Proposals to Amend the  New 
Zealand ( Maximum Residue 
Levels for Agricultural 
Compounds ) Food Notice   
 
New Z ealand Food Safety Discussion  Paper  No: 2022/05 
 
  
Prepared for public consultation  
By New Zealand Food Safety  
 
 ISBN No: 978 -1-99-105211 -7 ( (online)  
ISSN No: 2624- 0157 (online)  
 
 
 
 
29 August  2022 
 
 
Disclaimer  
 
While every effort has been made to ensure the information in this publication is accurate, the  
Ministry for Primary Industries  does not accept any responsibility or liability for error of fact, omission, 
interpretation or opinion that may be present, nor for the consequences of any decisions based on this 
information.  
 
This publication is available on the Ministry for Primary Industries  website at  
http://www.mpi.govt.nz/news -and-resources/publications/   
  
© Crown Copyright - Ministry for Primary Industries   
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  1 Contents  Page 
 
1 Request for submissions  2 
2 Introduction  3 
2.1 Estab lishing  Maximum Residue Levels  3 
2.2 Summary of Proposed Amendments  7 
3 Proposals  8 
3.1 Proposal to amend the MRLs for cyantraniliprole  8 
3.2 Proposal to amend t he MRLs fo r tetracyclines  9 
3.3 Proposal to delete the Notice entry for trichlorfon  10 
3.4 Proposal to set an entry for lactic acid in Schedule 3  10 
 
   
2 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice  New Zealand Food Safety  1 Request for s ubmissions  
New Zealand Food Safety  invites public comment on this discussion document, which 
outlines proposals to amend the New Zealand (Maximum Residue Levels for Agricul tural 
Compounds) Food Notice (Notice) . 
 
For each compound  you are commenting on, please clearly answer the following questions.  
 
Do you agree or disagree with the proposed addition, amendment or deletion? 
 
For compounds listed in Schedule 1 , do you agree or disagree with the proposed 
MRL (s)?  
 
For compounds listed in Schedule s 2 or 3, do you agree or disagree with the listing or 
the conditions?  
 
Please feel free to include with your answers above, any supporting discussion, data or 
examples that you feel is relevant.  
 
Submissions close at 5pm on 28 October  2022 . Your comments should be sent to:  
MRL Amendments  
New Zealand Food Safety  
Ministry for Primary Industries  
PO Box 2526 
Wellington 6140 
Email: MaximumResidueLevels@mpi.govt.nz . 
Please include your name and address on your submission. If you are making comments on behalf of an organisation, also include your title and the name of the organisation.  
Please make sure your comments can be clearly read, as a number of copies of your 
submission may be made.  
 
The Official Information Act  
The Official Information Act 1982 (the OIA) states that information is to be made available 
unless there are grounds for withholding it. The grounds for withholding information are outlined in the OIA.  Submitters may wish to indicate any grounds for withholding information 
contained in their submission.  Reasons for withholding information could include that 
information is commercially sensitive or that the submitters wish personal information such as names or contact details to be withheld.  The Ministry for Primary Industries  will take such 
indications into account when determining whether  to release information.  Any decision to 
withhold information requested under the OIA may be reviewed by the Ombudsman.  
 
