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Subject: Chemistry Science Advisory Council (ChemSAC) Meeting Minutes

Meeting Date: 12/14/2011

To: HED’s Chemistry Interest Group

From: HED’s ChemSAC

Attendees: See Attached

PART I. Review of the Analysis of the U.S. Department of Agriculture (USDA)

Interregional Research Project No. 4 (IR-4) Crop Grouping to Amend the Crop 

Group Regulation and Commodity Definitions Related to the Crop Group 4 Leafy 

Vegetables and Crop Group 5 Brassica Leafy Vegetables (PMRA and IR-4 joined by

conference call). 

There were four proposals associated with this petition.

PART IA. IR-4 Proposal 1. “Amend the existing leafy vegetable crop group in 40 CFR 

180.41 (c) (4) that consists of two subgroups and 27 commodity entries to an expanded 

crop group that consists of a total 78 commodity entries.”

Dr. Schneider stated that “based on similarities of the comparison of the proposed leafy

vegetable commodities plant morphology, cultural practices including all are row crops, 

similar pest problems, edible food portions and lack of livestock feed portions, similar 

exposure to residues, geographical locations, processing, established tolerances, and for 

international harmonization purposes, I recommend that ChemSAC concur to amend the 

current leafy vegetable crop group 4 to a leafy vegetable crop group 4-12.” In addition 

the current leaf petiole subgroup 4B should be removed to form a new stalk, stem, and 

leaf petiole crop group 22. In addition, the current Brassica leafy greens subgroup 5B 

should be moved to crop group 4 as a new subgroup since its commodities are more 

similar to the leafy vegetables in crop group 4 than the head and stem vegetable subgroup 

in crop group 5. Inclusion of Brassica leafy vegetables in a separate subgroup is

desirable because of potentially different actions of herbicides on leafy Brassicas verses 

other leafy (non-Brassica) crops. Also, for harmonization purposes with Codex, the 

leaves of root and tuber vegetables, human food crop group 2 commodities may also be 

added to the amended crop group 4 as a subgroup; but it depends upon further discussion 

of the individual IR-4 proposals (see PART IB and IC) to the amended crop group 4. 

Both ChemSAC and PMRA agreed with the analysis to changes proposed for both crop 

group 4 and 5 in moving the current leaf petiole subgroup 4B to a new stalk, stem, and 

leaf petiole crop group 22 and to move the Brassica leafy greens subgroup 5B from crop 

group 5 to an amended crop group 4.
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However, ChemSAC and PMRA did not agree to move all the leaves of root and tuber 

vegetables, human food crop group 2 commodities to the amended crop group 4 without 

further discussion (See PART IB and IC).

Also, Dr. Schneider recommended deleting twenty proposed commodities due to lack of 

cultivation or being a noxious weed. ChemSAC suggested that for international 

harmonization purposes and for continued development ethnic crops to revisit these 

commodities. These commodities were revisited and thirteen were added back to the 

amended group based on that they are grown in Asia, Europe, or Africa, and may have 

potential to be grown in North America based on future consumer demands or imports

(see Table 1). 

Table 1. Proposed Crop Group 4 Commodities and whether they are 

Recommended to be Accepted (A) or Rejected (J) in This Analysis. (Originally 

these were the list of rejected commodities, except for garland chrysanthemum). 

Proposed Crop Group 4 

Commodities 

Recommend Accepted (A) or Rejected (J) Commodities to 

Crop Group 4 and, if Rejected, Why

Aster, Indian A – Locally grown mainly in Africa.

Blackjack A – Some cultivation in Africa, and mainly gathered from the 

wild in Africa.

Cat’s Whiskers A – Some cultivation of leaves in Africa and SE Asia.

Cham-chwi A– Korea and China mostly gathered from wild and it is

cultivated in Asia.

Cham-na-mul A – Mostly gathered from wild in Korea, China, and Russia.

Chayote, leaves J – Leaves of cucurbits were not accepted due to being 

morphologically dissimilar to other leafy crops.

Chrysanthemum, corn J – The significant edible leafy chrysanthemum is garland 

chrysanthemum.

Chrysanthemum, edible-leaved J – According to USDA GRIN Taxonomy this crop is another 

name for garland chrysanthemum.

Chrysanthemum, garland A – Correct commodity name.

Chrysanthemum, tricolor J – Major use is as an ornamental and is covered under garland 

chrysanthemum. 

Cosmos A – Mostly grown in Malaysia and it is rare in the U.S. and is not 

in marketplaces yet.

Dol-nam-mul A – mostly grown in Korea, and it has ornamental uses and can 

be a weed in the U.S.

Feather cockscomb A – Valuable in Africa and China other areas it is an ornamental. 

