Crop Protection Association
CPA
The Crop Protection Association (CPA) is a key voice of the UK Plant Science Industry.
ID: 473338314989-02
Lobbying Activity
Response to Criteria to identify endocrine disruptors for plant protection products
26 Jul 2016
The Crop Protection Association (CPA) strongly objects to numerous aspects of the Commission’s proposal for criteria to identify endocrine disruptors for PPPs and therefore to the proposal as a whole. Fundamentally, as the proposal uses the WHO/IPCS definition alone, it fails to allow all available and relevant scientific evidence to be taken into account when evaluating PPPs for potential endocrine-disrupting properties. Consequently, the criteria will capture substances which present little or no risk. By failing to distinguish between substances dangerous to the environment and health and those that are not, the criteria fail to be fit for purpose as a regulatory tool. CPA objects to the proposal on this basis and urges the Commission and Members States to include hazard characterisation elements in the criteria. These should include not only potency, which was considered in the roadmap, but also severity, reversibility and lead toxicity.
The definition selected by the Commission is unfounded based on its own impact assessment and does not provide any benefit to human health or the environment that could not be achieved without impacting as negatively on the competitiveness of EU agriculture. As detailed in the Commission’s impact assessment, Options 2, 3, and 4 all provide the same high level of protection for human health and the environment, while Options 2 and 3 were identified as impacting most strongly on sectorial competitiveness, agriculture, and trade. Given the equivalence of health and environment protection across the options, the most logical choice would be to select the option which is least damaging to the economy and to food security. The selection of Option 2 therefore cannot be supported by CPA.
Although CPA supports the EFSA Scientific Committee, the Scientific Committee on Consumer Safety, and the BfR consensus statement in concluding that endocrine disruptors must be regulated by risk assessment (i.e. considering both hazard and exposure rather than hazard alone), our view is that this must be built into the criteria rather than having elements of risk and exposure introduced via derogation, as the Commission has proposed. Regulation by derogation indicates that the basic regulation itself is fundamentally flawed and creates uncertainty. In contrast, scientifically robust criteria that are fit for regulatory purposes promote innovation and product development. Innovative solutions and new products are needed in the UK to ensure continued food security and to support the feasibility of resistance management across crop sectors. In the end, it is important that this legislation does not stop farmers and growers having access to products critical to their ability to grow safe, high quality affordable food. If improperly implemented, the loss of triazole fungicides, for example, would likely result in a total inability to grow bread making wheat in the UK and Ireland, due to a lack of tools to control key diseases caused by Septoria and Fusarium.
We therefore ask that the Commission and Member States reconsider the proposal with a view of developing proportionate and science-based criteria for endocrine disrupting properties which are fit for purpose as regulatory tools that can distinguish between substances dangerous to the environment and health and those that are not.
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