  
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  3 2 Introduction 
Agricultural compounds are natural or synthetic substances used in the direct  management 
of plants and animals, and include all  agricultural chemicals (e.g. fungicides, herbicides,  and 
insecticides) , veterinary medicines, a nd other compounds used to maintain plant and animal 
health and productivity.  Growers and farmers use these agricultural compounds to manage 
disease in animals and crops, protect the food supply, and maximise the quantity and quality 
of the food they grow.  
Agricultural compound use can leave residues in the food harvested from treated crops and 
animals. To manage these residues, it is important to ensure that only the appropriate amount of an agricultural compound is used to achieve its  intended purpose and leave the 
smallest amount of residue practicable without compromising the compound’s efficacy. The set of principles and methods used to manage that balance is known as good agricultural 
practice (GAP ). These pri nciples apply to the production of safe and good quality 
horticultural , agricultural,  and animal products.  Maximum residue levels (MRLs) are then 
established for each compound/food commodity combination by evaluating the residues left in food commodities a s a result of the highest authorised GAP use  (the ‘critical GAP’) .  This 
value is compared against the health- based guidance value before a maximum level of 
agricultural compound residue allowable in that food commodity  is set . How the MRLs are 
determined, and how they are used once they have been set, are explained in more detail below.   
MRLs are the maximum legal levels for residues of agricultural compounds permitted in food for sale in New Zealand. They are established based on domestic uses of a particular compound, and are used to monitor GAP compliance in New Zealand while ensuring food safety. Because they are based on New Zealand authorised uses according to domestic 
GAP, MRLs may differ from those established overseas  for a similar use because their GAP 
may be different.  However, as noted below, imported food can also comply with Codex 
MRLs.  
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and Phytosanitary Measures (the SPS Agreement) , proposals for new and amended MRLs are 
notified to the World Trade Organization. Any country may choose to comment if they believe 
a proposed MRL represents a barrier to their trade.  
2.1 ESTABLISHING MAXIMUM RESIDUE LEVELS  
2.1.1 Regulatory Structure  
MRLs  are th e maximum legal levels of agricultural compound residues  permitted in food for 
sale in New Zealand  and are set out in the Notice. The Notice is updated up to four times a 
year to reflect changes in the use of agricultural compounds in the production of food. The 
Notice is available from the Ministry for Primary Industries (MPI) New Zealand Food Safety 
website at: https://www.mpi.govt.nz/dmsdocument/19550- maximum- residue- levels -for-
agricultural -compounds .  
New Zealand Food Safety administers the Notice, with the final decision on any changes to the Notice resting with the Director -General of MPI. The Notice is issued under section 405 
of the Food Act 2014. When setting or amending MRLs, the Director -General must follow, as 
far as p racticable, international best practice on dietary intake assessment and setting of 
maximum residue levels.  The requirements for the content of the Notice are set out in Part 6 
of the Food Regulations 2015  (the Food Regulations), allowing for the setting  of MRLs for 
agricultural compounds as well as specifying compounds to which no MRL applies .   
4 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice  New Zealand Food Safety  In addition to establishing the requirements for domestically produced foods, Part 6 of the 
Food Regulations  also outlines the residue level compliance requirements for imported 
foods. Regulation 144 states that food must not contain residues of agricultural compounds  
unless the residue level  does not exceed : 
- the MRLs specified for that food in a notice set under  the Food Act 2014 
(regulation 144(1)(a)); or 
- the default MRL of 0.1 mg/kg ( regulation 144(1)(c)); or  
- for imported food, the current editions of either the Maximum Residue Limits 
(MRLs) and Extraneous Maximum Residue Limits (EMRLs) for Pesticides (Codex 
Pesticides Residues in Food Online Database), or the Maximum Residue Limits 
for Veterinary Drugs in Food (Codex Veterinary Drug Residue in Food Online Database) ( regulation 144(1)(d)).  
These provisions  allow for New Zealand Food Safety to set MRLs for impor ted food 
commodities when such l evels are required. As imported food commodities can comply with 
either a Codex MRL or a MRL established in the Notice, New Zealand’s obligations under the 
SPS Agreement are met.  
On the whole, the Food Regulations allow for the management of residues in all foods 
consumed in New Zealand.  
2.1.2 Determining Maximum Residue Levels  
The first step in determining MRLs for an agricultural compound is establishing GAP for the 
use of the compound in the target speci es or crop. New Zealand Food Safety establishes 
GAP by evaluating public health, crop safety, animal health and safety, occupational , and 
environmental safety considerations for the range of treatments and use patterns  approved 
and proposed for each compound. Once GAP has been established for an agricultural compound, the residues resulting from the highest authorised dose or application rate and 
use pattern,  which is likely to give rise to the highest residues  (the ‘critical GAP’)  is then used 