Fern, Edible (Fiddlehead) J – Growth characteristics different from the members of the 

Leafy vegetable crop groups 4 and 5. It should be consider as a 

Stalk, stem and leaf petiole vegetable.

Iceplant J – Cultivated in some areas but invasive weed in others, also 

used to stabilize soils.

Lettuce, bitter A – Gathered mostly from the wild, invasive but important in 

Africa.

Plantain, common change to Buckhorn 

plantain

A – Mostly found in the U.S. as a weed, not cultivated in the U.S. 

but it is found available in some gourmet restaurants and for 

Italian cooking. Also called Minutina Plantago coronopus L.

Primrose, English A – Mostly used now as an ornamental in North America, but it is 

marketed in Europe.

Shepherd’s purse A – Gathered from the wild weed most of world, but grown in 

China and Korea.
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Proposed Crop Group 4 

Commodities 

Recommend Accepted (A) or Rejected (J) Commodities to 

Crop Group 4 and, if Rejected, Why

Sowthistle J – Major temperate invasive weed grown in some places often 

gathered from the wild.

Velvet plant, leaves A – Locally grown mostly in Asia.

Violet, Chinese A – Mostly gathered from the wild in Asia and Africa, and it also 

has herbal uses.

Another crop considered, but not included was lambsquarter (Chenopodium album L.), 

which although consumed in certain parts of the world (Africa, India, Japan, and China), 

is considered a noxious weed in many other parts of the world. However, tree spinach or 

giant lambsquarter (Chenopodium giganteum D. Don) is grown as a leafy vegetable in 

Russia and the UK and will be added to the amended crop group 4.

PART IB. IR-4 Proposal 2: “The proposed representative commodities for the leafy 

vegetable crop group 4 – 12 are head lettuce, leaf lettuce, spinach, mustard greens or 

kale, and beet, garden, leaves and sweet potato, leaves.”

Dr. Schneider recommended ChemSAC approve head lettuce, leaf lettuce, spinach,

mustard greens or kale, and beet, garden, leaves as representative commodities for the 

leafy vegetable crop group. These representative commodities represent over 93 % of the 

total leafy vegetable harvested acres reported in the USDA Ag Census, and are also the 

highest consumed commodities on a per capita basis in the group. Head lettuce accounts 

for 43% of the acres and leaf lettuce 37% (includes Romaine lettuce), spinach (rep for 

subgroup 4A) accounts for 11 %, and mustard greens or kale for 3%. These commodities 

have a long regulatory history as being representative commodities for crop groups 4 and 

5. It is expected that all proposed members of the amended leafy vegetable crop will 

have similar residue levels based on similarities of the raw agricultural commodities 

(RAC’s), cultural practices, and pest problems. Sweet potato leaves were not 

recommended to be an alternative representative commodity with beet, garden, tops or 

leaves due to the production being too low compared to garden beet leaves. Garden beet 

tops can adequately represent the members of the proposed leaves of root and tuber 

subgroup 4C.

ChemSAC and PMRA agreed with the recommendations that head lettuce, leaf lettuce, 

spinach, and mustard greens would be adequate representative commodities for the 

amended leafy vegetable crop group 4-12. However, Canada did not recommend kale be 

an alternative representative commodity with mustard greens since it has much less 

production than mustard greens, and ChemSAC concurred. In addition both ChemSAC 

and PMRA did not recommended beet, garden, leaves as a representative commodity

because they feel it should remain in crop group 2. Further crop subgroup 

recommendations will be discussed in PART IC IR-4 Proposal 3 below.

PART IC IR-4 Proposal 3: “Propose establishing three crop subgroups 4A – leafy

greens subgroup with forty-one commodities with head lettuce and leaf lettuce and 
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spinach being representative commodities, 4B – Brassica leafy greens subgroup with 

twenty-two commodities with mustard greens or kale being representative commodities, 

and 4C – leaves of root and tuber vegetable, human food subgroup with thirteen 

commodities with garden beet leaves and sweet potato leaves being the representative 

commodities.”

Dr. Schneider recommended that ChemSAC approve the three proposed crop subgroups 

because of similarities between cultural practices, potential residue exposure due to leaf 

area, dietary consumption importance, and lack of livestock feed items as well as 

similarities to the current leafy vegetable crop group. The three crop subgroups are 

similar to the current established crop groups 4, 5, and 2. The proposed leafy greens 

subgroup 4A – 12 is the same subgroup 4A in the current crop group 4 with the same 

representative commodities. Based on these criteria, three representative commodities 

are proposed (head lettuce, leaf lettuce and spinach) for subgroup 4A; one representative 

commodity (mustard greens or kale) is proposed for subgroup 4B and one representative 

commodities (garden beet, tops) are proposed for subgroup 4C. Beet, garden, tops 

(leaves) can adequately represent the members of the proposed leaves of root and tuber, 

human food subgroup 4C. The crop subgroup for leaves of root and tuber, human food 

subgroup 4C was recommended by IR-4 to harmonize with the Codex leafy vegetable 

group.

