed against the
sellers' profit motive, which may promote the sale of
only what they perceive to be most profitable products.
According to many farmers and commodity groups,
the American consumer is perceived to want produce that
is highly aesthetically pleasing. * Food retailers evidently
share this perception. Ray Harris, general manager of
Harrison Farms, Aroostook County, Maine recently
commented on the amount of potatoes wasted each year
because restaurants and supermarkets refuse to buy
misshapen potatoes. Chairman Tony Hall of the House
Select Committee on Hunger indicated that 60 million
tons of "so called imperfect food" is thrown away each
year.'
This is not suggesting that consumers do not desire
aesthetically pleasing fruits and vegetables. However,
based on what is available .to the consumer, "imperfect"
is a relative term. For example, when the retail consumer
in the produce section of the supermarket is deciding
among fruits and vegetables that are generally uniform in
size, shape, and color, a slightly smaller irregularly
shaped and colored fruit or vegetable could be deemed
undesirable, depending on the commodity.
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1-2
Economic Factors Effecting Grower Behavior
In writing contracts with growers or shippers for
supply of fresh produce, the profit-maximizing retail
operator is interested in two things: salability and profit
margin per unit. It is the multiplicative product of these
which must be maximized, which is to say that a product
which sells well, but only at a slim profit, or a product
on which a high profit margin can be obtained but which
sells in very limited quantities, are both inferior in
profitability to a product which sells well at a relatively
high margin of profit.
Produce exhibiting the highest levels of cosmetic
quality typically sells for premium prices as it passes
along the distribution chain since it is perceived that such
produce will sell easily to the consumer at premium
prices.7 Even slight blemishes may render fruits and
vegetables incapable of being sold to the fresh market -
- in part because the blemish may render the items
unsuitable for transport or storage, given the existing
production and distribution system and the need to
transport produce long distances.1 Oversupply may cre-
ate an incentive to sell only the most profitable commodi-
ties [For an illustration of how the distribution system
has expanded the market, see Figure 1-1]. Such com-
modities may find a market in processing, but for
growers targeting the fresh market, this frequently means
selling at lower levels of profit or even a loss.*
The message to the grower then is clear. Fruits and
vegetables will sell more readily, and will obtain a higher
price, if they are of better cosmetic quality. This is
especially true of the fresh market, but applies as well to
fruits and vegetables grown for processing.
Grower Objectives and the Use of
Agricultural Chemicals
As the previous discussion suggests, the grower
aims to achieve two primary objectives-one that is
quality-related, the other quantity-related:
In a cost-effective manner, sell as many units as
possible, over as long a season as possible. By
spreading out the growing season, a grower can
risks from loss due to weather and other
factors, and can take advantage of periods of lower
supply to receive premium prices.
In a cost-effective manner, ensure that a high per-
centage of crop attains the highest grade and highest
level of cosmetic appeal. I0
Over the past several decades, awiderangeof agronomical
and technological innovations have emerged which fa-
cilitate, in one way or another, the attainment of these
two primary objectives. The following are six examples
of such innovations.
Figure 1-1
Market Expansion Through Product Shelf-Life Extension
Point of
Production/Distribution
Traditional Market Range
Expanded Meiket Range Qnen
Longer Produce Shelf-Life Due to Such
Addition* M Pott Herveet Chemieele
Point of Sale
Varioua poet-harveet innovations such aa refrigeration, waxing, and post-harvest fungicide application* have allowed the
traditional market range (in terms of both shipping distance and shelf-life) to expand dramatically.
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An Overview of Fruit and Vegetable Standard! Relating to Cosmetic Appearance and Pesticide Uee
1-3
1. Expanding the growing season.. This is accom-
plished using greenhouse starting, early and late grow-
ing varieties, growth regulators and artificial ripening
(to ripen fruit, in color but not necessarily in sugar
content, early and late in the natural growing season).
2. Extending the shelf-life and/or shipping distance
potential of produce. This is achieved by the following:
controlling pest incidence prior to harvest (insecticides,
fungicides, herbicides); removing pests after harvest
(post-harvest insecticide and fungicide application, or
various mechanical means); applying sprout inhibitors
to preserve items of produce longer into the off-season;
refrigeration; controlled atmospheric storage; and, wax-
ing. (See Figures 1-1 and 1-2)
3. Improving shipping qualities. Shipping costs and
shipping losses have been reduced through the develop-
ment of plant varieties (cultivars) which yield hardier,
more uniformly-shaped (ie: * squarer' for packing pur-
poses) fruits and vegetables, field cooling, and by
picking and shipping fruits and vegetables while unripe
and then artificially ripening them at the outlet market.
4. Improving produce appearance. This has been
achieved through the development of plant varieties
(cultivars) which yield more attractive and more durable
fruits and vegetables, prophylactic chemical spraying to
preclude potential minor pest damage, use of growth
regulators to provide control over external attributes
relative to the picking and distribution schedule (ie:
simultaneous ripening of all fruit on a tree), artificial
ripening, waxing, and use of fertilizers to enhance fruit
size."
5. Reducing per unit costs of production. This
usually means reducing labor inputs through the use of
hardy plant varieties (cultivars), regularly-scheduled
broad scale pesticide application, and mechanized pick-
ing and packaging.
6. Protecting and enhancing yield. Pesticides are
designed to 'protect yield' by ensuring the integrity of
fruits and vegetables (to a degree based upon notions of
what constitutes acceptable quality), and by minimizing
competition from weeds. Enhancement of yield is gener-
ally accomplished by using high-yielding plant varieties
(cultivars), and by irrigating and applying nutrient
material-in the past several decades this has meant
primarily quick-release (water soluble) inorganic fertil-
izers.
Such innovations have brought per unit production
costs down, reduced transit losses, and yielded bountiful
and beautiful produce. They have also, however, given
rise to a system of food production for which there exists
Figure 1-2
Theoretical Value of a Given Grade Over Time
With and Without Post-Harvest Chemical Applications
Decreasing
Market
Price
premium grmdm for
primary gndo for proe
frmstt mmrkmt \
1
1
1
1
L.
•stop merirer |
•
"1
1
1
1
1
With
Pott-Harvest
Chemical*
Without
Pott-Harvest
Chemical*
Increasing Time From Harvest
TheoreticaMy. a* a given grade of a frutt or vegetable age. the market price eventuaHy decree***. In the dashed line above, we iduitrste
how the ute of post-harv**t chemicals allows grower* and distributors to effectively increase the economic value of their product. Also,
the second pricing plateau with and without post-harvest chsmicals Mustrates sales of hvstore 'seconds'.
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I - 4
Economic Factors Effecting Grower Behavior
considerable uncertainty regarding external costs (hu-
man health, ecosystems, and environmental resources).
Though pesticide registration and cancellation, use re-
strictions, applicator certification and residue testing set
certain bounds on pesticide use, the true magnitude of
risks and actual damages cannot be stated with certainty,
even under the most controlled scenarios.12
As a result of this uncertainty, the imparting of risk
information to the consumer has not been systematized,
and risk has only in exceptional cases entered into the
consumption decision." Some consumers buy organic or
'pesticide free' produce and pay a higher price to avoid
the perceived pesticide risk. According to a study by
James Hammitt prepared for the U.S. EPA, organic
produce buyers as well as conventional produce buyers
do not distinguish much among risk differences across
different fruits and vegetables (which can vary widely)
except in cases where the media has identified potential
risks (as was the case with Alar for apples).14 Without
good information and labeling to make risk compari-
sons, concerned consumers are forced to use the choices
available: organic certification programs, a handful of
laboratory testing programs such as NutriClean, or non-
certified labels and information given by some sellers.11
According to many recent surveys, consumers are will-
ing to make trade-offs between price and quality at-
tributes such as environmental and health risk.1' Like
other products that are being marketed as healthy and
environmentally friendly, different levels of health and
environmental concern can further differentiate the qual-
ity of produce (in terms of environmental and health
benefits).17
Efforts on the Part of Growers to
Control Pesticide Costs
One professional estimate places returns to farmers
for pesticide use between $3 and $5 for every $1
expended.u This suggests that pesticides are economi-
cally advantageous to growers, but it must be remem-
bered that this return represents averted losses. Pesti-
cides affect pot only plant yield (production of fruit or
vegetable biomass), but also protect economic yield (that
is, harvest which is salable). Pesticide products represent
significant expense to the farmer and it is in his or her
economic interest to minimize pesticide use. Many
farmers, in an effort to reduce pesticide costs, have
recently begun to employ methods known collectively as
Integrated Pest Management (IPM). While IPM systems
are varied and encompass a wide range of biological and
mechanical control strategies, many share the principle
that in order to maximize economic return, some degree
of pest damage is tolerable, and that pesticides should be
employed only when a certain threshold of economic
damage has been reached. Alternatively, IPM may mean
that as a result of pest scouting, a small amount of
pesticide is deemed necessary to eradicate pest eggs or
larvae (hence potential economic damage) instead of the
greater amount that would be required later if the eggs or
larvae were to develop." In either case, the objective of
minimising pesticide costs to the grower, while main-
taining acceptable protection, governs use decisions
(what exactly constitutes acceptable protection is a mat-
ter of degree, and reflects perceptions of what is market-
able).
IPM may result in lower environmental and human
health risks than conventional practices by reducing the
amount and/or frequency of chemical spraying. On the
whole, the emphasis that IPM places on the minimization
of chemical costs to the grower offers significant poten-
tial for pollution prevention and hence environmental
benefits.30
Many farmers, however, do not adopt IPM tech-
niques, even where they are available. They may use
pesticides 'prophylactically,' that is, they apply pesti-
cides preventively, without prior observation of pests or
pest larvae in the field. Some of these fanners are
resistant to change, others may wish to adopt IPM but
have reservations about whether it will work for a
particular pest, whether they will be able to sell their
produce, or whether it adequately compensates for the
additional knowledge and management required. Still
others have adopted IPM but feel constrained in their use
of such strategies because of the need to insure that their
products meet certain standards of quality. Organic
growers too, who operate according to the principle that
no synthetic chemical product is to be used on plants and
thereby can generally receive premium prices for their
produce, may be constrained in marketing by standards
of quality that they cannot meet, or can meet, but only at
greater costs of production.21
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use II • 1
Chapter II
Government Programs Affecting Produce Quality
and Their Implications for Pesticide Use
Efficient operation of the fruit and vegetable market
demands adequate protection of the interests of growers,
intermediaries and consumers alike. Government inter-
ventions into the fruit and vegetable supply (summarized
in Table II-l on the following page) are intended to
ensure such protection. The following statements briefly
describe the roles envisioned for some of these:
Voluntary food grading standards (federal or state)
convey important information to producers and
middlemen about the nature of a product to be
bought, thereby facilitating marketing transactions.
Compulsory federal Defect Action Levels (DALs)
screen out fresh (in the case of strawberries) and
processed foods containing excessive amounts of
contaminants, including filth of all types.
Compulsory federal and state pesticide registration
requirements effectively prohibit the use of chemi-
cals that pose unacceptable risks to farm workers,
the environment, and consumer health. At the same
time, the economic value of a pesticide product is
recognized and a well considered risk-benefit test
supplies the basis for regulatory decision-making.
Chemicals that demand special care are subject to
restricted use provisions.
State monitoring of compliance with pesticide use
guidelines coupled vrilhfederal and state monitor-
ing and enforcement of maximum permissible resi-
due levels in foods ensure that consumers do not
ingest levels of pesticides that could result in adverse
health effects and mat the environment is not ad-
versely affected.
Federal and state marketing orders (MOs) provide
for the orderly marketing of agricultural products in
order to protect the farm sector against debilitating
fluctuations in supply and prices. Created voluntar-
ily by industry, marketing orders become manda-
tory for all growers within the marketing region
represented.
Considerable uncertainty exists about how well
pesticide risks are controlled under this system of gov-
ernment interventions. In the four to five decades during
which the regulatory program has evolved, pesticides
have been registered under differing regimens for data
quality. Under the Federal Insecticide, Fungicide, Ro-
denticide Act (FIFRA) of 1988, there are tight statutory
deadlines for re-registration of more than 600 pesticide
chemicals by 1997, but re-registration under strict and
uniform standards is a time consuming and expensive
process (for industry and government alike).
The effectiveness of compliance and monitoring
efforts is difficult to gauge. States and local authorities
generally do not have adequate resources to fully deter-
mine compliance with pesticide laws. Food and Drug
Administration residue testing, for its put, seeks to spot
shipments contaminated by any one of hundreds of active
ingredients in billions of pounds of produce. Mean-
while, so called "inert' ingredients, many of which are
not biologically inert, have not been adequately tested
for their risks to health or the environment, or have been
shown at some level to be hazardous to health and the
environment, are generally not monitored at all.1
While regulation provides a crucial measure of
control over gross negligence and misuse, the great
H«»man^« it imposes on institutional resources and the
constraints imposed by the unavailability of data suggest
that identification of opportunities for voluntary risk
reduction can significantly enhance the effectiveness of
the total program. Such an opportunity may exist where
pesticide use is influenced by cosmetic quality goals. The
remainder of this chapter provides a more detailed look
at some of the major government programs affecting the
fruit and vegetable supply.
USDA Food Grading Standards
As of September 30, 1989, there were 157 U.S.
grade standards covering 85 fresh fruits, vegetables and
related commodities and 157 U.S. grade standards cov-
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11-2
Government Programs Affecting Produce Quality end Their Implications for Pesticide Use
ering 74 processed fruits, vegetables, and related com-
modities.2 The standards enable the marketplace to
function smoothly by providing a standard language of
trade. As with any product, the wary wholesale buyer
wants to know what he or she is buying and the producer
needs to know what minimum specifications a buyer
seeks. United States Department of Agriculture (USD A)
grading standards establish such specifications for a
variety of food items, including fresh and processed
fruits and vegetables, grains, meat, poultry, dairy prod-
ucts, cotton and tobacco. Hence, an East Coast apple
broker buying apples from a Washington grower, for
instance, can be assured of a given standard of quality
(however defined). Established to aid transactions be-
tween buyers and sellers, the grading standards are
voluntary. As long as produce is not represented as
meeting a given USD A standard when it does not, it may
be sold on the open market. Unlike the Food and Drug
Administration's Defect Action Levels (discussed later
in this chapter), USDA's grading standards cannot be
invoked to ban produce from interstate commerce (un-
less a MO is in place). With the exception of the Federal
Grain Inspection Service which administers grain stan-
dards, the administering agency within USDA for both
Table 11-1
Summary of Regulatory Factors Affecting Grower Behavior
Program
Purpose
Effectiveness
Grading Standards
[Fedenl/USDA]
Voluntary
State Grading Standards
[State/State agricultunl entities and
produce marketing boards]
Defect Action Levels
[Federal/FDA]
Mandatory
Federal Marketing Orders
[Federml/USDA]
Mandatory for growers within
production region voting to
enact an MO
State Marketing Orders
[State or regional/State agricultunl
entities]
Mandatory for industries electing
to be subject to them
Pesticide Registration
[Federal/EPA]
Mandatory
Pesticide Residue Testing
[Federal/FDA]
Mandatory
To provide a standardized trading language for
fruits, vegetables, and nuts, relating to attributes
such as size, shape, color, maturity, defects,
shipping and edible qualities.
Mote stringent than federal standards in order to
enable a state or region build name recognition for
quality and improve market share.
To prevent rotted or filthy (insect parts, rodent
bans, excreta, and mold) food from contaminat-
ing the U.S. food supply.
To improve supply and price stability by control-
ling the supply and/or quality of a commodity
mrVng domestic markets; to develop new mar-
To focus on building a brand name and
market share, and expanding the demand for a
To prevent the use of pesticides which pose
unacceptable risks—human health or otherwise -
such as through the ingestion of pesticide residues
on food, under generally sccepted agricultural
practices.
To prevent domestic or imported fruits and veg-
etables which contain pesticide residue levels
above EPA tolerances from reaching consumers.
Ensure that buyer and seller are discussing
the same quality attributes. A major tool in
the marketplace.
Effectiveness varies from stale to state.
Reflect technologically feasible removal
rates. Effective in keeping filthy processed
foods from market.
Relatively successful at expanding uses for
commodities through quality control, re-
search and promotion on production, dis-
tribution, consumption and volume con-
trol. Producer-run. See discussion for
relation to pesticide use.
Effectiveness varies from state to state.
Over 600 pesticides must be reregistered
against current risk standards. The process
has been legislated under the FIFRA of
1988 to be completed by 1997.
Reliability of tests has been questioned;
see discussion.
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use II - 3
grading standards and federal marketing orders is the
Agricultural Marketing Service (AMS).
Attributes covered by the grading standards for
fruits and vegetables (depending on the commodity)
include: size, shape, color, uniformity of color, taste,
sugar content, firmness, tenderness, smoothness, dry-
ness (for tree nuts), maturity, freedom from decay,
freedom from surface blemishes and various types of
injury, and freedom from other defects considered to
indicate unwholesomeness, likelihood of spoilage in the
course of shipping, or relative unsaleability.1 For some
crops, USD A also sets tolerances for variations in size or
other attributes among a given load.
Grade standards for fruits and vegetables facilitate
transactions in the wholesale market but they generally
do not enter directly into the purchasing decisions of
consumers. The primary exception to this rule for fruits
and vegetables is pre-packaged produce, (often the case
with potatoes, for example) whose packaging may bear
indication of the product's grade. The grading standards
were not originally intended to provide information to
the consumer. A mechanism does exist, though, by
which the grading standards can be changed in order to
respond to consumer preferences, as manifested prima-
rily by purchasing behavior (For an outline of how a
grading standard may be changed refer to Appendix A).
It is open to question how well and how readily the
grading standards respond to consumer preferences and
whether they more clearly reflect an accommodation of
dominant production technologies, which are perceived
or purported to provide what the consumer wants. In the
case of attributes which are of concern to the consumer
but which cannot be assessed by the senses—visual,
tactile or olfactory-such as the occurrence of pesticide
residues, or the nutritional value of a fresh food item,
consumer preferences are not easily communicated to the
food industry through purchasing behavior. As stated in
Chapter I (see page 1-4), consumer preferences regarding
such attributes could benefit both consumers and produc-
ers through a demand for new products. Where willing-
ness-to-pay studies have been conducted, consumer
behavior has been demonstrated to change with addi-
tional exogenously supplied information (such as de-
creased pesticide use).4 Evident consumer concern about
pesticide residues in food and environmental risks from
pesticides has led to the demand for organic produce and
for a program to certify its production without the use of
synthetic pesticides.9
The grading standards do not provide intermediate
handlers or consumers with information regarding po-
tential pesticide residues. All food actually reaching the
market is assumed safe because of the existence of the
various regulatory interventions: EPA pesticide regis-
trations (e.g., use requirements contained on pesticide
labels and pesticide residue tolerance levels), state en-
forcement of pesticide laws, and FDA spot checks to
determine pesticide residues in produce. However, con-
siderable uncertainties remain regarding human health
risks.
