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 eight times a year in York.
Those present:
Chairman: Professor D Coggon
Members: Dr J Cherrie, Mr J Clarke, Dr R Clutterbuck, Professor G Edwards-Jones, Dr C Elcombe, Dr I Grieve, Ms R Howells,
Dr C V Howard, Dr L Maltby, Professor G Matthews, Ms D McCrea, Dr P McElhatton, Dr D Osborn, Professor R Smith, Mr C Stopes,
Dr V Tohani, Dr R Waring.
Apologies: Dr D N Bateman, Professor D Macdonald.
Representatives from the following Departments and other organisations were present: The Pesticides Safety Directorate (PSD), Health & Safety Executive (HSE), Food Standards Agency (FSA), Scottish Agricultural Science Agency (SASA), English Nature (EN), Environment Agency (EA), Rothamsted Research Centre (RRes), Department for Environment, Food and Rural Affairs (Defra).
At its meeting on 18 March 2004, the Committee discussed the following issues:
Agenda Item 1:
1.1 a) 305th Meeting: Minutes [ACP 1 (306/2004)]
1.1.1 Agreed. (view minutes of 305th meeting)
1.2 b) 305th Meeting: Detailed record of discussion [ACP 2 (306/2004)]
1.2.1 Agreed as amended.
2. Agenda Item 2: Secretary’s report. [ACP 3 (306/2004)]
2.1 The Secretary to the Committee reported on the recommendations made at the meeting held on 15 January 2004
3. Agenda Item 3: Matters arising
3.1 a) Health Risks from the use of Polyacrylamides in Pesticide Formulations [ACP 10 (306/2004)]
3.1.1 At the 302nd meeting of the Committee held on the 4th September 2003, a member had asked about possible health risks from exposure to contaminant acrylamide monomer in the polyacrylamides that are used in some pesticide formulations. HSE had responded that they held data that were relevant to this, and had undertaken to provide these to the Committee.
3.1.2 In follow-up to this, members were now presented with information from an EU review of acrylamide, which indicated that levels of the monomer in polyacrylamides were very low. HSE reported that polyacrylamides are used in only a few rather specialised formulations of pesticides, and that given the amount of polymer present in these products, an extremely low operator exposure to acrylamide was predicted.
3.1.3 Members noted that the predicted exposure to acrylamide monomer would be very much lower than from dietary intake of acrylamide formed in food during cooking, and concluded that any risks to users of these pesticides were minimal. The Committee agreed that no regulatory action was needed.
3.2 b) Pesticide disposal [ACP 17 (306/2004)]
3.2.1 At an earlier meeting a member of the Committee had undertaken to produce a paper on pesticide disposal and this was now presented to members.
3.2.2 Prior to a discussion of the paper, Defra advised members that changes were expected to waste disposal regulations, and that a related consultation process was expected to start in the near future. Defra confirmed that the consultation could be copied to members. The Chairman suggested several points that might usefully be addressed in the background to such a consultation including: the distinction between pesticides and their containers; the distinction between farm, other professional and amateur use; the current regulations and any problems that are known to have occurred with them; and potential changes in the need for disposal of pesticides and their containers as a consequence of the withdrawal of approval for some products. He considered that the ACP would need this type of information before it could give properly informed consideration to the matter.
3.2.3 Defra agreed that a further paper could be prepared for the Committee along these lines. The Environment Agency (EA) representative told members that EA colleagues were working with PSD on this area of policy, and suggested that EA could contribute information to the paper.
3.2.4 Members agreed that they needed more information and would consider the matter again when the further paper had been received.
3.3 c) First evaluation for UK provisional approval (PPPR) of cyflufenamid as an agricultural fungicide, in the product ‘NF-149 EW’ and first consideration of the inclusion of cyflufenamid in Annex I of Directive 91/414/EEC [ACP 5 (306/2004)]
3.3.1 Following consideration of this application at the January 2004 ACP meeting further data on the compound's mammalian toxicology had been requested. Some additional information had now been supplied by the applicant.
3.3.2 Members agreed that this new information was helpful, but concluded that some issues still required further clarification before approval could be recommended.
3.4 d) E-mail correspondence relating to the aquatic risk assessment of fluoxastrobin [ACP 16 (306/2004)]
3.4.1 Provisional approval of fluoxastrobin had been considered by the Committee at their last meeting.
3.4.2 The Chairman reported that, as noted in the post meeting note in the minutes of that meeting, following discussion by relevant members, it had been possible to make a recommendation for approval. This had subsequently been accepted by departments.
3.5 e) Impacts of Genetically Engineered Crops on Pesticide use in the United States: the first eight years. C Benbrook [ACP 4 (306/2004)]
3.5.1 There had been references to this paper by C Benbrook in the information presented to the ACP at its last meeting, as well as in the media. Members were now asked whether the information in the paper about pesticide usage on GMHT (genetically modified herbicide tolerant) crops in the USA had implications for the UK.
