Promoting precaution

Concern about the known, unknown and uncertain impacts of chemicals has led public interest groups to lobby regulators to take a more precautionary approach to pesticide safety and approval. David Buffin reports on the debate. 

'Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing cost effective measures to prevent environmental degradation' said the 1992 UN Conference on the Environment and Development(1). In 1990, the heads of EC Member States announced that efforts to protect and enhance the natural environment would be developed 'on the principles of sustainable development and preventative and precautionary action(2).' The European Commission has since developed a more detailed interpretation of the Precautionary Principle(3). The Science and Environmental Health Network (a consortium of North American environmental groups concerned with the wise application of science to the protection of the environment and public health) definition includes health as well as environment: 'When an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically(4).' 

Linking the Principle to pesticides
A paper by the Pesticide Action Network (PAN) Europe examined the pesticide regulation process under Directive 91/414 [for agricultural pesticides](5). It argues that future regulation should encourage a far greater level of protection by incorporating the Precautionary Principle into existing European Union legislation and should reconsider the degree of need for each individual pesticide.

Reporting to the ACP
PAN UK and other public interest groups were asked to present a paper on the Precautionary Principle at a recent Open Meeting of the UK Advisory Committee on Pesticides (ACP) [the body which advises government ministers on pesticide safety](6).    
    Although focused on the situation in the UK, the report has relevance for other national regulatory bodies around the world. It emphasized that future pesticides regulation should be based on the highest protection level available, which means that avoiding the negative impacts or dangers to human health and the environment should take priority over the objective of improving crop production. Agricultural policy should aim for sustainable agriculture, including reduction and replacement of chemical pesticide use, and the pesticide approval process should reconsider the degree and need for each individual pesticide.
Public interest groups do not consider that the ACP is operating the Precautionary Principle sufficiently to satisfy their concerns. Recent meetings among UK public interest NGOs on the Precautionary Principle identified some common elements and recommendations (see below). 

Openness
In spite of increasing transparency at the ACP, aspects of its work remain opaque, for instance: how decisions are arrived at; whether issues are ever voted on; what happens to minority views on the committee; and who is representing consumers interests. 

The paper recommended regulators must:

  • broaden the appraisal process, incorporating wider perspectives;
  • open access to pesticide dossiers, meetings and reports of relevant bodies;
  • clearly define the term 'commercial confidentiality', which should not be used as an excuse for excessive restriction of information;
  • provide access to regulatory committees and inclusion of comments for public interest NGOs;
  • develop pesticide databases on production/sales/usage, and poisoning and pollution incidence reporting;
  • provide more genuine public participation, such as citizens' juries.

Science and uncertainty
Science has an important role to play in identifying hazards, but there are often gaps in knowledge. The level of acceptable risk to people's health and the environment is ultimately the domain of politicians and the wider society. It is they, and not scientists, who should decide what is safe and what is an unacceptable risk. Estimating exposure to pesticides may not always be possible. We may not know how much of the pesticide is being released into the environment. Often protective clothing is not worn, or is not up to acceptable standards. Vulnerable groups such as women, children, the chemically sensitive, and the elderly are exposed to pesticides in food, drinking water and other products, for example toys and carpets. There is an acknowledged lack of understanding of how these chemicals may interact with each other and the implications for public health.
    Pesticide regulation in Sweden provides one example of a stringent approach. A pesticide re-registration programme between 1989 and 1995 led to about 80 pesticides coming off the market because of health or environmental concerns(7).

The paper recommended:

  • increasing resources for monitoring of active ingredients in human health, food and the environment to be substantially financed by industry;
  • introduce the Substitution Principle: A pesticide must not be authorised if it can be substituted by non-chemical methods or active ingredients that are less harmful to human health or the environment;
  • time limiting the pesticide approval period to five years;
  • consideration of introducing mixture toxicity effects into the approvals process;
  • including tests to identify hazards to developing organisms.

Pesticide reduction policies
Precautionary Principle measures should be incorporated into an overarching policy. The approach would establish pesticide use reduction programmes, based on a common framework, with specific numerical targets designed to achieve progressively more stringent, qualitative and quantitative reductions in pesticide use and with regular evaluation and revision involving stakeholder participation. Such an approach would also encourage sustainable agriculture that would increasingly lead to the uptake of alternatives to chemical pest control.

The paper recommended:

  • promotion and support for alternative pest control methods and for research and extension on organic and low-input agriculture;
  • provision of free independent advice and training to farmers on minimizing effective use of pesticides and using non-chemical methods of pest control;
  • setting up a database and independent assessment of non-chemical alternatives;
  • establishment of national pesticide use reduction programmes;
  • introduction of a tax and/or levies on pesticide products.

The terms of reference of the ACP need to incorporate the Precautionary Principle. The European Commission will have increasing influence on pesticide approval in the years to come, and as such the implications for EU legislation need to be considered. PAN will be arguing for the above measures to form the basis of a new EU Directive entitled: EC Directive on measures for reduction of impacts to health and environment from the use of pesticides. 
    If the ACP takes on board the concerns and alternatives raised in this paper some concrete action on reducing the hazards of pesticides in the UK will be accomplished.

1. Earth Summit, UN Environment Programme, 1992.
2. Summit Meeting, EC Member States, Dublin, 1990.
3. Brussels, 2.2.00 COM(2000)1 Final, 2000.
4. Wingspread Statement on the Precautionary Principle, 1998, www.sehn.org/precaution.
5. Position Paper on EU Pesticides Authorisation, PAN Europe, March 2001.
6. Contact davidbuffin@pan-uk.org for a copy.
7. Pers. comm. KEMI, Sweden.

[This article first appeared in Pesticides News No. 53, September 2001, page 10]