Tea in the Annual FDA Pesticide Report
The U. S. Environmental Protection Agency (EPA) approves the use of pesticides and may establish tolerances for pesticide chemical residues that could remain in or on food. A tolerance is the EPA established maximum residue level of a specific pesticide chemical that is permitted in or on a human or animal food in the United States.
The Food and Drug Administration is responsible for enforcing the EPA tolerances for domestic foods shipped in interstate commerce and foods offered for import into the U.S., except for meat, poultry, catfish, and certain egg products that are regulated by the U.S. Department of Agriculture.
FDA monitors a broad range of foods samples (over 7000 in fiscal year 2016), using a multi-residue method that analyzes approximately 700 different pesticide chemical residues in a single analysis and selective residue methods that detect pesticide chemical residues not covered by the multi-residue method.
A no-tolerance violation is when a pesticide chemical residue is detected, quantified and confirmed in a commodity for which EPA has not established a tolerance or tolerance exemption for that particular pesticide/commodity combination.
The EPA has established very few pesticide tolerances for tea!
An over-tolerance violation is when pesticide chemical residues are detected at a level above the limits established by EPA for a specific food.
The violation rate is the percentage of samples that contain at least one violative pesticide chemical residue.
Foods that are imported from other countries usually have a higher violation rate because other countries may allow the use of different pesticides or different amounts of pesticides than the U.S. allows.
PPM is one part out of 1 million parts, e.g., a residue of 1 ppm is equivalent to 1 µg of residue in one gram of a food sample.
Typically, fruits and vegetables comprise the majority of the human foods tested in the FDA regulatory pesticide program. This was the case in FY 2014 for import samples, of which 75.7 % were fruits and vegetables. However, only 36.1 % of FY 2014 domestic samples were fruits and vegetables because FDA conducted two focused sample surveys that comprised about half the domestic samples, “Collection of Domestic and Domestic Import Tea Samples for Pesticide Residue Analysis” (Tea assignment) and “European Union Audit Field Assignment” (EU assignment).
In FY 2013 FDA conducted a survey of black, green and white teas collected from retail outlets with the intention of determining pesticide levels in teas. In FY 2014, FDA repeated the tea survey to obtain additional data on the levels of pesticides in teas. FDA analyzed 21 samples of black and green tea leaves collected from retail outlets for pesticide residues. Of the 21 samples analyzed, no residues were detected in 5 samples, and 12 (57.1 %) were found to contain violative pesticide residues. Table 6a lists the 26 different pesticide residues found in the tea samples, the frequency and range of residue levels at which they were detected, and the tolerance level allowed on tea leaves.
The violative findings for tea are not unexpected, because EPA has established very few pesticide tolerances for tea, a crop that is not produced domestically. These findings are unlikely to be a safety concern for several reasons, including that the violative pesticides found are approved for use on tea internationally and the levels found on tea leaves is much higher than the trace levels found in brewed tea drink, as seen in the TDS program.
A 2018 Snopes Article Do These 8 Teas Contain “Illegal Amounts of Deadly Pesticides”? helps to debunk the alarmism by striking up an email conversation with the FDA residue expert, Chris Sack:
If a product contains a pesticide residue for which EPA has not set a tolerance, at any level, it is adulterated. We actually classify the residue that way in our data. The regulatory action is a separate thing. Think of it like the speed limit... I should note that 0.01 ppm is the default MRL in several countries, including the EU, Japan, Australia, etc. In the US we flag the adulterating residue, but we don’t normally take action until the residue is 0.01 ppm, or higher.
In many cases, these pesticide chemicals have MRLs set for non-tea food items that are far higher than 0.01 ppm, but because of a lack of data for dried tea (even though tea typically has higher tolerances than types of food thanks to the chemical loss that occurs when brewing tea), the extremely low bar of 0.01 ppm counts as an infraction. Lumping these two types of infractions together provides a misleading portrait of the testing results used for this blog post.
That article also talks about the Greenpeace Study and brushes it off as being old... four years old at that point... which seems a little premature.
While we are not at all alarmist, we do recognize that we should spend more time and energy on collecting data and understanding the the possible risks of our favourite beverage!