ChemSAC and PMRA agreed with the recommendations to establish a leafy greens 

subgroup 4A and a Brassica leafy greens subgroup 4B. Canada did not recommend kale 

be an alternative representative commodity with mustard greens in the Brassica leafy

greens subgroup and ChemSAC concurred. 

Both ChemSAC and PMRA did not agree to approve a crop subgroup 4C “leaves of root 

and tuber, human food” which would have harmonized with Codex. Based on a long 

history of the Root and tuber vegetable crop group having a separate leaves of root and 

tuber vegetable, human food or livestock feed crop group 2, ChemSAC felt that it was 

better to remain in crop group 2. They did state that when IR-4 pursues amending crop 

group 2 that separate crop subgroups for human food and one for livestock feed would be 

beneficial.

Regarding the Brassica leafy greens subgroups, ChemSAC wanted more information on 

turnip greens and radish leaves. The questions were: 1) are these crops grown as distinct 

varieties for their leaves; and 2) are label restrictions on these two crops adequate.

As a follow-up to these questions, Dr. Schneider has submitted a separate document to 

ChemSAC entitled: “Additional Information Requested by ChemSAC on Turnip Greens 

and Radish Leaves Varieties Grown Only for Their Edible Leaves and Current Pesticide 

Labels Describing Their Use and Restrictions, December 30, 2011” which addresses 

these two questions. It was found that rutabaga greens, even though a Brassica spp.,

should remain in the leaves of root and tuber vegetable group since there are no distinct 

varieties of rutabagas grown just for their edible leaves. 
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Therefore, in summary, ChemSAC approved head lettuce, leaf lettuce, spinach, and 

mustard greens as representative commodities for the leafy vegetable crop group, and 

crop subgroup 4A - 12 leafy greens will have head lettuce, leaf lettuce, and spinach as the 

representative commodities which are the same as the current leafy vegetable crop 

subgroup 4A (leafy greens subgroup). The current crop subgroup 5B leafy Brassica

greens will be transferred to crop subgroup 4B and have mustard greens as its 

representative commodity. Crop subgroup 4C was not approved and the “leaves of root 

and tuber, human food” subgroup should be returned to crop group 2 as a possible 

subgroup 2B, and the rest of crop group 2 will become the “leaves of root and tuber 

vegetable, livestock feed subgroup 2A” and will include the leaves of various root and 

tuber commodities used as livestock feed such as fodder beets (mangel beets), fodder 

turnips, and the forage Brassica ‘tyfon’. The USDA IR-4 will address amending crop

groups 1 and 2 in a future petition and will utilize these comments.

The recommended leafy vegetable crop group commodities and the two crop subgroups 

with their representative commodities and list of acceptable commodities in each crop 

subgroup is in Table 2 below:. 

TABLE 2. LIST OF CHEMSAC/PMRA APPROVED LEAFY VEGETABLE CROP 

GROUP/SUBGROUP, REPRESENTATIVE COMMDODITIES AND INDIVIDUAL 

COMMODITIES FOR EACH CROP SUBGROUP.

Crop Group / 

Subgroup

Recommended 

Representative 

Commodities

Recommended Commodities

Leafy Vegetable 

Crop Group 4 - 12

Head lettuce, leaf 

lettuce, spinach, and 

mustard greens

(60 commodities) - Amaranth, Chinese; Amaranth, leafy; 

Arugula; Aster, Indian; Blackjack; Broccoli raab; 

Broccoli, Chinese; Cabbage, Abyssinian; Cabbage, 

seakale; Cat’s whiskers; Cham-chwi; ,Cham-na-mul;

Chervil, fresh leaves; Chinese cabbage, bok choy; 

Chipilin; Chrysanthemum, garland; Cilantro, fresh leaves; 

Collards; Corn salad; Cosmos; Cress, garden; Cress, 

upland; Dandelion; Dock; Dol-nam-mul; Ebolo; Endive; 

Escarole; Fameflower; Feather cockscomb ; Good King 

Henry; Hanover salad; Huauzontle; Jute leaves; Kale; 

Lettuce, bitter; Lettuce, head; Lettuce, leaf; Maca; 

Mizuna; Mustard greens; Orach; Parsley, fresh leaves; 

Plantain, buckhorn; Primrose, English; Purslane, garden; 

Purslane, winter; Radicchio; Radish, leaves; Rape greens; 

Rocket, wild; Shepherd’s purse ; Spinach; Spinach, 

Malabar; Spinach, New Zealand; Spinach, tree; Swiss 

chard; Turnip greens; Violet, Chinese ; Watercress; 

Cultivars, varieties, and hybrids of these commodities

Crop Subgroup 4A. 

