Ms. Peltier.

MS. PELTIER: Thank you. Good afternoon. My name is Jean-Mari Peltier and I'm the president of the California Citrus Quality Council. Our organization was created over three decades ago, with the purpose of assuring that wholesome citrus fruit finds its way into both domestic and international markets with no pesticide residues in exceedance of internationally and nationally established standards.

We're involved in assisting our growers in quality control, in quarantine matters, providing technical assistance and helping with international compliance. We appreciate this opportunity to speak at this information gathering session and are glad to be able to provide information on critical agenda items as the world prepares itself for this -- actually, the millenium round of multilateral trade negotiations.

International trade is extremely important to the citrus industry, as Mr. Nelsen referred to earlier. Roughly, a third of our orange and lemon crops from California find their way into the international market, with a value at something over $450 million.

CCQC has been involved through the years in assuring that phytosanitary standards are based on science, as Mr. Nelsen referred to. And we've also worked as a member of the North American Plant Protection Organization, as well as the Codex Committee on pesticide residues.

In addition, in a previous life, I was the Chair of the Fruit and Vegetable Agricultural Technical Advisory Committee on trade and most recently served at the Department of Pesticide Regulation here in California and as a member of the Tolerance Reassessment Advisory Committee.

It's from this context that I would like to raise just one important issue with you today and that's the establishment of Codex maximum residue levels in compliance with our tolerances established by the Environmental Protection Agency.

The value of Codex limits to the citrus industry can't be over estimated. They serve, if you will, as a passport for entry into foreign markets. In the absence of these Codex limits, food shipped in international trade isn't provided the protection of the World Trade Organization. And it's at the risk of being rejected by regulatory authorities in the importing countries. And certainly, this is the situation that we found ourselves in at the current time with Taiwan.

In going through that process, I had the opportunity to review the existing tolerances established for the citrus industry and the corresponding Codex MRLs and was alarmed to find out that less than a third of the pesticides for which we have EPA tolerances have Codex MRLs. And that represents about 50 percent of the pesticides that are used in the California citrus industry that currently don't have Codex MRLs established.

As Secretary Rominger knows all to well, the world changed in August of 1996 when the Congress unanimously passed the Food Quality Protection Act. That Act called on the EPA to go through a rigorous review of existing tolerances on all the tolerances on pesticides with a third of those to be completed by August of this year. As EPA is going through this rigorous review of existing tolerances, tolerances subjecting them to the new standard of taking a look at the cumulative and aggregate impacts, they are simultaneously trying to expedite the registration of newer reduced-risk technologies. And this has been the case with six new materials since 1996 for the American citrus industry.

The difficulty arises with the lag time between establishment of an EPA tolerance and a Codex MRL. That's currently ranging, depending on who you talk to, anywhere from two years to eight years. The average is somewhere around five, from what I understand. What we would like to get on the radar screen of our negotiators is coming up with some sort of a process for expedited acceptance of national MRLs for Codex MRLs.

Now, obviously, from our perspective we would say that if you have an existing EPA tolerance, because of the kind of rigor of their current review, that ought to be sufficient for getting a Codex MRL. The devil is going to be in the details obviously. And dealing with an issue of reciprocity with other countries, that don't have similar kinds of reviews, is going to be difficult.

I'd like to submit for the record today a copy of a draft working paper that we've prepared on this and would welcome the opportunity to continue to work with you, our negotiators, as we go into this round.

Thank very much.