The 12th Annual Open Meeting of the ACP was held at The Park Inn York on Monday 14 November 2011. The Agenda (below) included the launch of the Draft Report from ACP's Pesticide Adverse Health Effects Surveillance Working Group (PAHES), the ACP and Climate Change and an update on Bees and Pesticides. In a return to the previous format of smaller discussion groups, the afternoon session featured working group discussions of the key agenda items.
Over 100 attendees participated in a wide ranging discussion of the Agenda issues.
12th Annual Open Meeting of the Advisory Committee on Pesticides (ACP) - The Park Inn, North Street, York, Monday 14 November 2011, commencing 11am.
1. Welcome - Professor Jon Ayres, Chairman of the ACP
2. The ACP and Climate Change
3. Launch of the Report of the PAHES
4. Bees and Pesticides - update on the latest information
6. Afternoon Workshop Discussions
- PAHES Working Group Draft Report
- Climate Change
- Bees and Pesticides
7. Summary of Workshop Discussions
9. Tea/coffee and depart
Presentations to the 2011 Open Meeting
The presentations from the Open Meeting can be viewed here.
Notes from the 12th Annual Open Meeting of the ACP
The ACP held its 2011 open meeting on 14 November 2011. As usual there were over 100 participants and lively discussion on all three of the key topics discussed.
A short summary of the discussion is provided for each topic.
1.BEES AND PESTICIDES
1.1 The latest draft data requirements indicate the need for laboratory data on the acute oral and contact toxicity of a pesticide to adult bees, the chronic toxicity to bees as well as data on the effects on honey bee development and other honey bee life stages.The endpoints from these studies will then be used in a standardised risk assessment.Are there any further data that you feel should be generated to carry out an initial risk assessment?
Initial risk assessment
The group agreed the need for international standardisation and good statistical robustness of a chronic bee toxicity guideline. This will need to be progressed through OECD as soon as a promising protocol has been developed.
Foraging performance was an important behavioural end point, but there was a challenge as to how this might be measured.Possibilities included recognising key behavioural changes in the standard lab tests that could be related to and provide an analogue of likely impacts on foraging behaviour in the field. One of the problems is that such endpoints are notoriously difficult to standardise because of poor reproducibility between laboratories. It is therefore not expected that a standardised chronic bee toxicity guideline will be quick to develop (perhaps 5 years).
Hive performance was also an important end point, and may reflect a summation of small (and potentially undetectable) effects on individuals that became more significant at hive level.‘Hive products’ such as wax could also provide useful data.Such endpoints would be appropriate for semi-field and field studies rather than laboratory studies.
The sensitivity of trigger values selected will be important. Triggers should be chosen by comparing the results of laboratory chronic studies with those from field studies for a number of test materials, and picking values which only allow a move to field studies in cases where there is a realistic prediction of longer-term adverse health effects.
1.2 If on the basis of the initial assessment concern is raised semi-field/field trials are conducted.CRD has highlighted that these studies should, where necessary, continue overwinter and hence determine if there are any prolonged effects on colony survival.Is there any further information that you feel should be generated to determine if there is any long-term or delayed effect on colony survival?
Semi-field and field trials Should there be consideration of multiple chemical exposures and if so how? This could be an important issue, especially in situations where more than one systemic insecticide is proposed for use simultaneously on a crop. However, the logistic difficulties of mixture experiments should not be underestimated, and it recognised that testing all possible mixtures is unrealistic.This issue of exposure to multiple compounds is not one that is specific to bees and represents a general challenge to environmental risk assessment for pesticides.
What is the impact of the use of bee health chemicals?There is possibly a need for joined up working in considering pesticides, bee health and bee medicines.For example, to keep experimental bees in good health, it may be necessary to treat them with a miticide before testing which might in turn have additive or synergistic effects together with the test substance. On the other hand, untreated bees may have Varroa infections which could weaken them and also cause heightened sensitivity to the test material
Queen health could be an important consideration.Is there a need for specialist trials perhaps?
How long should the studies be for is an important point to consider, but there was general agreement that over-wintering performance of hives is a key factor for consideration.
1.3 SETAC developed a risk assessment scheme for non-apis bees; EFSA is considering a risk assessment scheme for honey bees, bumble bees and solitary bees.Are there any specific species of bees that should be considered?
What species? Bombus spp, other pollinators such as hoverflies and butterflies could be considered, but it was uncertain where these sit in the species sensitivity distribution, and this would be an important factor in the selection of representative groups.
