HEJSupport joins Citizens for Science in EU Pesticide RegulationBlog
HEJSupport joins the Citizens for Science in Pesticide Regulation. More than 100 NGOs and experts published a manifesto demanding a better pesticides regulation.
Read the manifesto here.
The EU pesticides regulation explicitly prioritises the protection of human and animal health and the environment. However, the rules are not implemented properly and the regulatory system is allowing private interests to be given priority over health and the environment.
Major conflicts of interest persist in the pesticides regulatory system. For example, industry does its own safety testing and is heavily involved in designing the methods for risk assessment. Expert panels of the European Food Safety Authority (EFSA), which conduct the peer review and publish an opinion on whether the application meets the criteria for approval of the pesticide, continue to include people with financial ties to the agrochemical industry. The Monsanto Papers, internal Monsanto documents disclosed in cancer litigation in the USA, show how industry can actively subvert science. It is now clear that industry must be kept at arm’s length from safety testing, risk assessment and risk management.
The result of the failure to properly implement the regulation is a rapid collapse of biodiversity (birds, bees, butterflies, frogs, and insects) in agricultural areas and serious harm to humans (including damage to the brain of the unborn foetus and a steady rise in hormone-related cancers such as breast and prostate). In addition to its failure to protect health and the environment, the current system also fails to protect food security for future generations, since biodiversity, pollinators, and soil fertility – the building blocks of a productive and resilient agriculture – are put at risk by pesticides.
Main points of the Manifesto
A full reform of the current pesticide risk assessment and risk management systems is required, as follows:
A. PRIORITISE PUBLIC HEALTH, THE ENVIRONMENT AND SUSTAINABLE AGRICULTURE
- The European Commission shall propose the approval of a pesticide substance only when all the scientific evidence shows that the substance or the final product causes no adverse effect on humans, animals, and the environment, all uses proposed by industry are considered safe by EFSA, and no safer alternative (substance or practice) is available.
- The Sustainable Use of Pesticides Directive must be respected: pesticides must be used only as a last resort when all other non-chemical alternatives have been applied and failed.
- The European Commission, as risk manager, shall operate transparently and with accountability. It must fulfil its obligation under the pesticide regulation to prioritise public health and the environment over all other considerations, such as private profit. The decision-making process – the discussions between the European Commission and the Member States, or any other entity – shall be public.
- To enable EU farmers to improve their practices without being ‘punished’ by markets, the European Commission shall not place them in a position of unfair competition and shall therefore ban imported products that contain residues of non-approved pesticides, or that contain residues of any pesticide exceeding permitted levels, with no exceptions
B. ENSURE THAT DECISION-MAKERS RELY ON DATA THAT IS COMPLETE, PUBLIC, UP TO DATE, AND FREE FROM INDUSTRY BIAS
5. Safety testing of pesticides shall be carried out by independent laboratories and not by the pesticide industry itself. The process shall be paid for by an industry-supplied fund that shall be managed by an independent public body such as EFSA.
6. To prevent cherry-picking of favourable data, all safety studies must be registered in advance. No safety study that is not registered shall be used in support of regulatory authorisation of a pesticide.
7. All experts involved in risk assessment shall be subject to a strict conflict of interest policy and rules. Any ties to commercial interests will exclude them from the process.
8. Existing guidelines on risk assessment shall be fully reviewed by independent scientists because in many cases they were designed and promoted by industry and are biased in favour of industry interests.
9. EU-funded research programmes shall prohibit industry-linked individuals from joining projects that design or evaluate risk assessment methodologies.
10. The data requirements to assess whether a pesticide should be authorised need to be updated urgently, because major health effects, such as immunotoxicity, endocrine disruption and developmental neurotoxicity, are not adequately covered and the impacts on environmental ecosystems are severely underestimated.
11. Industry dossiers shall only be accepted into the authorisation process when all required data is delivered, including all independent peer-reviewed publications related to health and environmental effects of the pesticide. Pesticides that do not fulfil all the requirements of the regulation must be banned.
12. Formulations of pesticides as sold and used (and not just the isolated active ingredient) shall be tested and assessed for crucial endpoints (e.g. mutagenicity, carcinogenicity,developmental toxicity, and endocrine disruption) relevant to humans, mammals and all non-target species, such as bees, birds, frogs, and earthworms.
13. The cocktails of pesticide residues to which EU citizens are exposed every day must be considered when calculating “safe” daily exposure levels. Until this is implemented, an additional “safety” factor of 10 shall be applied in all pesticide risk assessments. This additional safety factor shall also be applied in the calculation of the acceptable environmental concentrations of pesticides.
C. ENABLE DECISION-MAKERS, CIVIL SOCIETY, AND THE SCIENTIFIC COMMUNITY TO SCRUTINISE THE INTEGRITY AND EFFECTIVENESS OF THE POLICY
14. All the results and data of all pesticide safety tests shall be published on the internet in a consistent and searchable format.
15. National authorities shall conduct routine independent post-approval monitoring of the effects of pesticides on health and the environment. The monitoring shall be paid for out of a fund supplied by the pesticides industry but managed by an independent body. There must be no contact on these matters between the monitoring authorities and industry.