Many of us have got by until now without having to worry about endocrine disruption. Well, I’m afraid that over the next couple of years we’ll be made only too aware of the subject. The fall-out from this issue could result in reduced EU food production and the inability to grow commercially some vegetable crops in the UK and possibly the EU. For the record, endocrine disruptors are chemicals that interfere with the endocrine (or hormone system) in animals, including humans.
The recent EU pesticide regulations introduced certain hazard cut-off criteria. Failure to meet these criteria will result in the pesticide being withdrawn whatever the level of risk. Many scientists consider that assessments based on hazard rather than risk is going further down the slippery slope where prejudice rather than science becomes the basis of decision-making. The introduction of hazard cut-off criteria for endocrine disruption is a further example of this.
First of all, how endocrine disruption is assessed and cut-off criteria are set were not clear when the new registration system was introduced in 2012. A more precise assessment and setting of the hazard cut-off criteria is expected by the end of this year. This does not sound good law-making to me; passing a regulation with unclear criteria and hence with unknown consequences.
Secondly, the EU regulators seem to be sanguine about some more obvious endocrine disruptors that continue to be used without question. What I am talking about here is that much of the endocrine disruption in the environment is a result of the use of the contraceptive pill. However, as far as I can understand, this is seen by the EU regulators as part of the natural background of endocrine disruption. I’m not sure of the logic as surely these pills are made in a chemical factory just like pesticides.
The level of debate over this issue will start to increase as the time for decision making approaches. This debate will be stoked by a clearer picture of which pesticides may have to be withdrawn because of the hazard cut-off criteria.
CRD, the UK pesticide regulation directorate, produced a possible list a couple of years ago which included key triazole fungicides and some pesticides essential for the production of ‘minor’ but important crops, including many green vegetables. There are currently other studies being carried out.
Naturally, the impact on food production will depend on the final agreement on setting the level of the hazard cut-off criteria. It is now clear that any definition is likely to be damaging to agricultural production and there is the possibility that the productivity of the industry could be severely curtailed.
Whatever the final agreement, there needs to be an assessment of what is the likely impact of setting these criteria on food production. This seems absolutely essential when, as in this case, a regulation is introduced without knowing the true implications of its impact. Also, in the quest for true transparency, it would be illuminating to know what is considered to be the current impact of endocrine disruption on human health and the environment.
In addition, the industry would be particularly interested to know the additional risk posed by pesticide usage over and above the ‘natural background’ level of endocrine disruptors, which not only include the contraceptive pill but also chemicals naturally found in plants.
I understand that EU law states that assessments are made to estimate the likely impact of new directives and regulations. Because of the possible effect on EU food production and food prices, such an impact assessment on the implications of setting the hazard cut-off criteria has to be done openly and transparently.