Expansion of the Low-Risk Substances in the Framework of the European Pesticide Regulation (EC) No 1107/2009

Signed in 2009, the plant protection Commission Regulation EC No 1107/2009 created a new category of active substances, the low-risk substances, with specific status defined in Article 22. The initial and specific criteria, not suitable for microorganisms and natural substances, were modified in 2018, and the first low-risk substance, allocating Part D of Regulation EC No 540/2011, was granted in the same year. Since then, thirty-three low-risk substances have been granted with this specific status through approvals and renewals, while a larger list of potential low-risk substances from already-approved active substances was published. This list is only exploited during renewals, and this process would take another five years to complete. After four years of the implementation of this status, the number of such substances is still low, but is intended to increase slowly. Two more low-risk substances are already pending in 2021, which will bring the number of low-risk substances to thirty-five, while the initial list of potential low-risk substances (only renewals) included fifty-seven substances.

Challenges for Pesticide Regulation and Use

Many farmers still apply a wide range of pesticides, but are exposed to some which are highly hazardous to use. Is there sufficient legislation and control of pesticide use to remove these pesticides? Even applying the less hazardous pesticides, farmers need to be better trained to improve their application and minimise exposure to the chemicals. The use of chemical pesticides has increased immensely over the last 80 years, since the development of DDT, with a range of many other insecticides, fungicides and herbicides being marketed. Although legislation to control the use of insecticides had been introduced in the USA back in 1910, it was only after World War II that other countries began to start registration of pesticides and WHO created a Classification based on the toxicity of the chemicals. More recently there has been greater concern about the extent to which certain pesticides, especially those rated as Highly Hazardous Pesticides (HHPs) have been used. WHO estimates that there are 1.6 million deaths per year from poisoning by chemicals. There are other problems, such as the herbicide glyphosate, use of which has expanded with farmers growing maize, soybean and cotton crops genetically modified to provide tolerance to this weedkiller. The use of this herbicide has resulted in many court cases claiming it use results in ill health.

Suicide by pesticide ingestion in Nepal and the impact of pesticide regulation

Background Nepal recorded 5754 suicides in 2018–19 - a high number for a relatively small country. Over 24% of these suicides were by poisoning, most by ingestion of highly concentrated agricultural pesticides. Nepal has actively regulated pesticides to reduce their health impacts since 2001. We aimed to analyse Nepal’s history of pesticide regulation, pesticides responsible for poisonings, and relate them to national suicide rates. Methods Information on pesticide regulation was collected from the Plant Quarantine and Pesticide Management Centre of the Ministry of Agriculture and Livestock Development. National data on suicides from 1980 to 2019 were obtained from the National Statistical Bureau and Nepal Police. Data on the pesticides responsible for self-poisoning and pesticide suicides over time were obtained from a systematic literature review. Results As of June 2020, 171 pesticides were registered for use in Nepal, of which one was extremely hazardous (WHO Class Ia), one other highly hazardous (WHO Class Ib), and 71 moderately hazardous (WHO Class II). Twenty-four pesticides have been banned since 2001, with eight (including five WHO Class I compounds) banned in 2019. Although the suicide rate has increased more than twelve-fold since 1980, particularly for hanging (15-fold increase from 1980 to 2018), fatal pesticide self-poisoning has increased by 13-fold. Methyl-parathion is reported to be the key pesticide responsible for pesticide self-poisoning in Nepal, despite being banned in 2006. Conclusion The full effect of the recent pesticide policy reform in Nepal remains to be seen. Our analysis shows a continuing increase in suicide numbers, despite bans of the most important pesticide in 2006. This may indicate smuggling across the border and the use of the brand name (Metacid) for pesticides in general making it difficult to identify the responsible pesticide. More information is required from forensic toxicology labs that identify the individual compounds found. The effect of recent bans of common suicide pesticides needs to be monitored over the coming years. Evidence from other Asian countries suggests that HHPs bans will lead to a marked reduction in suicides, as well as fewer cases of occupational poisoning.

The Slow Decrease of Active Substance Candidates for Substitution in the Framework of the European Pesticide Regulation (EC) No 1107/2009

The specific status of active substance candidates for substitution (CfS) is detailed by Article 24 of plant protection Commission Regulation EC No 1107/2009 (PPP Regulation). The criteria of candidates for substitution are now clearly defined: low acceptable daily intake/acute reference dose/acceptable operator exposure level or two persistent, bio-accumulative or toxic criteria, or by nature of the critical effects: non-active isomers, carcinogen 1A/1B, toxic for reproduction 1A/1B or endocrine disruption properties, with these later properties now being well characterised. The total number of active substances CfS has been in constant evolution since 2011, with the first batch of candidates for substitution being published in 2015 and updated since then. After a slow decrease, growth is again observed, with another list of active substances being granted this status. CfS are substances targeted by the PPP Regulation that are supposed to be cancelled or non-renewed at the active substance level or substituted at the market authorisation level. CfS are also supposed to be replaced by substances with better toxicological profiles. However, after five years of implementation of the status, their number, which is intended to decrease, remains high, at sixty residual CfS. We exhibit here their evolution.