to determine the MRLs in food commodities from  treated  crops  and animals.   
Although the primary function of MRLs is to ensure conformance with established New 
Zealand GAP, the MRLs also play a role in managing dietary exposure and risks to trade in 
food commodities. T o ensure the MRLs w ill effectively manage residues related to those 
risks, a national estimated daily intake or NEDI calculation is conducted to evaluate 
consumption risk  and a  review of all international MRLs for the compound/commodity 
combinations being considered is completed to evaluate trade risk. If it is found that the MRL 
being considered may pose a food safety or trade risk,  the proposed MRL is not progressed.   
Where it  has been determined that MRLs can be set, those MRLs are proposed for inclusion 
in the Notice for approved or proposed agricultural compound uses . For veterinary 
medicines, MRLs may be proposed for animal products from a specific species ( e.g., cattle, 
chicken) or a species group ( e.g., mammalian, poultry) depending on the residue and 
metabolism profile of the agricultural compound being considered. Similarly,  for agricultural 
chemicals, an MRL may be set for an individual crop or crop product ( e.g., avoca dos, wheat 
grains) or for a crop grouping ( e.g., pome fruits). When it has been determined that assigning 
an MRL to a crop grouping is appropriate, the grouping used aligns with the Codex classifications of foods and animal feeds.  
For a gricultural chemical s used on a crop from which both food and animal feed commodities 
are derived, MRLs are  proposed for both the food commodities intended for human 
consumption from the treated crop , and animal commodities for the species or species group 
to which the feed commodity is fed.  If the compound for which the MRLs are set is also used 
as a veterinary medicine, all approved veterinary and agricultural chemical uses are  
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  5 considered when setting the animal commodity MRLs.  If an agricultural chemical is  used on 
a crop from which only animal feed is harvested (e.g., pasture, fodder crops) , only animal 
commodity MRLs will be proposed.   
2.1.3 Estimat ing Chronic Dietary Exposure   
National estimated daily intake 
The objective of the estimated chronic dietary exposure is to determine whether residues in 
food commodities will pose an unacceptable risk to consumers as a result of the authorised 
use of an agricultural compound according to established GAP. This exposure is estimated 
by calculating the national estimated daily intake  (NEDI ) in accordance with Guidelines for 
predicting dietary intake of pesticide residues (revised) [World Health Organization, 1997] . 
The N EDI calculation  uses  the total residues in food derived f rom all New Zealand authorised 
uses of an agricultura l compound,  including all toxicologically significant residues,  and 
regional dietary consumption data derived from the 1997 National Nutritional Survey for 
adults and the 1995 National Nutrition Survey of Australia for children. The calculated NEDI 
is then compared with the  health based guidance value (HBGV)  associated with the 
compound; if the total residues derived from all uses of the agricultural compound is 
estimated to be less than the HBGV, the dietary exposure is unlikely to pose a health risk to consumers.   
Health Based Guidance Values  
The HBGV used in determining the estimated dietary exposure may be either a Potential Daily Exposure (food) (PDE
(food)) or an Acceptable Daily Intake (ADI). The ADI and PDE (food) 
are largely equivalent as they are determined using the same set of toxicology data and through a very similar scientific proces s. Both values are reported as milligrams of compound 
per kilogram bodyweight per day (mg/kg bw/d).  
A PDE
(food) is a value determined by a toxicological evaluation by the New Zealand 
Environmental Protection Authority ( NZ EPA) as part of its responsibility for managing public 
health under the Hazardous Substances and New Organisms Act 1996.  A PDE (food) gives the 
potential daily exposure to a substance that  a person may be subject to via food, and is the 
food- specific part of a set of values for different exposure pathways comprising the NZ EPA’s 
assessment of acceptable daily exposure (ADE) for an agricultural com pound.  
An ADI is defined by the World Health Organization (WHO) as “the daily intake which, during 
an entire lifetime, appears to be without appreciable risk on the basis of all the known facts at 
the time”. “Without appreciable risk” has been further def ined as: “the practical certainty that 
injury will not result even after a lifetime of exposure”. ADIs are established by the WHO and 
Food and Agriculture Organization (FAO) of the United Nations joint expert committees, 
which are made up of toxicologists and residue specialists. The ADI information from these joint committees also feeds into the Codex Alimentarius Commission (Codex), which sets international MRLs.  
New Zealand Food Safety  uses the PDE
(food) set by the NZ EPA as the HBGV for the 
estimation of dietary exposure when one is available. If there is no PDE (food), the NEDI  is 
compared with an  ADI set by the WHO/FAO joint expert committees, the Australian 
Pesticides and Veterinary Medicines Authority, the European Food Safety Authority, or 
another r egulatory authority. If none of these are available, the HBGV used will be a New 
Zealand Food Safety -determined ADI.    
6 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice  New Zealand Food Safety  2.1.4 International MRLs and Trade  