Several other points concerning grading standards
and their potential to affect pesticide use are outlined
below:
Although the standards are voluntary, there may not
be alternative markets for raw produce that does not
make the highest grades. Growers have little choice
on whether to meet the "voluntary" standards. In
order to sell their produce at a reasonable price, they
virtually must meet them, or else sell in secondary
markets such as road side stands, formers' markets,
or processing markets (if such alternatives are avail-
able) where prices are generally much lower.
Grading standards are often made legally binding6
through marketing orders or marketing agreements
and for produce destined for import or export. In
such cases, the grower does not have the option to
sell produce of a greater degree of imperfection (that
which obtains a lower grade), even where markets
exist for such grades. While MO's usually establish
"exempt outlets," to which produce failing to meet
MO requirements can be shipped, prices com-
manded at outlet markets are likely to be signifi-
cantly lower than primary markets.
Grading Standards may constrain the use of 1PM
techniques. Conversations with IPM consultants
suggest that more growers would adopt IPM tech-
niques were it not for cosmetic criteria contained in
the grading standards.7
State Grading Standards
Some states also establish food grading standards, in
addition to, or in the absence of, USDA standards. For
processing fruits and vegetables, states generally use
USDA standards unless no USDA standard exists for a
given product (which is the case with certain specialty
fruits or vegetables grown in small quantities). For fresh
produce, both USDA and state grading standards may
exist.
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Government Programs Affecting Produce Quality and Their Implications for Pesticide Use
State standards usually establish minimum matu-
rity, as well as other criteria, some of which pertain to
cosmetic attributes of the product. ' Some states establish
more stringent standards than those established by USD A-
-this may help a state to build a reputation and/or brand
name based on higher than average quality . In such cases,
quality is usually viewed primarily in terms of cosmetic
appearance.
FDA Defect Action Levels
The Food, Drug, and Cosmetic Act prohibits the
introduction, delivery, sale, or receipt in interstate
commerce of any 'adulterated" food. The Act defines as
"adulterated" any food consisting "in whole or in part of
any filthy, putrid, or decomposed substance, or if it is
otherwise unfit for food. "' The Food and Drug Admin-
istration (FDA) of the U.S. Department of Health and
Human Services is responsible for upholding these
provisions. The primary means by which the agency does
so is through the setting and enforcement of Defect
Action Levels (DALs).
The DALs provide a regulatory mechanism whose
objective is to keep adulterated foods, both fresh and
processed, from reaching the consumer.10 DALs are
permitted levels of adulteration-exceedance
of these levels can result in confiscation and destruction
of the load in question. FDA may also initiate detentions,
prosecutions, injunctions, and recalls. Food deemed
adulterated has generally been contaminated by insect
fragments, excreta, rodent hairs or mold. FDA's inter-
pretation of "adulteration* extends, in some cases, to
tiny amounts of insect fragments or rodent filth that are
detectable only by using a microscope.
Regardless of the growing and processing methods
used, food will virtually always contain some insect
fragments and mold; hence, virtually all food is to some
degree adulterated.11 Therefore, FDA sets the DALs to
permit small levels of adulteration in raw produce and
processed food that are deemed "unavoidable" based on
predominant agricultural practices (including the use of
pesticides) and processing technologies (including vari-
ous means of removal in cleaning processes). The DALs
are based on estimates of "attainable* levels found by
conducting a nationwide "market basket* survey of the
product to be regulated. For new DALs, a sampling size
of 1500 is generally used; for updating old samples, 500
are used.12 While the samples do ensure adequate geo-
graphical representation, and may be taken in a number
of years to obtain an average level of insect infestation,
they do not differentiate between different growing
methods (chemical-intensive, IPM, organic). Since or-
ganic and IPM growers who fully adopt IPM precepts
comprise a small part of the market supply, DALs
generally reflect levels that are attainable under more
chemically-intensive systems.
Because DALs were not developed in consideration
of possible pesticide use, they, at least in some cases,
presuppose a use of pesticides that runs contrary to the
practices and objectives of IPM growers - applying
pesticides only after a threshold of economic damage has
been met. Less pesticide use is likely to allow greater
amounts of minute insect parts to occur on raw produce,
which will likely mean more insect parts pass through
processing into the final product. Also, the use of
beneficial insects to reduce the population of destructive
insects, can result in higher levels of insect fragments on
the harvested commodity. Hence, under certain circum-
stances, DALs pose an obstacle to the adoption of IPM
techniques, though this is a supposition that needs to be
researched. Significantly, many DALs have been made
more stringent over time, paralleling technological ad-
vancements that have allowed industry to prevent or
remove more and more adulterating materials, whether
harmful or innocuous."
FDA acknowledges (and the preface to the DALs
states) that unavoidable defects that are the subject of the
DALs pose no hazard to human health.l< Research in this
area corroborates FDA's position-ingestion of minute
or relatively small amounts of insect debris has been
found to pose no discernible health concerns.19
The basing of the DALs on predominant agricultural
and manufacturing methods that provide greater protec-
tion from adulteration than what is necessary to protect
human health establishes the DALs as technology stan-
dards. The level at which a given DAL has been set, in
certain cases, provides a measure of "cosmetic* protec-
tion well beyond what many would consider excessive
adulteration. The amount of insect parts which consti-
tutes "adulteration* is a matter of degree, but should be
investigated with a view to its implications for pesticide
use. It might be noted that systemic pesticides cannot be
washed off of a fruit or vegetable, while tiny insect parts,
rodent hairs, and excreta can.
Unlike USDA grading standards, FDA's DALs can
be legally binding. While technically the standards are
•guidelines* and do not carry the force of law," they are
generally upheld in the courts. DALs have not been
established for all processed foods. However, even for
products without established DALs, growers and pro-
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use II - 5
cessors are still bound to produce unadulterated products
according to the definition of 'adulterated* set out by
FDA (that is, adulteration which is avoidable using
standard agricultural or processing technologies). This
de facto standard has developed because, in the event of
a lawsuit over contamination, the courts have usually
taken the same approach as FDA, basing their decision
on whether the contamination at issue, given the current
state of technology, was "usual" or "unavoidable."
Thus, a court may rule that a product is contaminated
simply because it contains some level of avoidable
defects, regardless of whether it poses health risks or is
detectable without a microscope.17
A grower is generally unable to assess what level of
insect infestation will be acceptable under the DALs.
Because DALs are measured at the marketplace rather
than in the field (providing further opportunity for pest
infestation during storage and transport), and because
commodities for which no DALs have been developed
are still subject to similar standards enforced through
court proceedings, the grower must seek simply to
minimi M> tU insect contamination." Thus, there is an
incentive for farmers to apply pesticides prophylacti-
cally, even if they do not believe it is necessary to control
a pest population from causing significant yield loss; if
the commodity does not meet the DALs, "economic
yield* is zero.
More study, given regional differences in pest
pressure, would be necessary to determine whether a
grower could reasonably expect to satisfy the majority of
the DALs despite reductions in the use of pesticides and
changing growing practices.
EPA Pesticide Registration and
Special Review
Pesticide products must be registered with the U.S.
Environmental Protection Agency before they are per-
mitted to be used in the United States. EPA registers
pesticides under authority of the Federal Insecticide,
Fungicide and Rodenticide Act (FIFRA). In the early
1970s, more stringent registration standards were devel-
oped. Pesticides which had been registered before 1972,
however, were permitted to remain in use under the
provisions of their earlier registrations, pending review
under the more stringent standards. The majority of
pesticides in use today fall into this category. When a
pesticide registered under the former standards meets
certain lexicological and environmental triggers, it goes
into a process called Special Review. A part of this
special review process considers the economic value of
the pesticide in question (ie: its indispensability or
substitutability).
The case of Alar suggests how 'indispensability1
might be overestimated because fanners feel bound to
achieve certain cosmetic criteria. Alar is a growth
regulator (regulating fruit set, size, coloring, and ripen-
ing) used predominantly on apples. Alar was manufac-
tured by Uniroyal until June of 1989 when the company
decided to halt sales due to a heightened level of public
concern over human health risks. Although EPA's Sci-
entific Advisory Panel (SAP) recommended banning
Alar in 1985, Alar was not banned, in part, because of
its perceived economic 'indispensability'." The 1989
apple harvest, the first without Alar, produced a near
record crop and the 1990 harvest was predicted in
November 1990 to be about average. Meanwhile, on an
industry-wide basis, prices remain strong, despite the
fact that some varieties are not as red as they were in the
past and may not make the Extra Fancy grade. The
president of a major trade group conceded that "the loss
of Alar is not a major catastrophe for growers. *" This is
not to deny there were economic benefits of Alar (which
varied depending on variety and location), but it does
suggest the need to look carefully at chemicals that
growers perceive to be indispensable to their long-term
economic viability.
Federal and State Marketing Orders
Marketing orders (MOs) are industry self-regula-
tion programs that grew out of advene market structure
conditions in the agricultural sector during the Depres-
sion. At that time, growers received low returns on their
production because of the market power of a small
number of packing houses and large processing opera-
tions able to dictate selling prices for many small farmers
in various regions of the country.21 To gain market power
and boost growers' incomes, these small fanners banded
together into a type of growers' union. Although grow-
ers are producers of a good, they were exempted from
anti-trust law under the Capper-Volstead Act of 1922,
and allowed to form marketing cooperatives.
These cooperatives often failed for lack of disci-
pline. Some growers chose not to participate reducing
the cooperatives' ability to bargain, while cooperative
members often cheated when faced with unsold goods by
selling on the open market.
In response to the difficulties growers were facing,
the federal government legislatively authorized collec-
tive marketing arrangements, which, once approved by
an industry (usually growers of a given fruit or veg-
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11-6
Government Programs Affecting Produce Quality and Their Implication* for Pesticide Use
etable), were legally binding on all members of the
industry. MOs are the contracts which specify the legally
binding conditions of association for each participating
industry. The goal of a MO is to control market quantity
or quality (it varies by commodity), with the ultimate
goal of stabilizing or boosting grower prices. To some
degree, MOs may also improve long-term demand for a
commodity, which may also stabilize or boost commod-
ity prices. Once a MO is accepted by an industry and by
the Secretary of Agriculture, all industry handlers,
whether they favored the order or not, are bound to abide
by it
MOs theoretically may increase incentives to use
pesticides. By limiting supply to the primary markets
through grade requirements, in certain cases, marketing
orders increase competition among growers (especially
in regard to factors incorporated into MOs for the
premium market). With quality attributes related to
cosmetic appearance, to a large extent, determining
access to the premium and primary markets, there is
greater incentive to use pesticides as insurance against
damage that can down-grade fruits and vegetables. The
methods by which MOs may affect supply or quality are
described below. (For a listing of federal MOs and when
they were established, see Appendix B)
Components of Marketing Orders
Federal MOs differ in their components and goals.
For example, regional or state-specific MOs do not
generally attempt to control supply. Instead, they aim to
increase demand by ensuring consistent quality within a
geographic area and to develop a brand name. Unless a
region produces a large majority of the national supply,
attempts to control supply through a regional MO would
likely be defeated by producers outside the region.
Rather than the desired increase in product price, the
participants in the MO would simply see a loss of market
share.
Marketing order components fall into several cat-
egories: supply management, quality controls, and de-
mand management. These three categories are described
below.22
Supply Management
In theory, supply management is supposed to in-
crease returns to growers and reduce price volatility of
the products. Actual effects on prices in practice are not
entirely clear and depend on (1) whether the marketing
order is national or regional, and (2) the role of imports
Ways Supply Can Be Managed Through Marketing Orders
1. Producer allotments fix the quantities that
handlers for specific growers may sell in a specific
market The allotments agreed upon an generally
based on historical sales and may or may not allow
market entry for new producers.
2. Market allocation fixes the ™Timum quantity
that handlers may ship to different markets. By
restricting supply to high-return markets and di-
verting the remainder to lets profitable ones (ie:
domestic fresh vs. export or processed), overall
returns are increased. This may actually hurt
producers who grow primarily for the secondary
market or who are unable to gain a foothold in the
restricted market
3. Reserve pools are crop set-asides for future
changes in markets. They stabilize the quantity
supplied to markets over time by reducing supply
during peak shipments and increasing supply dur-
ing low periods. Reserve pools are very similar to
market allocations, except that the "excess" prod-
uct is not immediately diverted to other uses (such as
the processing market). The pool may be used in the
primary market at a later date, diverted to secondary
markets, or utilized for non-food uses (e.g.: feed,
ethanol).
4. Market Flow Regulations are a subset of supply
controls and aim to restrict supply over time, rather
than by markets. In theory, all production is sold
(though in practice not all produce may be marketable
in the next time period, due to rot, etc.), but returns
are increased by regulating the rate at which it is sold.
Two approaches are used to regulate market flow:
• Prorates specify the maximum amount a handler
may ship to a primary market in a specific period
of time (week or month).
• Shipping holidays are periods during which all
commercial shipping is prohibited. Shipping holi-
days are used primarily to avoid a build-up of
supplies in terminal markets during periods of
restricted trade activity.
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An Overview of Fruit and Vegetable Standard* Relating to Coametic Appearance and Pesticide Uee
and other substitutes for the product (e.g., processed
fruit products, such as orange juice, substituting for
fresh orange consumption). Where successful, supply
management can increase prices received for produce by
reducing the quantity supplied for marketing. The four
ways in which supply can be managed are listed in the
box on page 11-6.
Quality Control
Quality controls establish minimum grade, size, and
maturity requirements for a product. They are enforced
through federal, state, or other designated inspection
services and often consist simply of making USD A food
grading standards for a particular commodity mandatory.
While quality controls may sometimes protect the
consumer from immature and poor quality fruits and
vegetables, they may also provide another form of
supply control. For example, MOprovisionsforkiwifruit
prevent oval kiwis from being marketed, even though
they are identical (other than in shape) to kiwis that do
reach market.11
Two researchers found that in most cases the
specified requirements remain unchanged from one mar-
keting year to another. Such behavior suggests that the
industry means to impnae and maintain • minimum level
of product quality over time. In some cases, the require-
ments are frequently changed, bom within a shipping
season and from one season to another possibly due to
fluctuates in the level of quality due to weather, unusual
pest infestations or other extenuating circumstances.
This suggests quality standards an used as a form of
quantity control to manipulate the amount sold.14 In
practice, quality control provisions may be set in such a
way as to circumvent the need to change them, in view
of the legal morass that may be encountered:
Federal and date statutes often require drawn out
legislative or administrative procedures to modify or amend.
. . Therefore, marketers are belter off maintaining somewhat
low quality standards that are general enough to allow interpre-
tation or other methods (such as speeding up any manual
inspection processes) to provide the flexibility to maintain even
supply in both times of surplus and times of shortage.15
Factors other than strict statutory language play an
important role in grower decisions; for instance, Jesse
and Johnson acknowledge that "the vigor with which
quality regulations are enforced varies considerably
among orders."1*
Thus, while explicit quality controls (in the form of
MOs) may not restrict supply, market interpretations of
the orders, especially during periods of excess supply
relative to demand, may implicitly lead to a very differ-
ent result. These interpretations, which are flexible due
to supply and quality levels within the market, become
the marketplace-enforced messages that growers must
listen to in order to remain in business.
Demand Management
Marketing orders are also used to facilitate joint
research and advertising and promotional activities to
enhance consumer demand. For example, the costs for
industry promotion of California pears, plums, and fresh
peaches are paid by fees assessed at the handler level.27
Effects of Marketing Orders
InJanuary 1992 there were 44 MOs covering 32
crops in 32 states2* designed to help the small fanner
("price-taker") get a fair price from monopsonist buyers
("price-setter"). Whether they have successfully done
this is unclear. One USDA study found that "price
comparisons for fruits and vegetables covered by federal
marketing orders with similar or identical commodities
not under orders suggest that the orders have not yielded
higher or more stable farm prices." The authors of this
report did not find any study to indicate the contrary.2*
Some growers are large enough to bargain success-
fully with the large produce buyers. These growers exert
market power over smaller growers and may create
barriers to entry to prevent new competition.10 The buyer
still controls the purchase conditions because marketing
order-based standards are often flexible enough, in
regard to certain quality levels, to give the packing
houses latitude over what they may or may not legally
accept, depending on growing and market conditions.
This flexibility, especially in the face of perpetual
oversupply of many products, makes bargaining more
difficult for the seller.
Although MOs do exempt certain outlets, on an
industry-wide basis, they effectively act as barriers for
the marketing of less aesthetically perfect produce.
Today, secondary grades of fresh produce seldom appear
in supermarkets.
On the basis of the case studies researched in this
report, it appears that MO quality requirements are
generally less stringent than the market-based cosmetic
standards that growers must ultimately meet. It is unclear
which changes to MOs to reflect less stringent cosmetic
standards lead to changes in grower behavior and pesti-
cide use patterns without concomitant changes in con-
sumer behavior. The latter may require consumer educa-
tion.11
-------
II - 8 Government Program* Affecting Produce Quality and Their Implications for Pesticide Use
As to changes in the process of establishing market- in the industry.12 Although MOs are designed to help
ing orders, Feenstra asserts that the members of the small fanners, who make up a large share of the produc-
marketing order administrative committee, the organiza- ers employing low-input agricultural practices, they may
tion responsible for carrying out the marketing order be very poorly represented.
statutes, represent only the interests of the major forces
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An Overview of Fruit end Vegetable Standard* Relating to Cosmetic Appearance and Pesticide Use
III - 1
Chapter III
Market-based Factors Affecting Cosmetic Appearance
A number of market-based factors may promote
pesticide use and pose barriers to the adoption of less
chemically-intensive systems. These practices include
contractual purchase agreements between the grower and
the processor, wholesaler or retailer, and stipulations
over growing practices on the part of lending institutions
or crop insurers (see Table ffl-l below).
Contractual Agreements Between
Buyers and Sellers
Contractual agreements between buyers and sellers
have the most direct influence on grower behavior
regarding pesticide use and cosmetic criteria. Govern-
ment ff*««darH« enforce the minimum quality standards
allowable in the marketplace, but the actual standards
required by buyers may be set at will. Generally, the
greater the supply of produce relative to demand, the
more power the buyer has over the seller in setting price
and quality requirements; in the United States, supply is
seldom scarce giving buyers the edge. Thus, while
formal standards exist for fruits and vegetables for both
the fresh and processing markets,
for many crops the operationally effective standards are
those that are required by contractual agreement between
producers and buyers, or by the joint agreement of producer!
through marketing cooperatives and marketing orders. In most
cases this latter type of quality standard is much more stringent
than the statutory standard.'
Table 111-1
Summary of Market-based Factors Affecting Grower Behavior
Program
Purpose
Effectiveness
Written or de facto contractual agreements
LEVEL: Local contract*, which in the
aggregate, affect national marlrtu
INSTmmONS:peclcinfbou«», bro-
ken, large retail chains, and proces-
sor*
Voluntary, but certain term* have
become mandatory
To ensure the buyer get* exactly the type of
product denied. May contain stricter guide-
line! many any government standard*. Can be
sued to control volume. Explicit contractual
requirements may, over time, become market-
enforced, df facto indiutry standard*.