Leafy greens

Head lettuce and Leaf 

lettuce and Spinach

(40 commodities) - Amaranth, Chinese; Amaranth, leafy; 

Aster, Indian; Blackjack; Cat’s whiskers; Chervil, fresh 

leaves; Cham-chwi; ,Cham-na-mul; Chipilin; 

Chrysanthemum, garland; Cilantro, fresh leaves; Corn 

salad; Cosmos; Dandelion; Dock; Dol-nam-mul; Ebolo; 
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Crop Group / 

Subgroup

Recommended 

Representative 

Commodities

Recommended Commodities

Endive; Escarole; Fameflower; Feather cockscomb ; Good 

King Henry; Huauzontle; Jute leaves; Lettuce, bitter; 

Lettuce, head; Lettuce, leaf; Parsley, fresh leaves; 

Plantain, buckhorn; Primrose, English; Purslane, garden; 

Purslane, winter; Radicchio; Spinach; Spinach, Malabar; 

Spinach, New Zealand; Spinach, tree; Swiss chard; Tanier 

spinach; Violet, Chinese; Cultivars, varieties, and hybrids 

of these commodities

Crop Subgroup 4B. 

Brassica leafy 

greens

Mustard greens (20 commodities) - Arugula; Broccoli raab; Broccoli, 

Chinese; Cabbage, Abyssinian; Cabbage, seakale; 

Chinese cabbage, bok choy; Collards; Cress, garden; 

Cress, upland; Hanover salad; Kale; Maca; Mizuna; 

Mustard greens; Radish, leaves; Rape greens; Rocket, 

wild; Shepherd’s purse; Turnip greens; Watercress; 

Cultivars, varieties, and hybrids of these commodities.

PART ID. IR-4 Proposal 4:”Propose a new commodity definition for edible ferns 

because there are too many species to list as commodities as follows:”

Dr. Schneider recommended ChemSAC consider the edible ferns commodity definition 

when the stalk, stem, and leaf petiole crop group proposal is reviewed (see PART IIID, 

IR-4 Proposal 4). 

In addition, no new commodity definitions [(40 CFR § 180.1(g)] will be needed for this 

revised crop group. However, there are five commodity definitions for the leafy

vegetables and three for lettuce: lettuce; lettuce, head; lettuce, leaf; and one for endive, 

and one for turnip tops or turnip greens. When the leafy vegetable crop group regulation 

is published, there will be no need for the endive = escarole definition since they will 

both be listed as separate commodities in the crop group. In addition, there will no longer 

a need for the turnip tops or turnip greens definition since all the commodities it covers 

(broccoli raab and Hanover salad) are Brassicas and will all be proposed members of the 

leafy Brassica greens subgroup 4B. The three lettuce definitions are still useful in 

determining which lettuce varieties are considered head and/or leaf lettuce. 

Also in 2002, ChemSAC approved a commodity definition for parsley to include cilantro 

leaves; since some tolerances have been established by RD using this commodity

definition for parsley, fresh leaves to cover cilantro, fresh leaves, HED recommends that 

this commodity definition be added to the Federal Register. 

PART II. Review of the Analysis of the USDA IR-4 Crop Grouping Proposal to 

Amend the Current Crop Group 5 Brassica Leafy Vegetables, Removal of the Leafy 

Brassica greens subgroup, and Proposed New Brassica Head and Stem Crop Group.
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There were four proposals associated with this petition.

PART IIA. IR-4 Proposal 1: ”Amend the existing crop group in 40 CFR 180.41 (c) (5) 

that consists of the current head and stem Brassica subgroup with nine commodity entries

to a amended crop group called “Brassica head and stem crop group 5-12 with five major 

commodities.”

Dr. Schneider stated that based on similarities of the comparison of the proposed head

and stem Brassica vegetable commodities plant morphology, cultural practices including

they all are row crops, similar pest problems, edible food portions and lack of livestock

feed portions, similar exposure to residues, geographical locations, processing, 

established tolerances, and for international harmonization purposes, I recommend that 

ChemSAC concur to amend the current Brassica leafy vegetable crop group 5 to a new 

Brassica head and stem vegetable crop group 5-12. 