Because  New Zealand MRLs are based on domestic GAP, they may differ from th e MRLs  
established overseas  for the use of the same compound in the same target species or crop if 
the GAP us ed to set those MRLs are different . To ensure the New Zealand MRLs will not 
unduly impact trade, the MRLs set by Codex and a selection of other international regulatory 
bodies  are reviewed to evaluate trade risk.  
For animal commodities, the MRLs set by Australia, Canada, China, Codex, the European Union, Japan, and the U nited States  are commonly  reviewed and compared; for horticultural 
commodities, MRLs set by Codex and Australia are commonly  reviewed and compared. 
Other international MRLs  may also be reviewed and compared if there is a particular trade 
risk to be considered for those regions  for any exported commodity .  
Where there are relevant international MRLs to be considered in the trade assessment  for 
the proposal , these are included in a table in the “Relevant International MRLs” section of 
each proposal entry. This table includes all MRLs for the agric ultural compound /food 
commodit y combinations for which new or amended New Zealand MRLs are being 
proposed; international MRLs for other commodities for which New Zealand MRLs already exist are not included. If there are no MRLs set by an international authority for a particular 
compound/commodity combination, the aut hority is not listed in the table.  
2.1.5 Agricultural Compounds for Which No Maximum Residue Level Applies   
Not all agricultural compounds require a n MRL to manage their use in crops or animals . This 
may be because there are no residues present due to the prope rties of the  compound such 
as rapid elimination from the plant, animal, or their environment,  or because there are no 
food safety or trade risk s associated with the residues that are present. Regulation 141 of the 
Food Regulations allow s for the listing of specified compounds that fit these criteria as 
agricultural chemicals or veterinary medicines for which no MRL applies. These compounds 
are listed in Schedule 2 and Schedule 3 of the Notice, respectively , and the conditions of 
listing c an be set  for a particular use, a particular animal or crop, or general use as an 
agricultural chemical or veterinary medicine.  
Agricultural chemicals and veterinary medicines being considered for  listing as compounds 
for which no MRL applies undergo a similar scientific assessment of their use as that 
undertaken for MRL assessment. This assessment is done in accordance with international 
methodologies published by the Organisation for Economic Cooperation and Development 
(OECD), International Cooperation on Harmonisation of Technical Requirements for 
Registration of Veterinary Medicinal Products (VICH), or FAO. It includes establishing the 
GAP use of the compound, the relevant metabolism and residue information, and the 
potential risks posed to public heal th and trade.  The assessment may also include an 
assessment of dietary exposure when considered necessary to fully assess the risks.  
Where New Zealand Food Safety has determined that a n MRL is not required, the compound 
is proposed for list ing in Schedule 2 (for agricultural chemicals)  or Schedule 3 (for veterinary 
medicines) with conditions on their use to ensure the listing applies only to those situations 
that have been evaluated. If a compound listed in Schedule 2 or 3 is used in a way that does 
not meet the specified condition, the default MRL of 0.1 mg/kg will appl y to food derived from 
treated plants  or animals. Each proposal for inclusion in Schedule 2 or 3 includes a 
discussion of the rationale behind the considerations for listing , and a discussion of the 
assessed risks and proposed conditions .   
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  7 2.2 SUMMARY OF PROPOSED AMENDMENTS  
The proposed MRLs have been thoroughly assessed in accordance wit h international 
methodologies published by the O ECD, VICH, or FAO . Information on the technical 
assessment of each proposal is included in this document (refer section 3) and covers:  
• the new or amended entry proposed for inclusion in the Notice;  
• the ration ale for the new entry or amendment being proposed;  
• New Zealand good agricultural practice for the compound and target crop or species ; 
• the relevant residues information used in determining the proposed MRLs ; 
• a summary of the dietary risk  and public health assessment ; and 
• the MRLs set by Codex and other authorities  that are  relevant to the new or amended 
entry.  
Where an existing entry is proposed for revision, new or revised entry content is listed in bold 
print, and content proposed for removal is  identified by a strikethrough.  
The MRL compliance and dietary risk assessment residue definitions are included in the 
residues information section of the proposal . The HBGV used to compare to the NEDI 
calculation and determine the potential public health risk is included in the dietary risk and 
public health assessment section of the proposal .  
2.2.1 Amendments to Schedule 1 : Maximum Residue Levels for Agricultural Compounds  
MPI proposes to make the following changes to Schedule 1 of the Notice : 
• An amendm ent to the entry for cyantraniliprole, to set an MRL at 0.05 mg/kg in 
mammalian liver;  
• The removal of the fish meat MRL at 0.1 mg/kg from the tetracyclines entry; and 
• The removal of the Notice entry for trichlorfon.  
2.2.2 Amendment to Schedule 3 : Veterinary Medi cines for which No Maximum Residue Level 
Applies  
• The addition of a new entry for lactic acid, when used as a teat sanitiser.    
   
