Hazard – EU decision making

4 Dec 2014


SprayerThe Pope has had a little dig at the EU institutions suggesting that they have lost their way and that they view the member states “with aloofness, mistrust and even, at times, suspicion.” Pretty tough talk and perhaps the Pope is the only person who could proffer such an opinion without a huge backlash from the bureaucrats in Brussels and Strasbourg. 

I suspect that many in the pesticide industry would endorse the Pope’s analysis. Increasingly, legislation appears to be determined by mistrust and aloofness and has resulted in some key decision-making on pesticides and GMs not being based on science. Perhaps this is best demonstrated by the green blob’s coup of lobbying for the post of EC Chief Scientist to be discontinued. Sure enough, within a month or two Ann Glover was sacked. Could it be that the reason for their hostility was that she supported GMs? Her support was derived from hard evidence and good science. The green blob, knowing that any successor to the post would also be a scientist who would rely on the same sound principles, decided that the post rather than the current incumbent should go. 

The new pesticide legislation will result in active substances being banned solely because they are defined as hazardous. This is a departure from the previous science-based practice where the risk of using a potentially hazardous substance was assessed. This approach was based on the principle that it is only the level of exposure to a hazardous substance that defines the level of risk. Just to give an example of the difference between a risk and a hazard: electricity is hazardous but the risk of using it is very low because we are not directly exposed to it. 

We may lose a lot of pesticides (e.g. the triazole fungicides) because they could be characterised as hazardous as they may be defined as potential endocrine disruptors i.e. they disrupt the hormone systems of animals. Those who support the hazard cut-off for endocrine disruption quote the increase in endocrine diseases (primarily diabetes) in humans and the feminisation of male fish. The link with diabetes seems to have been made with pesticides long banned in Europe and used particularly in parts of the world where pesticides are less regulated (http://www.diabetesandenvironment.org/home/contam/pesticides). However, as the definition of what may be an endocrine disruptor has yet to be agreed, it is impossible to assess precisely the likely extent of the damage to the agricultural industry from this hazard based approach. 

I have been taking an interest in the potential level of exposure of humans and wildlife to those pesticides that may be defined as endocrine disruptors. One potential source of endocrine disruptors to humans (and fish!) is surface and ground water. However, less than a handful of those pesticides that may be defined as endocrine disruptors have been found in water in the UK and then at incredibly low levels. A recent Defra pamphlet stated that “research has found small amounts of endocrine disruptors in some of our rivers. However they tend to occur only in immediate proximity to industrial and wastewater discharges” (http://dwi.defra.gov.uk/consumers/advice-leaflets/edc.pdf). I accept that pesticides were probably not counted as endocrine disruptors in this survey but it is important to state that there are other sources of such chemicals. 

The other significant source for humans ingesting endocrine disruptors is through food. However, the surveys of wheat flour carried out under the auspices of the Defra Expert Committee of Pesticide Residues in Food and the European Food Standards Agency have, with one or two exceptions (which were typically well below Maximum Residue Levels), failed to detect traces of those cereal pesticides that may be defined as endocrine disruptors. 

Another potential threat could be to spray operators but, as far as I am aware, surveys on their health have not picked up any problems that can be associated with endocrine disruption except where there has been prolonged exposure to pesticides that were banned in Europe many years ago. Finally, exposure of bystanders to spray drift is a hot topic. I am not sufficiently briefed to comment on the level of risk from this source but the adoption of air induction nozzles and good spray practice should minimise any risk. 

I have come to the conclusion from this rather simplistic analysis that the exposure of humans and animals to those pesticides that may be defined as endocrine disruptors could be negligible or extremely limited. Hence, it seems incredible to me that they may be banned as a matter of course. It is worth noting at this point that some foodstuffs naturally contain potential endocrine disruptors, such as the phyto-oestrogens in soya bean products, the fibre of whole grains, vegetables and flax seed (http://www.cancerresearchuk.org/about-cancer/type/breast-cancer/about/risks/diet-and-breast-cancer#soya). 

The European Commission is running a consultation exercise Endocrine Disruption Legislation (http://ec.europa.eu/eusurvey/runner/ED-consultation). It is essential that farmers and their representatives respond to the consultation and state the likely effect on the yield and quality of the crops grown, the impact on pesticide resistance management, the fact that there is a lack of alternative control methods in some cases, as well as what this means to their businesses. Those not close to the industry will be unaware that it takes only small changes in cropping and/or a reduction in yield to have a devastating impact on the finances of a farm business. A report by Anderson’s for the NFU, AIC and CPA provides much of the background information required (http://www.nfuonline.com/andersons-final-report/). I think that it is also important to ask if there is a credible reason (i.e. not just the unrealistic invocation of the precautionary principle) to suspect that the pesticides that may be listed as endocrine disruptors are a threat to human health and the environment. The green blob considers that numbers count in terms of response to consultations and so too should the industry.