**UNITED STA TES ENVIRONMENTA**  **L PROTECTION A GENCY**  **WA SHINGTON, D.C. 20460**  **OFFICE OF CHEMICA L SA**  **FETY AND POLLUTION**  **PREVENTION**

**MEMORANDUM DATE**  : January

2, 2013 **SUBJECT:** Crop Grouping

– Follow - up t o the Anal ys is 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 Phy siologist

Chemis try

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 Selwy

n, Monica L e, and Su san 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 le afy vegetable and dillweed , a current member of the herb and spice group which we will recommend be moved to the leafy vegetable group.2

**HED RECOMMENDATIONS** : I recommend that ChemSAC agree to add dang - gwi and dillweed to the amended Leafy vegetable cr op 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 wh y dang - gwi and dillweed will be added to the Leafy vegetable crop group. **DISCUSSION** : Each of the two commodities will b e discussed separatel y. **(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 (I CGCC) that the Korean delegation had requested that dang - gwi, a leafy vegetable be added to the L eafy 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 currentl y being grown in the U.S. as an ornamental, but it is locally grown and/or g athered from the wild as a leaf vegetable. Itis 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 i ncluding cham - chwi, c ham - na - mul, and dol - nam - mul . If approved d ang - gwi will also be a member of the amended Leafy vegetable crop group and the leafy greens subgroup 4A along with cham - chwi, c ham - 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.**3

**Figure 2. Picture of Leaf Lettuce** .

**(2) Dillweed**  : Barbara Madden, Mino r Use Officer, RD contacted me about a co nversation 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 Idisc ussed 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 th e 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 L iaison Committee, came up to me and asked if dill weed would also be moved into the leafy vegetables group. I checked the ChemSAC write - up and s aw 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 Icontacted Mr. Buurma and requested additional inform ation on grower practices for dillweed and fresh herbs. He stated: d ill weed (Figure 3) and c ilantro (Figure 4) are planted twice a week starting on April 1st and ending on September 17th.4

We plant the cilantro first and then change seed and continue to p lant 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 dill weed and cilantro are harvested when they are ap proximately

12 - 15 inches tall, which is right before they go to seed. Both crops mature in 45 day s depending on the time of year but they both grow about the same. Disease and insect pests for both crops are almost identical. Insummary , dillweed and c ilantro 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 day s to harvest are the same, the harvest size and the packag ing are basicall y 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 harvesti ng techniques. **Figure 3. Dillweed.** 

**Figure 4. Cilantro**  .