Conditions for crop loans or crop insurance
LEVEL: Local contract*, federal
INSTITUTIONS: bank*, crop in-
surer*
Voluntary, but term* of agreement*
become legally binding
To provide grower with financial resource*
and income security. Minimize risk to the
lender by •M"m"i"g short-term grower re-
turn through pencribed growing practice*.
As the market standard for'quality', repre-
sent* the most direct impact on grower
behavior. The relative market power of
buyer or handler compared to grower af-
fect* the nature of the agreement in term*
of quality characteristic* and growing prac-
tice*.
Can curtail grower flexibility in accepting
some pest related crop loaac*, and to try
new management technique*, which are not
generally approved by tender* and insur-
er*.
-------
Ill-2
Institutional Factors Affecting Produce Appearance
The importance of written or de facto contractual agree-
ments is apparent in the case studies of apples and
tomatoes presented in Chapter IV.
Contractual agreements accomplish a number of
important things. They allow growers to plan crop
plantings with some degree of knowledge about future
sales and future revenues. They provide processors and
retail chains a similar ability to plan production strate-
gies, as well as an assurance that existing capacity will be
filled. They also ensure that some minimal level of
quality will be provided to the buyer. Contracts cannot
control acts of nature that alter the quality of delivered
produce nationally or regionally. Nor will contracts
necessarily protect a buyer from over-commitments to
buy produce of a particular quality in bumper years.
However, in order to protect the buyer from both the
problems of oversupply and undersupply, contracts are
often made flexible by leaving room for somewhat
subjective quality assessments by the buyer. Product
attributes not differentiable in the marketplace (e.g.: the
presence of different levels of residual pesticides below
EPA tolerances) are unlikely to be included in such
agreements, and will therefore be left out of production
decisions. To the extent that contracts are used to reduce
or eliminate pesticide usage, they may have a dramatic
effect on grower practices as well.2
The nature of purchase contracts varies according to
the relative powers of buyer and seller. A small tomato
grower contracting with a large processor may have few
or no alternative markets for his tomatoes, while the
large company has multiple sources for obtaining toma-
toes (i.e., the buyer acts as a monopsonist). In such a
case, the contractual agreement reached is likely to favor
the large firm because of the grower's limited bargaining
power.
Industry Concentration and Market Power
The fruit and vegetable industry has seen a shake-out
of many wholesalers and intermediate distributors.1
While wholesalers and distributors still exist, by verti-
cally integrating their own distribution, retail chains
now serve a majority of the distribution channels. As a
result, the buyers of produce are now concentrated in
fewer and fewer retail chains, which are now the largest
purchasers from packing houses. It is these large retail
supermarket chains, therefore, that set most of the
operational decisions on fruit and vegetable aesthetics. If
their contractual standards are not met, the retail buyers
do not have to pay full price at the packing houses. Rather
than risk monetary losses, the packing houses take steps
to ensure that the growers meet these standards.4
Downgrading Quality Standards Along the
Produce-Handling Chain
Standards enforced by the retail chains, the last
stopping point before produce is sold, has led to another
problem. Because fresh fruits and vegetables are har-
vested, packed, and often shipped long distances before
they reach the retail chains for sale (where produce
quality is checked), there is a risk that the produce may
be damaged or aged during handling and shipping. Thus,
while the produce may have been initially up to the
contracted standards, it may no longer satisfy the agreed
upon quality standards when it reaches the point of sale.
If this occurs, it could cost the growers and handlers both
money and future contracts.
To protect themselves against the possibility of not
meeting the standards established by the large retail
chains, all intermediate handlers require a safety margin
between the actual quality of the produce they buy and
the promised quality of the produce they deliver. For
example, one apple grower described how his apples
were advertised by a broker as "better than Extra Fancy'
(the highest USDA apple grade), since they did exceed
US Extra Fancy standards. However, by the time they
reached the stores, they would go out on the shelves as
US #1, the third highest grade. Downgrading quality
along the chain protects the intermediate handler from
complaints from the seller and protects the seller from
complaints from consumers.3
Qualitative Measures to Protect the Produce
Buyer
There are assertions that standards have been kept
purposefully vague to allow produce buyers or proces-
sors to buy a volume that equals their needs (1) by
excluding produce that technically meets quality stan-
dards during times of oversupply, or (2) by buying
"below" grade produce in lean production years. Ac-
cording to one study, middlemen such as packers,
shippers, and marketing cooperatives act independently
by using "quality standards not so much as ensure a safe
and nutritious produce for the consumer, but to control
which and how much produce gains access to the mar-
ket.'«
Supply control is established at the packing houses
by increasing quality standard decisions, thereby reduc-
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use
ing the volume of fruit "making grade.' Because the
grower has no objective way to determine ahead of time
what level of quality will be acceptable at the packing
house, as many defects as possible are eliminated to
ensure the load will be saleable. Eliminating most
defects on many fruits and vegetables requires ex-
tremely careful harvesting and handling, and, under
most circumstances, the use of pesticides — unless there
is an alternative distribution channel for the grower,
such as the organic market, which pays a premium for
lower (or no) pesticide usage, the grower cannot recoup
the greater cost of production.
Pest control exhibits diminishing returns per unit of
pesticide applied as the allowable defects approach zero.
Allowing higher damages with less chemical controls
may both reduce pesticide use and increase returns. For
example, Dr. Ted Wilson, a researcher at UC Davis,
estimates that pesticide use on processing tomatoes may,
under some circumstances, be reduced 40-60 %, with a
concomitant reduction in cosmetic quality.'
Use of Quality Standards To Control Supply
in the Citrus Market
Qualitative judgments regarding fruit quality play
a role in supply control in the citrus industry in the West.
The enforcing agent in the orange market is not a retail
chain, but rather the growers' cooperative, Sunkist
Growers, Inc.
Sunkist sets standards based on attributes such as
flavor, form, color, texture, condition, freedom from
decay, and freedom from defects.* The interpretation of
these standards fluctuate depending on growing season
and time of season. While less variation is tolerated on
the Sunkist brand name, fairly wide variation exists for
other grades - especially when supply is low (i.e., more
cosmetic damage is allowed).10
Oranges trademarked Sunkist are excluded if they
are more than slightly scarred, puffed, sunburned,
rough, soft overmature, or damaged by frost or aging.
Sunkist claims inspectors are adequately trained to
consistently Judge these criteria"; however, van den
Bosch suggests
it is difficult to know exactly what "more than
slightly scarred" means. Additionally, the cause of many of
the defects is not specified...The wide range of exterior
defects specified in the quality standards are not detected by
any quantitative technique. Rather, the oranges are screened
visually by packing-house worker* as they are carried down
a conveyor belt.0
Contractual Agreements to Reduce
Risk to the Buyer
Because, in many cases, there is no viable fresh
market for "secondary" quality fresh fruits and veg-
etables, producing such produce exposes more than just
the farmer to unacceptable financial risk. Buyers fear that
presenting fresh produce with an occasional insect will
prevent produce sales and convey a message that the rest
of the produce is impure. They
maintain that the presence of one insect often indi-
cates that more may be present in the shipment. It makes no
difference whether the insect is one which attacks the commod-
ity. Evidence of insect damage is treated almost as seriously as
the presence of insects. Buyers said that produce must be
practically free of insect damage to be saleable.11
This appears no less true today then it was in 1978,
judging by the effort that the growers with whom we
spoke put towards prevention of insect damage to their
produce. To reduce their risk (whether perceived or real)
of a reaction from consumers, buyers insist on an absence
of any insects on their fruits and vegetables.
Some buyers or processors attempt to control the
quality of their contracted produce by explicitly requir-
ing particular growing practices in the contract. Thus,
contracts may force the grower to
spray fields a stipulated number of times each season
regardless of insect infestation to "assure" a bug-free crop. A
grower's failure to follow the treatment schedule is sufficient
basis for contract cancellation.14
Implicit control of growing practices, through buying
decisions, also seems to affect grower pesticide use. For
example, processors can and do raise die threat of "load
dumping" at the processing plant in the event that the
grower has not followed the prescribed pesticide control
practices. This threat is taken quite seriously since "it is
quite easy to find insects or 'insect' damage in any load
of produce if one really tries.*15
The greater the degree to which the buyer can
stipulate growing practices, the more accurately he or
she can predict expected crop losses. With more certainty
on the amount of damaged produce to expect, the buyer
may determine the supply needed for production or sale
with a lower margin of error. A lower margin of error
improves buyer profitability. While expected losses
from organic or IPM techniques could potentially be
predicted with equal accuracy, doing so is more difficult
and requires an understanding of many more production
factors."
U S EPA Headquarters Library
MT:icod.=. Cr'01
^OO^.-^s-.'Svnrna/won-jeNW
Warvisnv.or. DC 20460
-------
Ill- 4
Institutional Factors Affecting Produce Appearance
Retail Chain Produce Contracting and
Pesticide Use
In an effort to ensure that their supermarkets have
fresh produce year-round, produce buyers have placed a
premium on the surety of supply. Thus, a supplier that
promises a constant supply of tomatoes year round may
win the entire contract for tomatoes in that- chain,17
although the chain may sell artificially ripened, out of
state or foreign, tomatoes even during the local tomato
season." Such contracts make it very difficult forsmaller,
local suppliers to feed the local retail outlets, even when
their crop is in season."
To supply fresh produce year round, the large
growers and supply houses need to rely on several post-
harvest technologies. To give produce a longer shelf-
life, there has been a large increase in post-harvest
chemical applications, wax applications, and controlled
atmospheric storage.20 Waxes reduce crop moisture loss
30-40 % preventing the shriveling of the produce and the
onset of decay. Half a dozen different waxes are cur-
rently FDA-approved.21 Many of the wax applications
also contain fungicides to further reduce losses from rot.
Many of the fungicides used are suspected carcinogens,
though the levels present on foods are likely to pose a
relatively low risk.3 When combined with the waxes, the
fungicides can be washed off only by using detergent and
water.
Suppliers have also bad to develop growing regions
in the South to supply northern markets during winter
months. Unfortunately, some of the major growingareas
for this purpose, such as Florida, are quite humid and
have severe problems with mold and fungus. Southern
growers must use far more fungicides on their crops than
growers in other regions of the country.29 Thus, through
contracts to supply the northern consumer with fresh
produce year-round, pesticide use has been affected by
(1) application of post-harvest chemicals to ensure trans-
portability and storability and (2) shifting of production
to areas of the country (or different countries) where
greater pesticide usage is necessary.
Bank and Crop Insurance
Restrictions on Grower Practices
Farming is a cash flow industry. Investments in land
are enormous, as are expenditures on farm equipment to
work the land. Seed, fertilizer, and pesticides are all
substantial costs. An agricultural financing system has
evolved whereby the grower will often borrow against
future crops in order to pay for the needed inputs to those
crops. Growers also purchase insurance against crop
failure to reduce risk from year to year. As a result, if a
grower loses a crop to pest infestations, the grower's
bank and insurer also lose. As was demonstrated in other
contractual agreements, parties subject to high risk
intervene with grower choices in an effort to reduce that
risk. The federal government and the institutional lend-
ers also intervene to minimize their respective risks.
Further research is needed to determine the full extent to
which these restrictions may affect grower practices.24
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An Overview of Fruit and Vegetable Standard* Relating to Cosmetic Appearance and Peeticide U«e IV • 1
Chapter IV
Case Studies1
Fresh Market Tomatoes
In the fresh tomato market, contractual obligations
are generally more highly associated with pesticide use
for cosmetic purposes than MOs or food grading stan-
dards.
In the fresh market, USD A Standards for Grades of
Fresh Tomatoes include the following quality attributes:
color, size, maturity, firmness, shape, smoothness,
freedom from defects (including insect injury, puffiness,
catfaces, scars, growth cracks, and hail), and freedom
from decay, freezing injury, and sunscald.2 The USDA
Standards for Grades of Fresh Tomatoes were made
mandatory in all Federal MOs affecting fresh market
tomatoes.1
While Federal standards allow 15 percent of the
tomatoes, en route or at destination, to be lower than
U.S. f 1 Grade4, the packing houses must sort the bad
tomatoes out by hand. Generally, packinghouses aim for
as low as a 5 percent incidence of tomatoes below U.S.
11 Grade. Packing houses' explicit (contractual) or de
facto (based on past actions) standards, rather than MOs
or food grading standards, appear to be the quality
standards of greatest import to me grower in pesticide use
decisions. However, most of the key elements of pack-
inghouse standards are drawn from the quality criteria
incorporated in federal standards and hence their impor-
tance should not be overlooked.
To control the number of rejects, a number of
strategies are employed. Growers choose to plant tomato
strains mat are disease resistant, and have tough skins
and a slightly square shape for better packing. Pesticides
are used, generally on a basis of cosmetic damage
threshold rather than an economic damage threshold.
With a cosmetic damage threshold to ensure that the final
product meets the standards at packing houses,
growers must use more pesticides than they might
otherwise. Some giowus, in fact, may spray up to 40 times a
season in some fresh market tomato districts...1
However, this pesticide use can be significantly
reduced. Preliminary results of a 1986 study of 40 IPM
fresh market tomato growers in Florida found that
available IPM methods reduced insecticide inputs by
about 21 percent and yielded an average increase in net
returns of $121/acre for the 62 percent of the growers
reporting increased returns.' What the exact relationship
is between IPM methods and cosmetic damage thresh-
olds is unclear and needs to be researched.
The trend towards year-round marketing of fresh
tomatoes in supermarkets throughout the United States
has led to an expansion of tomato production areas
throughout the southern U.S. and Mexico and has been
accompanied by the development of longer-term con-
tracts between supermarketsand these producers. Mexico
supplies a high percentage of tomatoes in late Winter,
where they are washed inachlorinebath and then ripened
with ethylene gas.7 Some of the pesticides frequently
applied to tomatoes (dimethoate for thrips,
methamidophos for stink bugs) are systemic, that is, they
are absorbed into fruit or vegetable tissue, and cannot be
washed off.1 Fungicides are added to tomatoes for long-
term storage and long-distance shipping. There are
claims that the use of fungicides would, to a great extent,
be unnecessary if the tomatoes were properly cooled,
packed, and sent to local market for consumption within
-------
IV-2
Case Studies
1-2 weeks, instead of the 3-4 weeks' time it takes to send
them through more complicated distribution channels to
more distant markets.' The 1-2 week period is generally
not enough time for the tomatoes to develop mold.
Fungicides are also heavily used to treat end-of-season
(post-Oct. 15th) tomatoes. Hence, like many other fruits
and vegetables, there are trade-offs between year-round
availability and pesticide use for fresh tomatoes.
To improve shipping qualities, tomatoes frequently
are picked "mature green"10 and gassed at shipping point
or destination with ethylene. Ethylene gas alters the
color, but does not yield the same tissue changes that lead
to ripe tomato flavor. So long as the skin is not cracked
and the tomato has a good pale red color, the grower and
broker will have fulfilled their contractual agreements.
Despite the availability of in-season tomatoes locally
grown and naturally vine ripened tomatoes. The exist-
ence of long-term contracts with brokers and growers in
California and Florida often prevents local growers from
selling to local markets in-season."
The costs to a grower of having his or her tomatoes
rejected is very high. Because the production of fresh and
processing tomatoes are each very specialized activities,
they are essentially different crops.u Thus, a grower for
the fresh market has very few alternatives for crops not
making grade: he or she may not be able to sell to
processors, regardless of the price, and long-term con-
tracting by the retail outlets greatly reduces any options
for direct marketing of either a primary- or a secondary-
quality product. Faced with almost no options, and with
a great deal of time, money, and capital tied into tomato
production, prophylactic pesticide application can al-
most become a necessity.
Processing Tomatoes
Tomatoes grown for processing are used in products
such as ketchup, tomato sauces, juices, soups, pastes and
whole canned tomatoes. In most of the products, the
tomatoes art ground up, often the skins are removed, and
rarely (canned whole tomatoes are an exception) do the
fruits remain whole. Strict restrictions on certain cos-
metic attributes rarely affect the appearance of the final
product While processed tomatoes which are heavily
infested with insects may be undesirable, the presence of
'2x* instead of 'x' microscopic insect fragments in
spaghetti sauce is unlikely to cause any additional health
risk.'1 Yet, whether the lowering of the cosmetic stan-
dards results in a significant reduction in the level of
pesticide residues in the foods needs to be investigated.
Processing tomatoes are one of the few processing
commodities that has a State of California quality stan-
dard. The state has standards for worm damage; in recent
yean, an actuated two-thirds of the pesticides used in
the production of processing tomatoes has been for
tomato fruit worm control. According to van den Bosch,
a large portion of this pesticide use is historically for
cosmetic purposes. '* Until 1968, the standard allowed up
to 10 percent worm damage. In 1968, this standard was
reduced to 2 percent. In the late 1970s,
processor contracts generally [didn't] allow more
than 1 percent worm damage, and in fact many contracts allow
the buyer to reject shipments which contain in excess of 1/2
percent worm damage, and in some cases, the buyer may
require zero worm damage.a
In 1987, a state processing tomato MO was formed.
The quality standards set out by the order duplicate those
previously included in the California Food and Agricul-
ture Code. Factors monitored include color, worm
damage, dirt, mold, green, material other than tomatoes,
and various tomato disease*. The California marketing
order level for worm damage is still 2 percent, while
many processors still require less than 0.5 percent worm
damage, despite that processed tomatoes are usually
pulverized and the damage would never be visible.
Regardless of the rationale behind the processor's dam-
age standards,
losses are high for growers whose loads exceed the
0.5 percent worm damage threshold. Not only are their loads
rejected, but they stand to lose future contracts with the
processor if they consistently exceed the standard.14
-------
An Overview of Fruit and Vegetable Standard* Relating to Cosmetic Appearance and Pesticide Use IV - 3
With a contracted damage level of 0.5 percent, the
grower aims for zero damage in order to have some
degree of safety. Although there are growers profitably
using integrated pest management (IPM) or organic
methods to produce processed tomatoes, they are un-
likely to produce zero loss. Even doing so with frequent
sprayings of chemicals is likely to be extremely diffi-
cult."
As with fresh market tomatoes, grower behavior is
driven by industry standards which incorporate, and
make more stringent, the quality criteria of government
standards. Critics argue that these industry standards,
rather than improving die quality of the final product,
serve instead to reduce aggregate supply and provide a
way for the processors to reject shipments that exceed
their desired production quantities.
To meet the zero damage target, growers face
economic pressure to plant extra acreage and use pesti-
cides more aggressively. Insecticides and fungicides are
used, often prophylactically-that is, in anticipation of a
pest problem but without good information on the
existence or extent of the problem—to ensure that the
crop will not be rejected outright by the processor for
failure to meet the contractual standards.
