UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

OFFICE OF CHEMICAL SAFETY AND

POLLUTION PREVENTION

MEM ORANDUM

DATE : November 1 5 , 2010

SUBJECT : ChemSAC Review of the USDA IR

- 4 Crop Grouping Proposal to Amend

the Tree Nut Crop Group 14, and Analysis of the USDA IR

- 4 Petition to Amend the Crop Group Regulation 40 CFR § 180.41 (16) an d Commodity Definitions [40 CFR § 180.1 (g) ]

.

FROM : Bernard A. Schneider, Ph.D., Senior Plant Physiologist

Chemistry and Exposure Branch Health Effects Division (7509P)

TO: Michael Doherty , Ph.D. and William Donovan, Ph.D.,

Chairpersons HED Chemistr y Science Advisory Council (ChemSAC) Jennifer Selwyn

, PMRA

Felix Valer a , SAGARPA , Mexico Barbara Madden, Minor Use Officer , RD (7505P) Laura Nollen, RD (750 5P )

cc: IR

- 4 Project, Bill Barney, Jerry Baron, Dan Kunkel, Debbie Carpenter, Van

Starner

BACKGROUND:

The current Crop Group 14, Tree Nuts group published in 40 CFR 180.41 (14) includes 12 commodity entries in seven botanical families including Anacardiaceae

, Betulaceae, Fagaceae

, Juglandaceae

, Lecythidaceae

, Proteaceae, and Rosaceae

. Almo nd and pecan were selected as representative commodities for this group. There have been 55 group tolerances established on tree nut crop group based on the residue data generated from the representative crops.

Botanically, a nut is a hard indehiscent (not opening at maturity) one

- seeded fruit.2

It is also defined as a hard shelled fruit or seed of which the kernel is eaten by humans. A

nut is the seed of a tree. However, a nut in commerce and cuisine has a much less

restrictive definition than a nut in botany. The term is applied to many seeds that are not true nuts. Any large kernel found within a shell and used in food may be regarded as a nut. For example, almond is the edible seed of a drupe, while the Brazil nut is the seed from a capsule. C andlenut and cashew nut are seeds. Pine nut is the seed of several species of pine, while the pistachio nut is the seed of a thin

- shelled drupe. Peanuts can be disqualified from “nuts” because peanuts include two or three seeds in the indehiscent pod and are legume crops.

Since the tree nut crop group is a somewhat artificial crop group and because the various crops within the group come from diverse families, they are not expected to be susceptible to the same pests and diseases requiring the same pes ticide treatment. T here are 18 different plant families represented in this proposed tree nut crop group. However, in practice, residues (expressed on the edible portion) in tree nuts from field use are often low or not detectable irrespective of the pes ticide use, so a tree nut group tolerance can be

achieved. Most are grown in similar orchard or plantations and maintained with similar cultural practices. Comparing U

. S

. , Codex, and the EU Tree nut MRL’s/ tolerances based on residue data generated from t he representative crops r ange from 0.01 to 0.5 ppm with one Codex tolerance established at 1 ppm for carbaryl. Most U

. S

. tolerances for the Tree

Nuts are < 0.2 ppm.

Since this crop group was established in 1995, more species and varieties of tree

nuts h ave become popular in commercial production and some in international trade. Tree nuts that were previously considered as orphan crops include tropical almond, betelnut, coconut, ginkgo, heartnut, bur oak, pili nut, pine nut and pistachio.

