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Changing the rules of the Codex club

The Codex Committee on Pesticide Residues (CCPR) has been quietly meeting since 1966 to establish maximum residue limits (MRLs) for pesticides in food.  Does it promote public health, or the interests of pesticide companies? Lisa Lefferts, one of the few public interest representatives, reports on the inside workings of Codex.

Consumers International (CI), representing more than 220 consumer organisations worldwide, has been urging the Codex Committee on Pesticide Residues (CCPR) to redress its risk assessment procedures, and in particular not to advance MRLs for organophosphate (OP) pesticides, which pose particular risk to children, until risk assessments for pesticides address the following facts:

  • the greater exposure of children to pesticides than adults

  • the wide variation in consumption of foods and in residues in foods among infants and children

  • multiple residues in the diet, of pesticides sharing a common mechanism of action (for example, OPs)

  • the greater vulnerability of children, infants, and foetuses to the toxic effects of pesticides, compared to adults

  • the significant non-dietary exposures to OPs and other pesticides that many people, particularly children, receive

  • the full spectrum of acute and chronic effects of pesticides.

Mixed success
Our success to date has been mixed. CI was extremely active and vocal at the last CCPR meeting, probably making more interventions than any other delegation present. An international conference was held in the UK focusing on issues relating to the variability of residues and acute toxicity concerns and a second international conference will be held in April 1999, immediately prior to the next CCPR meeting, in the Netherlands, addressing many of the same concerns. CI was invited to make a presentation at both conferences. While CI's comments were pertinent, most of our interventions did not garner sufficient support for the Committee to reach consensus on them. Codex decisions are normally made by consensus. And several delegates have tried to block CI from including statements representing its views in the final report.
    CCPR did request the Joint Meeting on Pesticide Residues (JMPR) to evaluate the issue of a common mechanism of toxicity of OPs and carbamates at its next meeting-something CI had urged-which was held late in 1998. The JMPR is a FAO/WHO body consisting primarily of experts from (or retired from) government that meet in closed session. JMPR conducts risk assessments and proposes MRLs for CCPR. While the report of the meeting is not yet available, it seems the JMPR has made little progress in dealing with the combined residues of OPs in the diet as a group.
    At the last CCPR meeting, draft MRLs for OP insecticides were progressed to the next step of the Codex procedures, despite CI opposition. All draft Codex standards, including MRLs, do not become finalised until the Codex Alimentarius Commission adopts them. The Commission, which meets every two years, will meet this summer in Rome. CI will oppose the approval of MRLs for OPs at that meeting.
    Meanwhile, at the York meeting, the toxicology working group did agree that residues with a common mechanism of action (such as OPs) should be combined for acute risk assessment.

Dominance of industry 
The 1998 CCPR meeting was attended by more than 200 delegates from 49 member countries and 15 international organisations. Business and government interests outnumber consumer and environmental interests almost 50 to one. CI and the International Co-operative Alliance generally are the only public interest international organisations observing the meeting, each consisting of a delegation of two.  The only other member of a public interest group present was a representative from Pesticide Action Network in Germany, who sits on the German national delegation. In contrast, pesticide and food industry consultants and representatives abound, both on international delegations, as well as country delegations. The Global Crop Protection Federation delegation, which represents the pesticide industry, included 30 members at the 1998 meeting. Three of the four members of the Swiss delegation represent industry (Novartis and Nestec/Nestlé). Mingled into other delegations are representatives from Dow, Monsanto, and a multitude of multinational companies, from Avcare to Zeneca.

Greater Third World input needed
Most of the work on residue analysis has been done in developed countries,  such as the US, EU, Australia, and Canada, that have in general a relatively well regulated food supply- and enough to eat. But in developing countries, pesticides that are acutely toxic in the short term are widely used. Vulnerable populations are those whose main diet consists of food treated with OP or carbamate pesticides, and whose diet is the same day in day out. Codex is mainly concerned with food in international trade, not for domestic food production. Who is looking out for the safety of home produced grains, vegetables and pulses where the outlook for the consumer is a regular diet of OP residues?

Consumers must speak up
Codex's ability to affect our health is increasing, as it plays a more important role in global trade. Members of the public who are concerned about these issues need to learn more about Codex and CCPR, and to make their voices heard in the Codex arena. To find out about upcoming Codex meetings and agenda items under discussion, or to locate the Codex Contact Point in your country, visit the FAO Codex website, at http://www.fao.org./waicent/faoinfo/economic/esn/codex/default.htm. You can also find out who represents your country at CCPR meetings by downloading the latest report of the CCPR meeting, which can also be found at the FAO Codex website. Let that person know that you support the agenda items laid out by Consumers International, above. Your voice is desperately needed to make Codex listen to our concerns.

Lisa Lefferts is a consultant to Consumers Union in the US and Consumers International in London, who has been attending CCPR and other Codex meetings for several years.

Action needed
Specifically, CI has asked CCPR to:

  • use an additional safety factor to protect children, infants, and foetuses in the absence of reliable data on the effects of pesticides on developing organisms, such as when there are no pesticide-specific tests on immature animals for effects on the developing brain, endocrine and immune systems;

  • establish MRLs which protect highly exposed children and other vulnerable populations;

  • explicitly consider non-dietary, non-occupational exposures to OPs and other pesticides in establishing MRLs;

  • take into account both acute and chronic risks when establishing MRLs;

  • develop explicit risk assessment policies based on sound science which clearly identify components of the process where uncertainties exist and where assumptions and value judgements must be made, and which provide guidance on how to do so, in order to enhance transparency and involve the public;

  • balance reports more fairly, to include those assumptions that tend to lead to an underestimate of risk, as well as those that tend to lead to an overestimate of risk;

  • explicitly consider "other legitimate factors" (other than science) which are or should be considered in elaborating and deciding upon standards for pesticide residues in food;

  • strongly endorse IPM and other methods which reduce residues, and encourage countries to use IPM and set IPM goals, and report on their successes annually.

[This article first appeared in Pesticides News No. 43, March 1999, page 6]
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