Processors may also intervene directly in growing
processes to ensure a uniform product that meets their
specifications. For example,
not only do canneries want red tomatoes, but they
want them to arrive in an even flow throughout the season. To
obtain red tomatoes regularly, particularly early and late in the
season, canneries can contract with growers to use a chemical
growth regulator called cthephon (Ethrel). Ethephon triggers
the release of ethykne in processing tomatoes, which turns
them red. It is used on approximately 30 percent of the total
processing tomato acreage.1*
Even though definitions regarding what pests are a
purely cosmetic nuisance (versus pests that are destruc-
tive to productive capacity as well) vary greatly, there is
some evidence that a substantial amount of pesticides
used on processing tomatoes are used to meet cosmetic
quality standards." With slightly higher crop loss rates,
pesticide use may be reduced, as suggested by
research done from 1980-84 by Craig Weaktey, a
Sutler county [California] farm advisor, shows that insecticide
use could be reduced by 40% by growers using an IPM
Figure IV-1
Produce Marketing Options in the Apple Market1
Fresh Market Premium1
(USDA EXM Fancy and Fancy)
Fresh
Market Seconds4
(USDA f 1 and 12)
Premium Processing Grade
(Apple* Grown for Procsuinf and
Rsjects {torn the Fresh Market)
AppUSauet
odur No»-jutct product*
1 ProfltabMty of the markets continue* to i
move from fresh, to processing, to feed uses.
* Highest profit market.
' Detects from the fresh market which are used In processing
tend to have high production costs and tow sals volues.
4 Whis this market would Bksty earn higher profits than the
processing markets, no secondary fresh market cunentfy exists.
and USDA *1 and f 2 grades are used hi processing.
-------
IV- 4
Ca*a Studies
sampling technique and economic venu* cosmetic threshold*
for worms."
Nevertheless, growers will not change their processes so
long as doing so would leave them with a nonmarketable
commodity. Research is necessary to investigate public
willingness to accept greater insect damage or contami-
nation in exchange for lower pesticide use.
Apples
Apples are not subject to any federal MOs, although
Washington apples are subject to the Washington State
MO. Quality and levels are specified officially only
through USDA's "United States Standards for Grades of
Apples."11 These grades are voluntary; however, they
serve, in effect, as the minimum quality levels fresh
apples. The operational standards, which drive the
grower's behavior, are set by the market through bro-
kers, packinghouses, and retail chains. Unlike the fresh
tomato market, where growers unable to sell in the
primary market do not have the opportunity to sell in the
processing tomato market, apple growers can use the
processing market to sell off their lower quality fruit
There are, however, some growers who do produce
directly for the processing market.
A major selling factor in the red apple market is
perceived to be color, and the marketplace is extremely
strict with respect to this parameter. The marketplace
standards do not need to be set contractually, although
they sometimes are. In many cases, however, buyers
base their decisions on what they think consumers want.
They learn by experience. Hence, if a packer ships a load
that is rejected by the market, he changes his packing
standards so that his apples will not be rejected again.
This process of upholding apple 'quality* occurs regard-
less of the way the apples get into the retail channel (e.g.
through a broker, a shipper, a packer, or direct market-
ing).21
Color is important to growers because it sells apples.
Consumer preferences are believed to be dominated by a
desire for big, bright red apples. While this preference
would appear to be valid in the case where all else is
equal, consumer awareness of differentials in pesticide
residues may significantly redefine the preference. One
study demonstrated that consumers are willing to trade
off 11.9% damage (measured as percentage of the
surface area of an apple)23 for no pesticide residues in the
apple."
In the current marketplace, however, color earns
profits. Good color, with no disease or insect damage, is
the aim of the fresh market grower. Especially good
color on some apples in a batch may compensate for other
defects. Thus, slightly higher bruising rates and some
below-color fruits in a crate may be allowed so long as
there are some deep red, shiny apples. To matimin the
number of apples with good color, growers may pick
more than once in a season (allowing maximum tree
ripening time), although multiple harvests add to pro-
duction costs.11
The quality standards currently enforced by the
marketplace substantially exceed those set by USDA.
Fresh apples meeting grade U.S. #1, the third highest
grade, and which show mild scars from healed insect
stings, canno longer be marketed in the fresh market. US
Fancy, the second highest grade, is marketable, but not
profitable (unless there is a shortage). Most of the fresh
market is served by apples meeting and/or exceeding the
requirements of US Extra Fancy. Thus, most growers
aim for this grade. If the highest grades are not achieved,
a grower's crop is destined for the processing apple
market (see Figure IV-1). The sale of apples to the
processing market by growers who have used growing
and handling practices with the intent to sell to the higher
profit fresh market, is usually a last resort to reduce
losses, as the costs of production are generally higher
than the prices paid by apple processors.2*
One grower estimates pesticide usage for apples to
be 50-60% of what it once was.27 Possible causes of this
reduction are a desire to reduce chemical control costs,
or pressure to reduce chemical usage from environmental
regulations. Pesticide use for some apple pests remains
high, however, and use rates vary substantially with
location. For example, control of apple scab in Califor-
nia, due to its dry climate, can generally be accomplished
with 2-5 chemical applications per season. The same
control in New York state, which has more summer rain,
can take 15-20 applications.1*
Frequent sprayings of pesticide are used to attain a
high proportion of the total crop in the Extra Fancy
grade, significant quantities of pesticides are often used.
One farmer who describes himself as a "serious" EPM
grower, produces 90-95 percent of his crop, in the Extra
Fancy grade.1* A high proportion of his spraying is to get
from his crop the extra 5-6 percent Extra Fancy at the
packinghouse. IPM in recent studies10 has the potential
to reduce pesticide use between 25 and 30 percent in
some areas." Yet, because there are usually no profitable
markets for secondary quality fresh apples, and because
spraying is generally relatively cheap compared to the
economic impact of fruit losses,11 there may be no
economic incentive to reduce spraying and accept a lower
percentage of Extra Fancy.
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use V - 1
Chapter V
Conclusions
Government f**B
-------
V • 2 Conclusion*
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use A • 1
Appendix A
Creating or Modifying USDA Grading Standards for Fresh Produce
There are nine general steps in the creation and modification of USDA grading standards. This regulatory
process, which can take from 1 to 41/2 years from start to finish, is described below.'
Step 1: Initiation of New or Revised Standards
Creation of new standards or revisions of old standards can be initiated by interested parties through
correspondence with the Chief of the Fresh Products Branch, Fruit and Vegetable Division of the Agricultural
Marketing Service, USDA. Historically, the requests are initiated by industry groups. The industry may form a
national standards committee to represent as much of the industry as possible, although there is no statutory
percentage of the industry that must be represented. USDA makes a qualitative judgment as to whether enough
of the industry is represented so that going on with the process makes sense. A majority of the committee must
vote in favor of the new standards in order for the process to begin.
Because USDA views the grading standards simply as a standardized wholesaler trading language, created for
and used by the producers, the ability for consumers to alter this process is not known.2
Time frame: Initiation occurs any time a change is desired.
Step 2: Industry Meeting
Upon receiving a request from industry, a USDA standardization specialist may attend industry meetings to
explain the process for standards change and answer any questions from industry.
K There could be one week to 2 years between initial interest and USDA meeting with industry.
Step 3: Initiation of a Formal Request for Change
Procedures to revise a standard begin when industry formally requests a change. If the request is considered
"reasonable and beneficial" to industry by USDA, the USDA standardization specialist would get approval from
the Chief of the Fresh Products Division to file a work plan. A work plan must be filed with the Office of the
Assistant Secretary for Marketing and Inspection Services to obtain authorization to proceed with industry's
request.
The judgment of "reasonable and beneficial" is a qualitative assessment made by USDA. This determination
is made by USDA officials considering both consumer interests and industry preferences. Requests based on short-
term phenomena (such as severe frosts), or which are likely to benefit only a small number of growers are rejected
by USDA.
Time frame: May require up to six weeks for final approval of work plan.
-------
A - 2 Appendix A
Step 4: The Market Survey
Once a work plan has been approved, if there are significant changes requested by the proposal, the USD A
standardization specialist may develop a "market survey" to get ideas and comments from those who may be
affected by the proposal before an official proposal is developed and published in the Federal Register. (Where
only minor changes to the standard are requested, steps 4-6 are by-passed.) The specialist contacts inspection
personnel, state and local government officials, members of the research community, growers, packers, receivers,
and anyone helpful in providing useful information about the product and necessary changes in the product
standard.1
According to USDA officials, consumer or environmental interests are unlikely to be solicited directly for
input since USDA does not maintain a standard roster of names for each mailing, on the premise that each
commodity has a very different constituency.
Time frame: 1 month to 1 year (for seasonal products) after request for standard change is approved.
Industry may also organize a committee to develop its own survey to develop the information necessary for
a revision in the standards rather than rely on a USDA market survey. In such a case, an industry survey would
be done instead of a USDA survey. Survey or polling requirements are not procedurally set. Industry is
responsible for forming a representative industry group. Survey results may be used to request specific changes
in the standards on behalf of that industry. The industry group may either give their recommendations directly
to USDA for further action, or first present their findings to the entire industry (e. g., at an industry annual meeting)
for approval.
Time frame: Approximately 2 months.
Step 5: Mailing the Market Survey
If the market survey is undertaken by USDA (rather than by an industry group), the survey is mailed out to
all relevant parties, including those in die industry and "anyone that might have an interest in submitting
comments" (generally state inspectors, state agricultural associations, and industry trade associations).
Environmental and consumer interests are not regularly solicited.
Time frame: At least 90 days for responses.
Step 6; Review Survey Comments
Survey comments are reviewed by USDA for completeness and degree of controversy over the changes. A
high degree of controversy may lead to a second survey.
Time frame; Evaluation of comments usually takes about 4 weeks.
Step?: Proposed Rule Developed
The USDA standardization specialist uses all of the information generated thus far to prepare a proposed rule
for publication in the Federal Register. The specialist also is responsible for ensuring that the proposed rule is in
the public interest.
Time frame: 2 weeks to prepare a proposed rule; 3-12 additional weeks for USDA clearances and publication
in the Federal Register.
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use A - 3
Once published in the Federal Register, the proposed rule is subject to a comment period. Small changes to
existing standards may have only a 30 day comment pehod. Other rules may have a comment period as long as
one year.
Time frame: 1 to 12 months.
Step 8: Comments of Proposed Rule Reviewed
Comments on the proposed rule-making are then evaluated by the specialist. If the comments show a wide
range of disagreement between portions of the industry or if USD A believes that it is not in the public interest,
the proposed rule change may be withdrawn. The industry would be notified about the problem, and may be
brought together for another industry meeting, or a new market survey would be issued. If industry generally
agrees with the proposal, a final rule would be developed.
Time frame: Evaluation of comments usually takes 6 weeks.
Step 9: Issuance of Final Rule
The final step of this process is the issuance of the Final Rule, which is a rewrite of the proposed rule, including
any relevant comments. Final rules must be authorized through the same process as the proposed rule. Rules
generally become effective 30 days after publication in the Federal Register.
Time frame: 5 to 14 weeks.
Creating or Modifying Defect Action Levels4
Creating or modifying a defect action level involves a number of steps, presented below.
Step 1: Initiation of New or Revised Standards
Initiatives for new or modified DAL's generally originate in one of the FDA district offices, or through an
industry request. FDA tries to target commodities that have a long history of" filth" contamination. Industry may
request new or revised defect action levels for a couple of possible reasons. They may wish to protect their
product's image by eliminating avoidable defects from the marketplace which could cause consumer aversion to
their commodity. Alternatively, industry may wish to have a government body determine that a particular defect
is, indeed, unavoidable, thereby eliminating a basis for rejection of their goods.1 The unbiased appearance of
government standards seems to be an issue in requesting FDA DAL's, since many industry groups already have
their own quality assurance standards which measure the same or similar criteria, and which are often more
stringent than FDA standards.'
Step 2: Industry Survey
Following a request for a revised defect action level, FDA undertakes an industry survey to assess, given
current technology, unavoidable defects. The survey is national and involves 1500 samples for new DAL's and
500 samples for revisions. Samples are analyzed by FDA district laboratories. A new defect action level is set
U.S. EPA Headquarters Library
1200 PoT^/.v-ima Avenue NW
Was'-,i<-:o?Dn DC 20460
-------
A - 4 Appendix A
at the 95th percentile of purity (i.e., 5 % of the current market will fail).1 The survey may take one year, or may
be conducted over a series of years to compensate for annual variations in adulteration levels.
Step 3: Publication in the Federal Register
Once FDA has developed modified Defect Action Levels, they will publish the new standard in the Federal
Register. There is then a 60 day comment period for all interested individuals or industries. This comment period
may be extended to one year for seasonal commodities to facilitate data collection.
Step 4: Final Decision by FDA
At the end of the comments period, FDA will announce its final decision regarding the propriety of the new
or revised DAL's. Sixty days after the publication of the final decision in the Federal Register, the new DAL will
become effective.
Creating or Modifying Marketing Orders
As was the case with USDA grading standards and FDA defect action levels, creating or modifying marketing
orders can be a complex and drawn out process. The necessary steps are presented below.'
1) Orders are initiated by growers, either directly or through their cooperative organizations. Industry
representatives submit a proposal to the Secretary of Agriculture for an order.
2) The Secretary of Agriculture (or the appointed USDA representative) makes a preliminary investigation to
determine the feasibility and necessity of a marketing order.
3) If this investigation determines an order is needed, a notice of public hearing is issued.
4) At the public hearing, any interested party may present information or opinions related to the proposed order.
5) After assessing available information from the meeting, the Secretary of Agriculture determines whether
a proposed order is appropriate, and whether to continue the process of order formation or modification.
6) This is followed by a comment period on the proposal. Any interested person may file exceptions or
recommendations. Following the comment period, and analysis and integration of comments, USDA issues
a final decision and order.
7) The final order is men presented to industry for a vote. Approval of a new order, or modifications to an old
order, requires two-thirds of the producers voting (three-fourths for California citrus fruit), or by SO percent
of the producers representing two-thirds of the volume sold by voting farmers.
8) Once approved, orders are managed by committees of growers, or growers and handlers, and are binding on
all handlers in the areas designated.
9) An order can be ended if at least half of the producers (or producers representing at least half of the production)
vote to end it. Growers may periodically vote to continue their orders.9
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use A • 5
Marketing orders can be amended by following the same general procedure used to initiate new orders. Roles for
the non-industry interests are somewhat limited, and include:
Submitting requests to the Secretary of Agriculture to amend Marketing Order
Providing evidence during the hearing or comment period
Providing evidence to USDA that the order is operating against the public interest, in the hopes that the
Secretary of Agriculture may rescind it
Obtaining an appointment on an administrative committee as a non-industry member (this is difficult to do
because not all committees have non-industry members).10
-------
A - 6 Appendix A
-------
An Overview of Fruit and Vegetable Standard* Relating to Coemetic Appearance and Pesticide Uee
B- 1
Appendix B
Table 1-1.0
Factor* for Fro«h Frultt In th« U.S. Oradee (US) and the) Catrbmia Food and Agricultural Coda (CA)
Fruit
Apple
Apricot
Avocado
Blueberry
Cherry,
*weet
Standard
Mats'!
US (1976)
CA (1983)
US (1928)
CA (1983)
USI19S7)
CA (1983)
US (1966)
US (1971)
CA (1983)
Quaff? Factor*
Maturity, color (color charts) related to grade, firmness, shapa and sizs,
and freedom from decay, internal browning, internal breakdown, scald,
scab, bitter pit. Jonathan spot, freezing injury, weter core, bruises,
russeting, scars, insect damage, and other defects.
Maturity (as determined by soluble solids content (SSC) end firmness
tests)
Cuftrvar SSC Rrmnon
(%) llbl
Red Delicious 11.0 18
Golden Delicious 12.0 18
Jonathan 12.0 19
Rom* 12.5 21
Newtown Pippin 1 1 .0 23
Mclntosh 11.5 19
Gravenstein 10.5 -
Maturity, size, shape, and freedom from defect and decay.
for Fhrido avocado*: Maturity, shape, texture, skin and flesh color, and
freedom from decay, anthracnoas, freezing injury, bruises, russeting,
scare, sunburn, mechanical damage, and other defects.
Maturity (17% to 20.5% dry weight of the fleeh depending on cultivar),
size, and freedom from defect, insect damage, freezing injury, rancidity,
and decay.
Maturity, color, size, and freedom from defect and decay.
Maturity, color, size, shape, and freedom from cracks, hail damage,
russeting, scars, insect damage, and decay.
Maturity (entire surface with at least a solid light red color and/or 14% to
1 6% soluble solids depending on the cultivar), and freedom from bird
pecks, insect injury, shriveling, growth cracks, other defects, and decay.
itfvt
Soureotfor Toolot 1.0- 1.3: AM A. Koaor. -StondonHaOon or* Mapectfeft of frood Voootoolof.'in Unbonity of Cotfomio Coo*
firranaAM Sor** Poithonom TocHnolow of HorOeullurol CKOOO. IMS. pp. 124-130. U.S. Stonoonlt hovo boon updotod»» of Oetooor 1991
us** USDA/AMS gndn Itot nfontteft for fut ctotiontl; CoHfomm ttondw** won not upootod.
'Doto whon ttonotrd wot itiuod or ruvitoa.
-------
B - 2 Appendix B
Fruit
Standard
(data*)
Quatfty Factor*
Citrus,
Grapefruit
Citrus,
Lemon
Citrus,
Lima
Citrus,
Oranga
Citrus,
Tangerine and
Mandarine
Cranberry
Data
US (1950) Caflrbmia end Aritonm: Maturity, color, firmness, size, shape, skin
thickness, smoothness, and freedom from defect and decay.
US (1980) Florid*: Maturity, color (color charts), firmness, size, smoothness, shape,
and freedom from discoloration, defect, and decay.
US (1969) Ttxmt ano* other stitta: Maturity, color, firmness, size, shape, smoothness
and freedom from discoloration, defect and decay.
CA (1983) Maturity (minimum soluble solids/acid ratio of 5.5 or 6 [desert areas] and
>2/3 of fruit surface showing yellow color - 0.9 GY 6.4O/5.7 Munsell
color) and freedom from decay, freezing damage, scars, pitting, rind
staining, and insect damage.
US (1964) Maturity (28% or 30% min. juice content by volume depending on grade),
firmness, shape, color, size, smoothness, and freedom from discoloration,
defect, and decay.
CA (1983) Maturity (30% or more juice by volume), size uniformity, and freedom
from decay, freezing damage, drying, mechanical damage, rind stains, red
blotch, shriveling, and other defects.
US (1958) Color, shape, firmness, smoothness, and freedom from stylar and
breakdown, bruises, dryness, other defects, and decay.
CA (1983) Maturity, snd freedom from defect (freezing injury, drying, mechanical
damage) and decay.
US (1957) CtUfomi* »nd Arizona: Maturity, color, firmness, smoothness, size, and
freedom from defect and decay.
