The Dirty Dozen for 2021 is anything but current

By Lance Jackson

The Central Valley of California is the fruit basket of the entire United States, with well over 90% of the nation’s tree fruit and nuts grown here; and I believe we have the safest food supply in the entire world.   Farming in the state of California has become more difficult with each passing year, and more importantly, each passing legislative session in Sacramento that subjects us to the heaviest regulation and oversight in the entire country.

In March of 2021, the Environmental Working Group, or EWG, released their annual “Dirty Dozen” list of the “most contaminated’ fruits and vegetables, based upon information gleaned from the USDA Pesticide Data Program (PDP).    The EWG compiles its annual list by analyzing U.S. Department of Agriculture data “to identify which fresh fruits and vegetables are most and least contaminated with pesticide residues.”

“This year, the USDA’s tests found residues of potentially harmful chemical pesticides on nearly 70 percent of the non-organic fresh produce sold in the U.S.,” EWG said in a press release. “Before testing fruits and vegetables, the USDA washes, scrubs and peels them, as consumers would.”  EWG went on to say, “Most pesticide residues that the USDA finds fall within government-mandated restrictions.  But legal limits aren’t always safe.”  

There are a number of issues with this alarmist portrayal of our food supply that I, as a California Farmer, take issue with.  First off, EWG disregards the “Maximum Residue Limit” or MRL—standards that USDA and every country we export to have set for different materials used in agricultural production.  With the advent of technology capable of detecting the equivalent of an eyedropper of food dye in a typical swimming pool, reasonable limits had to be set.  

Second, EWG does not define the Country of Origin for ANY of the fruits and vegetable listed, which is readily available from the USDA PDP database.  Produce brought in from Mexico, South America, and Asia, all routinely test higher in residues than that from the United States, even if those residues are under allowable MRL limits.

Third, and perhaps most egregious and misleading, is the fact that while EWG presents this “list” annually, the USDA PDP database is not updated, or even completely tested, annually.  The EWG’s most contaminated commodity for 2021 is Strawberries, but the most recent update on the USDA PDP database was the 2015/2016 crop year.  Following is the Dirty Dozen list and what year the commodities were last updated in the USDA PDP database:

As a California farmer, one is required to have the following, outside the other rules and regulations that are part of being an employer in California;

1. County Ag Permit – this allows a farmer to purchase and use pesticides, fungicides and herbicides in order to protect the crop, manage crop quality, and help crop yields.  Ag permits are granted by county and may be good for 1 to 3 years, depending on which county the farm is in.  In order to obtain an ag permit, the farmer also needs to take and pass a test demonstrating proficiency in material application, safety protocols, and the specific labeled instructions on each material used on the operation.  Once passed, the farmer is granted a Private Applicator Certificate, which is good for three years.  During those three years, the farmer is also required to accrue “continuing education” units by attending courses in person or online.  Failure to gain enough units will mean the farmer has to take the proficiency test again.  The last part of the County Ag Permit is reporting; every material that is applied on the farm.  This must be reported monthly to the Ag Commissioner’s office, which is then forwarded to the California Department of Pesticide Regulation (DPR).  Failure to do so may result in loss of the permit.
2. Nitrogen Management Plan – Nitrate contamination in our ground water is a significant concern in parts of the valley.  As a result, the State has mandated that all agricultural producers have a Nitrogen Management Plan that indicates how much of a nitrogen “reservoir” is in the root zone of the soil, and the water that has been applied to the crop, plus how much additional nitrogen has been applied to the crop via fertilizer application.  Following this, there are a series of calculations to determine how much nitrogen is taken out of the “reservoir” over the growing and harvesting of the crop.  The idea is that the total input into the nitrogen reservoir equal the outputs from crop growth and harvesting, thus leaving no nitrogen to leach past the root zone and into our underground water supplies.  Each and every parcel in the operation must have its own plan submitted to the State.  At this point, I am not going to debate the validity of the process.  It is simply what we are currently required to do.  Of course, the farmer needs to be certified by the State in order to write his own Nitrogen Management Plans, which requires passing another proficiency test and maintaining Continuing Education credits.  Alternatively, the farmer can pay an independent consultant a fee to write and submit the plans every year.
3. Food Safety Modernization Act or FSMA. – Agricultural producers are required by FDA to be trained and to comply with FSMA regulations, which cover the following: Worker Health, Hygiene and Training, Soil Amendments, Wildlife and Domesticated Animal Management, Agricultural Water (not nitrates), and Post-Harvest Handling and Sanitation.  The farm is to have in place a “Farm Food Safety Plan.”  Here again, an 8-hour course and proficiency testing are required for the farmer to gain FSMA compliance certification. 

In addition to the State-mandated programs, there is also the Global Good Agricultural Practices (GAP) program that many produce buyers demand.  Global GAP is similar to FSMA, but is administered by third-party agencies.  The farm operators have annual inspection and certification procedures, annual pesticide residue testing BEFORE harvest, water quality testing, and verification of fertilizer and chemical inputs.  

Finally, there is the option of being certified Organic, which encompasses an entirely different array of testing, compliance, and operational procedures and inspections that would take up more time and space than we have available.

Regardless what you think about the validity of reports, such as what is offered by activist groups like EWG, please take the time to research what you’re buying, and especially Country of Origin.  I believe you will find it hard to go wrong with anything grown in the USA and especially in California.