Miller Magazine Issue: 139 July 2021

89 ARTICLE MILLER / july 2021 harmonizing domestic regulatory documents with the EU di- rectives is a matter of minimizing trade risks, ensuring the competitiveness of agricultural products, but above all – it’s about the health of consumers. From the point of view of Ukrainian exports, the most significant risks of exceeding the limits of this pesticide arise regarding oilseeds (sunflow- er, soybeans, rapeseed) and vegetable oils (because it is fat-soluble). However, the risk is confirmed for cereals too (as chlorpyrifos is used in the processing of grain warehouses). According to the State Register of Pesticides and Agro- chemicals of the Ministry of Environmental Protection and Natural Resources, there are currently about 40 trade names of products registered in Ukraine containing chlorpyrifos and/or chlorpyrifos-methyl. Crop protection products with both active ingredients are used to treat grains, oilseeds, and vegetable crops. According to the State Statistics Ser- vice of Ukraine, in 2019, about 3 million hectares of Ukrainian agricultural land were treated with products containing chlorpyrifos and chlorpyrifos-methyl. Over the past year, an active public discussion continued on whether Ukraine, following the EU, should legally establish permissible levels for chlorpyrifos and chlorpyrifos-methyl. The opinions of market participants, state bodies, and industry asso- ciations were mixed - some considered this measure necessary, while others believed that agricultural producers had the right to make their own decisions about the pesticides they could use. Cotecna Ukraine was one of the first to draw attention to this topic and brought the discussion of chlorpyrifos into the public debate, revealing it in numerous publications and interviews and the framework of the industry conferences. Besides, with the support of Cotecna Ukraine in November 2020, an online conference was held where the topic was covered as comprehensively as possible and taking into ac- count the vision of all market participants. According to Arina Korchmaryova, the Vice President of Co- tecna Inspection S.A. (Black Sea and Baltic regions), Ukraine's decision is timely and justified because, after the EU, many countries will soon control the usage of such pesticide as chlorpyrifos and regulate the level of its residues in products. As she explains, there should be no chlorpyrifos residues in the samples of Ukrainian milling wheat, but they are there. Even more, the most considerable excess is noted precisely in vegetable oil - by 49% in 2019 and 45% in 2020. According to Cotecna Ukraine data, another significant product that ex- ceeded the levels of chlorpyrifos was rapeseed; the excess of the MRL level was 58% in 2019 and 28% in 2020 (even though the EU is the primary buyer of rapeseed from Ukraine). As for pesticide testing, more attention should be given to the reliability of detection on the technical side of pesticide con- trol, especially in the threshold ranges of values of about 0.01 mg/kg. For chlorpyrifos and chlorpyrifos-methyl, the new limits (MRL) are equal to the limit of quantitative detection (LOQ) for a significant part of the instruments used in Ukrainian labora- tories. However, false-negative results obtained on equipment with low sensitivity are no less dangerous than false-positive results caused by possible local contamination of the cargo at different stages outside or inside the laboratory. So, for checking the compliance of the cargo with the Eu- ropean requirements, it is essential to be confident in the results issued by the laboratory, defined by its capabilities and level of qualifications. Modern high-precision equipment at the Cotecna Ukraine laboratory, its experienced staff, and many years of testing various pesticides ( including chlorpyr- ifos and chlorpyrifos-methyl) are the key factors that allow for a correct definition or interpretation and reliable and timely delivery of information. Arina Korchmaryova Vice President of the Cotecna Inspection S.A. Group (Black Sea and Baltic regions) Head of Cotecna Ukraine Ltd.