US (1980) Florid*: Maturity, color (color charts), firmness, size, shape, and freedom
from discoloration, defect and decay (used also for tangelos).
US (1969) Taxa* ano* o«r>er *fafM: Maturity, color, firmness, shape, size and
freedom from discoloration, defect and decay.
CA (1983) Maturity (soluble solids/acid ration of 8 or higher and orange color on 25%
of the fruit - 7.5 Y 6/6 Munsell color - or soluble solids/acid ratio of 10 or
higher and orange color on 25% of fruit - 2.5 GY 5/6 Munsell color), size
uniformity, snd freedom from defect and decay.
US (1948) Stars* other then Roridu: Matunty. firmness, color, size, and freedom
from defect and decay.
US (1980) Florid*: Maturity, color (color charts), firmness, sizs, shape, and freedom
from dafact and decay.
CA (1983) Maturity (yellow, orange, or red color on 75% of fruit surface and soluble
solid/acid ratio of 6.5 or higher I, size uniformity. «nd freedom from defect
and decay.
US (1971) Maturity, firmness, color, and freedom from bruises, freezing injury, scars,
sunscald, insect damage, and decay.
CA (1983) Freedom from insect damage, decay, black scald, fermentation, and other
defects.
-------
An Overview of Fruit and Vegetable Standard* Relating to Cosmetic Appearance and Pesticide Use B - 3
Fntft
Standard
Idaw'l
Quaity Factor*
Dewberry,
blackberry
Grape, table
European
Vinifera type
American
bunch type
Kiwifruit
Nectarine
Olive
Peach
Pear
Winter
Summer and Fall
US (1928)
CA (1983)
US (1991)
US (1983)
US (1986)
US (1966)
CA (1983)
CAM 983)
US (1952)
CA (1983)
US (1956)
US (1955)
CA (1983)
Maturity, color, and freedom from calyxes, decay, shriveling, mechanical
damage, insect damage, and other defects
Maturity and freedom from decay and damage due to frost, bruising,
insects, or other causes.
Maturity (as determined by percent soluble solids as set forth by the
producing states), color, uniformity, firmness, berry size, and freedom
from shriveling, shattering, sunburn, waterberry, shot berries, dired
berries, other defects, and decay. Bunches: fairly well-filled but not
execessivety tight. Stems: not dry and brittle, and at least yellowish green
in color. For states other than California and Arizona, and countries
exporting to U.S.:
Cufttor
Muscat
Cardinal, Emperor, Perlette, Ribier,
Olivette Blanche, Rish Baba, Red Malaga,
and similar verities
All other cultivars
Minimum SSC (%>
17.5
15.5
16.5
Maturity, (juiciness, eaaa of separation of type skin from pulp), color,
firmness, compactness, and freedom from defect and decay.
Maturity (more than 6.5% soluble solids), firmness, cleanness, uniformity,
and freedom from worm holes, growth cracks, insect injury, broken skin
not healed, bruises, sunacaM, freezing injury, internal breakdown, and
decay. Free from injury by bruises, leaf or limbrubs, discoloration, hail,
growth cracks, scab, scars, heat, sprayburn, or sunburn, scale, insects,
other diseases, and mechanical or other means.
Maturity, color depending on variety, shape, and size, and freedom from
growth cracks, insect damage, scars, bruises, russeting, split pits, other
defects, and decay.
Maturity (surface ground color, fruit shape), and freedom from insect
injury, split pits, mechnicai damage, and decay.
Freedom from insect injury, especially scale.
Maturity (shape, size ground color), and freedom from decay and defect
(split pit, hail injury, insect damage, growth cracks).
Maturity (skin and flesh color, and fullness of shoulders and suture), and
freedom from defect and decay.
Maturity (color, firmness), size, and freedom from internal breakdown,
black end, russeting, other defects, and decay.
Maturity (color, firmness), shape, size, and freedom from defect and
decay.
Maturity (Barlett: Average firmness test of <2Slb. and/or soluble solids
content 13%, and/or yellowish green color - COFA color chart), and
freedom from insect damage, mechanical damage, decay and other
defects.
-------
B- 4 Appendix B
Fruit
Standard
(dete'l
Quaffty Facto**
Persimmon
Pineapple
Plum and
fresh prune
Pomegranate
Quince
Raspberry
Strawberry
CA (1983) Maturity aa indicated by surface color. Hichivt: Blossom end's color is
organge or reddish color equal to or darker then Munsell color 6.7 YR
5.93/12.7 on at least 1 /3 of the fruit's length with the remaining 2/3 a
green color equal to or lighter than Munsell color 2.5 GY 5/6. Otfitf
cu/tivars: A yellowish green color equal to or lighter than Munsell color 10
Y 6/6. Freedom from growth cracks, mechanical damage, decay, and
other defects.
US (1990) Fruit: maturity, firmness, stem removal, uniformity of size and shape,
freedom from fresh cracks, rodent feeding, freezing injury or frozen,
decay, and freedom from injury by discoloration, insects, and tolerances.
Tops: single stem, color, length, straightness, end freedom from injury by
crown slips, bruising, sunburn, gummosis, internal breakdown, insects,
healed cracks, mechanical or other means.
US (1969) Maturity, color, shape, size, and greedom from decay, sunscald, split pits,
haH damage, mechanical damage, scars, russeting, and other defects.
CA (1983) Maturity as indicated by surface color (minium color requirements are
described for 56 cultivara), and freedom from decay, insect damage,
bruises, sunburn, hail damage, gum spot, growth cracks, and other
defects.
CA (1983) Maturity (< 1.85% acid content in juice and red uice color equal to or
darker than Munsell color 5 R 5/12), freedom from sunburn, growth
cracks, cuts or bruises, and decay.
CA (1983) Maturity, and freedom from insect damage, mechanical damage, and
decay.
US (1931) Maturity, color, shape, and freedom from defect and decay.
CA (1983) Maturity, and freedom from decay and damage due to insects, sun frost,
bruising, or other causes.
US (1965) Maturity (> 1/2 or >3/4 of surface showing red or pink color, depending
on grade), firmness, attached calyx, size, and freedom from defect and
decay.
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use
B-S
Table B - 1.1
Oualty Factors for Freeh Vegetables hi tha U.S. Grade* (US) and the Cattfomia Food and Agricultural coda (CA)
Vegetable
Anise, sweet
Artichoke
Asparagus
Bean, lima
Bean, snap
Beet, bunched or
topped
Baat greens
Broccoli
Brussel sprouts
Cabbage
Cantaloupe
Carrot, bunched
Standard
(datt'l
US (1973)
US (1969)
CA (1983)
US (1966)
CA (1983)
US (1938)
US (1990)
US (1955)
US (1959)
US (1943)
CA (1983)
US (1954)
CA (1983)
US (1945)
CA (1983)
US (1968)
CA (1983)
US (1954)
CA (1983)
Quatty Factors
Firmness, tenderness, trimming, blanching, and freedom from decay and
damage caused by growth cracks, pithy branches, wilting, freezing,
seedstems, insects, and mechanical means.
Stem length, shape, overmaturity, uniformity of size, compactness, and
freedom from defect and decay.
Freedom from decay, insect damage, and freezing injury.
Freshness (turgidity), trimming, straightness
Turgidity, straightness, percent showing white color, stalk diameter, and
freedom from decay, mechanical damage, and insect injury.
Uniformity, maturity, freshness, shape, and freedom from damage (defect)
and decay.
Uniformity, cleanness, size, maturity, freshness (firmness), and freedom
from defect and decay.
Root shape, trimming of rootlets, firmness (turgidity), smoothness,
cleanness, minimum size (diameter), and freedom from defect.
Freshness, cleanness, tenderness, and freedom from decay, other kinds of
leaves, discoloration, insects, mechanical injury, and freezing injury.
Color, maturity, stalk diameter and length, compactness, base cut, and
freedom from defects and decay.
Freedom from decay and damage due to overmaturity, insects, or other
causes.
Color, maturity (firmness), no seed stems, size (diameter and length), and
freedom defect and decay.
causes.
Uniformity, solidity (maturity or firmness) no seed stems, trimming, color,
and freedom from defect and decay.
Conform to U.S. commercial grade or better.
Soluble solids (>9%). uniformity of size, shape, ground color and netting;
maturity and turgidity: and freedom from "wet slip*, sunseald, and other
defects.
Maturity (soluble solids >8%), and freedom from insect injury, bruises,
sunburn, growth cracks, and dscay.
Shape, color, cleanness, smoothness, freedom from defect, freshness,
length of tops, and root diameter.
Number, size, and weight per bunch, freshness, end freedom from defect
end decay (tops).
-------
B • 6 Appendix 8
Stamford
VeoetaWe
Ouaffty Factors
Carrot, topped
Carrots, with
short trimmed
top*
Cauliflower
Celery
Collard green*
and broccoli
green*
Com, green
Cucumber
Cucumber,
greenhouse
Dandelion green*
Eggplant
Endive, e*caro)e,
or chicory •
Garlic
Honeydew and
honeybaU
melon*
US (196S) Uniformity, turgidity, color, shape, size, cleanness, smoothness, and
freedom from defect (growth crack*, pithiness, woodiness, internal
discoloration).
CA (1983) Freedom from defect (growth cracks, double*, mechanical injury, green
discoloration, objectionable flavor or odor) and decay.
US (1954) Root*: Rrmness, color, smoothness, and freedom from defect (sunburn,
pithiness, woodiness, internal discoloration, and insect and mechanical
injuries) and decay. Leave*: (Cut to <4 inches). Freedom from yellowing
or other discoloration, disease, insects, and seed stems.
US (1968) Curd deanne**, compactness, whit* color, size (diameter), freshness and
trimming of jacket leave*, and freedom from defect and decay.
CA (1983) Freedom from insect injury, decay, freezing injury, end sunburn.
US (1959) Stalk form, compactnees, color, trimming, length of stalk and midribs,
width and thickness of midrib*, no seed stems, and freedom from defect
and decey.
CA (1983) Freedom from pink rot and other decay, blackheart, seed stems, pithy
condition, and insect damage.
US (1953) Freshness, tenderness, cleanness, and freedom from seed stem*,
discoloration, freezing injury, insect*, and diseases.
US (19S4) Uniformity of color and size, freshness, milky kernels, cob length, freedom
from defect, coverage with fresh husk*.
CA (1983) Milky, plump, well-developed kernel*, and freedom from inaect injury,
mechanical damage, and decay.
US (1958) Color, shape, turgidity, maturity, size (diameter and length), and freedom
from defect and decay.
US (1934) Freshness, shape, firmness, color, size OS.5 inches), and freedom from
decay, cut*, scars, and other defect*.
US (1955) Freshness, cleenness, tenderness, and freedom from damage caused by
seed stem*, discoloration, freezing, diseases, insects, and mechanical
injury.
US (1953) Color, turgidity, shape, size, end freedom from defect *nd decey.
US (1964) Freshness, trimming, color (blanching), no seed stems, and freedom from
defect and decay.
US (1944) Maturity, curing, compectness, well-filled clovee. bulb size, and freedom
from defect.
CAC1983) Size (bulb diameter).
US (1967) Maturity, firmness, shape, and freedom from decay and defect (sunburn,
bruising, hail spots, and mechanical injuries).
-------
An Overview of Fruit end Vegetable Standard* Relating to Cotmatic Appearance and Peeticida Uae B - 7
Vegetable
Horseradish root*
Kale
Lettuce,
crisp-head
Lettuce,
greenhouse leaf
Lettuce,
romaine
Melon
caaaba and
Persian
Mushroom
Mustard
green* and
turnip greens
Okra
Onion, dry
Creole
Bermuda-
Granex-Grano
Other cultivars
Onion, green
Onion sets
Parsley
Parsnip
Standard
(data*)
CAI1983)
US (1936)
US (1934)
US (1975)
CA (1983)
US (1964)
US (1960)
CA (1983)
US (1966)
US (19S3)
US (1928)
US (1943)
US (1985)
US (1971)
US (1947)
US (1940)
US (1945)
US (1945)
Quaffty Factors.
Maturity, soluble solids (> 10%), and freedom from decay, sunscald,
bruises, and growth cracks. Honey ball melons should be netted and
should have pink flash.
Uniformity of shape and size, firmness, smoothness, and freedom from
hoNow heart, other defects, and decay.
Uniformity of growth and color, trimming, freshness, and freedom from
defect and decay.
Turgidttv, color, maturity (firmness), tirmming (number of wrapper leaves),
and freedom from upbum, other physiological disorders, mechanical
dmage, seed stems, other defects, and decay.
Freedom from insect damage, decay, seed stems, upburn, freezing injury,
broken midribs, and bursting. For sectioned, chopped, or shredded latuca:
Same as inteect heads plus freedom from discoloration and excessive
moisture.
Wall-developed, well-tnmmed, and freedom from coarse stems, bleached
or discolored leaves, wilting.freezing, inaacts, and decay.
Freshness, trimming, and freedom from decay and dmage caused by seed
stems, broken, bruised, or discolored leaves, tipbum, and wilting.
Maturity, and freedom from growth cracks, decay, mechanical injury, and
sunburn.
Maturity, shape, trimming, size, and freedom from open veils, disease,
spots, insect injury, and decay.
Freshness, tenderness, cleanass, and freedom from dage caused by seed
stems, discoloration, freezing disease, insects, or mechanical means.
Roots (if attached): firmness and freedom from damage.
Freshness, uniformity of shape and color, and freedom from defect and
decay.
Maturity, firmness, shape, size (diameter), and freedom from decay, wet
sunscald, doubles, bottlenecks, sprouting, and other defects.
Turgidity, color, form, cleaneas, bulb trimming, no seed stems, and
freedom from dafact and decay.
Maturity, firmness, size, and freedom from decay and damage caused by
tops, sprouting, freezing, mold, moisture, dirt, diseasa, insects, or
mechanical means.
Freshness, graan color, and freedom from defects, seed stems, and decay.
Turgidity, trimming, cleanness, smoothness, shape, freedom from defect
and decay, and size (diameter).
-------
8 - 8 Appendix 8
Vegetable
Standard
(dale')
Quality Factor*
Pea, fresh
Pea, Southern
(cowpea)
Pepper,
sweet
Potato
Radish (topped)
Rhubarb
Shallot,
bunched
Spinach leaves
Spinach plants
Spinach, bunched
Squash, summer
Squash, winter
and pumpkin
Sweet potato
Tomato
US (1942) Maturity, size shape, freshness, and freedom from defect and decay.
US (1956) Maturity, pod shape, and freedom from discoloration and other defects.
US (1989) Maturity, firmness, color, shape, size, and freedom from damage and
injury (sunburn, bacterial spot, freezing injury, hail, scars, sunscald).
CA (1983) Freedom from insect damage and decay.
US (1972) Uniformity, maturity, firmness, cleanness, shape, size, and freedom from
sprouts, Mackheart, greening, and other defects.
CA (1983) A minimum equivalent of U.S. No. 2 grade. Maturity is described in terms
of extent of skin missing or feathered.
US (1968) Tenderness, cleanness, smoothness, shape, size, end freedom from
pithiness and other defects.
US (1966) Color, freshnesa, straightnees, trimming, cleanness, stalk diameter and
length, and freedom from defect.
US (1946) Rrmness, form, tenderness, trimming, cleanness, and freedom from decay
and damage caused by seed stems, disease, insects, mechanical and
other means. Tope: freshness, green color, and no mechanical damage.
US (1946) Color, turgidity, cleanness, trimming, and freedom from defect.
US (1956) Freshness, cleanness, trimming, end freedom from decay and dmage
caused by coarse stalks or seed stems, discoloration, insects, and
mechanical means.
US (1987) Cleanness, freshness, trimmness, degree to which well grown, freedom
from decay, freedom from damage (coarse stalks, seedstems, flower
buds, discoloration, wilting, foreign material, insects, freezing, mechanical
and other).
US (1984) Immaturity, tenderness, shape, firmness, and freedom from decay, cuts,
bruises, scars, and other defects.
US (1983) Maturity, firmness, freedom from discoloration, cracking, dry rot, insect
damga, and other defects; uniformity of size.
US (1963) Rrmness, smoothness, cleanness, shape, size, and freedom from
mechanical damage, growth cracks, internal breakdown, insect damage,
other defects, and decay.
CA (1983) Freedom from decay, mechanical damage, insect injury, growth cracks,
and freezing injury.
US (1991) Maturity and ripeness (color chart), firmness, cleenness, uniformity,
shape, smoothness, size, and freedom from defect (puffiness, hail,
sunseald, freezing injury, scars, catfaces, growth cracks, insect injury, and
other defects) and decay.
CA (1983) Freedom from insect and freezing damage, sunburn, mechanical damage,
blossom-end rot, catfaces, growth cracks, and other defects.
-------
An Overview of Fruit and Vegetable Standard! Relating to Cosmetic Appearance and Pesticide Uee 8 - 9
Vegetable
Standard
Idala'f
Quafty Factors
Tomato,
greenhouse
Turnip and
rutabaga
Watermelon
US (1966) Maturity, firmness, shape, size, and freedom from decay, sunscald,
freezing injury, bruises, ousts, shriveling, puffiness, catfacet, growth
cracks, scars, disease, and insects.
US (1955) Uniformity of root color, size, and shape, trimming, freshness, and
freedom from defects (cuts, growth cracks, pithiness, woodinass, water
core, dry rat).
US (1978) Maturity and ripeness (optional internal quality criteria: soluble solids
content - >10% vary good, >8% good), shape, uniformity of size
(weight),and freedom from anthracnoaa, decay, sunscald, and whiteheart.
CA (1983) Maturity (arils around the seeds have been absorbed and flesh color is
>75% red), and freedom from decay, sunburn, flesh discoloration, and
mechanical damage.
-------
B-10 Appendix B
Table B- 1.2
Quafty Factor* for Processing Fruit* in the U.S. Standard* for Grades (US) and tha Calfomia Food and
Agricultural Coda (CA)
Standard
FruH
Ouatfty Factors
Appl.
Berries
Blueberry
Cherry,
red tour
Cherry,
sweet for canning
or freezing
Cherry,
sweet for
sulfur brining
Cranberry,
red sour
Currant
Grape,
America type for
processing and
freezing
Grape, juice
(European or
vinifera type)
Grape for
processing and
freezing
Peach,
freestone for
canning, freezing,
or pulping
Pear for
processing
US (1961) Ripeness (not overripe, mealy or soft), and freedom from decay, worm holes,
freezing injury, internal breakdown, and other defects that would cause a loss
of >S% (U.S. No. 2) by weight.
US (1947) Color, end freedom from caps (calyxes), decay, and defect (dried, undeveloped
and immature berries, crushing, shriveling, sunscald, insect damage, and
mechanical injury).
US (I960) Freedom from other kinds of berries, clusters, large stems, leaves and other
foreign material, and freedom from damage caused by decay, shriveling, dirt,
overmaturity, or other means.
