Final Minutes of the 310th meeting of the Advisory Committee on Pesticides (ACP) held on 18th November 2004
The Advisory Committee on Pesticides provides independent advice to Ministers on matters relating to the regulation and use of pesticides, including applications for approval of new products and reviews of existing approvals. It usually meets in closed session (because of intellectual property and commercial secrecy considerations) approximately six times a year in York.
Those present:
Chairman: Prof D Coggon
Members: Mr J Clarke, Dr R Clutterbuck, Prof G Edwards-Jones, Dr C Elcombe, Dr I Grieve, Dr C V Howard, Ms R Howells, Prof D Macdonald, Prof G Matthews, Ms D McCrea, Dr P McElhatton, Dr D Osborn, Prof R Smith, Mr C Stopes, Dr V Tohani.
Apologies: Dr D N Bateman, Dr J Cherrie, Prof L Maltby, Dr R Waring, Department of Health (DoH), English Nature (EN), Food Standards Agency (FSA), Rothamsted Research Centre (RRes)
Observers : Prof. D R Coleman, Prof G Hawksworth, Dr G M McPherson
Written comments received from: Dr D N Bateman, Dr J Cherrie, DoH
Representatives from the following Departments and other organisations were present: The Pesticides Safety Directorate (PSD), Health & Safety Executive (HSE), Food Standards Agency (FSA), Department of Health (DoH), Scottish Agricultural Science Agency (SASA) Department for Environment, Food and Rural Affairs (Defra), National Assembly of Wales Agriculture Department (NAWAD), Department of Agriculture and Rural Development Northern Ireland (DARDNI).
At its meeting on 18th November 2004, the Committee discussed the following issues:
1. Agenda Item 1: Minutes and Detailed record of discussion
1.1 a) 309th Meeting: Minutes [ACP 1 (310/2004)]
1.1.1 Agreed as drafted.
1.2 b) 309th Meeting: Detailed record of discussion [ACP 2 (310/2004)]
1.2.1 Agreed as amended.
2. Agenda Item 2: Secretary’s report. [ACP 3 (310/2004)]
2.1 The Secretary to the Committee reported on the recommendations made at previous meetings
3. Agenda Item 3: Matters arising
3.1 a) Sulphuric acid – Letter from J Gathercole [ACP 7 (310/2004)]
3.1.2 Following the Committee’s discussion of sulphuric acid at its September meeting, Ms J Gathercole, a member of the public, had written to several members expressing concerns about pesticidal use of the compound. The Committee agreed that the Chairman should reply to her, clarifying the ACP’s position on the matters raised.
3.2 b) Correspondence with the authors of the ‘Ontario Report’ [ACP 14 (310/2004)]
3.2.1 The Chairman had contacted the authors of the ‘Ontario Report’ as had been agreed at the September meeting.
3.2.2 The Committee discussed a response received from the ‘Ontario Report'’s authors to the ACP statement . The Committee appreciated the authors’ willingness to engage in discussion of the report, and sympathised with the constraints under which the authors had worked. The Committee agreed that the response should be published on the ACP website.
3.2.3 Most members felt that the response did not alter their previous view that the report did not indicate a need for regulatory action or further examination of possible links between ill health and pesticide exposure beyond those already initiated as a result of the ACP’s own monitoring of the scientific literature. However, four members felt that in the light of the response they wished to issue a minority statement.
3.2.4 A draft minority statement was discussed and accepted by the four members. Other members suggested some modifications to better reflect the views of the rest of the Committee. It was agreed that a final minority statement would be completed by the four members and that this would be placed on the ACP's website.
3.2.5 It was further agreed that it would be helpful to readers of the website to set the minority statement in context, both with regard to the scientific process being followed, and also concerning the expertise of those who put their names to it.
3.3 c) Beauveria bassiana – advice from the Advisory Committee on Releases to the Environment (ACRE)
3.3.1 At its July meeting , the Committee had identified a need for expert microbiological advice on this new biological pesticide. The Committee discussed advice which had now been received from ACRE, and agreed the additional data requirements ACRE had proposed.