The Crop Grou p 14 proposal was generated at the USDA/IR

- 4 Crop Grouping Symposium in Washington, DC, October 2002 by the Temperate Tree and Small Fruit Workgroup Chaired by Van Starner of USDA, IR

- 4 and Co

- Chaired by Craig Hunter, Canadian Horticultural Center, Rick Me lnicoe, University of California Department of Environmental Toxicology, Dr. Richard Loranger and Chris Olinger, EPA, HED and John Wise, Michigan State University . It was further discussed and developed within the Tree Nut Workgroup of the International C rop Grouping Consulting Committee (ICGCC). This workgroup consists of 200 crop or regulatory experts from the US, NAFTA, EU, Asia, Middle East, Africa, and Latin America regions representing 30 countries. The Workgroup discussed and validated each of the existing crop group commodities and representative commodities. It was proposed that “Filbert (hazelnut)” be changed to “Hazelnut (filbert)”. Additional tree nuts proposed at the Symposium included guana, nut

- o

- nogal, cajou, dalison, okari nut, bunya an d candlenut. These additional tree nuts were also validated at the Symposium, except it was later determined that dalison should be considered as part of the tropical fruit group. Also, guana was not included in this submission since it apparently only g rows in eastern Cuba and is a threatened species. It was determined that n ut

- o

- nogal is a alternative name for black walnut and will be included in the EPA Food and Feed Commodity Vocabulary as a lookup term.3

The concept of having separate temperate an d tropical/subtropical subgroups was not validated at the Symposium, so no subgroups are proposed in this submission. The Symposium also proposed crop definitions for the representative crops of almond and pecan, but due to the previously discussed divers e taxonomic nature of tree nuts, no crop

definitions are proposed in this submission.

Another important aspect is the harmonization with the Codex crop classification. The Codex Classification of foods and animal feeds for Tree nut Group is also undergo ing revision. The IR

- 4/EPA Crop Grouping Working Group and the International Crop Grouping Consulting Committee (ICGCC) are collaborating with t he revision of the Codex crop classification. The expanded Tree Nut Group and the representative commodities p roposed in this petition would facilitate the harmonization of the U.S. and the Codex crop classification systems. Proposed additions to the Codex Classification including Brazilian pine, castanha

- do

- maranhao, Guiana chestnut and monkey

- pot were also incl uded in the petition.

Other t ree nuts presented to the ICGCC but not validated include the Australian or Moreton Bay chestnut, canarium nut, shea nut, suari nut, African walnut and tallow tree. Two proposed crops, purging nut and karanj were not accepte d because of the poisonous nature of the nut or bean and because development of these crops is primarily for biofuel

. One additional proposed crop kalamungay ( Moringa oleifera ) will be considered to be added to a future tropical fruit crop group. Further work by the ICGCC also identified four more potential commodities to be proposed for the Tree nut group. They are the African nut tree [ Ricinodendron heudelotii (Baill.) Heckel], dika nut [ Irvingia gabonensis (Aubry

- Lecomte ex O’Rorke) Baill.], mongongo nut [ Schinziophtyon rautanenii (Schinz)

Radcl.

- Sm.], and the peach palm nut ( Bactris gasipaes Kunth var gasipaes )

.

T he world total hectares for tree nuts (almond, betelnut, brazil nut, cashew, chestnut, coconut, hazelnut, pistachio, and walnut) reported b y FAO (FAO 2009, have increased from 17,420,730 hectares (ha) in 1997 to 19,961,492 ha in 2007, and the total production of these nuts has increased from 57,174,933 metric tons in 1997 to 72,519,897

metric tons in 2007

.

S ome “minor” tree nut commodities l ike the chestnut, pili nut, pine nut, and okari

nut are becoming more popular. Some of these nuts don’t have large commercial production, and thus have little chance to be added to pest control products labels unless they are placed in the tree nut group. By being excluded from the crop groups, means that tolerances requested for these commodities would have to be established based on separate residue studies. Without a doubt the inclusion of these commodities in crop groups will benefit growers, consume rs, save time and tax payer’s money on residue studies, save government agencies time in reviewing residue data, as well as facilitating the establishment of import tolerances. Many of these crops are of economic importance or have a great potential to be grown in larger scale in the future due to their nutritional value or medicinal value, or the increased market demand driven by both the growing ethnic populations and greater awareness of these crops by the non

- ethnic population as a4

whole. The American cuisine has a distinct global nature that includes many orphan crops not yet in a crop group.

