Guidance on Chlorpyrifos Recordkeeping

By Brett Bultemeier and Lauren Diepenbrock

The revocation of chlorpyrifos residues and tolerances that became effective on Feb. 28, 2022, caused some confusion and concern when it was first announced. The legal description provided by the Environmental Protection Agency is challenging to fully understand. Therefore, the Pesticide Information Office from the University of Florida Institute of Food and Agricultural Sciences (UF/IFAS) has provided more direct guidance for growers regarding how the U.S. Food and Drug Administration (FDA) plans to handle food that enters the market that was sprayed with chlorpyrifos.

Here is what you need to know:

• Any food treated with or exposed to chlorpyrifos on or after Feb. 28 that tests for any chlorpyrifos residue is considered adulterated and unsellable.
• Any food treated with or exposed to chlorpyrifos before Feb. 28 that tests above the tolerance level is considered adulterated and unsellable.
• Any food treated with or exposed to chlorpyrifos legally before Feb. 28 that tests for residues that fall below the tolerances in place before Feb. 28 is not deemed adulterated.

The recordkeeping requirement for restricted-use products is two years. The FDA is extending the tolerance allowance, as described above, for frozen, preserved and processed goods until Aug. 28, 2026. It is strongly recommended that growers maintain all records related to chlorpyrifos until this time.

Prior to this guidance, several growers had asked about the ability to use chlorpyrifos on nonbearing trees and on grove floors for ant management. Based on this guidance and a discussion with the Pesticide Information Office, these actions are not advisable. Detection tools are highly sensitive and can now detect even minute traces of the original pesticide and its breakdown products. Any use of chlorpyrifos in groves now is risky and not a good idea. See the Florida Citrus Production Guide for recommendations on other materials to use for pests in groves.

Brett Bultemeier is an Extension assistant professor in the UF/IFAS Pesticide Information Office in Gainesville. Lauren Diepenbrock is an assistant professor at the UF/IFAS Citrus Research and Education Center in Lake Alfred.

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