3.3.2 The Chairman explained that the Committee does not currently include a microbiologist as this kind of expertise is needed only infrequently. He would write to thank ACRE for their help.
3.4 d) Other matters arising [ACP 17 (310/2004)]
3.4.1 The Secretary presented a report on other matters arising. Most actions had now been completed.
3.4.2 HSE informed the Committee that standards for bait containers had now been discussed by the Biocides Consultative Committee (BCC) who were supportive of the proposed development of new BS/EN standards. HSE would maintain contact with the industry. Given the likely timescale for development of these standards it was probable that further work in this area would fall to the BCC to take forward.
3.4.4 In response to a question from an ACP member, PSD explained that following the announcement of closure of Biotechnology and Biological Sciences Research Council (BBSRC) Silsoe, the future of pesticides application research in the UK was still unclear. However PSD was continuing to work with both Silsoe and others, seeking a satisfactory way forward for research on application technology.
4. Proposed methodology for operator risk assessment for formulations containing more than one active substance [ACP 11(310/2004)]
4.1 The Chairman had outlined the principles of this proposed methodology at the September meeting, and these had subsequently been considered by the Medical and Toxicology Panel at their October meeting. The Panel had concluded that the methodology provided a conservative risk assessment, and represented a sensible logical approach.
4.2 The ACP agreed that the methodology as set out in the paper was appropriate, but requested some further clarification of terminology to remove ambiguity
4.3 Members confirmed that this guidance should be used by PSD in risk assessment of formulations containing more than one active substance where there is a potential for combined toxicity equivalent to additivity of dose. It was recognised that the approach would not be appropriate if other patterns of combined toxicity were anticipated.
5. Second evaluation for UK provisional approval (COPR) of the product ‘Scenic’ as an agricultural fungicide for seed treatment – further consideration of operator exposure [ACP 10 (310/2004)]
5.1 Approval had been requested for ‘Scenic’, a flowable concentrate for seed treatment, containing fluoxastrobin, prothioconazole and tebuconazole. A combined risk assessment for operators covering the three active substances in the formulation formed part of the application. At the September meeting the Committee had proposed a revised methodology for operator exposure risk assessment in such cases.
5.2 The applicant had provided further information and a revised risk assessment. In the light of this additional information the Committee agreed they could now recommend provisional approval for the product.
6. Review of long term arrangements for extension use of pesticides [ACP 5 (310/2004)]
6.1 Arrangements for extension of use of pesticides have been in place since 1988. They provide a ‘light touch’ regulatory approach under Control of Pesticides Regulations (COPR), enabling the use of approved pesticides for minor uses in situations where the risks will be the same or less than from an approved ‘on-label’ use.
6.2 The current arrangements are due for review at the end of 2004. However, these arrangements will not be valid under the Plant Protection Products Regulations (PPPR) which are progressively superseding COPR, and under which, individual approvals will be needed for each crop/product combination.
6.3 The Committee agreed to PSD’s proposal that the current arrangements for extension of use under COPR should remain in place for a short time without further review, while resources were concentrated on developing a replacement system under PPPR.
6.4 The Committee was pleased to note that the replacement individual product approvals would represent an improvement on the current arrangements in terms of a more transparent risk assessment.
7. Draft ‘regulatory update’ on PSD and ACP approach to assessing the mammalian toxicity of two or more compounds in a pesticide product (formulation) that might interact. [ACP 15 (310/2004)]
7.1 The Committee had discussed a previous version of this regulatory update at the September meeting , and the document had since been revised by the Medical and Toxicology Panel.
7.2 The Committee agreed that with some changes to clarify terminology this document would give companies useful guidance on what data are likely to be needed for approval of products containing more than one active substance.