Dr. Schneider also agreed with IR-4 recommendations on removing Chinese broccoli to 

the revised Brassica leaf vegetable subgroup 4B (PART IA) because the leaf morphology

of Chinese broccoli is more of a leafy nature rather than forming a tight head similar to 

other members of the current head and stem subgroup. Residues in Chinese broccoli can 

be higher than the representative commodities of broccoli and cabbage (unpublished IR-4 

data). In addition, kohlrabi residues are often higher than broccoli or cabbage, and its 

exposure to residues with its exposed enlarged, bulb-like stem should be moved to the 

proposed stalk, stem and leafy petiole vegetable that are fully exposed to pesticides. Dr. 

Schneider also agreed not to keep Chinese mustard cabbage (gai choy) as a distinct crop 

in the revised group since it a common name that refers to various leafy non-heading 

Brassica greens. Therefore, Chinese mustard cabbage is not included in the proposed 

revision to the Brassica head and stem crop group 5. Also, Dr. Schneider agreed to 

remove ‘Cavalo broccoli’ from the proposed new Brassica head and stem crop group

since it is the same species as cauliflower. ‘Cavalo broccolo’ may have been a common 

name applied to various types of broccoli or cauliflower in the past. 

Both ChemSAC and PMRA agreed with the analysis to changes proposed for both crop

group 4 and 5 in moving the current leaf petiole subgroup 4B to a new stalk, stem, and 

leaf petiole crop group 22 and to move the Brassica leafy greens subgroup 5B from crop

group 5 to an amended crop group 4. The current crop group has 17 commodities, and by

removing the leafy Brassica greens subgroup 5B to add a new crop subgroup to the 

amended leafy vegetable crop group 4 (see separate leafy vegetable crop group analysis

PART IB Proposal 2). The new Brassica head and stem crop group will have five major 

economic crops and important for high dietary consumption. In addition, the new 

Brassica head and stem group will not have any crop subgroups.

PART IIB. IR-4 Proposal 2: ”The proposed representative commodities for the 

Brassica head and stem crop group 5-12 will be broccoli or cauliflower and cabbage as 

follows:”
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Crop Group Proposed 

Representative 

Commodities

Proposed Commodities

Brassica Head and 

Stem Vegetable

Crop Group 5

Broccoli or 

Cauliflower 

and Cabbage

Broccoli; Brussels sprouts; Cabbage, head; 

Cabbage, Chinese (napa); Cauliflower

Dr. Schneider recommended ChemSAC concur to retain broccoli or cauliflower and 

cabbage as representative commodities for the amended Brassica head and stem crop

group 5-12. These representative commodities account for > 99% of the harvested acres 

for the members of this amended crop group, and are the most widely grown Brassica

head and stem commodities in the U.S. with the largest acreages and geographical 

distribution. The representative commodities are based on similarities in its vegetable 

structures, exposure to residues, and cultural practices and geographical locations, as well 

as their high production (both acres and yield) and consumption. A comparison of 

established tolerances on the current head and stem Brassica crop subgroup 5A also 

supports that residue levels will be similar between members of the crop group. 

Essentially, there will be no change in the required representative commodities for this 

crop group compared to the current Brassica head and stem subgroup 5A. The 

commodity head cabbage should be just cabbage since there are no non-heading types of 

cabbage.

Corrected crop group, and proposed commodities:

Crop Group Recommended 

Representative 

Commodities

Recommended Commodities

Brassica Head and 

Stem Vegetable 

Crop Group 5

Broccoli or 

Cauliflower 

and Cabbage

Broccoli; Brussels sprouts; Cabbage; Cabbage, 

Chinese, napa; Cauliflower

Both ChemSAC and PMRA agreed with the recommendations that broccoli or 

cauliflower and cabbage would be adequate representative commodities for the amended 

Brassica head and stem crop group 5-12, since they are identical to the current 

representative commodities for the Brassica head and stem subgroup 5A. 

PART IIC. IR-4 Proposal 3: ”No crop subgroups or new commodity definitions are 

recommended for this proposed crop group.”

Dr. Schneider agreed that there is no need for any crop subgroups to the proposed 

Brassica head and stem vegetable crop group, since the current head and stem Brassica

subgroup 5A have the same commodities and representative commodities for the 

amended Brassica head and stem vegetable crop group 5-12. Both ChemSAC and 
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PMRA agreed with the recommendation. 

PART IID. IR-4 Proposal 4: “No new commodity definitions are recommended for 

this proposed crop group.”

Dr. Schneider agreed with that no new commodity definitions are needed for this crop 

group. However, there are currently two commodity definitions for Brassica head and 

stem vegetable commodities for broccoli and cabbage. They are broccoli equal to 

“Broccoli, Chinese broccoli (gia lon, white flowering broccoli)” and cabbage equal to 

“Cabbage, Chinese cabbage (tight headed varieties only).” 