REQUEST :

William P. Barney, Crop Grouping Project Coordinator and Tracey Switek, USDA Interregional Research Project No. 4 (IR

- 4), State Agricultural Exper iment Station, Rutgers University has submitted a petition (May 29, 2008) on behalf of the IR

- 4 Project, and the Tree Nuts Workgroup of the International Crop Grouping Consulting Committee (ICGCC) to amend the Crop Group Regulation 40 CFR § 180.41 (c) (16) Crop Group 14, Tree Nut Group.

The above

- mentioned Tree nut crop group petition requested the following four proposals:

IR

- 4 Proposal 1: “Amend the existing crop group in 40 CFR 180.41 (c) (14) that consists of following twelve commodity entries:

1. Almo nd, Prunus dulcis (Mill.) D.A. Webb ( Rosacea e)

2. Beechnut, Fagus spp. ( Fagaceae )

3. Brazil nut, Bertholletia excelsa Bonpl. ( Lecythidaceae )

4. Butternut, Juglans cinerea L. ( Juglandaceae )

5. Cashew, Anacardium occidentale L. ( Anacardiaceae )

6. Chestnut, Castanea spp. ( F agaceae )

7. Chinquapin, Castanea pumila (L.) Mill. ( Fagaceae )

8. Filbert (Hazelnut), Corylus spp. ( Betulaceae )

9. Hickory nut, Carya spp. ( Juglandaceae )

10. Macadamia nut, Macadamia integrifolia Maiden & Betche ( Proteaceae )

11. Pecan, Carya illinoinensis (Wangenh.) K.Koc h ( Juglandaceae )

12. Walnut, black and English, Juglans spp. ( Juglandaceae );

To an expanded crop group that consists of following Thirty

- two commodity entries :

1. Almond, Prunus dulcis (Mill.) D.A. Webb ( Rosaceae )

2. Beechnut, Fagus spp. ( Fagaceae )

3. Betelnut, Areca catechu L. ( Arecaceae ( Palmae ))

4. Brazil nut, Bertholletia excelsa Bonpl. ( Lecythidaceae )

5. Brazilian pine, Araucaria angustifolia ( (Bertol.) Kuntze ( Araucariaceae )

6. Bunya, Araucaria bidwillii Hook. ( Araucariaceae )

7. Bur oak

, Quercus macrocarpa Michx. ( Fagaceae )

8. Butternut, Juglans cinerea L. ( Juglandaceae )

9. Cajou nut, Anacardium giganteum Hancock ex Engl. ( Anacardiaceae )

10. Candlenut, Aleurites moluccanus (L.) Willd. ( Euphorbiaceae )

11. Cashew, Anacardium occidentale L. ( Anacardiaceae )

12. Castanha

- do

- maranhao, Pachira glab ra Pasq. ( Malvaceae )

13. Chestnut (Chinquapin), Castane a spp. ( Fagaceae )

14. Coconut, Cocos nucifera L. ( Arecaceae ( Palmae ))5

15. Ginkgo, Ginkgo biloba L. ( Ginkgoaceae )

16. Guiana chestnut, Pachira aquatic Aubl. ( Malvaceae)

17. Hazelnut (Filbert), Corylus spp. ( Betulaceae )

18. Hea rtnut, Juglans ailantifolia var. cordiform is (Makino) Rehder ( Juglandaceae )

19. Hickory nut, Carya spp. ( Juglandaceae )

20. Japanese horse

- chestnut, Aesculus turbinata Blume (Sapindaceae)

21. Macadamia nut, Macadamia integrifolia Maiden & Betche ( Proteaceae )

22. Monkey

- po t, Lecythis pisonis Cambess. ( Lecythidaceae )

