Note of the Dimethoate Stakeholders Forum 19 March 2001

Attendees

Introduction

1. The chair outlined the purpose of the meeting. Many of the issues for discussion in this meeting concerned dimethoate, but it might prove to be the first example of what could become a wider issue.
2. Combined exposure from all approved uses and imports could potentially exceed acceptable levels, although individual uses were acceptable. There was no immediate health risk. There is no an agreed method of reducing exposure by selecting which approved uses should no longer be permitted, and PSD therefore is looking to stakeholders to discuss the issue. Consumer safety would remain the highest priority. There were however broader issues, which could be taken into account within that constraint, such as the effects on the horticulture industry.
3. The combined exposure issue might recur when the final stage of the anticholinesterase review is carried out and PSD seeks to assess the combined exposure of consumers to all approved OPs and carbamates that remain approved.

Specific action proposed on dimethoate

1. The ACP had recommended that uses of dimethoate were suspended following a PSD review. This would be with effect from 9 April for Approval Holders with a 2 year use up period for existing stocks. The ACP requested a strategy from approval holders, and set data requirements for the longer term. Ministers agreed to this proposal.
2. An issue specific to dimethoate is its metabolism to omethoate. The intake of dimethoate and omethoate have, in the past, been considered separately. Consumer exposure from individual crop uses remained below the Acceptable Daily Intake (ADI). However, if the total diet is taken into account, the ADI could be exceeded for toddlers by both dimethoate and omethoate residues and for infants by dimethoate residues. PSD, however, is starting to look at combined residues for these particular compounds and in a wider context. A multi-departmental working group (Working Group on Risk Assessment of Mixtures of Pesticides (WIGRAMP)) is also looking at toxicological equivalence for a range of compounds including pesticides, and will make recommendations in 2002.
3. There is scope to treat approvals on particular crops differentially, but the need to address the ACP’s requirements for the data package would remain. The Dimethoate Task Force (DTF) believed dimethoate was still viable with an enhanced data package.
4. The meeting heard that the effect of food processing on residues (i.e. reducing residues) was looked at when processing data was available, but much of the data supplied by Approval Holders is based on raw agricultural commodities. Short-term consumer exposure assessments use the highest residue value seen in the residues trials but the median residue value is used for long term estimates.
5. A suggestion was made to withdraw summer uses of dimethoate, for instance allowing use up to 31 March. This however did not solve the problem of the inadequate data package, and separate data are not always available for winter uses. Approval holders would therefore have to supply data to support winter uses.
6. The meeting discussed the options of revised conditions of use ( (Good Agricultural Practise (GAP) e.g. longer harvest intervals). An extended harvest interval could be one option, as UK GAP tends to apply pesticides closer to market. This would depend on changing consumer attitudes to accept more crop damage.
7. The meeting agreed that, in practical terms, there is a ceiling to the number of applications of particular groups of pesticides such as OPs made to a crop. However, although instances of multiple residues were declining, some were still being found, for instance oranges and grapes with 2 or 3 OPs.

General action for dealing with excess dietary exposure

1. The chair explained that the primary aim of the pesticide regulations in the UK was to ensure acceptable safety, and that this was not negotiable. This aim had been strengthened by the creation of the Food Standards Agency (FSA). Within this, however, Ministers were open to ideas, and could take economic factors into account. A possible approach was for companies to bid for one major use for each product, with minor uses decided on the basis of wider criteria. Such minor uses could be important to specialised horticultural sectors. PSD is now looking for this next step, which provides a balance between what could be characterised as the consumer, grower and industry interests within the primary aim of safety. Combined assessments will, however, become a reality regardless of the specifics of the dimethoate situation.
2. The meeting thought there were 2 difficult issues to address. The first was how would imports be handled if Maximum Residue Levels (MRLs) stay the same and UK uses were banned. The second was how would this be handled to treat Approval Holders fairly? For example, dimethoate producers may pick up on other active ingredients with similar problems.
3. The chair stated that it would be inequitable to accept continuing imports if UK uses were banned. Any solution had to address the import issue. EU MRLs are based on single dietary elements and don’t take the cumulative exposure issue into account. PSD will take this up in Europe at the appropriate time.

Action: PSD

4. There was no fixed time frame as yet for resolution of the ‘sharing of uses’ issue. The first definite deadline for dimethoate is 9 September for submitting an adequate data package to the Advisory Committee on Pesticides (ACP). Then PSD would need to have a mechanism for dealing with dimethoate to present to Ministers by the end of this year. The wider total exposure issue would become increasingly important with the conclusion of the anticholinesterase review in 2002. A process for combined intakes for all remaining organophosphate (OP)s and carbamates would be needed by then.
5. The DTF suggested that the combined dimethoate and omethoate issue could be addressed by the end of the year, then move on to other active ingredients. If the DTF met ACP criteria for the dimethoate data package, PSD would need to advise Ministers on which approvals can be maintained while treating approval holders fairly.
6. PSD confirmed that guidance to the DTF would be supplied on how to meet dimethoate and omethoate data requirements.

Action: PSD

7. PSD will formally raise the broader issue of cumulative exposure with the EU during negotiations on Directive 91/414/EEC, although there have already been informal discussions between scientists. This is an emerging problem, and a new tier of risk assessment is required, for which we need a robust, understandable and flexible mechanism.

Action: PSD

8. The meeting heard that the Committee on Toxicology (COT) was looking at veterinary medicines in addition to pesticides. This should clarify whether individual risk assessments were still appropriate, or whether similar products should be looked at together.
9. PSD confirmed that a note of this meeting would be added to PSD’s website.

Action: PSD

10. The issue of the European food industry potentially advising members not to accept the use of anticholinesterase products was raised. PSD confirmed that it was happy to supply information to make the industry aware of the issues, but could not make decisions for it.

Next meeting

The next meeting could take place later this year if the DTF is successful in meeting data requirements. PSD invited comments in the meantime from attendees and other interested parties.

Action: Attendees/Other Interested Parties