When the Brassica head and stem group is published in the Federal Register there will be 

no need for the broccoli and the cabbage definitions. The Chinese broccoli will be 

included as a lookup term in the EPA Food and Feed commodity vocabulary and broccoli 

will be the preferred tolerance term. One correction to the current commodity definition 

is that “gia lon” spelling should be corrected to gai lon. Secondly, the cabbage 

definition is not needed since the Chinese cabbage tight-headed varieties, which are 

called napa, are included as a separate commodity in the crop group. The commodity is 

listed as Cabbage, Chinese, napa in the amended crop group. Cabbage is also a 

commodity in the proposed crop group. However, since there are several established 

broccoli and cabbage tolerances these commodity definitions should not be deleted at this 

time. Both ChemSAC and PMRA agreed that no new commodity definitions are needed 

for this crop group.

PART III. Review of the Analysis of the USDA IR-4 Crop Grouping Proposal to 

Establish a New Crop Group 22: Stalk, Stem, and Leaf Petiole Vegetable.

There were four proposals associated with this petition.

PART IIIA. IR-4 Proposal 1: “Add a new crop group to 40 CFR 180.41 (c) as “stalk, 

stem and leaf petiole vegetable Crop group” with the following 18 commodities: 

Proposed Commodities

Agave, Agave spp. 

Asparagus, Asparagus officinalis L

Bamboo, shoots, Arundinaria spp.; Bambusa spp.

Burdock, edible, tops, Arctium lappa L.

Cardoon, Cynara cardunculus L.

Celery, Apium graveolens var. dulce (Mill.) Pers.

Celery, Chinese, Apium graveolens L. var. secalinum (Alef.) Mansf.

Celtuce, Lactuca sativa var. angustana L.H. Bailey

Fennel, Florence, Foeniculum vulgare Mill. Subsp. vulgare var. azoricum

(Mill.) Thell. )
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Proposed Commodities

Fern, Edible (Fiddlehead)

Fuki, Petasites japonicus (Siebold & Zucc.) Maxim.

Kale, sea, Crambe maritima L.

Kohlrabi, Brassica oleracea L.var gongylodes L.

Palm hearts, various species including: Peach Palm, Bactris gasipaes

Kunth; Palmyra palm, Borassus flabellifera L., etc

Prickly pear, pads, Opuntia ficus-indica (L.) Mill.

Prickly pear, pads, Opuntia ficus-indica (L.) Mill.

Rhubarb, Rheum x hybridum Murray

Udo, Aralia cordata Thunb.

Zuiki, Colocasia gigantea (Blume) Hook. f. 

Previously ChemSAC (minutes, May 19, 2010) had agreed that combing stem and stalk 

vegetables into the leaf petioles subgroup 4B is a good idea, and ChemSAC agreed that 

the stalk, stem and petiole vegetables could be a separate crop group similar to the Codex

stalk and stem group. After review of the IR-4 petition, Dr. Schneider recommend that 

ChemSAC concur to approve a new stalk, stem, and leaf petiole vegetable crop group 22, 

based on similarities of the stalk, stem, and leaf petiole vegetables, similar cultural 

practices, edible food and livestock feed portions, similar plant exposure to pesticide 

residue levels, geographical locations, processing, food uses, established tolerances, and 

for international harmonization purposes. This group will have 17 commodities; all 

except burdock, edible, tops and combines 10 orphan crops including agave; bamboo 

shoots; Chinese celery; edible ferns; fuki; sea kale, palm hearts; cactus (prickly pear, 

pads); udo; and zuiki to this group. Dr. Schneider also agreed with USDA IR-4 that 

globe artichoke should not be a member of this new crop group stalk, stem and leaf

petiole vegetables. Globe artichoke was not included in this proposal because artichoke 

is not a stalk, stem, or leafy petiole, but is an immature flowerhead of the family

Compositae and is morphologically dissimilar to other stalk and stem vegetables and pest 

problems are dissimilar. Burdock is currently in crop group 2 (leaves of root and tuber 

vegetables (human food or animal feed). While burdock, edible is proposed by IR-4 for 

inclusion in the stalk, stem and leaf petiole crop group, although the root is the primary

part valued, the young stalks and leaves are also consumed and the peeled stem is also 

eaten. Upon further consideration, it was felt that Burdock, edible leaves should remain 

as a member of crop group 2, leaves of root and tuber vegetables and not become a 

member of the proposed stalk, stem, and leaf petiole crop group 22. 

