The European Parliament's environment committee argues that one of the primary intentions of the new rules is to "protect consumer health". Yet, the Pesticides Safety Directorate's (PSD's) revised impact assessment states: "No meaningful benefits to public health protection from any of the criteria have been demonstrated."
The current proposal being "railroaded" through the EU process aims to use a hazard-based system instead of a scientifically based risk assessment of pesticides.
One of the proposed "hazard triggers", endocrine disruption, still has no proper definition, let alone an agreed standardised test for it.
This potentially affects a large number of pesticides, especially the triazole fungicides, a very important group of products on many agricultural and horticultural crops. Residue levels in produce at harvest are either zero or trace levels only, and scientific risk assessment has previously demonstrated that there is a negligible risk to consumers.
It is possible that these products will be banned through the proposed shift to a hazard-based approval system. Consider this though - similar triazole fungicides are also used in human and veterinary medicines. So, on the one hand, environmental "green" lobby groups are suggesting that minute traces of residues of triazole fungicides in our food might do us harm, yet many people willingly swallow triazole fungicides in high doses on advice from their GP.
There are a few other important points. Farmers and growers unable to grow crops economically in the EU due to these proposals will find production being exported outside the EU and subject to "import tolerances", which remain risk-based.
The current hazard trigger approach will effectively stop the registration process in its tracks for certain groups of compounds - the proposed new "neurotoxicity trigger" alone will potentially ban some 20 or so important insecticides.
Rather than applying an automatic cut-off, why not follow the lead adopted by REACH and use the triggers to determine the need for additional data to complete a risk assessment?
Referral of such "at risk" compounds to the European Food Standards Authority would allow for a scientific risk assessment in relation to the intended use.
Pesticides are merely phyto-medicines used to prevent infections but, unlike in human and veterinary medicine, immunisation programmes are not generally available in the agricultural and horticultural sector so control options are much more limited.