23. Okari nut, Terminalia kaernbachii Warb. ( Combretaceae )

24. Pachira nut, Pachira insignis (Sw.) Savigny ( Malvaceae )

25. Pecan, Carya illinoinensis (Wangenh.) K.Koch ( Juglandaceae )

26. Pequi, Caryocar spp. ( Caryocaraceae )

27. Pil i nut, Canarium ovatum Engl. ( Bursraceae )

28. Pine nut, Pinus edulis Engelm. ( Pinaceae )

29. Pistachio, Pistacia vera L. ( Anacardiaceae )

30. Sapucaia nut, Lecythis zabucaja Aubl. ( Lecythidaceae )

31. Tropical almond, Terminalia catappa L. ( Combretaceae)

32. Walnut, black, Jugla n s spp. ( Juglandaceae ) and Walnut, English, Juglans regia L. ( Juglandaceae )

And all edible varieties and/or hybrid s of Fagus species, Castanea species, Corylus species, Carya species, Caryocar species, and Ju glans species.”

IR

- 4 Proposal 2 : Representa tive Commodities:

IR

- 4 recommends that the following commodities,

Almond and pecan remain as representative commodities for the expanded group.

IR

- 4 Proposal 3 . Crop Subgroups:

No crop subgroups are proposed for the Tree Nuts crop group.

IR

- 4 Pr oposal 4 . Crop Definitions:

No commodity definitions for the Tree Nuts are proposed or were recommended

at this time.6

HED RECOMMENDATIONS:

Each of the proposals and recommendations will be discussed below, followed by a

series of other recommend ations on terminology, database development, and harmonization with Codex. The EPA would like to commend the valuable and high quality input of the ICGCC, all its members, and the Committee Chairperson Bill Barney,

USDA IR

- 4, as well as Dr. Yuen

- Shaung Ng , Biologist, HED, Doug Dotson, Chemist, Susan Stanton, Roger Chesser, Andy Ertman, and Laura Nollen, Biologists, RD, EPA for their input and development of various databases in this report and Dr. Paul Schwartz, USDA, Office of Minor Use Pesticides for his advice and peer review of the analysis.

IR

- 4 Proposal 1:

1. “Amend the existing crop group that consists of twelve commodity entries 40 CFR 180.41 (c) (14) ”

To an expanded crop group that consists of following thirty

- eight commodity entries :

Tree Nut Commodities

African nut tree Hazelnut (Filbert)

Almond Heartnut

Beechnut Hickory Nut

Betelnut Japanese horse

- chestnut

Brazil nut Macadamia nut Brazilian pine Monkey

- pot Bunya Mongongo nut

Bur oak Okari nut

Butternut Pachira nut Cajou nut Peach pa lm nut

Candlenut Pecan

Cashew Pequi

Castanha

- do

- maranhao Pili nut

Chestnut Pine nut Chinquapin Pistachio

Coconut Sapucaia nuts

Dika nut Tropical almond Ginkgo Walnut, black

Guiana chestnut Walnut, English

And all edible varieties and/or hybrid s o f Fagus species, Castanea species, Corylu s species, Carya species, Caryocar species, and Juglans species.”7

HED Recommendations for Proposal 1:

Based on similarities of the comparison of tree nuts cultural practices, edible food

and animal feed it ems , residue levels, geographical locations, processing, established tolerances, and for international harmonization purposes, I recommend that ChemSAC concur to amend the Tree Nut Crop Group 14 from twelve commodities to thirty

– nine

commodities (See Tab le 1)

. T here are 18 different plant families represented in this proposed tree nut crop group. Since the tree nut crop group is a somewhat artificial crop group and because the various crops within the group come from diverse families, and they are all n ot expected to be susceptible to the same pests and diseases requiring the same pesticide treatment, but their harvesting, processing (hulling, drying), marketing,

uses, and nutritional value are very similar. Also, in practice, residues (expressed on the edible portion) in tree nuts from field use are often low or not detectable irrespective of the pesticide use, so a tree nut group tolerance can be achieved, and most are grown in similar orchard or plantations and maintained with similar cultural practice s. The members of this crop group have similar uses, and all are consumed after maturity or consumed cooked or roasted in various recipes including salads, meats, and cookies. Some of these tree nuts also have medicinal properties. Many of the tree nut s from the same botanical family with similar biological and cultural aspects suggests they should also encounter similar pest problems and hence have similar needs for pest control products in similar use patterns. All of these commodities except for bet elnut were found

to have similar characteristics and uses to become a member of the Tree nut group.