In addition, Dr. Schneider recommended including edible ferns (fiddlehead) in the stalk, 

stem, and leaf petiole vegetable group because, although they are found for a limited time 

in grocery stores and included in some gourmet restaurants, they are so far rarely 

cultivated and are often gathered from the wild for personal consumption, and they are 

sold to markets and restaurants. They have a very limited season, typically early spring 

for a short time as the fronds first emerge, and some of the ferns can be toxic if not 

harvested at the correct growth stage. However, after consideration of current research to 

develop it as a crop, use in Europe, use in gourmet restaurants, and its potential as a 
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commercial specialty crop and for international harmonization it was recommended to 

include ferns as a commodity in this crop group

Changes to the EPA Food and Feed Commodity vocabulary includes bamboo, shoot will 

be bamboo shoots because this is how the crop is listed commercially. Palm hearts will 

also be listed as palm hearts with no comma since it is a marketing name. Edible ferns 

will have a new commodity definition to cover all the types of edible ferns. Prickly pear, 

pads will be changed to cactus to cover other edible cacti besides prickly pear. In 

addition, the name of the crop group should be stalk, stem, and leaf petiole vegetable 

group 22 instead of stalk, stem, and leafy petiole vegetable group. This will match the 

use of the term “leaf petiole” which was established as crop subgroup 4B which moved

these commodities from crop subgroup 4B to the proposed stalk, stem, and leaf petiole 

crop group 22. The RAC for Florence fennel should be fennel, Florence, fresh leaves and 

stalk to distinguish from the commodity fennel, Florence, seed in crop group 19 herbs 

and spices and crop subgroup spice 19B.

Both ChemSAC and PMRA agreed to establish a stalk, stem, and leaf petiole vegetable 

crop 22, as discussed above.

PART IIIB. IR-4 Proposal 2: ”The proposed representative commodities for the stalk, 

stem, and leaf petiole vegetable crop group 22 are asparagus and celery.”

Dr. Schneider recommended ChemSAC concur to have asparagus and celery, as 

representative commodities for the proposed new stalk, stem, and leaf petiole group 22. 

These proposed representative commodities account for >98% of the harvested acres and 

production for the proposed members of this group. They are the two most widely grown 

stalk, stem, and leaf petiole crops in the U.S. with both the largest acreages and 

geographical distribution. The representative commodities are based on similarities in 

vegetable morphology (stalk and stem and not leaves), and cultural practices and 

geographical locations, as well as their high production (both acres and yield) and 

consumption. Comparisons of established tolerances on stalk, stem, and leaf petiole 

commodities also supports that residue levels will be similar between members of the 

crop group. 

Both ChemSAC and PMRA agreed with the recommendation to have asparagus and 

celery as representative commodities to the stalk, stem, and leaf petiole group 22.

PART IIIC. IR-4 Proposal 3: “Propose establishing two crop subgroups 22A – stalk

and stem subgroup with eleven commodities and 22B – leaf petiole subgroup with seven 

commodities as follows with asparagus being the representative commodity for crop 

subgroup 22A and celery for crop subgroup 22B as follows:

Crop Subgroup 22A. Stalk and stem subgroup - Representative commodity - asparagus:
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Agave

Asparagus

Bamboo, shoots

Burdock, edible, tops

Celtuce

Fennel, Florence

Fern, edible

Kale, sea

Kohlrabi

Palm hearts

Prickly pear, pads

And 

Crop Subgroup 22B. Leaf petiole subgroup – Representative commodity - Celery:

Cardoon

Celery

Celery, Chinese

Fuki

Rhubarb

Udo

Zuiki

“

Dr. Schneider recommends that ChemSAC approve the two proposed crop subgroups: 

22A stalk and stem vegetable and 22B - leaf petiole vegetable. The petiole vegetable 

subgroup name of the crop subgroup 22B leafy petiole vegetable should be leaf petiole 

subgroup. This will match the use of the term leaf petiole which we have established as 

crop subgroup 4B which moves these commodities from crop subgroup 4B to the 

proposed stalk, stem, and leaf petiole crop group 22 (see table below). For terminology

purposes, the commodity name for prickly pear, pads should be changed to Cactus which 

would include the other edible cactus species. Burdock, edible, tops should not be 

included in the stalk and stem subgroup 22A as previously discussed in PART IIIA, IR-4 

Proposal 1.

The representative commodities for each of the subgroups represent over 99% of the 

production and are widely grown in the U.S. The stalk and stem subgroup 22A will have 

asparagus as the representative of vegetables that have edible stalks and stems including

celtuce and kohlrabi. The leaf petiole subgroup 22B will have celery as the 

representative commodity of the other leaf petiole crops such as Chinese celery, cardoon, 

and rhubarb. Comparison of tolerances for the individual members of each subgroup also 

supports that these two representative commodities will support the crop subgroups. 
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The recommended crop subgroups, representative commodities, and included 

commodities are shown in Table 3 below:

TABLE 3. LIST OF CHEMSAC/PMRA APPROVED STALK, STEM, AND LEAF 

PETIOLE VEGETABLE CROP GROUP/SUBGROUP, REPRESENTATIVE 

COMMDODITIES AND INDIVIDUAL COMMODITIES FOR EACH CROP 

SUBGROUP.