8 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice  New Zealand Food Safety  3 Proposals  
3.1 PROPOSAL TO AMEND THE MRLS FOR CYANTRANILIPROLE   
It is proposed that the mammalian liver  MRL for cyantraniliprole  is amended to better support 
the GAP use of the compound in animal feed commodities.  The current MRL is 0.03mg/kg,  
and the proposed change is an increase in the MRL to 0.05mg/kg.  
The revised entry in Schedule 1 of the Notice will read:  
Compound 
Common Name  CAS#  Residue to which the 
maximum residue level 
applies  Food  Maximum Residue 
Level (mg/kg)  
Cyantraniliprole 736994 -63-1 Cyantraniliprole Bulb onions  
Mammalian fat  
Mammalian kidney  
Mammalian liver  
Mammalian meat  
Milk 
Potatoes  
Tomatoes  0.01(*)  
0.01(*)  
0.02 
0.05 
0.01(*)  
0.02 
0.01(*)  
0.1 
(*) indicates that the maximum residue level has been set at or about the limit of analytical quantification.  
3.1.1 Amendment Rationale  
A review of the use of cyantraniliprole in animal feed commodities has recently been 
undertaken to re -evaluate the GAP use of  and withholding periods for  the compound when 
used in animal feed crops . The result of this review was confirmation of all animal commodity 
MRLs except mammalian liver, which required a change to better reflect GAP.  
3.1.2 Good Agricultural Practice  
Cyantraniliprole is an anthranilic diamide insecticide which acts by activation of muscle 
receptors leading to paralysis and eventual death of the insect. The compound is currently 
registered for use on field tomatoes, potatoes, onions,  fodder beets, and fodder brassicas.  In 
animal feed commodities, cyantraniliprole is used at a rate of 15 gai per hectare at the first sign of insects or damage, repeated at 2- 3 week intervals for up to three applications per 
season. This use attracts with holding periods of 28 days for fodder beets and 14- 28 days for 
fodder brassicas.  
3.1.3 Residue Information 
The residue data for the use of cyantraniliprole on fodder beets and fodder brassicas  are 
sufficient to conclude that, when used according to established G AP in these animal feed 
crops and observing the applicable withholding periods, residues of cyantraniliprole should 
not exceed 0.01 mg/kg in mammalian fat and meat, 0.02 mg/kg in mammalian kidney and milk, and 0.05 mg/kg in mammalian liver.  
The current residue definitions remain appropriate for animal commodities: ‘cyantraniliprole’ 
for GAP compliance and ‘s um of cyantraniliprole, 2- [3-Bromo -1-(3-chloro- 2-pyridinyl) -1H-
pyrazol -5-yl]-3,4-dihydro -3,8- dimethyl -4-oxo-6-quinazolinecarbonitrile [IN -J9Z38], 2 -[3-
Bromo -1-(3-chloro -2-pyridinyl) - 1H-pyrazol -5-yl]-1,4-dihydro -8-methyl -4-oxo-6-
quinazolinecarbonitrile [IN -MLA84], 3 - Bromo -1-(3-chloro- 2-pyridinyl) -N-[4-cyano -2-
(hydroxymethyl) -6- [(methylamino)carbonyl]phenyl] -1H-pyrazole -5-carboxamide [IN - N7B69] 
and3- Bromo -1- (3-chloro -2-pyridinyl) -N-[4-cyano -2[[(hydroxymethyl)amino]carbonyl] -6-
methylphenyl] -1Hpyrazole- 5-carboxamide [IN -MYX98], expressed as cyantraniliprole’ for 
dietary intake.    
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  9 3.1.4 Dietary Risk Assessment  
The HBGV  of 0.007 mg/kg bw/d was considered appropriate for use in the assessment.  
Based on the residue profile expected in food from  crops treated with cyantraniliprole and in 
commodities from animals fed animal feed crops treated with cyantraniliprole according to 
GAP, the NEDI is estimated to total less than 3 % of the HBGV.  
New Zealand Food Safety  has therefore determined that the use of cyantraniliprole on 
horticultural crops and in animal feed crops  in accordance with the GAP specified above, and 
complying with the revised MRLs, is unlikely to pose any health risks from authorised use.   
3.1.5 Relevant International MRLs 
Authority  Food                                                                         Maximum Residue Level 
(mg/kg)  
