Comments on: New endocrine disruptor rules address your trade concerns, EU tells US, Canada EU news and policy debates across languages Mon, 08 Apr 2019 14:38:46 +0000 hourly 1 By: David Zaruk Tue, 13 Dec 2016 12:03:54 +0000 I cringed at the basic misunderstanding of risk and hazard in this article. The author seems to mix them up with several interpretations of the precautionary principle (which are also mixed up).
A hazard-based approach to EDCs would see potential harm from EDCs from certain pesticides (regardless of the level of exposure) and demand precaution – precaution here interpreted in the EEA form as the reversal of the burden of proof – until science can prove safety (a subjective concept that we can leave as the absence of any level of harm), a substance is not allowed on the market. This is not risk-management, but uncertainty management which does not consider the potential lost benefits. The likely consequence of this approach is that all pesticides, including the thousands approved for organic farming, would be taken off of the market.
A risk-based approach to EDCs would consider the potential harm from EDCs in relation to exposure scenarios (to farmers, to consumers …) and look at means to lower the exposure via ALARA (as low as reasonably achievable). If exposure cannot be reduced then precaution would be applied – precaution here following from the UN’s 1992 Triple Negative which would also consider loss of benefits to agricultural output should a large number of plant protection products be removed from markets.
The NGOs are pushing the hazard-based approach for good reason – they want to remove all pesticides (except those approved for organic farming) but is it logical to consider a harm that very few people are exposed to? When there are more toxins, carcinogens and EDCs in a single cup of coffee than the pesticide exposure from an entire year of fruit and vegetable consumption, are we really not doing a disservice to basic common sense with this exercise (something not taken into account in the hazard-based approach)?
EURACTIV, please try to put some balance into your reporting if you can’t put common sense into your journalists!