8. Consultation on the offence of possession of any pesticide containing one or more prescribed active ingredient [ACP 12 (310/2004)]
8.1 A new offence of possessing particular pesticides without a lawful excuse has been introduced under the Wildlife and Countryside Act in Scotland. This is designed to assist enforcement authorities in Scotland to address the abuse of pesticides for poisoning birds of prey and other wildlife.
8.2 The Committee agreed a response to a consultation document issued by the Scottish Executive concerning the implementation of the legislation. The proposed list of specified pesticides included those that were most commonly abused, and members noted the importance of ensuring flexibility so that others could easily be added in the future should the need arise. The Committee felt it was important that penalties for offences under the Act should be sufficiently severe to have a deterrent effect.
8.3 The Committee noted that they would be consulted on forthcoming separate but similar proposals for England and Wales.
9. Report from 30th meeting of the Medical and Toxicology Panel held on 12 October 2004 [ACP18 (310/2004)]
9.1 The Committee noted the report of this meeting.
10. Pesticides and Parkinson’s Disease [ACP 19 (310/2004)]
10.1 The Medical and Toxicology panel had considered the report of a Defra funded review of the scientific literature on links between Parkinson’s Disease and pesticide exposure in some detail at their October meeting. The Panel had agreed with the proposals made by the authors of the review that further mechanistic research would be the best way forward.
10.2 The Committee also agreed that further mechanistic research was necessary. In addition, they considered that further epidemiology could be useful where exposure to specific pesticides could be ascertained with reasonable confidence (e.g. cohort studies of pesticide production workers or long-term prospective studies of pesticides users). The review indicated a correlation between recalled pesticide exposure and Parkinson’s Disease, but did not point to a particular toxic mechanism or a hazard from a specific compound or group of compounds.
10.3 One member was keen for the full report to be published as soon as possible. Others felt that waiting for the Medical Research Council (MRC) Institute for Environment and Health to organise publication through peer reviewed journals, as is normal with government research, would be more appropriate. PSD advised the Committee that dissemination had already commenced with the presentation of a poster at a recent conference.
11 HSE Field Operation Directorate’s Pesticide Incidents Report 2003/2004 [ACP 24 (310/2004)]
11.1 The Committee discussed this report of pesticide incidents investigated by the Field Operations Directorate of HSE between April 2003 and March 2004. Members noted that there had been no increase in the frequency of complaints, that no major health effects had been reported, and that reported environmental incidents related predominantly to damaged hedges immediately adjacent to treated areas. The Committee noted that phenoxy acid herbicides were implicated in an increased number of incidents, and asked for further details on this.
11.2 The Committee discussed ways in which data collection could be improved to enable better use of the data.
12 Date of next meeting: 13 January 2005
13 Any other business
13.1 Human Health Questionnaire [ACP 9/1 (310/2004)]
13.1.1 The Committee discussed an outline report of the results from
PSD’s exercise seeking details of reports made to approval holders where users had human health concerns.
13.1.2 The Committee noted that this exercise had asked for details of all reports, even where any link to pesticides was tenuous, whereas the current requirement on approval holders to report adverse data was limited to more substantial concerns. Although no reports had been received indicating a major health effect, members asked to receive summary details of each incident at a future meeting to enable them to make better use of the information.
13.2 Indirect Effects of Pesticides on Wildlife
13.2.1 Following discussion at the previous day’s Open Meeting the Committee discussed the next steps for this work. Defra agreed to report back to the ACP on progress as the recommendations of the Committee were considered in the future development of policy in the department in the mid to longer term. In the meantime PSD agreed it would be useful to draw out straightforward advisory messages for users on this issue. The ACP asked the Environmental Panel to consider prioritisation of the research proposals set out in the paper to assist their consideration in the PSD and Defra research strategies.
13.3 Members standing down
13.3.1 This was the last meeting for three members of the Committee as their terms of appointment came to a close at the end of 2004. The Chairman led the Committee in thanking these members for all their hard work.
[Professor David Coggon
January 2005]