Sir,

In recent months EurActiv has published several very useful articles and reports on the new EU legislation on pesticides. Your latest LinksDossier “Pesticides: Striking the right balance?” is another useful contribution. However, I was surprised that it made no mention at all of the fundamental nature of the change this legislation would bring about if it is enacted without significant amendment.

The Commission proposes to change the basis for future pesticide authorisations from assessments based on RISK to assessments based on HAZARD. ‘Hazard’ and ‘risk’ are very different. The link between the two is EXPOSURE – if there is no exposure, there will be no risk, even when the hazard is high.

This proposed change, from risk-based assessments to hazard-based assessments, will have profound effects on the future availability of plant protection products within the EU. This, in turn, may have serious implications for crop production within the EU – neither of which have been assessed by the Commission.

What is even more worrying, however, is the precedent that the proposed change would set for other areas of regulation. There are serious hazards associated with many materials and processes in everyday use but we do not ban them, because we know the risks are negligible or small. It is completely illogical, and totally unscientific, to base any regulatory system on the assessment of hazard alone.

Regards,
Dr. James Gilmour,
Edinburgh, Scotland, UK.

Dr. James Gilmour was head of crop protection for ten years at the Scottish Agricultural College at Edinburgh and then director of the Agricultural Advisory Service for Scotland, a post from which he retired in 1997. He was an independent (individual) member of the British Crop Production Council from 1997 to 2007.