Craig Winneker is the director of communications at the European Crop Protection Association (ECPA). He answered questions by EurActiv's Henriette Jacobsen.
Some health campaigners and NGOs say the EU’s pesticides law (Regulation 1107/2009) should be updated in order to ban more substances suspected of being endocrine disruptors. What do you think of such a suggestion?
Like everyone else, we believe in safeguarding public health and the crop protection industry is committed to working with regulators and relevant stakeholders to address issues of concern.
Our products already comply with one of the most stringent regulatory frameworks in existence. Unlike REACH, the regulation governing plant protection products, Regulation 1107/2009, includes hazard-based cut-off criteria to address endocrine disruption.
The current testing framework for crop protection products is designed to identify all adverse effects, including those that may occur via the endocrine system. Any pesticide that is shown to cause unacceptable adverse effects, including effects via disruption of the endocrine system, will not be approved for use in the EU.
What we have to be careful not to do is to broaden the regulation in relation to endocrine disruption by disregarding the need for science-based criteria. This point was recently argued strongly in a recent letter from 81 scientists to the EU’s chief scientific advisor.
In everyday life we are exposed to substances which can interact with the endocrine system and which may have an effect on it in some way. Many of these substances, which can be both natural as well as synthetic, appear in our diet in things such as red wine, soy products, and in certain vegetables (e.g. beans and cabbage).
Sometimes, as in coffee, they have an effect on the endocrine system. Not all of these interactions are considered harmful. In almost all cases at the doses we commonly consume, these substances produce either no response or only a minor response in the endocrine system and these represent fluctuations that the endocrine system can cope with in maintaining normal function.
Protecting human and environmental safety should not be compromised and the current legislative framework for plant protection products already ensures that.
How would this effect the pesticides industry?
Extending the scope of chemicals regulation beyond established scientific boundaries would result in the unnecessary removal from the market of pesticide substances that have already gone through stringent evaluation and have been proven to be safe to human health and the environment.
Taking such action will provide no additional benefit to human health and the environment, but would make it increasingly difficult for crop protection companies to bring new and innovative substances to the market.
More importantly, it will have an impact on food production. Even with crop protection solutions that we have available now, between 26% and 40% of the world’s potential crop production is lost annually because of weeds, pests and diseases. These losses could double without the use of crop protection practices.
Removing essential crop protection tools from European farmers will make it increasingly difficult for them to control pests and diseases in their crops, and thus more difficult to meet the growing consumer demand for food.
If the Regulation 1107/2009 law was to be updated, what would you like the result to be?
In the short term, Regulation 1107/2009 will be updated to incorporate the final Commission criteria for the identification of endocrine disruptors. Longer term, Europe’s crop protection industry would welcome a review of the hazard based cut-off criteria in Regulation 1107/2009 including for endocrine disruption. ECPA fundamentally believes that endocrine disruptors should be addressed via risk assessment -- a conclusion also reached by EFSA in its recent scientific opinion released in March 2013.
Some anti-chemicals NGOs say that all the chemicals suspected of being endocrine disruptors can be substituted. How is this possible?
Substances which are proven to have unacceptable adverse effects should not be authorised and should be replaced by safer alternatives (if they exist).
But for pesticides, developing a suitable substitute, or any new product for that matter, is a long process. It takes up to 12 years to deliver a single new pesticide active substance from research to the market. New pesticides must meet all the necessary requirements in terms of a high level of protection to human health and the environment, but still be effective for farmers. Increasing uncertainty about what new regulatory standards will look like is already discouraging R&D in the sector, with a slowdown in the number of new active substances being developed.
Health campaigners and environmentalists say there is not enough innovation going on from the industry side, from those who use chemicals for production, manufacturing, pesticides etc., so they stick to the traditional ways of doing things. What is your response?
This is clearly not the case. We are an R&D-driven industry, working constantly to provide innovative solutions to crop protection that have minimal impact on human and environmental health. This process requires a significant investment of time and resources.
That means we need a predictable and stable regulatory process that encourages and fosters innovation to enable newer, safer substances to come to the market. Legal decisions that are not based on science and that go against the principles of predictability, consistency, proportionality and legal certainty put at risk Europe’s competitiveness and discourage industry from innovating.
The discussion about endocrine disruptors in chemicals tends to involve “the precautionary principle”. Why is it that the industry doesn’t think it’s better to be safe than sorry?
This is not a question of whether the crop protection industry thinks human and environmental safety are important. Endocrine disruption is a highly political and emotional topic and therefore it needs a careful and comprehensive science-based approach. We believe it is possible to ensure health and safety while keeping the tools we need for a productive agricultural sector if the endocrine disruption criteria focus on actual rather than perceived risks.
Criteria which are over-precautionary and not science-based (i.e. rejecting the established ability to set regulatory thresholds) will deprive farmers of needed technology without improving human or environmental safety.
The existing testing framework for pesticides is already designed to identify all adverse effects, including those that may occur via the endocrine system. Any pesticide shown to cause unacceptable adverse effects, including effects via disruption of the endocrine system, has not been approved for use in the EU. We are already safe; let’s not be sorry we made an unnecessary regulatory change.