A REVIEW OF BRAZILIAN BILL N. 6,299/2002 ON PESTICIDE REGULATION AND ITS IMPACTS ON FOOD SECURITY AND NUTRITION

Brazilian legislative proposal n. 6,299/2002, addressing pesticide regulation, represents an attempt to loosen and weaken the regulation of these substances, threatening the rights to food and a healthy environment as enshrined in the Constitution of the Federative Republic of Brazil. This article reviews the bill and its more troublesome provisions through the lenses of food security and nutrition as well as national environmental law principles and provisions. Within this background, the paper concludes that Bill n. 6,299/2002 works against previously achieved progress in providing alternative policy pathways for sustainable agriculture in Brazil. It clashes with environmental law principles, neglecting precaution and prevention, representing a regression in terms of protection levels, while undermining human rights to food and a healthy environment. The methodology includes a literature and documentary review, along with inductive reasoning.

Emerging pesticides responsible for suicide in rural Sri Lanka following the 2008-2014 pesticide bans

Background Sri Lanka has reduced its overall suicide rate by 70% over the last two decades through means restriction, through means restriction, through a series of government regulations and bans removing highly hazardous pesticides from agriculture. We aimed to identify the key pesticide(s) now responsible for suicides in rural Sri Lanka to provide data for further pesticide regulation.Methods We performed a secondary analysis of data collected prospectively during a cluster randomized controlled trial in the Anuradhapura district of Sri Lanka from 2011-16. The identity of pesticides responsible for suicides were sought from medical or judicial medical notes, coroners’ records, and the person’s family. Trend analysis was done using a regression analysis with curve estimation to identify relative importance of key pesticides. Results We identified 337 suicidal deaths. Among them, the majority 193 (57.3%) were due to ingestion of pesticides while 82 (24.3%) were due to hanging. A specific pesticide was identified in 105 (54.4%) of the pesticide suicides. Ingestion of carbosulfan or profenofos was responsible for 59 (56.2%) of the suicides with a known pesticide and 17.5% of all suicides. The increasing trend of suicides due to carbosulfan and profenofos over time was statistically significant (R square 0.846, F 16.541, p 0.027). Conclusion Ingestion of pesticides remains the most important means of suicides in rural Sri Lanka. The pesticides that were once responsible for most pesticide suicides have now been replaced by carbosulfan and profenofos. Their regulation and replacement in agriculture with less hazardous pesticides will further reduce the incidence of both pesticide and overall suicides in rural Sri Lanka.

Pesticide regulation in the European Union and the glyphosate controversy

The glyphosate controversy before the renewal of the authorization of glyphosate in the European Union (EU) once again turned the spotlight on pesticide regulation in the EU. In the EU, pesticides are attracting more public attention than in other parts of the world, and many nongovernmental organizations specifically target pesticide regulation, trying to influence politicians and other decision makers. Following an overview of the EU pesticide legislation and the impact hitherto on EU agriculture, this paper outlines the glyphosate controversy and presents the outcome of desk studies conducted in Germany, the United Kingdom, France, and Sweden on the potential effects of a glyphosate ban on agricultural productivity and farm income. All studies concluded that the loss of income depends very much on farm type and cropping practice, but they all reached the conclusion that particularly no-tillage farming/conservation agriculture will be facing severe problems without glyphosate to control weeds and terminate cover crops. No-tillage/conservation agriculture is viewed as an effective strategy to prevent soil erosion and loss of nutrients, which could become larger problems without glyphosate. Other issues highlighted in the studies were the impact on resistance management, as glyphosate is largely seen as a “herbicide-resistance breaker.” Without glyphosate, fundamental changes in farming practices in the EU are required, and it is hard to imagine that they will come without a cost, at least in the short term.

Achieving a High Level of Protection from Pesticides in Europe: Problems with the Current Risk Assessment Procedure and Solutions

The regulation of pesticides in the European Union (EU) relies on a network of hard law (legislation and implementing acts) and soft law (non-legally binding guidance documents and administrative and scientific practices). Both hard and soft laws govern how risk assessments are conducted, but a significant role is left to the latter. Europe’s pesticide regulation is one of the most stringent in the world. Its stated objectives are to ensure an independent, objective and transparent assessment of pesticides and achieve a high level of protection for health and environment. However, a growing body of evidence shows that pesticides that have passed through this process and are authorised for use may harm humans, animals and the environment. The authors of the current paper – experts in toxicology, law and policy – identified shortcomings in the authorisation process, focusing on the EU assessment of the pesticide active substance glyphosate. The shortcomings mostly consist of failures to implement the hard or soft laws. But in some instances the law itself is responsible, as some provisions can only fail to achieve its objectives. Ways to improve the system are proposed, requiring changes in hard and soft laws as well as in administrative and scientific practices.