UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND POLLUTION 

PREVENTION

MEMORANDUM

DATE: January 2, 2013

SUBJECT: Crop Grouping – Follow-up to the Analysis of the USDA IR-4 Petition to Amend 

the Crop Group Regulation 40 CFR § 180.41 (c) (5) Crop Group 4 Leafy

Vegetables to Add Two Additional Commodities Dillweed and Dang-gwi. 

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

Chemistry and Exposure Branch 

Health Effects Division (7509P) 

THROUGH: Donna Davis and Donald Wilbur, Chairpersons

HED Chemistry Science Advisory Council (ChemSAC)

Health Effects Division (7509P) 

TO: ChemSAC Members

Jennifer Selwyn, Monica Le, and Susan Wong, PMRA

Barbara Madden, Minor Use Officer, Registration Division (7505P)

cc: IR-4 Project, Bill Barney, Jerry Baron, Dan Kunkel, Debbie Carpenter, Van Starner 

BACKGROUND: 

Since the HED ChemSAC/PMRA meeting which approved the revisions to amend the 

leafy vegetable crop group 4 on November 30, 2011 and was updated December 23, 2011, it has 

come to our attention that two more commodities need to be considered as members to the Leafy

vegetable group 4. The commodities are dang-gwi, a Korean leafy vegetable and dillweed, a 

current member of the herb and spice group which we will recommend be moved to the leafy

vegetable group. 
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HED RECOMMENDATIONS:

I recommend that ChemSAC agree to add dang-gwi and dillweed to the amended Leafy

vegetable crop group 4-13 and Leafy greens subgroup 4A based on similarities of cultural 

practices, pest problems and maturity and harvesting techniques to other members of the Leafy

vegetables crop group. Since these leafy vegetables are grown in close proximity to each other 

by being members of the crop group will avoid inadvertent residue problems. The discussion 

below will further describe why dang-gwi and dillweed will be added to the Leafy vegetable 

crop group.

DISCUSSION:

Each of the two commodities will be discussed separately. 

(1) Dang-gwi:

The Codex Electronic Crop Grouping Workgroup notified William P. Barney, Crop 

Grouping Project Coordinator, USDA Interregional Research Project No. 4 (IR-4), and leader of 

the International Crop Grouping Consulting Committee (ICGCC) that the Korean delegation had 

requested that dang-gwi, a leafy vegetable be added to the Leafy vegetable group. Dang-gwi 

(Angelica gigas Nakai family Apiaceae/alt. Umbelliferae) is a leafy vegetable native to eastern 

Asia including China, Japan, and Korea, reaching up to 6.6 ft (2 m) in height. It has thick, 

hollow, ribbed stems, purple in color and broad pinnate leaves (see Figure 1). The plant is also 

currently being grown in the U.S. as an ornamental, but it is locally grown and/or gathered from 

the wild as a leaf vegetable. It is valued for its young leaves and shoots, which are edible and 

used a tender vegetable. It is also valued for the root, which is used medicinally.

ChemSAC (minutes November 30, 2011) approved several leafy vegetables similar to 

dang-gwi which have similar cultural practices, share the same pest problems, and are members 

of the same plant family. They are used fresh in salads, pickled, or cooked by boiling or frying. All 

of these also have medicinal uses including cham-chwi, cham-na-mul, and dol-nam-mul. If 

approved dang-gwi will also be a member of the amended Leafy vegetable crop group and the 

leafy greens subgroup 4A along with cham-chwi, cham-na-mul, and dol-nam-mul. The crop group 

already includes parsley and cilantro leaves. Residues based on leaf morphology and cultural practices 

for dang-gwi should be similar to leaf lettuce (Figure 2) the representative commodity for the leafy greens 

subgroup 4A-13.

Figure 1. Picture of Dang-gwi.
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Figure 2. Picture of Leaf Lettuce.

(2) Dillweed:

Barbara Madden, Minor Use Officer, RD contacted me about a conversation she had with a 

grower during the September 2012 IR-4 Food Use Workshop. According to Barbara Madden: 

“I made a presentation and as part of the presentation I discussed crop groups and shared with 

them the plans to move the Brassica leafy vegetables in with the other leafy vegetables and to 

create a new stalk and stem group. I also mentioned during the presentation that cilantro leaves 

was going to be included in the revised leafy vegetable group. I encouraged people to look at 

these proposals and to provide us with comments during the process while these changes are 

being proposed. Afterwards Bruce Buurma of Buurma Farms bruce@buurmafarms.com, who is 

also a member of the IR-4 Commodity Liaison Committee, came up to me and asked if dillweed

would also be moved into the leafy vegetables group. I checked the ChemSAC write-up and saw

no mention of dill leaves. According to Mr. Buurma cilantro and dill are grown together and if 

cilantro is going to be moved into the revised leafy vegetable group he recommended that dill be 

moved as well. 

After receiving Barbara’s email I contacted Mr. Buurma and requested additional 

information on grower practices for dillweed and fresh herbs. He stated: dillweed (Figure 3) and 

cilantro (Figure 4) are planted twice a week starting on April 1st and ending on September 17th.
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We plant the cilantro first and then change seed and continue to plant with the dill seed so they

are literally inches apart. We plant both herbs on a 10 inch raised bed with 2 rows 10 inches

apart on top of the 20 inch bed, and there are 36 inches between beds. Both dillweed and 

cilantro are harvested when they are approximately 12 - 15 inches tall, which is right before they

go to seed. Both crops mature in 45 days depending on the time of year but they both grow 

about the same. Disease and insect pests for both crops are almost identical. In summary, 

dillweed and cilantro are planted at the same time from the beginning to the end of the season, 

they are planted by the same equipment in the same field, both are seeded at 16 - 17 lbs. of seed 

per acre, the days to harvest are the same, the harvest size and the packaging are basically the 

same, and they share the same insect and disease problems.

As with cilantro leaves and parsley, we find dillweed is grown in very close proximity

with other leafy vegetable crops and to avoid inadvertent residues it makes sense to move 

dillweed to the amended leafy vegetable group, and leafy greens subgroup 4A-13 in which leaf 

lettuce is the representative commodity. Dill seed will remain in the Herb and spice crop group 

19, because it has different cultural practices and harvesting techniques.

Figure 3. Dillweed.

Figure 4. Cilantro.