BCPC calls for proper risk assessment of possible endocrine disruptors

The stakeholder Consultation by the European Commission on determining what pesticides will be considered as endocrine disruptors (EDs) has just closed. Options proposed by the Commission ranged from retaining the current “interim” criteria in the Plant Protection Products Regulation (1107/2009), through to assessment of the presence of products at toxicologically relevant concentrations.

“BCPC is clear that there is absolutely no scientific justification for the current “interim criteria”, which are based on toxicological effects unrelated to an ED mode of action,” explained Dr. Colin Ruscoe, Chairman, BCPC. “A second option proposed, based on the WHO/IPCS (2002) ED definition, considers neither the dose nor exposure. BCPC believes that regulation should not be applied without reference to the risks of adverse effects occurring in practice. The dose makes the poison; all substances, including oxygen and water, can cause adverse effects, including death, at sufficiently high doses.”

“The third option presented by the EU does allow assessment of whether the product might be encountered at toxicologically relevant concentrations – but does not include additional characteristics, related to severity and reversibility of effect. BCPC believes that these factors – absorption, distribution, metabolism and excretion – should also be included in this risk assessment. Such an approach was recommended by the EFSA Scientific Committee in their Scientific Opinion (March 2013) on assessment of EDs. The pharmaceutical industry operates entirely under such a risk-based assessment. If it did not, we would have no drugs at all, given their intrinsic hazards,” says Dr Ruscoe.

The October 2014 Andersons Report, “The Effect of the Loss of Plant Protection Products on UK Agriculture and Horticulture and the Wider Economy”, identified 17 leading fungicides, herbicides and insecticides that would be lost under the current “interim” ED criteria. This would in turn put greater pressure on the few remaining products, hastening resistance development. A proper risk assessment approach would prevent unnecessary bans of critical crop protection chemicals.

BCPC continues to be concerned that current use of unscientific hazard criteria in EU pesticide legislation, rather than risk-assessment, means research will be even more focused on Americas and Asia Pacific crop protection targets. There, the science-based, more ordered and objective regulatory environment provides an innovation-conducive environment. The EU regime impacts adversely on product innovation for EU agriculture, in turn affecting competitiveness and growth of economies and employment in the EU.