Crop Group 

Subgroup

Recommended 

Representative 

Commodities

Recommended Commodities

Stalk, Stem and 

Leaf Petiole 

Crop Group 22

Celery and 

Asparagus

(17 commodities) Agave; Asparagus; Bamboo 

shoots; Cactus; Cardoon; Celtuce; Celery; 

Celery, Chinese; Fennel, Florence, fresh leaves 

and stalk; Fern, edible; Fuki; Kale, sea; 

Kohlrabi; Palm hearts; Rhubarb; Udo; Zuiki

22A. Stalk and 

Stem Vegetable

Asparagus (10 commodities) Agave; Asparagus; Bamboo 

shoots; Cactus; Celtuce; Fennel, Florence, fresh 

leaves and stalk; Fern, edible, Kale, sea; 

Kohlrabi; Palm hearts

22B. Leaf Petiole 

Vegetable

Celery (7 commodities) Cardoon; Celery; Celery, 

Chinese; Fuki; Rhubarb; Udo; Zuiki

Both ChemSAC and PMRA agreed with the recommendation to establish the two 

subgroups, Subgroup 22A and Subgroup 22B.

PART IIID. IR-4 Proposal 4: “A New Commodity Definition for Edible ferns is 

recommended.” 

Dr. Schneider recommends that ChemSAC approve the edible fern commodity definition, 

so that the various types of edible ferns can be easily distinguishable and defined. The 

edible commodity fern definition is as follows:

“

(A) General Category (B) Specific Commodities

Fern, edible

Fern, edible; Fiddlehead including: Black lady fern, Deparia japonica 

(Thunb.) M. Kato; Bracken fern, Pteridium aquilinum (L.) Kuhn; Broad

buckler fern, Dryopteris dilatata (Hoffm.) A. Gray; Cinnamon fern, 

Osmundastrum cinnamomeum (L.) C. Presl; Lady fern, Athyrium filixfemina (L.) Roth ex Mert.; Leather fern, Acrostichum aureum L.; Mother 

fern, Diplazium proliferum (Lam.) Thouars; Ostrich fern, Matteuccia 

struthiopteris (L.) Tod.; Vegetable fern, Diplazium esculentum (Retz.) 

Sw.; Zenmai fern, Osmuda japonica Thunb. 

“
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It was also recommended to establish a new commodity definition for palm heart so that 

the various palm heart varieties can be easily distinguishable and defined, and the crop 

group commodity table would be decreased in size. The palm hearts commodity

definition is as follows:

“

(A) General Category (B) Specific Commodities

Palm hearts

Palm hearts, various species including: Peach Palm, Bactris gasipaes

Kunth; Palmyra palm, Borassus flabellifera L.; African fan palm, 

Borassus aethiopum Mart.; Coconut, Cocos nucifera L.; Cabbage palm, 

Euterpe oleracea Mart.; Wine palm, Raphia spp.; Royal palm, Roystonea 

oleracea (Jacq.) O.F. Cook; Salak palm, Salacca zalacca (Gaertn.) Voss; 

Saw palmetto, Serenoa repens (W. Bartram) Small; Cabbage palmetto, 

Sabal palmetto (Walter) Schult. & Schult. f.

“

In addition, there is a current commodity definition for celery that ChemSAC had 

approved a revision to add Chinese celery to the commodity definition for celery as 

follows (ChemSAC (Reviewer’s Guide and Summary of HED ChemSAC Approvals for 

Amending Commodity Definitions [40 CFR 180.1(h)] and crop group/subgroups [40 

CFR 180.41], Schneider, B., 6/14/02):

“

(A) General Category (B) Specific Commodities

Celery Celery, Florence fennel (sweet anise, sweet fennel, finochio) (fresh leaves 

and stalks only), Chinese celery. 

“

With the proposed establishment of a new crop group for stalk, stem, and leaf petiole 

vegetables, the need for a celery commodity definition to cover Chinese celery is negated 

since the proposed leaf petiole vegetable subgroup 22C has celery as the representative 

commodity that covers Chinese celery. In addition, Florence fennel, fresh leaves and 

stalks has been shown in this petition to fit closer to the stem and stalk subgroup 22A 

with asparagus as the representative commodity. Celery is the proposed representative 

commodity for crop subgroup 22B leaf petiole. Therefore, HED recommends deleting 

the commodity definition for celery as part of the establishment of the stalk, stem, and 

leaf petiole vegetable crop group. However, to avoid confusion from current celery

tolerances, HED has no objection to not deleting this commodity definition at this time.

ChemSAC and PMRA agreed with the commodity definition changes.
15