While USDA IR

- 4 also recommended adding betelnut to the Tree nut group, however, after analysis of this crop, I recommend ChemSAC concur not to add this commodity to this crop group. Betelnut is used mostly as a stimulant crop and is chewed during the day, so it does not share the traditional uses of the tree nut crops. Also, I

recommend deleting Castanha

- do

- maranhao (Pachira glabra Pasq), because it is limited to Brazil, endangered, and appears at this timing to have limited chance of further expansion.

There were no crop subgroups proposed by IR

- 4 for this crop group. HED is also recommending adding three other commodities that meet the tree nut cri teria to the group. The three commodities are: coquito nut, monkey puzzle nut, and yellowhorn. These three nuts are available to grow in the U.S. and coquito nut is already available in the marketplace and in commercial nursery catalogs

. Therefore, the recommended Tree nut crop group 14

- 10 or 14

- 11 commodities are listed in Table 1 below and include their appropriate scientific names. Table 2 contains a comparison between the current Tree Nut Crop Group and the recommended changes to the proposed Tree Nut Crop Group 14

- 10 or 14

- 11.

“HED Recommended Tree Nut Crop Group 14

– 10 or 14

- 11 ”.

Commodities
African nut tree, Ricinodendron heudelotii (Baill.) Heckel
Almond, Prunus dulcis (Mill.) D.A. Webb
Beechnut, Fagus grandifolia Ehrh., F. sylvatica L., F. sylvatica L. subsp. s ylvatica8

Commodities
Brazil nut, Bertholletia excelsa Humb. & Bonpl. Brazilian pine, Araucaria angustifolia (Bertol.) Kuntze Bunya, Araucaria bidwillii Hook.

Bur Oak , Quercus macrocarpa Michx.
Butternut, Juglans cinerea L. Cajou nut

, Anac ardium giganteum Hance ex Engl.
Candlenut, Aleurites moluccanus (L.) Willd.
Cashew, Anacardium occidentale L. Chestnut, Castanea crenata Siebold & Zucc., C. dentata (Marshall) Borkh., C. mollissima Blume, C. sativa Mill. Chinquapin, Castanea pumila (L. ) Mill., Castanea ozarkensis Ashe
Coconut, Cocos nucifera L

. Coquito nut, Jubaea chilensis (Molina) Baill.
Dika nut, Irvingia gabonensis (Aubry

- Lecomte ex O’Rorke) Baill. Ginkgo, Ginkgo biloba L. Guiana chestnut, Pachira aquatica Aubl. Hazelnut (Filb ert), Corylus americana Marshall, C. avellana L., C. californica (A. DC.)
Rose, C. chinensis Franch.
Heartnut, Juglans ailantifolia C arrière var

. cordiformis (Makino) Rehder, Juglans ailantifolia Carrière Hickory nut, Carya cathayensis Sarg., C. glabra ( Mill.) Sweet, C. laciniosa (F. Michx.) W. P. C. Barton, C. myristiciformis (F. Michx.) Elliott, . C. ovata (Mill.) K. Koch, C. tomentosa (Lam.) Nutt. Japanese horse

- chestnut, Aesculus turbinata Blume
Macadamia nut, Macadamia integrifolia Maiden & Betche, Macadamia tetraphylla L.A.S.

Johnson Mongongo nut, Schinziophyton rautanenii (Schinz) Radcl.