3.5.2 The Committee had a number of reservations about the quality of the information presented in the paper and its interpretation by the author. Data had in some cases been extrapolated from one year to another, and the basis for some of the conclusions about explanations for trends was unclear.
3.5.3 The Chairman asked whether any lessons could be drawn with regard to methods of monitoring for possible effects on pesticide usage should GMHT crops be grown in UK in the future. Members commented that data would best be collected as part of the programme of work carried out by the Pesticide Usage Survey Group (PUSG), and it was agreed that one member should liaise with PSD outside the meeting to discuss what changes to current arrangements might be required in order to optimise the assessment of possible changes in pesticides usage.
3.6 f) Consultation on Bystander Exposure [ACP 23 (306/2004)]
3.6.1 The Pesticides Action Network (PAN) had proposed to Ministers that a Health Impact Assessment, integrated with an Environmental Appraisal, be required as an additional means of establishing the health risk to bystanders from pesticides. The Minister had asked for comments on this proposal from the health experts on the ACP.
3.6.2 The health expert members considered that health impact assessment was not appropriate in this context, since the current approach to risk management for pesticides was designed to ensure with reasonable confidence that no bystanders would suffer adverse toxic effects from the use of pesticides according to the conditions of approval.
3.6.3 Two members expressed their disappointment that papers collating responses to the recent consultations on crop spraying, bystanders and buffer zones had not yet been passed to Ministers and that no date could yet be given for when this would happen.
3.7 g) Other matters arising [ACP 24 (306/2004)]
3.7.1 The Secretary presented a summary of actions taken on other matters arising. Members noted with concern the BBSRC plan to close the Silsoe research centre.
4. Report from Environmental Panel meeting held on 26 February 2004 [ACP 22 (306/2004]
4.1 The Chairman of the Environmental Panel presented a short summary of the most recent Panel meeting.
5. First evaluation for UK approval (COPR) of Benthiavalicarb-Isopropyl (KIF-230) as an agricultural fungicide in the product ‘KIF 230 + Mancozeb’ for use on potatoes [ACP 6 (306/2004)]
5.1 Benthiavalicarb-isopropyl (code name KIF 230) is a new valinamide fungicide. The Committee was asked to consider approval for the use of ‘KIF-230+mancozeb’, a wettable granule formulation containing 17.5 g/kg benthiavalicarb-isopropyl and 700 g/kg mancozeb, on potatoes (including early and maincrop varieties and seed crops).
5.2 One member declared a non-personal specific interest in this item and was informed that he should therefore only contribute to the discussion if asked to do so by the Chairman.
5.3 After discussion, members agreed that they required further data to address toxicological concerns and that they could not recommend approval at this stage.
6. First evaluation for UK Provisional Approval (COPR) of Prosulfocarb, formulated as an emulsifiable concentrate containing 800G/l Prosulfocarb [ACP 8 (306/2004)]
6.1 Prosulfocarb is a thiocarbamate herbicide. The Committee was asked to consider approval for the use in the UK of an emulsifiable concentrate containing 800 g/L prosulfocarb for use on winter wheat and winter barley.
6.2 One member declared a non-personal specific interest in this item and was informed that he should therefore only contribute to the discussion if asked to do so by the Chairman. Another member declared a lapsed interest (7 years) and was advised that this did not preclude him from taking part in the discussion.
6.3 After discussion, members agreed that they required further data to address toxicological and environmental concerns and that they could not recommend approval at this stage.
7. Application for the use of ‘ECOguard® granules’, a (granular formulation) containing 45 % w/w garlic juice concentrate formulation type), as an agricultural/horticultural insecticide on various brassica crops [ACP 19 (306/2004)]
Post meeting note: Following the meeting one member declared a personal specific interest. He had assumed that this interest had lapsed since he had no involvement since 2001.
7.1 ‘ECOguard Granules’ is a granular formulation containing 45 % w/w garlic juice concentrate (Allium sativum extract). Garlic juice concentrate was first considered by the ACP at its meeting in March 2002. At that meeting, the Committee concluded that while the information submitted by the approval holder did not indicate any major adverse effects, further data were required to complete the risk assessment. In addition the efficacy data had indicated a variable response. Ecospray Limited had now submitted some further data.
7.2 The majority of members considered that, in line with the Committee's previous conclusions, further clarification was still required on the technical specification of the pesticide before approval could be recommended. In addition, the further data provided on efficacy again indicated a variable response, making interpretation difficult. A subgroup of members was asked to examine the evaluation of efficacy in more detail and report back to the next meeting.
8. UK Data Review: Oxadiazon [ACP 9 (306/2004)]
8.1 Oxadiazon is an oxadiazolone herbicide which currently holds approval for use on amenity vegetation, in ornamental plant production, around the base of fruit trees and in between rows of hops and cane fruit bushes. Following a submission of new data, the advice of the Committee was sought to establish an AOEL (acceptable operator exposure level).