US (1941) Color uniformity, and freedom from decay, pulled pits, attached stems, hail
marks, windwhips, scars, sunacaM, shriveling, disease, end insect damage.
US (1946) Maturity, shape, freedom from decay, worms, pulled pits, doubles, insect and
bird damage, and mechanical injury, and freedom from damage caused by
freezing, softness, shriveling, cracks and skin breaks, scars and sunscald.
Tolerance is 7% (U.S. No. 1) or 12% (U.S. No. 2) by count.
US (1940) Maturity (ease of pit separation), firmness, shape, and freedom from decay and
defect (bruises, bird and insect damage, skin breaks, russating, shriveling,
scars, sunscald, and limbruba).
US (1957) Maturity, color, firmness, size, and freedom from defect (insect damage,
bruises, scars, sunscald, freezing injury, and mechanical injury) and decay.
US (1952) Color, stem attached, and freedom from decay and damage caused by
crushing, drying, shriveling, insects and mechanical means.
US (1975) Maturity (> 15.5% soluble solids), color, freedom from shattered, split,
crushed, or wet berries, and freedom from decay and from damage caused by
freezing, heat, sunburn, disease, insects, or other means.
US (1939) Maturity (> 16% to 18% soluble solids depending on cultivar). freedom from
crushed, split, wet, watarberry and redberry, and freedom from defect (insect,
disease, mechanical injury, sunburn, and freezing damage).
US (1977) Maturity (> 15.5% soluble solids content), and freedom from decay and defect
(dried berries, discoloration, sunburn, insect damage, and immature berries).
US (1966) Maturity, color (not greener than yellowish green), shape, firmness, and
freedom from decay, worms and worm holes, spilt pits, scab, bacterial spot,
insects, and bruises. Grade is based on the severity of defects with 10%
tolerance.
US (1970) Maturity, color (less than yellowish green), shape, firmness, and freedom from
scald, hard end, black end, internal breakdown, decay, worms and worm holes,
scars, sunburn, bruises, and other defects. Grade is based on the severity of
defect with 10% tolerance.
-------
An Overview of Fruit and Vegetable Standard* Relating to Co*metic Appearance and Pesticide U»« B - 11
Fruit
Standard
(date*)
Quality Factors
Raspberry
Strawberry.
grower* stock
for manufacture
Strawberry,
washed and
sorted for freezing
US (1952) Color, and freedom from decay and defect (dried berries, crushing, shriveling,
sunscald, scars, bird and insect damage, discoloration, or mechanical injury).
US (193S) Color, freedom from decay and defect (crushed, spit, dried or undeveloped
berries, •unsceld, and bird or insect damage), size, and cap removal.
US (1935) Color, cleanness, size, cap removal, and freedom from decay and defect
(crushed, split, dried or undeveloped berries, bird and insect damage,
mechanical injury).
Table •-1.3
Quafty Factors for Tree Nuts in the U.S. Standards for Grades (US) and the CaWonua Food and
Agricultural Code (CA)
Standard
Fruit
Ojuaity Factors
Almond,
•helled
Almond,
in-shell
Brazil nut.
in-sh«ll
Filbert,
in-shell
Mixed nuts,
in-shell
US (1960) Similar varietal characteristics (shape, appearance) size (count per ounce),
degree of dryness, cleanness (freedom from dust, particles, and foreign
materials), and freedom form decay and defect (rancidity, insect injury,
doubles, split or broken kernels, shriveling, brown spot, or gumminess).
US (1964) Shell: similar varietal characteristics (shape, hardness), cleanness (freedom
from loose extraneous and foreign materials), size (thickness), brightness and
uniformity of color, and freedom from discoloration, insect infestation, adhering
nulls, and broken shells. Kernel: Degree of dryness, and freedom from decay
and defect (rancidity, insect damage, shriveling, brown spot, gumminess, and
skin discoloration).
US (1966) ShaH: Degree of dryness, cleanness (freedom from dirt, extraneous, and
adhering foreign materials), size (diameter), and freedom from damage caused
by splits, breaks, punctures, oil stains, end-mold. Kernel: Degree of
development (must fill more than 50% of the shell capacity), freedom from
decay and defect (rancidity, insect damage, end discoloration).
US (1970) Shed: Shape, size (diameter), cleanness, brightness, and freedom from defect
(blanks, broken or split shells, stains, and adhering husk). Kernel: Degree of
dryness (less than 10% moisture content), development (must fill more than
50% of the shell capacity), shape and freedom from decay and defect (insect
injury, shriveling, rancidity, and discoloration).
US (1970) Each species of nut must conform to a minimum size and grade (same quality
criteria used for that species). Grade of the mix is also determined by percent
allowable for each component (almonds, brazils, filberts, pecans, walnuts).
-------
B- 12 Appendix B
Fruit
Standard
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use B - 13
Table) 8-2.0
Frufc. Vegetable, and Specialty Crap Federal Marketing Agreements and Orders
(Currant as of January 1992)
M.O.
N*.
Peek Hew
*•»•"* • • 4 IB- Mejtet Hntrn
ft
rRMfuBtf • AflWf* GMIMflitttQ
AJkrtmenta O tfoing Headquartam
Fruit*
906
906
007
9oa
910
911
915
916
917
918
919
920
921
922
923
924
925
926
FL Cttnis Frutt x x 3 4
TX Orange* * x x x
Grapefruit
CA-AZ Navel x x
Orange*1
CA-AZ x x
Valencia
Orange*'
CA-AZ x x
LMROIM
FL Lime* x x x x x
FL Avocado* x x x 4
CA Nectarine* x x x
CA Fear* ft x x x
Peache*
QA Peache* x x
CO Peeche* x x
CAKrwrfrutt x x x
WA Peaches x x x
WA Apricot* xx x
WA Cherrie* x x x
WA-OR Freeh x x x
Prune*
CA Oeeert x x x 4
Grape*
CA Tokay x x x x
Grape*
Lakeland. FL
x x MeAlan. TX
x Nawhall. CA
x Newhali. CA
x Newhal. CA
x x Home*taad,
FL
x x Hom**t*ed.
Fl
x x Sacramento.
CA
x x Sacramento.
CA
Meeon. GA
x Pateade. CO
X SeMfeMVWntO ,
CA
x Yakima. WA
x Yakima, WA
x Yakima. WA
x Yakima. WA
x Indta. CA
x x Lodl. CA
ty lot f«ner«a«. bluett «*V««r pnma*, •vwearfe*. AIMS,
Sown*: USDA/AM3. 1332. •RM*rieOon» on Impom as wa# aa otonestfc eon
grmptfrutt, irittt pocaMee, onngmu. onion*, wmlnuu, abra*. flftwrs. t*M* gn»m. AnvMiu* tnd nivnt.
'Ordtronly 'AfnmmtMfnly '£xp«rrwiry 'Snipping holidty '/iaaanw only •App*~ to can/ wMtntM
'Content tatnoiity fort voJuntmrypro^uotr dnrunionprogrum •CoMUnt MvonKypnvuioai for»flotoxln dummgmdpmnut*
-------
B • 14 Appendix B
M.O.
N*.
927
920
929
931
932
Pack
A****** • • 4
Common* Omde Sin CMtabwr
OR-WA-CA x x
Whiter PMn
Hawaii xx x
Papaya*
10 Statee- 6 6
Cranoarnea
WA-OR xx x
Bartfatt Pear*
CAOMve* x x
8ow ft
W Market Baeanra hoduear fc Advw- CoMitftM
MMket AlMMloii PM< AfctimnW O tWng Haarfquertan
x x Portland. OR
x x Honoturu. HI
x x Waraham.
MA
x Portland. OR
x x Fraeno. CA
VaoetaMea
946
946
947
948
960
963
965
958
959
966
966
967
971
979
ID- E. OR x x x
Potato**
WA Potato** x x Pack
OR-CA x x Pack
Potato**
CO Potato** xx x
ME Potato** xx x
VA-NC x x
Potato**
VWaKa (QA)
Onion*
10-OR Onion* x x x
S. TX Onion* x x x
TXVaaey xx x
Tomato**'
FL Tomato** x x x
FL Catary x x x
S. TX Lattuc* xx x
S. TX Malona x x x
MahoFate,
IO
MoM*L*k*.
WA
x Salatn. OR
x Mont* Viata.
CO
Inaetiv*
EaatvW*. VA
x x VidaHa. QA
4 xx Parma. ID
4 x Marcadea.
TX
x x MeAken. TX
x x Orlando, Fl
x xxx Orlando, Fl
xx x Marcadea.
TX
x M*rc*de«,
TX
Specialty Crop*
981
CA Almond* x 5
x xx Sacramento,
CA
Souret: USDA/AMS, 1932. •AeMrfetiiMie en Impom •» wu* it domnOe commodity tor fomeroe*. block oKvot. prune*, evoeetfoa, Umo»,
gnpofrult. mart pototooo, onngot. oniont, wotovn. dotoo. Hbttti. MMe ff/epea. /rAwftu/r »na /»**•>«.
'Ordoronly 'Agnomont only 'Expononly 'Snipping noliooy 'ftooorvo onty 'AppKoo to only witMoH emtoorrio*
'Contuini outhority for o voluntary pndueor Ovoroion progrom 'Conceive Memnfty praviaton* for *«*fox*i demeaeo* peemrt*
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use B - 15
M.O.
MB.
982
984
986
987
989
993
Pock H*w
*•••* • • » to Market
CsnmuaTty orad* MM Container Market Afecatkm
OR-WA x x Pack x
Filbert*
CA-Ofl-WA x x Pack x
Walnuts
Far West
Spearmint 01
CA Dates x x Cent x
CA Raisins' x x x
CA Prunes7 x x Pack x
R
nBaMaTVi) PVOOUBoW • Afl^MP* CO^HHaitt«J^
Peel Atatmante O «afae Heaoquerteis
x x Tioard. OR
x x Sacramento.
CA
x xx Pssco. WA
x x Irtdlo. CA
x xx Fresno. CA
x x San Fran. CA
M.A.
146
Peanuts (16 x x
states!"
Atlanta. OA
U.S. EPA HsaciQuarfers Library
_
VVasr.in:x'j^ DC 20460
Soweev USOA/AMS, 1332. •/teetrfcCona MI invert* u wul •• domntie eommedHy for fomaiaas, Mse* oHvn. p/ufws, •vocals, Anas.
gnpffniit. iritti pottroca, onngtf. onion*, wuinun. dttn. flbart*. MMs gnp»*. Mwifnjlt ane* nftint.
'Onttrcnti 'Agnumunt oaty 'Egponoan, 'Snipping notduy 'fleaa/vs onty 'AppHut to only **M*H ennbunin
'Content minority for a rafanttry producer aVMramn progrum 'Content indemnity provision* for »flf toxin d»rr»god peanuts
-------
B - 16 Appendix B
Tcbte • • 3.0
D«f*ot Action Levee* (•• of January 1989)
Detect
Actfo* Level
ANepiee
Apple Butter
IMPM-V32)
MoU
(AOAC 44.197)
RodMrt Fifth
(AOAC 44.0861
InieCt*
(AOAC 44.0861
Apncot, PMCH, ftnd PVAT Mold
Nectar* and Pun** IAOAC 44.202)
Apricot*, canned
Aeparagu*. canned or
frozen
Bay (Laurel) Leave*
Beet*. eanrMd
Oruptot, canned and
frozen (blaekberriea,
•.etc.)
Ligon. canned
Mutter, canned
BreccoN. frozen
bteact Fifth
(MPM-V51)
InMCt Rloi
(MPM-V93)
Insect*
(MPM-V93)
IMPM-V32)
Ineact Fifth
(MPM-V32)
Mammalian axcrata
(MPM-V32I
Rot
(AOAC 44.206)
Inaeeta and lervea
(AOAC 44.0*9)
Inaect larvae
(MPM-V64)
Insect*
(MPM-V64)
Inaect* and mita*
(AOAC 44.108)
Average of 5% or more berriea by weight are moldy
Average of mold count ia 12% or more
Average of 4 or more rodent haire per 100 grama of apple butter
Average of 5 or more whole or equivalent inaeeti (not counting mitea. aphid*.
thrip*, or Male intact*) per 100 grama of apple butter
Average mold count i* 12% or more
Average of 2% or more by count inaect-infeatad or intact-damaged in a minimum
of 10 aubaamplaa
10% by count of *p*ara or piece* are infeated with 6 or more attached aeparague
beetle egg* and/or *ec«
Acparagua contain* an average of 40 or more thrip* per 100 gram* OR
Ineecta (whole or equivalent) of any size average 5 or more per 100 grama OR
Inaect* (whole or equivalent) of 3mm or longer have an average aggregate length
of 7mm or longer per 100 gram* of eaparegu*
Average of 5S or more of piece* by weight are moldy
Average of 5% or more piece* by weight are in*ect-inf*Mad
Average of 1 mg or more mammalian excreta per pound after preceding
Average of 5% or mom piece* by weight with dry rot
Average mold count ia 60% or more
Average of 4 or more larvae per 500 grama OR
Average of 1O or more whole inaocta or equivalent per 500 grama (excluding
thrip*. aphid* and mhaa)
Average of 3 or more larvae per pound in a minimum of 12 tubaamplea
Average of 4O or more thripa per No. 2 can in aK «ub*ample* and 20% of
•ubaamplae are materially infected
Average of 80 or more aphid*, thrip* and/or mitea per 100 grama
SOURCE: Center tor Food Safety and Applied Nutrition. Food and Drug AdmaWtratlon. TTte food Oefecr Action ieveto. current through
January 1989.
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use B • 17
Ae*os> Level
Brussels Sprouts, frozen Insects
(MPM-V96I
Capsicum:
Insect filth and/or mold
(MPM-V32)
Ground Capsicum
(excluding paprika)
(AOAC 44.2131
IneactfMh
(AOAC 44.131)
NOOtfn flnn
(AOAC 44.131)
Ground Paprika
(AOAC 44.213)
Insect flUn
(AOAC 44.146)
(AOAC 44.146)
Cassia or Cinnamon Bark MoM
(MPM-V32)
(MPM-V32I
MammaRan e
(MPM-V32)
eta
Cherries.
brined andmarashine
froeh, canned* or
frozen
Cherry Jem
Chocolate and ChooowtB
Liquor
(MPM-V46I
Rot
(MPM-V46)
Ineect FWi
(MPM-V4O)
(MPM-V61)
•IMCt FeWl
(AOAC 44.007)
nootnt FBoi
(AOAC 44.007)
Shea*
(AOAC 44.012 •
13.026)
Citrus Fruit Juices,
Average of X or more aphids and/or thrips per 100 grams
Average of more than 3% of pods by weight are insect-infested and/or moldy
Average mold count is more than 20%
Average of more than SO insert fragments per 25 grams
Average of more than 6 rodent hairs per 26 grams
Average mold count is more than 20%
Average of more than 76 insect fragments per 25 grams
Average of more than 11 rodent hairs per 25 grama
Average of 5% or more pieces by weight are moldy
Average of 5% or more pieces by weight are insect-infested
Average of more than 1 mg or more mammalian excreta per pound
Average of 5% or more pieces are iejects due to maggots
Average of 7% or more pieces are rejects due to rot
Average of 4% or more pieces ere rejects due to insects other than maggots
Average mold count is 30% or more
Average of 60 or more microscopic Insect fragments per 100 grams when 6 100-
gram sub-samples are examined OR
Any 1 eubsampla contains 90 or more insect fragments
Average Is more than 1 rodent hair per 100 grams In 6 100-gram sub samples
examined OR
Any 1
itaais more than 3 rodent hairs
For chocolate liquor, if the she! is in excess of 2% calculated on the basis of
alkali-free nibs
Average mold count la 10% or more
(AOAC 44.2181
-------
B-18 Appendix B
Ptoduct
(Matted)
Actfe* Level
Inaeet* and ineect egg*
(AOAC 44.096 ft.
44.096)
Stem*
(MPM-V-32)
Cocoa Bean*
IMPM-V18I
Coco* Powdor
PreaaCako
(MPM-V1BI
Intact filth and/or moU
IMPM-V18)
Mammalian excreta
(MPM-V161
Intect filth
(AOAC 44.007)
Rodent filth
(AOAC 44.007)
Shea!
(AOAC 44. 13.01 2-
13.0261
Coffee Been*.
green
(MPM-V1)
graded green
Condiment*! Seede other
than
Seaame Seed*
Com: Sweet Com.
canned
(MPM-V1)
PnorQrada
Mammalian excreta
(MPM-V32)
Inaeet larvae (com ear
worm*, com borer*)
(AOAC 44.1091
5 or more Oroaophila and other fly eggi par 250 ml or 1 or more maggot* par
250ml
Average of 5% or mere itema by weight
Mora than 4% of beent by count are moldy
Mere than 4% of beana by count are inaect-infatted including intact-damaged
Mora than 6% of beana by count are inaeet-lnfeated or moldy
Mammalian excreta la 10 mg par pound or more
Average of 75 or mere microecapie intact fragment! per tubtampla of SO grama
VUDMflpWt M QXMMOQO On
Any 1 lubtampla containa 1 26 or mere microscopic Inaect fragmentt
Average in 6 or more tubtempla* ia more than 2 rodent haira per tubaampla of 50
grama OR
Any 1 tubaample containa more than 4 rodent haira
2% or more aha* calculatad on the baaia of alkaH-free niba
Average 10% or more by count are ineact-infected or intact-damaged OR
(five in
tinfei
I ia preaent. 1 live intact in each of 2 or i
idlate
containen, or 1 dead intact in each of 3 or more immediate container*, or 3 live
or dead intectt in 1 immediate container AND
Slmiar live or dead intact infeatation preaent on or immediate proximity of the lot
OR
1 or more live intact* In each of 3 or more immediate container* OR
2 or mere dead whole intectt in 5 or more immediate container* OR
2 or more fcVa or dead intact* on S or mere of cloth or burlap container*
Average, of 10% or more bean* by count era moMy
Beana are poorer than Grade 8 of the New York Green Coffee Attociation
Average of 3mg or more of mammalian excreta per pound
2 or mere 3mm or longer larvae, cait akina. larval or eaat tkln fragment* of com
cor worm or com borer and the aggregate length of tuch larvae, catt (kin*, larval
or eaet akin fragment* exceedt 12 mm in 24 pounda (24 No. 303 cant or
equivalent)
-------
An Overview of Fruit and Vegetable Standards Rotating to Cosmetic Appearance and Pesticide Use 8-19
Defect
Action Level
Com Hueki for Tsmalet Insect fifth
(MPM-V116)
Commeel
Cranberry Sauce
Cumin Seed
Currant Jem. black
Currants
Curry Powder
Date Material
(chewed, sliced, or
Deles, pitted
Oatee. whole
Eggs and other egg
product*, frozen
C^*M^aJ ^ ——-«
rtJffWIVI 99J9JQ
Fig Paste
(MPM-V116I
Insects
(AOAC 048)
HOOtJO* faftfl
(AOAC 0481
(AOAC 44.2001
Send end grit
(AOAC 44.124)
(MPM-V61)
(MPM-VS3)
IntMCt null
(AOAC 44. 124)
(AOAC 44.124)
Insects
(MPM-V63)
Pits
(MPM-VS3)
MuMpto
(MPM-W3)
Pits
(MPM-V53)
Multiple
(MPM-VS3)
Average of 5% or mom pieces by weight of the com husks examined insect-
infested (including Insect-damaged)
Average of 5% or more pieces by weight are moldy
Average of 1 or more whole insects (or equivalent) per 50 grams
Average of 26 or more insect fragments per 26 grems
Average of 1 or more rodent heirs per 26 grems OR
Average of 1 or more rodent excreta fragment per 60 grems
Average mold count is more then 16% OR
The mold count of eny 1 subsemple is more than 50%
Average of 9.6% or more ash end/or 1.6% or more acid insoluble ash
Average mew count is 76% or nwre
5% or more by count wormy in the everaqe of the subsemples
Average of 100 or more insect fragments per 26 grams
Average of 4 or more rodent hairs per 26 grams
10 or more deed insects in 1 or more eubeemples OR
6 or more deed Insects (whole or equiveieot) per 100 grams
2 or more pita and/or ptt fragments 2 mm or longer measured in the longest
dimension per 900 grams
Average of 6% or more dates by count are rejects
insect
excreta, sour, dirty. end/or worthless) as determined by macroscopic sequential
Average of 2 or more pita and/or pit fragments 2 mm or longer in the longest
dimension per 100 data*
Average of 6% or more dates by count era refects (moldy, deed insects, insect
excreta, sour, dirty, and/or worthless ae determined by macroscopic sequential
examination)
2 or more cane decomposed end at leest 2
npoeedcans
(AOAC 46.003-46.012) heve direct microscopic counts of 6 maHon or more becterle per gram
20% or more of subsemples contain insects
(MPM-V32)
MammaHani
terete
20% or more of subi
main mammalian excreta OR
(MPM-V32)
Average of 3 mg or more of memmaien excreta per pound
Over 13 Ineect heeds per 100 grams of fig paste in each of 2 or more subsemples
(AOAC 44.092-44.093)
-------
8 - 20 Appendix B
Defect
(Method]
Acttoe. level
Fig*
R*h. freih or frozen
(applies to fi*h or fillet*
weighing 3 pound* or
(•••I
TuNooo*. Clecoe*.