- Sm. Monkey

- pot, Lecythis pisonis Cambess. Monkey puzzle nut, Araucaria araucana (Molina) K. Koch
Okari nut, Terminalia kaernbachii Warb.
Pachira nut, Pachira insignis (Sw.) Savigny Peach palm nut, Bactris gasipaes Kunth var. gasipaes
Pecan, Carya illinoinensis (Wangenh.) K.Koch Pequi, Caryocar brasiliense Cambess., C. villosum (Aubl.) Pers, Caryocar nuciferum L. Pili nut, Canarium ovatum Engl., Canarium vul gare Leenh. Canarium indicum L.
Pine nut, Pinus edulis Engelm., P. koraiensis Siebold & Zucc., P. sibirica Du Tour, P. pumila (Pall.) Regel, P

. gerardiana Wall. ex D. Don, P. monophylla Torr. & Frém., P. quadrifolia Parl. ex Sudw. P. pinea L.
Pistachio, Pistacia vera L. Sapucaia nut, Lecythis zabucaja Aubl. Tropical almond, Terminalia catappa L.
Walnut, black, Juglans hindsii Jeps. ex R. E. Sm.

, J. mi crocarpa Berland., J. nigra L. Walnut, English, Juglans regia L. Yellowhorn, Xanthoceras sorbifolium Bunge
Cultivars, varieties, and

/or hybrids of these commodities

HED Additional Recommendation for Proposal 1:9

 HED also recommends that in the crop group table the term “ all edible varieties and/or hybrid s of Fagus species, Castanea species, Corylus species, Carya species, Caryocar species, and Juglans species varieties and/or hybrids of these” should be changed to, “Cultivars, varieties, and hybrids, of these

commodities” will avoid all confusion with terminology regarding whether they are cultivars, varieties, or hybrids of the any tree nut commodities. This is also consistent with the other revised crop groups completed to date.

 HED also recommends changing the preferred commodity name for filbert to hazelnut, since hazelnut is the commodity term used in international trade and the U.S. Hazelnut Growers Marketing Board since 1981 has changed their name from filbert to hazelnut even though filbert is the correct name for the tree and nut. The name is of French origin and the tree was likely first i ntroduced into Oregon by early French settlers. Hazelnut is the name coined by the English and it was applied to the native species by early settlers. The EPA Food and Feed Commodity Vocabulary ( http://www.epa.gov/pesticides/foodfeed ) for

filbert will be changed to hazelnut as the preferred commodity term in the next vocabulary update.

T able 2

. EPA Crop Group Proposals Comparison of the Current Established EPA

Tree Nut Crop Group 1 4 with the Propos al Recommendations to ChemSAC to the

Amend ed 20 10 Tree N ut Crop Group 1 4

- 11

. Regulation Current Tree Nut Crop

Group 14 (May 17, 1995). 2010 Proposed Tree Nut Crop Group 14

- 10 for ChemSAC Approval

Name of the Crop Group Tree Nut Group 1 4 Tree Nut Group 14

- 11 hopefully.

Representative Crops Two:

Almond and

Pec an Two:

Almond and

Pecan same commodities Subgroup(s) None None

Commodities

included 12 ( Almond, Beechnut,

Brazil nut, Butternut, Cashew, Chestnut, Chinquapin, Filbert (Hazelnut), Hickory nut , Macadamia nut, Pecan, Walnut, black and English) 39 ( African tree nut, Almond, Beechnut, Brazil nut, Brazilian pine, Bunya, Bur oak

, Butternut, Cajou nut , Candlenut, Cashew, Chestnut, Chinquapin, Coconut, Coquito nut, Dika nut, Ginkgo, Guiana chestnut, Hazelnut (Filbert), Heartnut, Hickory nut, Japanese

horse

- chest nut, Macadamia nut, Mongongo nut, Monkey pot, Monkey puzzle nut, Okari nut, Pachira nut, Peach palm nut, Pecan, Pequi, Pili nut, Pine nut, Pistachio, Sapucaia nut, Tropical almond, Walnut, black, Walnut, English, and Yellowhorn, cultivars, varieties,

and /o r hybrid s of these)

. Commodity

Definitions 180.1(g). None were proposed. None10

IR

- 4 Proposal 2:

“The following commodities, Almond and Pecan, should remain as representative commodities for the expanded group.