Colony collapse disorder The group recognised this was not a significant issue in the UK compared with some other countries at present.The group also noted the importance of considering the role of other chemicals in this disorder, although the evidence for chemical causation of any sort is weak.
Other points discussed The action following from the German bee incident (bee mortalities from neonicotinoid dusts getting into flowering crops from adjacent seed drilling activities) resulted in further consideration as to how risk to bees is assessed at EU level. To date, there have been no incidents of this sort in the UK. The UK approach should there be an incident would be to review the data already available and to discuss with the approval holder appropriate further studies designed to address the concern.A review of adverse effects can be triggered at any time in the EU – it is not necessary to wait for the next formal review date.
Action: To feed this useful discussion into the EFSA process, highlighting the concerns raised and potential ways forward.
2.1 The group identified the heart of the questions related to the effects of climate change impacts on pesticide usage, cropping, pests and diseases, the environment, human health, policy and the regulatory process.There were also wider issues such as land use, food security, environmental pressures such as water demand.
The group considered these areas in more detail as follows:
2.2 What possible changes arising/developing as a result of climate change do you foresee that will impact on the future use of pesticides?
Unexpected extreme weather events Unpredictable lifecycle changes and outbreaks of pests and diseases – suggests a need for a robust and speedy approval system.
New and different crops and the effects those crops have on local biodiversity.
Changes in natural predators populations.
Some indigenous species could develop pest status and known pests could migrate from other countries.
Changes to cropping patterns resulting in changes to pesticides usage regimes.
Changes in soil temperature and moisture status could affect the rate of pesticide degradation. This could impact on efficacy and environmental pollution.
Use of GM crops.
Increased development of pesticide resistance due to shorter pest life cycles.
Interaction of effects (e.g. drought and water-logging will both result in reduced yield; impacts of higher ozone levels on crop physiology and pesticide chemistry).
Increased volatilisation may mean a need for larger water/spray volumes to reduce the possibility of phytotoxicity.
2.3 Do you anticipate any of these developments having potential impact on future environmental effects of pesticides?Do you have any evidence on which your ideas are based?
Increased temperatures may increase volatilisation.
Soils hydrology may need to be more robust.
Changes in weather patterns may result in smaller windows of suitable conditions for spraying resulting in spraying taking place in less than ideal circumstances more frequently.
Increased flooding and erosion risk may increase pesticide pollution of surface water.
2.4 Do you anticipate any of these developments having potential impact on future human health effects of pesticides?Do you have any evidence on which your ideas are based?
PPE may not be used in hot weather.
People may be wearing fewer clothes more generally so providing less incidental protection.
Increased volatilisation may result in increased exposure.
Potentially there could be more use of pesticides and a greater variety of pesticides being used.
2.5 Are there aspects of the regulatory process for pesticides that in your opinion should be reviewed to take account of the possible impacts of climate change?
There is likely to be a requirement for more MRLs, and these may need to be adjusted more frequently, so a more efficient process is likely to be required.
There is likely to be a need for more minor uses.
There is likely to be more opportunity to use data gathered in other countries which are already experiencing these types of climate/weather changes.
There are likely to be more emergency approvals required with more flexibility needed in considering repeated emergency uses.
Use of a streamlined approval process to gain quicker decisions.
Faster approvals for biological controls.
The group noted that a move to a zonal approach in the EU suggested that the regulatory process was starting to take note of data from other countries, but there was a question as to whether the UK was in the correct zone in terms of future proofing for climate change effects.It was noted that it is quite difficult to find an existing analogue for the expected UK changes, but that doesn’t mean that UK cannot learn important lessons from parts of the world having some climatic aspects that are similar.
Action: these issues to be drawn together into a supplementary report to Dept of Health.
3.PESTICIDES ADVERSE HEALTH EFFECTS SURVEILLANCE (PAHES)
Two groups considered this issue. This note draws on both discussions.
3.1 What features do you consider to be of most importance in a surveillance scheme for adverse health incidents associated with pesticides?
There is a need to raise awareness of pesticides across the community, both in terms of encouraging more personal responsibility and choice in actions for example when walking in fields that might have been treated and in terms of ensuring people are aware of pesticides and the possibility of reporting adverse effects.A suggestion that farmers post an ‘alert sign’ where they are spraying adjacent to roads to enable motorists to close windows when passing was made. An alert sign could include a visible marker such as a balloon .
Possible health monitoring for workers can be considered (some employers already offer regular blood tests to both provide reassurance to workers and their families and to identify and correct work practice that can result in increased exposures).