Codex  Edible offal (mammalian)  1.5 
Australia  Edible offal (mammalian)  0.05 
Canada  Meat byproducts of cattle  
Meat byproducts of goat  
Meat byproducts of sheep  0.4 
0.4 
0.4 
China Viscera of mammals (with the exception of marine mammals)  1.5 
European Union  Bovine liver  
Sheep liver  
Goat liver  1.5 
1.5 
1.5 
Japan Cattle liver  2 
United States  Cattle liver  
Sheep liver  0.4 
0.4 
3.2 PROPOSAL TO AMEND THE MRLS FOR T ETRACYCLINES   
It is proposed that the MRL for tetracyclines in fish meat are removed.  
The revised entry in Schedule 1 of the Notice will read: 
Compound 
Common Name  CAS#  Residue to which the 
maximum residue level 
applies  Food Maximum Residue 
Level (mg/kg)  
Tetracyclines  57-62-5, 564 -
25-0, 79- 57-
2, and  60-54-
8  MRLs cover  Oxytetracycline, 
Tetracycline, 
Chlortetracycline, or 
Doxycycline singly or in 
combination  
Chlortetracycline, doxycycline, 
oxytetracycline, or 
tetracycline , singly or in 
combination   Cattle kidney  
Cattle liver  
Cattle meat  
Cattle milk  
Fish meat  
Poultry  Eggs  
Pig kidney  
Pig liver  
Pig meat  
Poultry kidney  
Poultry liver  
Poultry meat  
Sheep kidney  
Sheep liver  
Sheep meat  0.6 
0.3 
0.1 
0.1 
0.1 
0.2 
0.6 
0.3 
0.1 
0.6 
0.3 
0.1 
0.6 
0.3 
0.1  
10 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice  New Zealand Food Safety  3.2.1 Amendment Rationale  
The removal of the historic fish meat  MRL is being proposed because the use of 
oxytetracycline or any other tetracyclines in fish has not been approved in New Zealand 
since 1991. As such, there is no need to retain the MRL to manage the GAP use of the 
compound in fish.  
All other uses of tetracyclines in cattle, pigs, poultry, and sheep are being retained, though the MRL for “ Poultry eggs” is being simplified to “ Eggs”. All MRL values will remain 
unchanged.  
In addition to the above,  some administrative changes are proposed for the entry. The text in 
the ‘Residue to which the maximum residue level applies ’ column has been edited to update 
the phrasing of the residue definition and place the compounds in alphabetical order, and CAS num bers have been added for chlortetracycline, doxycycline, and oxytetracycline to the 
‘CAS#’ portion of the entry for completeness. The identity of the compounds to which the maximum residue level applies has not changed.  
3.3 PROPOSAL TO DELETE THE NOTICE ENTRY FOR TRICHLORFON  
It is proposed that the following entry is deleted from Schedule 1 of the Notice:  
Compound 
Common Name  CAS#  Residue to which the 
maximum residue level 
applies  Food Maximum Residue 
Level (mg/kg)  
Trichlorfon   52-68-6 Sum of: Trichlorfon and 
dichlorvos  
Expressed as: Dichlorvos  Milk 
Sugarbeet  0.05 
0.05 
3.3.1 Amendment Rationale  
The deletion is being proposed because the compound is no longer used as an agricultural 
compound in New Zealand, with the last registered agricultural compound containing trichlorfon  de-registered in 2014. Trichlorfon  MRLs are therefore no longer required to 
manage the GAP use of the compound in New Zealand.   
3.4 PROPOSAL TO SET AN  ENTRY FOR L ACTIC ACID IN  SCHEDULE 3 
It is pr oposed that lactic  acid is added to Schedule 3 of the Notice to identify it as a veterinary 
medicine to which no MRL applies. Lactic acid is used as an antimicrobial ingredient in teat 
sanitisers, and it occurs naturally in milk and several other foods due to bacterial 
fermentation of lactose. When used as a teat sanitiser, the additional amount present resulting from veterinary medicine use is negligible compared to naturally occurring amounts and unlikely to present an additional hazard. It is therefore considered that residues of  lactic  
acid do not need to be managed through the application of a MRL when the compound is used as a teat sanitiser.  
The proposed new entry in Schedule 3 will read as follows:  
Substance  CAS#  Condition  
Lactic acid  50-21-5 When used as a teat sanitiser