Inconnu*. Chub*, and
Whiteflsh
Blue Fin end other
Red Rsh and Ocean
Perch
Ginger, whole
Green*, canned
Hope
Macaroni and Noodle
Product*
InMct fnth end/or mold
and/or dirty fruit or
piece* of fruit
(MPM-V53I
Decomposition
Parasites (cysts)
IMPM-V28)
Parasites (ey*t>)
(MPM-V28)
(cyvtv)
(MPM-V28I
Insect filth end/or mold
(MPM-V32)
Mammalian excrete
(MPM-V32I
Ineect* (ephidel
(AOAC 44.001)
Ineect firth
(AOAC 44.06*)
HOQtWIt flnlt
(AOAC 44.0691
•TMtct fwth 4afMl/or moid
(MPM-V3J)
MemmeMen excreu
(MPM-V32)
Foreiqn nwttw
(MPM-V32)
Mushrooms, canned and
dried
(AOAC 44.115 *
44.1161
Average of 10% or more piece* by count ere reject*
Average of more than 10% of piece* are insect-infsitsd and/or moldy dirty fruit
or piece* of fruit
Decomposition in 5% or more of the fi*h or fillet* in the temple (but not let* than
5) *how da** 3 decomposition over at least 25% of their area* OR
20% or more of the fl*h or fWeta in the temple (but not le** than 5) chow Cla*« 2
decomposition over at lea*t 25% of their area* OR
The percentage of fl*h or fillet* thowing Cta** 2 decompotition a* above pkit 4
time* the percentage of thoee thowing Cta** 3 decomposition •• ebove •quail at
leaat 20% and there ere at leaat 5 decomposed fith or fWeta in the temple
Cla**e* of Decompotition
1. No odor of decompotition
2. Slight odor of decompotition
3. Definite odor of decompotition
50 paraeWe cy*t* per 100 pound* (whole or fillet*), provided that 20% of the flan
examined ere infected
60 ey*t* per 100 fi*h (fi*h averagin 1 pound or le**l or 100 pound* of fith (fieh
averaging over 1 pound), provided that 20% of the fieh examined are infected
3% of the fl*»tt examined contain 1 or more copepod* <
pocket*
npenied by pue
Average of 3% or more piece* by weight ere ineect-infeited and/or moldy
Average of 3 mg or more of mammalian excreta per pound
Average of 10% or more of leave*, by count or weight, thowing mildew over
1/2* diameter
Average of more than 2.500 aphid* per 10 gram*
Average of insect fragment* equate or exceed* 225 per 225 gram* in 6 or more
subsamples
Average of rodent hair* equal* or exceed* 4.5 per 226 gram* in 6 or more
tubsamplee
Average of 3% or more piece* by weight era ineect-infected end/or moldy
Average of 3 mg or more of memmellen excreta per pound
Average of 1.5% or more of foreign matter through a 20-me*h tieve
Average of 20 or more maggot* of any *ize per 100 gram* of drained muihroom*
end proportionate liquid or 15 gram* of dried mushroom* OR
Average of 5 or more maggot* 2mm or longer per 100 gram* of drained
mushroom* and proportionate liquid or IS gram* of dried mushrooms
-------
An Overview of Fruit and Vegetable Standards Relating to Coamatic Appaaranca and Pesticide Uaa B - 21
Defeat
(Method)
(AOAC44.115
44.116)
Nutmag
Nut*, tf*
Abnondf
Brute
Caihaw
Qreen Chottnut*
Bakad ChMtnut*
(Mad Chaatnuti
Filbert*
UchaaNuta
Paean*
PI Nut*
Plitaehiea
Walnut*
Olives:
(MPM-V100)
Inaaet fifth and/or mold
(MPM-V41)
Multiple dafaett
(MPM-V81
Imported
Qraan
Salad
Salt-cured
(MPM-V87)
Intact damage
(MPM-V67)
(MPM-V87)
tfWOCt QMIMQaf
(MPM-V67)
(MPM-V71)
Black
Peaches, cannad and
fnusn
Peanut butter
IMFM-V67)
afflMCt wtWIMvJff
(MFM-V67)
Matty or Wormy
(MPM-VS1)
Inaaet damage;
(MPM-V61)
(AOAC 44.037)
(AOAC 44.0364)
Qrtt
(AOAC 44.034)
Awaraga of 75 mita* par 100 gram* drainad mushroom* and proportion*!* liquid
or 15 gram* of driad muthroom*
Avaraga of mora than 10%. by waigtrt. of muahroom* ara dacompoaad
Aoaraga of 10% or mor* piaea* by count •*• inaact-lnfa*t*d and/or moWy
n<)*et nut* (ln*act-infa*t*d. rancU. moWy, gummy, *nd thrivalad or ampty *haa*l
aa datarmlnad by macreaeopic axamination at or In axea** of tha foNoMring (aval*
8ha«*dl%l
S
10
6
10
10
IS
10
15
10
10
5
5
S
10
S
5
Avaraga of 1.3 or mora by count of oHva* with who** pit* and/or pit fragment*
2mni or tongac measured in the longest dimension
7% or more by count showing damaga by oava fruit fly
Average of 1.3 or more by count of oNve* with whote pit* and/or pit fragment* 2
mm or longer measured in tha longest dimension
9% or mom by count showing damaga by okVa fruit fly
Average of 6 *ub*amp4e* ia 10% or more olive* by count with 10 or more scale
insect* each
Average of 6 *ub*ample* ta 25% or more oava* by count are motdy
10% or mora by count showing damage by oeVe fruit fly
Average of 3% or more fruit by count ara wormy or moldy
In 12 1-pound cans or equivalent, one or mora larvae and/or larval fragments
whose aggregate length exceeds 5 mm
Average of 30 or more Insect fragment* par 100 gram*
Avaraga of 1 or more rodent hair* per 100 gram*
Gritty taate and water inaotuW* Inorganic residue I* more than 26 mg per 100
-------
B- 22 Appendix B
(Method)
Peanut*, (hailed
Peanut*. urraheNod
Peee: Black-eyed,
Cowpeaa. FieMpea*.
Dried
Peaa. Cowpeaa. Bleck-
eyed peee (eueculent).
canned
Pea* and Been*, dried
Pepper, whole
Multiple dofocta
(MPM-VB9I
inaect*
(MPM-V89)
Multiple defect*
(MPM-V89)
bieact damage
(MPM-V104)
Inaect larvae
(MPM-V104)
biMetfHth
IMPM-V104)
kiMCt flHIi end/Of fnoU
IMPM-V39)
Mammalian excreta
(MPM-V39)
Foreign matter
(MPM-V39I
Pineapple, canned
Pineapple Jute*
Plumt, canned
(AOAC44.199I
(AOAC44.199)
Hot
(MPM-V51)
Potato ch
-------
An Overview of Fruit and Vegetable Standard* Relating to Coematic Appearance and Pesticide Use B - 23
(Method)
Action Level
Salmon, canned
Soeame eeedt
Shrimp: freeh. or frozen.
raw. headtoea peeled or
Shrimp? imported.
earned or cooked/frozen
Spteee: leafy, other then
bay toavae
Spinach, canned or
frozen
Strowberriee: frozen.
whole, or taced
Tomatoaa. eannad
Tomatoaa. eannad with
on drained juice)
Tometoaa. canned.
packed In tomato puree
(baaed on drained Nquid)
Tomato Juice
Inaectt and inaact eggt
(AOAC 44.097 It
MPM-V76)
Decompoeition
Inaact Wth
(MPM-V32)
(MPM-V32I
Mammalian excreta
IMPM-V32)
Foreign matter
(MPM-V32)
Oecompoaition
Decompoeitton
Inaact fMh and/or mold
IMPM-V32)
Mammal*
ata
(MPM-V32)
Insects end ivMtss
(AOAC 44.1101
(AOAC 44.206)
Grit
(AOAC 44. 11 9)
(AOAC 44.2061
(AOAC 44.206)
Droeopntta fly
(AOAC 44.119)
10 or more whole or equivalent i
golden bleached raiaina
tt and 36 Oroaophila aggi per 8 ox. of
2 or more daaa 3 defective earn, ragardleat of tot or container tize OR
2 to 30 Ciaea 2 and/or daaa 3 defective cent aa required by templing plan baaed
on tot tixe and container aize
Average of 6% or more teedt by weight are ineect-lnfottod
Average of 5% or more aaeda by weight are decompoaad
Average of 5 mg or more mammalian excreta per pound
Average of 0.5% or more foreign matter by weight
5% or more are deal 3 or 20% or more are date 2 doeompoiition at determined
by organoleptle examination OR
If percentage of daat 2 thrimp pkit 4 timat percent of data 3 equalt or exceedt
2O% (See fieh product Hating for definition of deeompoaitton clattea)
Indole leveit in two or more tubtamplet equal or exceed 25 mferograma par 100
gramt for both original and check anaJyaia
Average of 5% or more piecea by weight are intact hifeated and/or moldy
Average of 1 mg or more of mammalian excreta per pound after procetting
Average of 60 or more aphidt and/or thripa and/or nritaa per 100 gramt OR
2 or more 3 mm or larvae and/or larval fragment! of epinaeh wonna (catarpitartl
whoae aggregate length exceedt 12 mm are preterit in 24 poundt OR
Leaf minere of any tize everage 8 or more per 10O grama or leaf minert 3 mm or
longer average 4 or more per 100 grama
Average mold count of 46% or more and mold count of at leaat Karl of the
tubaamplea it 66% or more
Berriat tatta gritty
Average of 10 or more fry egga par 600 grama; or 6 or more fly egge and 1 or
more maggot! per 500 grama; or 2 or more maggota per 600 grama, in a
minimum of 12 tubtamplet
Average mold count hi 6 tubtamplet la more than 15%. and the mold counta of
aN of the tubtampiet are more than 12%
Average mold count in 6 aubaamptoa it more than 29% and the counta of all the
tubaamplea are more than 25%
Average of 10 or more fly egga per 100 grama: or 5 or more fly egga and 1 or
more maggota par 100 grama; or 2 or more maggota per 100 grama, in a
minimum of 12 aubaamptoa
U.S. EPA Headquarters Library
^a:i ?0u3 320!
1200 '-'rT-^./ania Avenue NW
Vv>.V'!irnron DC 20460
-------
B-24 Appendix 8
Defect
•Mduct
Acttoa level
Tomato Paata. Ptaa.
and other taucee
Tomato Puree
Tomato pa«ta or pure*
Ptaa and other taucaa
(mold)
Tomato Saueo
(undiluted)
Tomato Cataup
Tomato powder (axcapt
spray-dried)
Tomato Powdar. apray-
Tomato aoup and
tomato product*
Tuna, canned: albaeora,
ikipiaek. and yeHowfin
Wheat
Whaat Flour
(AOAC 44.207)
OrotopMa fly
(AOAC 44.1191
Droeophila fly
(AOAC 44.119|
(AOAC 44.207)
Mold
(AOAC 44.2091
Mold
(AOAC 44.207)
(AOAC 44.207)
MoU
(AOAC 44.211)
Mold
(AOAC 44.211)
(AOAC 44.2081
Hictamine
(AOAC 16.067)
MtQGt QMTMQ6
(MPM-V15)
(MPM-V16)
ivwtct filth
(AOAC 44.0621
Average mold count in 6 aubaamplaa ia 24% or mora and the mold count* of aN
of tha aubaampla* ara mora than 20%
Averaga of 30 or mora fly agga par 100 grama; or 15 or mora fly aggs and 1 or
mora maggot* par 100 grama; or 2 or mora maggots par 100 grama, in a
minimum of 12 aubaamplat
Average of 20 or mora fly agga par 100 grama; or 10 or mora fly agga and 1 or
mora maggot* par 100 grama; or 2 or mora maggota par 100 grama, in minimum
of 12 aubaamplaa
Avaraga mold count in 6 aubaampta* i« 45% or mora and tha mold count* of all
of tha aubaamplaa ara more than 4O%
Avaraga mold count in 6 lubaamplee ia more than 34% and tha count* of aH of
tha *ub*amp4a* ara more than 30%
Avaraga mold count in 6 aubaampla* ia 46% or more and tha mold count* of a*
of tha •uoaamplea ara mora than 40%
Avaraga mold count in 6 lubaamplaa ia 56% or mora
Avaraga mold count in 6 aubaampla* ia 45% or mora and tha mold count* of all
of tha Mjbaamplaa ara mold than 40%
Avaraga mold count hi 6 aubaamplaa ia 67% or more
Avaraga mold count in 6 iub*amplaa ia 45% or more and tha mold count* of all
of tha aubaamplaa are more than 4O%
Hiatamina content par lubaampla equal* or exceed* 20 mg par 100 grama in both
original and check anaryai* (tow aubtamplaa minimum)
Avaraga of 32 or mora inaact-damaged kernel* par 100 grama
Avaraga of 9 mg or mora rodent excreta pellet* and/or pellet fragment* par
kilogram
(Aa of February 1989, he* bean changed to 'Average of 75 or mora inaect
fragment* par 50 grama in 6 (ubaamptoa")
A vat age of 1 or more rodent heir* par 50 grama in 6 mbaamplee
(AOAC 44.0621
-------
An Overview of Fruit and Vegetable Standard* Relating to Cosmetic Appearance and Pesticide Use R - 1
Notes
Introduction
1 Jean Kinsey, "Food Quality and Prices," in Agricul-
tural and Food Policy Issues for the 1990s, #10, sum-
mary of a paper presented at the National Agricultural
and Food Policy Workshop held on November 16-17,
1989 in Washington, D.C.
21990 Farm Bill, §1351 (7 USC 1622 note).
3 Van den Bosch, Robert, et al. Investigation of the
Effects of Food Standards on Pesticide Use. Prepared for
the USEPA, NTIS IPB-278-976, 1978; A. Ann So-
rensen, AFBF Survey on Cosmetic Standards and Pesti-
cide Use: A Narrative Summary of Results (Park Ridge,
IL: American Farm Bureau Federation, 1991).(Hereaf-
ter cited as AFBF Survey)
* USEPA, Science Advisory Board, The Report of the
Ecology and Welfare Subcommittee: Relative Risk Re-
duction Project, EPA SAB-EC-90-021A, 1990.
5 Agricultural Marketing Act of 1946 (60 Stat. 1087, as
amended; 7 U.S.C. 1621-1627).
6 Agricultural Marketing Agreement Act of 1937, § 10,
48 Stat 37, as amended (7 U.S.C. 610; found in 7 CFR
sections 900 and sequential).
7 Food, Drug, and Cosmetic Act (FDCA), 5 402 (aX3).
' The Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA) and Food, Drug, and Cosmetic Act, $408
and §409.
9 Robert Weaver, et al, cites seven recent willingness-to-
pay studies that indicate between 7156 and 94% of
consumers are concerned about pesticide use in fresh
produce. D. Weaver, et al, Pesticide Use in Tomato
Production: Consumer Concerns and WiUingness-to-
Pay, Staff Paper #200 (University Park, PA: College of
Agriculture, Pennsylvania State University, 1991).
10 See John P. Hoehn and Eileen van Ravenswaay,
Consumer Willingness to Pay For Reducing Pesticide
Residues in Food: Results of a Nationwide Survey, staff
paper no. 91-18 (East Lansing, MI: Michigan State
University, 1991). Also see other studies by Hoehn and
van Ravenswaay listed under references.
Chapter I: Economic Factors
Affecting Grower Behavior
11987Census ofAgriculture, Bureau of the Census, U.S.
Department of Commerce, (Washington, 1988).
3 In 1978, 91 % of apple and 72* of citrus acreage were
treated with insecticides. David Pimental, et al, "Ben-
efits and Costs of Pesticide Use in U.S. Food Produc-
tion, " Bioscience2&, no. 12 (1978): 778. (hereafter cited
as "Benefits and Costs of Pesticide Use") Approximately
95% of grape hectange is treated with fungicides.
(David Pimental, et al, 1991, p 403) In 1987, the
National Research Council suggested that "virtually all
perishable fresh fruits and vegetables... depend heavily
on pesticides. Some are treated a dozen or more times
each year with six or more active ingredients. * (National
Research Council, 1987, p. 49)
3 Robert L. Shewfelt, "Quality of Fruits and Vegetables:
Scientific Status Summary" (Chicago: Institute of Food
Technologists, 1990), 1-3; Weaver, et al.
4 Douglas D. Parker, etal, "How Quality Relates to Price
in California Fresh Peaches," California Agriculture 45,
no. 2 (March-April 1991): 14. In the case of California
fresh peaches, this survey suggests that sugar content is
relatively unimportant at the producer level while at the
retail level a higher sugar content can "increase price
over $2 per lug. "(p. 16)
* Personal communication with farmers and major com-
modity organizations in the fruit and vegetable industry.