8.2 Members confirmed reference values [ ADI (acceptable daily intake) , ARfD (acute reference dose) and AOEL] based on the data provided, but noted that whilst estimates of consumer exposure were acceptable, initial estimates based on limited data indicated a need for further clarification of operator exposure levels. The Committee asked that this further clarification be provided for consideration at the July meeting.
9. Second evaluation of Bis-(N-cyclohexyldiazeniumdioxy)-copper (Cu-HDO) for use as an industrial wood preservative [ACP 14 (306/2004)]
9.1 At the 298th meeting of the Committee, Members had considered an application from a company seeking approval for an industrial wood preservative containing the new active ingredient, bis-(N-cyclohexyldiazeniumdioxy)-copper (Cu-HDO). At that time, members had asked for clarification on various issues relating to mammalian toxicology and environmental risks. The Committee was now asked to consider an amended application for approval of Cu-HDO, incorporating additional information.
9.2 Members considered that the applicant company’s arguments for not submitting further mammalian toxicology studies were adequate. This was because the potential for exposures to Cu-HDO was sufficiently low, particularly if new gloves were worn for each usage period.
9.3 Members also examined the potential environmental risks posed by this product, particularly through release to surface water. Members agreed that provisional approval could be recommended subject to additional labelling requirements and submission of further environmental data post-approval.
9.4 Members asked HSE to prepare a report for a future meeting collating EA monitoring data on copper concentrations in watercourses near to timber treatment sites with data previously considered for the review of copper/chrome/arsenic (CCA).
10. UK Human Health Review of Thiodicarb – revised ADI, ARfD and consumer risk assessment [ACP 18 (306/2004]
10.1 Thiodicarb is a carbamate moluscicide and was considered as part of an ongoing UK human health review of anti-cholinesterase compounds. The document presented to the Committee contained a reassessment of consumer risk based on revised ADI and ARfD endpoints agreed by the ACP at their meeting in February 2003.
10.2 The Committee noted that the revised assessment indicated a theoretical potential for exceedence of the ARfD (acute reference dose) for methomyl (a metabolite of thiodicarb) from consumption of imported produce, but that in practice this was very unlikely to be a problem. They agreed that this issue would best be resolved as part of an ongoing EU Review of thiodicarb and methomyl. Meanwhile, they confirmed that UK approvals for thiodicarb could continue.
11. Application for approval for the use of ‘Galera’ as an agricultural herbicide on winter oilseed rape [ACP 20 (306/2004]
11.1 Galera is a new soluble concentrate formulation containing 267g/l clopyralid and 67g/l picloram intended for the control of cleavers and mayweeds in winter oilseed rape. Clopyralid is currently approved in a number of products for use in various circumstances, including on a range of edible crops. Picloram is also currently approved in several products, but not for use on edible crops. The paper presented to the Committee addressed the evaluation of the proposed first use of picloram on an edible crop.
11.2 Members considered the application and agreed reference doses (ADI and ArfD). The Committee confirmed that approval was appropriate for ’Galera to be used on oilseed rape as proposed.
12. Draft ACP Annual Report 2003 [ACP 21 (306/2004)]
12.1 The Committee was asked to consider a draft of the ACP Annual Report for 2003.
12.2 The Chairman asked members to confirm their current declarations of interest for inclusion in the Report, and to provide any other comments to the Secretariat. (View previous ACP Annual Reports)
13. Date of next meeting: 20 May 2004
14. Any other business
14.1 The Chairman responded to a concern raised by one member who had recently been asked to provide advice to HSE outside a meeting on a detailed issue that was peripheral to their main area of expertise. The Chairman said that in giving advice, members should make clear the limits of their expertise, and that departments should then take this into account. He noted that the Committee had the option to call on outside expertise on an ad hoc basis if it was required. It was agreed that the member concerned would discuss the way forward with HSE outside the meeting.
14.2 The Chairman told members that he had received a letter from Pesticides Action Network asking if representatives could attend ACP meetings as observers.
14.2.1 In discussion it was pointed out that if this request were granted, the opportunity to attend would have to be made available to others who made similar requests, and that this might be difficult to accommodate. In addition, based on recent experience, there were doubts that external observers could be trusted not to misrepresent the Committee’s proceedings in the media. In addition, some of the material considered by the ACP was commercially confidential, and the presence of external observers could be a threat to this confidentiality if it were not carefully controlled. Members concluded that these were real difficulties and that the request should therefore be refused. They noted that the ACP holds an annual open meeting at which all are welcome and that Ministers had appointed two lay members to the Committee specifically to ensure that consumer and environmental interests are represented in the advice provided.
14.3 Members had been sent, at her request, a video and written submission to the bystander consultation that had been prepared by Georgina Downs. The Chairman asked if there were any comments. Not all members had watched the video as they did not have access to a video recorder, but the Secretary to the Committee had prepared a written summary of its content. Members concluded that the video and written submission did not include information that would lead them to change their previous advice on health risks to bystanders.
Professor David Coggon
[ 2004]
