topics sprayers, pesticides, insecticides, fundgicides, Europe

Next week the controversial plan to revamp the EU’s system of approving pesticides will be presented to the European parliament for second reading. Ahead of this crucial debate, Farmers Weekly met the EU Commission team spearheading the changes. Philip Clarke put the questions

Q The current system of approving pesticides, Directive 91/414, has served the food and farming industry well for 17 years. It’s been described as the “gold standard” for pesticide approval. Why change it?

A It was always foreseen in Directive 91/414 that the EU Commission would review it after 10 years. This we did in 2001, presenting our report in 2002. We identified a number of weaknesses and in response the European parliament and the Council asked us to find ways of improving the system, in particular by setting clear criteria for approval.

Q But why suddenly introduce a hazard-based system, banning products that contain active ingredients that are carcinogenic or endocrine disrupting, rather than sticking with the established system based on actual risk?

A We were considering hazard criteria as part of the risk assessment anyway, but this was open to interpretation. By having clear criteria, the whole system becomes more predictable, making it easier for a manufacturer to know whether or not to develop a particular pesticide.

Q But what is the evidence that the existing, risk-based system has been failing or causing problems with human or environmental health?

A During the first review of pesticides in the EU, we removed substances which posed an unacceptable risk on the basis of current knowledge. However, science has progressed considerably over the last 20 years, and so did our knowledge about the risk of some substance classes. So now, we have to refine our assessments.

Q But many medicines contain hazardous active ingredients. You would not think of banning them.

A There is a fundamental difference. For example, if an individual has cancer, just because the treatment involves a risk, of course he or she will still take that medicine. But with food production, we are talking about what the whole population eats, as well as the safety of farm workers and the environment.

Q The UK Pesticides Safety Directorate has estimated that 15% of current pesticides would be removed from the market under the EU Commission’s proposal, and up to 85% under the European parliament’s position. Why are you so critical of the PSD’s findings?

A The PSD’s impact assessment is clearly a worst-case scenario, but also does not take into account the picture as it will be when the new regulation enters into force. It says large numbers of products will be taken off the market because of the criteria. But some of those pesticides will go anyway under the current review of existing pesticides for some others, it is not yet clear whether they would fall under the criteria or not. Ignoring both these elements makes the figures seem worse.

The assessment also ignores new products that are still in the system, many of which may get approval. And it ignores the many low volume substances, like plant extracts, pheromones and substances used in organic production, all of which are important for their users. Again, this distorts the figures.

Q Why has the EU Commission not published its own list of products that will be affected by the new cut-off criteria?

A Currently, due to the ongoing review, we do not have a robust baseline. Our best estimates, however, suggest that just 4% of substances will be lost because they are endocrine disrupting and 2% because they are carcinogenic, mutagenic or reprotoxic, which would mean about 20 active substances in total.

Q How do you define endocrine disrupting? This is the one hazard criteria that affects most pesticides, but is causing most confusion.

A. Endocrine disrupting means affecting fertility or reproductive behaviour. The proposed regulation says active ingredients will be subject to an agreed international or EU test. At the moment we are working hard to develop guidelines, though they have not been finalised yet.

Q Isn’t it irresponsible to introduce new legislation when there is no agreed guideline for one of the key criteria?

A By the time the legislation enters into force, the necessary guidelines will be defined. Endocrine disruption is a real danger, independent from the question of how you can measure it. In that respect it was important to include it in the proposed provisions, even if the implementing guidelines are not yet fully finalised.

Q Given the uncertainty, and given the belief that many pesticides will be lost, and given the fear that this will lead to reduced food output and increasing food prices, many in the industry are calling for a new impact assessment. Does the EU Commission agree?

A The initial impact assessment we did was thorough. We intensively sought the views of all stakeholders, including farmers, consumers and the pesticide industry over several years. Before finalising the proposal, we held a last meeting for 150 people from the whole spectrum of society, to allow for final submission of comments. We got none.

Q But wasn’t this before the hazard criteria were built into the proposal?

A Phasing out carcinogens, mutagens, substances toxic to reproduction and endocrine disruptors has been EU policy since 2001 and is already integrated in other policy areas.

Q But what about the effect of the new legislation on farmers who, at a time of food shortage, need pesticides to keep productive?

A We believe they will still have sufficient pesticides at their disposal. The new zonal system means that the authorisation of a pesticide will have to be recognised by all other countries of that zone upon request. Secondly, the new criteria will only apply when existing approvals come up for renewal, mostly around 2016, giving time for the industry to adapt. Finally, there is the derogation, which says that, if no alternative product exists, an active ingredient that would otherwise be banned may be approved for up to five years.

It also has to be stressed that the current emergency provision remains, which allows a national government to authorise any product for up to 120 days, to deal with a specific urgent problem.

Q And what about food price concerns?

A There are many factors at play in determining food prices. To draw a direct link between withdrawing some pesticides and increases in the price of food is simplistic.

Q Another common complaint is that, with less food produced by EU farmers, we will end up importing more, from countries which continue to use pesticides banned in the EU.

A Our regulation on maximum residue levels means that any imported food has to respect the thresholds we impose. So consumers are afforded the same level of protection whether the crop is grown inside or outside the EU.

* Have you signed our Save Our Sprays e-petition yet? If not, please visit our SOS campaign website.