' Both Ray Harris' and Tony Hall's comments were taken
from C. McCarthy, Thanks for Potatoes," The Wash-
ington Post (22 November 1990): A31.
i See Gail Feenstnt, Who Chooses Your Food: A Study of
the Effects of Cosmetic Standards on the Quality of
Produce (Los Angeles: CALPirg, 1988). Premium fruit
receives premium prices. In the citrus market, for ex-
ample, oranges which Sunkist stamped with its brand
name (its highest quality oranges) received $5/carton
more than did oranges at the second highest quality level
in 1986. Juice oranges that year received only $2/carton.
-------
R-2
Notes and References
Prices for the juice market were so low that packers
would not pay for shipping or hauling to the point of
processing. (Feenstra, 17-18) Fruit used for even lower-
value uses, such as animal feed, may command prices as
low as $2 to $5 per ton. Also see James F. Thompson,
'Preparation for Fresh Market: IV. Cull Utilization, * in
Postharvfst Technology of Horticultural Crops (Univer-
sity of California, Cooperative Extension Service, 1985),
26.
1 While such produce may be salable in the fresh market,
fresh produce distributors and retailers may be unable to
accommodate it at a point in time, preferring to handle
produce with a higher profit margin.
9 Steve Wood, New Hampshire apple grower, personal
communication, 29 March 1989.
10 Michael Reid, "Product Maturation and Maturity
Indices," in Postharvest Technology of Horticultural
Crops (University of California, Cooperative Extension
Service, 1985), 9.
" Dr. Hempler, Director, German Fertilizer Institute,
Telephone interview with Andrew Manale, 7 April
1990.
12 Commission on California State Government Organi-
zation and Economy, Control of Pesticide Residues in
Food Products: A Review of the California Program of
Pesticide Regulation, 1985, 37-53.
13 For an example regarding the growth regulator Alar,
see Philip Shabecoff "Apple Sales Rise After Scare of
'89," The New York Tunes (13 November 13, 1990):
A28.
14 James K. Hammitt, Estimating Consumer Willingness
to Pay to Reduce Food-Borne Risk (Santa Monica, CA:
Rand Corporation, 1986), 63.
15 NutriClean, Inc. is an independent lab which certifies
fruits and vegetables as residue-free at the time of
harvest. (Steel, p. 12-13) Many health food stores and
some direct marketing retailers label non-certified pro-
duce (such as 'transitional' organic) or provide informa-
tion concerning growing practices (such as pesticides
used or not used).
" For a summary of recent willingness-to-pay studies,
see Weaver, et al. Also see, Eileen van Ravenswaay,
"How Much Food Safety Do Consumers Want? An
Analysis of Current Studies and Strategies for Future
Research," in {Catherine L. Clancy, ed., Consumer
Demands in the Marketplace: Public Policy in Relation
to Food Safety, Quality in Human Health (Washington,
D.C.: Resources For the Future, 1988).
17 For example, with proper information and labeling,
produce grown under a certified level of IPM practices
(and possibly with lower cosmetic standards) may in-
crease consumer and retailer demand for such produce
(priced more competitively with conventional produce
than organic) offering an affordable alternative for the
average consumer. A recent survey of growers, suggests
many growers are interested in IPM certification (So-
rensen, AFBF Survey). However, some have suggested
that such a system would be avoided by retailers since it
may erode confidence in conventional produce safety.
(Steel, p. 13) Withstanding these concerns, in the current
trend of environmentally oriented marketing, adding
more consumer choices would be beneficial for those
retailers catering to the environmentally conscious con-
sumer as a way to profit by selling more environmentally
sound products.
11 J.C. Headley, "Estimating the Productivity of Agri-
cultural Pesticides," American Journal of Agricultural
Economics 50, no.l (Feb 1968): 13-15; Pimental, etal,
"Benefits and Costs of Pesticide Use", 772, 778-784.
" Alternative Agriculture (National Academy Press,
Washington D.C., 1989), 342; A. Ann Sorensen, IPM
and Growers: An Evolution in Thinking, American Farm
Bureau Federation (Park Ridge, IL: American Farm
Bureau Federation, 1991), p. 3. (hereafter cited as IPM
and Growers)
20 Sorensen./PM and Growers, p. 4.
21A number of organic growers with whom we have
spoken insist that they can meet existing federal grading
standards in season, though their costs do tend to be
higher than for conventional farmers. In a survey (Bunn,
et al, 1990) of 229 supermarket shoppers there was
initially low acceptance of cosmetically scarred oranges,
but acceptance rose substantially after information was
provided about reduced pesticide use. In a 1990 State of
Florida Department of Citrus fresh oranges commercial,
consumers were told how different colored orange skins
(yellow or green) do not determine how oranges taste
inside; based on marketing research, consumers changed
the way they perceive cosmetic quality in oranges.
(Report on the Performance of the Fresh Florida Or-
anges Commercial 'As Orange as They Get, 1990)
Chapter II: Government Programs
Affecting Produce Quality and Their
Implication for Pesticide Use
1 Commission on California State Government Organiza-
tion and Economy, Control of Pesticide Residue in Food
Products, 1985, 143-152.
2 United States General Accounting Office, Food Safety
and Qaulity: Who Does What in the Federal Govern-
ment, GAO/RCED-91-19B (Washington, 1990), 63.
-------
An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Peaticide Use
R-3
s See tables in Appendix B for a list of the attributes
included in the grading standards for various fresh and
processing fruits, vegetables and tree nuts.
4 See David Bunn, et al, "Consumer Acceptance of
Cosmetically Imperfect Produce," The Journal of Con-
sumer Affairs 24, no. 2 (1990): 268-279. For an analysis
of changes in consumer behavior resulting from the
Florida Citrus Association's 1990-1991 campaign to
educate consumers regarding the relationship between
citrus appearance and quality, see Report on the Perfor-
mance of the Fresh Florida Oranges Commercial 'As
Orange as They Get', prepared for the State of Florida,
Department of Citrus, (Princeton: Mapes and Ross, Inc.,
1990). For a brief summary of both of these citations,
refer to endnote 30, Chapter n.
9 Approximately 80% of consumers in a nationwide
survey considered residues to constitute a serious hazard.
In the past two years, almost 20% of consumers have
altered their purchasing patterns to include the purchase
of organic or certified * residue-free' produce. Marciel
A. Pastore and Christine M. Bruhn, "A Shopper's
Survey: California Nuts and Produce, Food Quality, and
Food Safety," California Agriculture 45, no. 1 (January-
February 1991): 25-27.
'U.S. General Accounting Office, The Role ofMarketing
Orders in Establishing and Maintaining Orderly Market
Conditions, July 31, 1985, GAO/RCED-85-57, p. 26.
For a specific example, see the marketing order for
Tomatoes Grown in Florida (7 Code of Federal Regula-
tions, Chapter DC, Section 966.10, January 1988 edi-
tion) to see how the marketing orders adopt existing
grading standards.
7 A. Ann Sorensen, 1PM and Growers. Also, personal
communications with consultants and growers.
'van den Bosch, Robert, et al, p. 11.
9 See 5 402 (a)(3) of the Act from van den Bosch, et al.,
p. 13.
10 The majority of Defect Action Levels affect canned,
bottled, frozen, or dried food products, including spices.
See Food and Drug Administration, The Food Defect
Action Levels, 1989, for a complete listing of all estab-
lished DALs.
11 van den Bosch, et al, p. 13.
12 Paris Brickey, Microanalytic Branch, U.S. Food and
Drug Administration, Telephone interview with Doug
Koplow, 18 September 1989.
13 For example, in the 1930s, the DAL for aphids in
spinach was 110 aphids in 100 grams; in 1977 it was 50
aphids/100 grams. The allowable level for leaf miners in
spinach was 40 per 100 grams in 1930; in 1978 it was 8
per 100 grams. Pimental, et al, "Pesticides, Insects in
Foods, and Cosmetic Standards," BioScience 27, no. 3
(March 1977): 179.
14 Faye Gibson, Division of Regulatory Guidance, U.S.
Food and Drug Administration, Letter to Andrew Manale,
20 April 1990.
11 David Pimental, et al, "Pesticides, Insects in Foods,
and Cosmetic Standards," p. 180. Article cites over 15
studies concluding that ingesting herbivorous insect
fragments poses insignificant health risks. Also see,
Feenstra, p. 7.
" Terry Troxell, Center for Food Safety and Applied
Nutrition, U.S. Food and Drug Administration, Tele-
phone interview with Doug Koplow, 15 September
1989; Paris Brickey, Microanalytic Branch, U.S. Food
and Drug Administration, Telephone interview with
Doug Koplow, 18 September 1989.
17 Except for information concerning note 16, informa-
tion for this paragraph is from van den Bosch, et al, pp.
17-18.
"Ibid., p. 21.
" John P. Hoehn and Eileen van Ravenswaay, "The
Impact of Health Risk Information on Food Demand: A
Case Study of Alar and Apples," in Julie A. Caswell, ed.,
Economics of Food Safety (New York: Elsevier Science
Publishing Co., Inc., 1991), 156-157.
20 Shabecoff, p. A28.
21 van den Bosch, et al, p. 6.
22 Marketing order components are from Edward V.
Jesse and Aaron C. Johnson, Jr., Effectiveness of Federal
Marketing Orders for Fruits and Vegetables, USD A,
National Economics Division, 1981; Glenn Zepp and
Nicholas Powers, " * Marketing Orders: Industry Self-
Regulation," Agricultural Outlook (September 1987):
16-18.
a Zepp and Powers, p. 18.
24 Jesse and Johnson, p. 12.
25 van den Bosch, et al, p. 5.
* Jesse and Johnson, p. 12.
27 Zepp and Powers, p. 24.
21 AMS/USDA, comments on the January 1992 draft
version of this report, 10 February 1992.
" Jesse and Johnson, pp. 44-45.
50 For example, since Sunkist has 50% of the represen-
tation, it has the power to influence decisions reached by
the citrus marketing board. (Feenstra, pp. 19-20) In the
Summer of 1991, Sunkist exercised its block vote to
continue the marketing order for naval oranges; many
Sunkist and independent growers and packers disagreed
with the move since it restricts their domestic sales of
navel oranges during the harvest season, but lacking a
-------
R-4
Note* and Reference*
majority, they could not stop it. Growers and packers
who do not comply with the orders (by selling on the
black market or cheating) face stiff fines. (Taylor and
McGraw, "Rural Rebellion Simmers Under Marketing
Rules", p. 14)
11 If consumers perceive a lower health and environmen-
tal risk from fruits and vegetables that look less than
perfect (minimally scarred or with a different color),
consumer demand might change. In a survey (Buna, et
al, 1990) of 229 supermarket shoppers there was initially
low acceptance of cosmedcally scarred oranges, but
acceptance rose substantially after information was pro-
vided about reduced pesticide use. In a 1990 State of
Florida Department of Citrus fresh oranges commercial,
consumers were told how different colored orange skins
(yellow or green) do not determine how oranges taste
inside; based on marketing research, the commercials
changed the way some consumers perceive cosmetic
quality in oranges. (Report on the Performance of the
Fresh Florida Oranges Commercial 'As Orange as They
Get)
32 Feenstn, p. 51.
Chapter III: Market-based Factors
Affecting Cosmetic Appearance
1 van den Bosch, et al, p. 2.
2 For example, Very Fine Apple Juice (Littleton, MA)
developed formal contracts stipulating that growers
could not use Alar in the production of their apples. The
contract was in effect until 1989 (the company deter-
mined that none of its growers were considering Alar use
following the 'Alar Scare') and was enforced by exten-
sive testing of shipments. This trend seems to be grow-
ing. (Ron Green, apple buyer, Very Fine, Inc., personal
communication, September 18, 1989).
1 Feenstra, p. 21.
4lbia\
1 Wood, 1989.
' Feenstra, pp. 2-3.
7 David Buna, CALPirg, Telephone interview with
Doug Koplow, 9 February 1989.
1 Dr. Ted Wilson, as quoted in Feenstra, p. 45.
' William Quarles, V.P. Government Affairs, Sunkist
Growers Inc., Telephone interview with Mark Liniado,
16 April 1992.
10 Feenstra, p. 20.
"William Quarles, 1992.
12 van den Bosch, et al, p. 76.
"Ibid., p. 7.
14 van den Bosch, p. 100.
15 Ibid.
"For example, IPM and organic methods require more
intensive monitoring of pest populations, weather, and
soil fertility, as well as more attention to crop rotation
patterns.
17 Bryan Jay Bashin, "The Freshness Illusion,"
Harrowsmith (January/February 1987): 43.
11 Surety of supply and lower shipping losses from unripe
tomatoes than from transport of ripe tomatoes, has
resulted in the current situation where about 95 % of fresh
market tomatoes are harvested at a stage referred to as
"mature green," and ripened artificially at the local
market. (Feenstra, p. 41). Though the fruit appears ripe,
it will never develop the natural sugars that help to give
vine-ripened fruit its flavor. (Bashin, p. 43; Feenstra, p.
41) According to the "U.S. Standards of Grade of Fresh
Tomatoes", maturity is defined as a "stage of develop-
ment which will insure a proper completion of the
ripening process, and that the contents of two or more
seed cavities have developed a jelly-like consistency and
the seeds are well developed." (7 CFR 51, 1973 and
1991)
"Bashin, p. 43.
20 There have been some suggestions that post-harvest
chemicals are currently being used as a substitute for
post-harvest refrigeration due to lower cost.
"Bashin, p. 44.
22 National Research Council of the National Academy of
Science, 1987.
25 Bashin, p. 46; Pimental, et al, 1991, p. 403.
24 See Sorensen, AFBF Survey.
Chapter IV: Case Studies
1 These case studies represent a snapshot in time, we do
have information that die manner of producing tomatoes
has changed since the sources for this chapter were
compiled in 1989 resulting in significant reductions in
the use of pesticides, in California for example. The
sources have not been updated except in the case of van
Raveoswaay and Hoehn in endnote 24 (a draft version
was cited in 1989).
2 USDA/AMS, "US Standards for Grades of Fresh
Tomatoes" (7 CFR 51, 1973 and 1991).
3 Tomatoes Grown in the Lower Rio Grande Valley in
Texas (7 CFR 965); Tomatoes Grown in Florida (7 CFR
966).
4 USDA/AMS, "US Standards for Grades of Fresh
Tomatoes" (7 CFR 51, 1973 and 1991). Although 15
percent are allowed not to meet tolerances, only a total
of 5 percent can be affected by decay, a total of 10 percent
can damaged by shoulder bruises or discolored or sunken
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use R - 5
scars on any parts of tomatoes, a total of 10 percent can
be otherwised defected, and a total of 5 percent can be
seriously damaged by any cause.
* Feenstra, p. 36.
4 K. Pohronezny, as quoted in National Research Coun-
cil, Alternative Agriculture, p. 341.
7 Bashin, p. 43.
' Feenstra, p. 38. Pesticide use on fresh tomatoes in
California has greatly foiled off since the adoption of drip
irrigation. (See lane Eickhoff and Barbara Petersen,
Survey of Pesticide Use on Fresh Market Tomatoes in
California, prepared for the California Fresh Tomato
Advisory Board, 1989)
* Ibid., p. 40.
10 See endnote number 16, Chapter m, for the definition
of "mature green."
11 Bashin, p. 44.
12 van den Bosch, et al, p. 108.
"Pimental, etal, 1977.
14 van den Bosch, et al, p. 114.
"Ibid., p. 111.
" Feenstra, p. 44.
17 See, for example, Robert Metcalf, "The Ecology of
Insecticides and the Chemical Control of Insects," in
Marcos Kogan, ed., Ecological Theory and Integrated
Pest Management Practice (New York: John Wiley &
Sons, 1986), pp. 251-297.
" Feenstra, p. 46.
19 Wilson, cited in Feenstra, p. 45.
20 Feenstra, p. 45.
21 In addition, some states have apple standards that are
more stringent than Federal standards. These affect
growers within the state, as well as out-of-sttte growers
who want to sell within the state. The purpose of such
standards is to help develop a state brand name that
consumers will recognize and associate with quality.
22 Wood, 1989.
25 Pest damage was measured as the amount of surface
area on an apple in a photograph.
24 Eileen van Ravenswaay and John P. Hoehn, Consumer
Willingness to Pay for Reducing Pesticide Residues in
Food: Results of a Nationwide Survey, Staff Paper no.
91-18 (East Lansing, MI: Depart, of Ag. Economics,
Michigan State University, 1991).
25 Arthur Kelly, Maine apple grower, personal commu-
nication, 3/28/89.
"Ibid.
TIbid. Two researchers estimate that most apple growers
have attempted some level of IPM, especially for mite
control. (M. Whalon and B. Croft, "Apple IPM Imple-
mentation in North America," Annual Review of Ento-
mology 29 (1984): 462.
21 Bethell, 1989.
* Wood, 1989.
30 Such as work by Dr. Carolyn Pickle of the U.S.
Cooperative Extension Service in California.
31 Bethell, 1989.
32 Between 5 and 10 percent of one apple grower' s budget
(Kelly, 1989).
Chapter V: Conclusions
No references cited.
Appendix A
1 Sources for altering food grading standards are: Ken
Mizelle, USDA Agricultural Marketing Service, Fruit &
Vegetable Division, Fresh Products Branch, Standard-
ization Section, Telephone interviews with Doug Koplow,
31 March 1989 and 3 April 1989; USDA, AMS/F&VD/
FPB "Procedures for Revision of U.S. Grading Stan-
dards," August?, 1986; USDA, "Guidelines for Devel-
oping New or Changing Existing U.S. Standards for
Fruits, Vegetables, and Nuts."
2 Mizelle, 1989.
3 USDA, "United States Standards for Grades of Fresh
Tomatoes," p. 2.
4 Process is from Federal Register, 16 April 1989, p.
12931; Federal Register, 21 September 1982, p. 41638;
Brickey, 1989; and Troxell, 1989.
3 For example, a 1982 DAL for cabbage was requested
by the National Kraut Packers Association because
sauerkraut processors were refusing to accept cabbage
infested with thrips (Federal Register, September 21,
1982, p. 41638).
6 Brickey, 1989.
7 Troxell, 1989. The 95th percentile is determined at a
99% confidence level.
' Source for steps to change a marketing order is Walter
Annbruster and Edward Jesse, "Fruit and Vegetable
Marketing Orders' (East Lansing, MI: Cooperative
Extension Service, 1984), unless otherwise noted.
*Zepp and Powers, p. 17.
10 Annbruster and Jesse, p. 8.
Appendix B
See table footnotes within the appendix for relevant
citations.
-------
- 6 Notes and References
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An Overview of Fruit and Vegetable Standards Relating to Cosmetic Appearance and Pesticide Use R - 7
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R - 8 Note* and References
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R - 12 Note* and Raferancas
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