MEPS from the Agriculture, ITRE and IMCO committees were asked to vote on an opinion on a regulation on the placing of plant protection products on the market as well as a Directive and a Thematic Strategy for the Sustainable Use of Pesticides.
The Health & Environment Alliance and the European Public Health Alliance are concerned that the debate and decisions taken will not adequately reflect recent scientific findings showing alarming evidence on the health effects of pesticide exposure. Our key policy recommendations to improve the current legislative proposals can be summarised as follows:
Exclusion of unacceptable active ingredients (cut-off criteria) in Article 4 and Annex II of the Regulation for pesticide authorisation: All substances with known or suspected carcinogenic, mutagenic, reprotoxic and endocrine disrupting effects, and that are persistent, bioaccumulative and toxic should not be approved. One critical step in ensuring hazardous substances do not gain authorization is to incorporate strict maximum “cut-off” criteria in risk assessment procedures based on the substance intrinsic properties and biological effects. An assessment of the combination, or “cocktail” toxicity of pesticides should also be considered and a precautionary approach should be ensured. omparative assessment and substitution by less hazardous or non-chemical;
Alternatives in Article 24, 48 and Annex II of the Regulation for pesticide authorisation: All chemical substances should be candidate for substitution by less hazardous substances or non-chemical alternatives. Candidates for substitution should be established in a list going beyond substances already classified as dangerous by existing legislation to include neurotoxic and immunotoxic substances, and could be authorized for a maximum of 3 years - instead of the 7 years currently foreseen in the authorization proposal. If non-chemical methods and practices are available for the crop in question, an active substance should not gain authorisation.
Protection of vulnerable groups and against combination, or “cocktail”, effects of pesticides: both the Regulation on Authorisation and the Directive on the Sustainable Use of pesticides should take into consideration the special vulnerability of children, women of child-bearing age and pregnant women. Article 4
and Annex II of the Regulation should also consider the possible combination toxicity of pesticides. Considering that the use of a single substance per crop is very rare, safety values should be further lowered if the toxic effects of two or more pesticides used together are likely to produce a more toxic effect than when either is used alone.
Progress made with this legislative process will determine the level of health protection afforded by pesticide regulation in Europe for the coming decades.
Letters attached.