An exposure driven scheme is favoured. It can be very hard to link exposures to health effects, particularly if we want to act on the findings.
Trying to collect too much data would result in less response. It is important to have a balance between asking the right questions without asking for too much. Measuring actual exposure and health effects are very difficult, but crucial.
Did exposure happen at all and if so, how much? Would the scheme end up being limited to more obvious routes – manufacturers, users etc? What about the general population?
It is recognised that it can be difficult to get accurate and honest information for a range of reasons (including lack of knowledge about the exposure, fear of reprisals in an occupational setting or in a case of illegal activity).
Information availability about spraying activity is important to support accurate and honest reporting.
Perhaps a scheme needs prioritising – could the data submitted as part of PPP authorisation process (e.g. field studies with operators – but rare) be used to look at highest risk groups.
Long term effects – difficult to look for and report.
There is a need for a scheme just to look at adverse health effects (but what about positive effects of a pesticides use e.g. how many people has it fed, has it reduced human disease etc? – is there another scheme that provides this information?)
A scheme will always get two types of inputs – short term and longer term based on location, situation etc. Can postcodes etc be included?
Cost is a big issue with any form of surveillance scheme. Cost benefit is crucial.
An online format (with option of written input) – easy to complete. Would examples be useful in the questionnaire? Use of closed questions – need to make it easier to complete the forms.
Exposure driven – needs to cover as many exposure routes as possible
Look at health effects – identify important events (can probably not identify all minor effects and/or some long term effects)
Long term effects
Collection of the right data
People to feel comfortable reporting incidents and to know where and how to report
Simple reporting format: essential information includes the chemical, the exposure detail and the adverse effects experienced
Standardised data collection to enable all schemes to report into an overarching system covering both acute and chronic effects
Important to include regulatory action to be taken as a result of reported findings
3.2 Should a scheme focus only on plant protection products – or should there be wider coverage – eg including other household chemicals, or certain biocides such as rat and mouse controls, wood treatments etc?
Definition of pesticides? Does this need greater consideration and explanation in the report? WHO have a good definition.
Widening of the brief is possible – e.g. biological control mechanisms etc rather than chemicals. Would all forms of pesticide be included and covered by the scheme?
Danger of reporting ONLY pesticides - may miss out cross effects from use of other chemicals.
Broader remit than PPPs may make it more difficult to collect reliable data and outputs. Perhaps starting small and looking at best way of collecting data before expanding is the best way.
Linking in with REACH activity has merit – e.g. funding and putting pesticides in context with more familiar chemicals.This can give a wider perspective, but a wider scheme might not be as efficient.
Keeping a scheme relatively simple would increase its success, so PPPs only would fit in with this.
The remit of the scheme should be as broad as practicable taking account of both ease and efficiency of data collection and funding.
3.3 Are there specific features of any of the schemes reviewed by the report that should be included in a UK scheme?
The approval holders scheme should be maintained as people are likely to contact approval holders if they have the product label available to them (i.e. mostly people using pesticides).It is important not to loose this information and that it is passed to CRD, so this recommendation should be revisited.
3.4 One of the areas of surveillance that poses most practical difficulties is surveillance of any long term ill health effects.Do you have any suggestions as to how this might be taken forward?
Ability to get data on actual exposure is difficult.
Cohort studies are best for this but expensive.
What about the HSE applicator group – these would be a good cohort group to use? What information do we have from 65,000 spray users? Can this be used (very limited data with mortality as endpoint)? Registered pesticide appliers tend to be young and so can’t look at longer term effects very well.
What about looking at biomarkers of exposure (would need reliable biomarkers)?
What about an industry wide scheme looking at manufacturers – however, it can be difficult to pinpoint exact exposure as multiple actives/products can be manufactured in single plants? Medical surveillance is already within the regulatory process – could this be expanded beyond routine monitoring/specific cases, looking at longer term effects?
There is a large data set on use of products kept by some companies (example given by amenity company who have a large data set on a limited range of herbicide products) – useful for acute monitoring. What about longer term effects – can these data be used by looking at health outcomes of the subjects? What about tracking of employees after they leave the company?
Local authority data – usefulness can be limited?
Use of high risk groups – can we use these to examine longer term effects.
There should be a focus on at risk groups – including operators and residents
Action: The working group to consider these thoughts and ideas in finalising their report.Aim to deliver the report to Defra by Christmas.Note: The advisory committee provides advice but it is Ministers who make decisions.