Introduction

Classes and uses of pesticides

Legal framework

Approval Levels

Scientific information in the regulatory process.

Risk Assessment Process

Constitution and function of the various organisations

Management of pesticides in the future.

FUTURE DEVELOPMENTS....

In this report we have attempted to summarise the system by which pesticides are currently regulated in the UK. However, the regulation of pesticides is a continually evolving process, and we can expect it to develop further in the future. Various influences may drive the changes.

Technological advances

One obvious area of development is in the pesticides themselves. In recent years the ACP has considered applications for approval of a number of biological pesticides containing living organisms (eg. Phlebiopsis gigantea a fungus used to control fungal infections in forestry). Such products are attractive in that, superficially at least, they may appear to offer a more natural and targeted method of pest control. However, they pose a challenge for risk assessment. For example, they might carry a risk of infection to people or animals. Current methods of assessing the toxicity of chemical pesticides are not designed to address this sort of hazard, and special risk assessments are therefore required.

Advances also occur in the ways in which pesticides are formulated, packaged and applied. In general these have the effect of reducing the exposure of operators or levels of environmental contamination, and as they become established, they allow tighter controls to be applied to existing as well as new products. For example, in December 1999 changes were required in the containers used for some organophosphate pesticides in order to reduce the potential exposure of operators.

A further area of development is in the way in which pesticides are used. Currently experimental work is being carried out to assess the use of herbicides on genetically modified herbicide tolerant crops as a means of weed control. In theory this might have ecological benefits by reducing the frequency with which herbicides are applied to the crops and perhaps allowing untreated ‘islands’ to be left in a field without a risk of uncontrollable spread of weeds to other parts of the crop. The field scale evaluations considered during 2004 have shown the impact of different crop management regimes on wildlife and in assessing whether this type of herbicide usage will be acceptable on a large scale, it will be important to establish what effects it has on wildlife in practice.

Scientific advances in risk assessment

Changes in the way in which pesticides are regulated may also arise from improvements in the science of risk assessment. Surveillance performed for the Pesticides Residues Committee (PRC) has detected residues of more than one pesticide in the same sample. During the approval of pesticides, active substances are normally assessed singly for their potential impact on human health. However, there are families of pesticides that work toxicologically through the same mechanism and, hence, it is possible that interactions between substances may result in a greater toxic effect than predicted during the approval process. Consumer groups have been concerned for some time about the possible implications of interactions between the components of mixtures of chemicals. In response to this, the Food Standards Agency asked the Committee on Toxicity to establish a Working Group (WiGRAMP) critically to review what is known about the science of mixtures and consider the implications for the risk assessment process.

WiGRAMP was also asked to consider exposure by mechanisms other than consumption of food, such as respiratory exposure to pesticides used in public hygiene, contact with pesticides applied to gardens, parks and veterinary products applied to pets. The report (pdf) of WiGRAMP was published in September 2002 and its conclusions and recommendations have been considered by the ACP. A number of reseachprojects relating to combined exposures have been commissioned. The WIGRAMPreport and the issue of combined exposures to pesticides has been raised with the EC.

The value of the new sciences of toxicogenomics and proteomics to chemical risk assessments has been considered by several expert committees (eg COT-COM-COCS - needs new ref) including the Medical and Toxicology Panel of the ACP. The current view is that this is a rapidly evolving field and at present the relevance to risk assessment is uncertain.

Risk assessment is developing in the environmental area too. Due to concerns raised regarding decreasing farmland bird species and other wildlife, the ACP set up a subgroup to investigate issues related to wider biodiversity. The subgroup has developed a risk assessment scheme that might be suitable for regulatory use. The scheme is designed to try and assess the effects of pesticides on biodiversity and proposes several possible means of mitigating effects. This proposal was the subject of wider stakeholder discussion and consideration at the ACP open meeting 2004 and in other fora.

Click for other ways in which risk assessment for pesticides may be refined in the future as the underlying science advances.

Public opinion and expectations

The regulation of pesticides depends not only on scientific assessment of their efficacy and of any risks that they might pose, but also on the acceptability of the risks that are identified. Judgements about the acceptability of risks are not simply a matter of science and require broader public input. Within the regulatory system this is achieved most obviously through the part played by Ministers of the elected government. Ultimately it is the elected government that has the final say in which pesticides should be approved and with what conditions.

Public attitudes to environmental hazards have changed over the years and the regulatory system must respond to these changes. One requirement has been for greater openness of the decision-making process. In the past there was a tendency not to publicise risk assessments widely for fear that they would be misunderstood and generate unnecessary anxiety. Now, however, the public are likely to be worried more by a failure to disclose information, fearing that a problem is being covered up.

The ACP has historically made much information available, and this openness will continue under the Freedom of Information Act 2000 and the Environmental Information Regulations 2003. As part of this initiative, we have produced a publication scheme listing the information that is already available.

Over recent years, there has also been growing pressure for more precautionary approaches to the management of environmental hazards. Many people worry about the pace of scientific and technological developments and their potential to do harm as well as good. They therefore call for positive evidence that new technologies will be acceptably safe rather than simply assuming adequate safety in the absence of evidence to the contrary. As described in Section 3, the regulation of pesticides is now more precautionary than in the past, and it is likely that this trend will continue.

Administrative changes

The other major factor that is altering the system for regulation of pesticides is the movement towards greater co-ordination within the European Community. As described in Section 3, an important part of the risk assessment for pesticides used as plant protection products is now being undertaken at a European level, and legislation is in place which establishes a parallel scheme for other pesticides (biocidal products). The EU review of active substances used in biocidal products has begun, with a first tranche covering wood preservatives and rodenticides. A second tranche will cover insecticides, molluscicides, repellents, attractants and antifouling products. As the reviews are concluded they will be considered by the Biocides Consultative Committee prior to decision-making in Europe. These products will then move out of the scope of COPR.

It is our intention to update this guide in the future as and when important changes in the regulatory process occur. In order to ensure that future editions are as useful as possible, we would be grateful for any suggestions that readers might have about ways in which the document could be improved.