HED Recommendation for Proposal 2:

I re commend ChemSAC concur to retain almond and pecan , as representative commodities for the amended Tree Nut Crop Group 14. These representative

commodities account for > 74 % of the harvested acres for the members of the amended Tree Nut Group, and are the two most widely grown tree nuts in the U.S. with the largest acreages and geographical distribution . The representative commodities are based on similarities in fruit (nut) and cultural practices and geographical locations, as well as their high productio n (both acres and yield) and consumption. A comparison of established tolerances on tree nut commodities also supports that residue levels will be similar between members of the crop group.

IR

- 4 Proposal 3: “No subgroups are proposed for the Tree Nuts crop group.”

HED Recommendation for Proposal 3 :

I agree that the Tree nut crop group will not benefit from establishing any crop subgroup.

IR

- 4 Proposal 4: “No Tree Nut crop definitions are proposed.”

HED Recommendation for Proposal 4 Commodity D efinition for Tree Nuts:

I agree that commodity definitions are not needed for the tree nuts.

Additional HED Recommendations/Conclusions:

HED Recommendation 5:

Another important aspect of crop grouping is the harmonization effort with the

Codex Cla ssification of Foods and Animal Feeds. The current EPA crop group for Tree nut group 14 is very similar to the corresponding Codex Group 022, Tree Nuts , which

consists of nineteen commodities including matches to the all the twenty

- four

commodities in the proposed amended EPA crop group 14. The differences are because several of the Codex commodities refer to another commodity in a similar manner to the EPA Food and Feed Commodity Vocabulary Lookup to Preferred Tolerance Terms, such as “Pignolia”, see Pin e nuts. Several Codex names are equivalent to lookup terms in the11

EPA Food and Feed Commodity Vocabulary like filberts is hazelnuts. The thirty commodities listed by Codex are really nineteen individual commodities. The U.S. is proposing to add the foll owing commodities: African tree nut, betelnut, Brazilian pine, bunya, bur oak, cajou, candlenut, castanha

– do

- maranhao, chinquapin, dika nut, ginkgo, Guiana chestnut, heartnut, monkey pot, monkey puzzle nut, okari nut, pachira nut, and pequi, that are not y et in the Codex system.

Recently, Codex has been reviewing the list of commodities in a revised Tree nut group 022 (Secretariat, 2010) derived from the USDA IR

- 4 proposal

.

Note that the current Codex crop group does not have representative commoditie s. A revision of the Codex Classification is underway with consideration to include adding new commodities, creating subgroups, and selecting representative commodities. The expanded Tree nut group and the representative commodities proposed in this peti tion

would facilitate the harmonization of the U.S. and the Codex crop classification systems.

HED Recommendation 6:

The Health Effects Division Dry Matter database was updated by Dr’s. NG and Schneider to include newer tree and presented in the Anal ysis of the Tree Nut Crop Group Petition, Table 40 Part I Analysis.

HED Recommendation 7:

Guidance for HED SOP 99.6

- “Classification of Food Forms with Respect to Level of Blending” issued August 20, 1999, and HED SOP 2000.1

– “ Guidance for Translation of Field Trial Data from Representative Commodities in the Crop Group Regulation to Other Commodities in Each Crop Group/Subgroup” issued September 12, 2000 can be updated to reflect the amendment to the Tree nu t group 14.

HED Recommendation 8:

Guidance on expressing tolerance terminology for the Tree nut crop group 14 is discussed under the “Tolerance expression guidance section of this analysis.

HED Recommendation 9:

New lookup and preferred EPA terms for the members of the Tree Nut Crop Group are listed in the EPA Food and Feed Commodity Vocabulary section of this report and these terms will be to the updated EPA Food and Feed Commodity Vocabulary

website ( http://www.epa.gov/pesticides/foodfeed ) when it is updated

.