Advertisement
Not a member of Pastebin yet?
Sign Up,
it unlocks many cool features!
- Dear Dr Flüh
- Dear ScoPAFF members
- Ahead of the SCoPAFF-phytopharmaceutical of 6-7 December, ECPA would like to take this
- opportunity to provide our input on a number of current issues. Reference is made to the
- meeting agenda item where relevant:
- Endocrine disruption (Agenda item A.18)
- ECPA would underline the concerns we have with the proposal for the criteria for endocrine
- disruptors. For decision making under Regulation 1107/2009, we believe regulators should
- be provided with the necessary tools to separate out those substances which have the real
- potential to cause harm, from those that do not. It remains our firm view that endocrine
- disruptors can and should be regulated like other substances of potential concern and be
- subject to risk assessment considering both hazard and exposure. A departure from this
- framework sets a precedent for regulation that neglects the consideration of all information
- potentially available to ensure the protection of human health and the environment.
- We hope that the Commission will look to adopt workable, proportionate and science based
- criteria which ensure that regulators have the necessary tools to make informed decisions;
- maintaining the existing high levels of protection for human health and the environment,
- while also ensuring that European farmers have access to essential crop protection products.
- Further information in the Zip file annex – ECPA letter ahead of Nov 18th SCoPAFF/ED
- meeting - doc.no.27011
- Bee guidance document (Agenda items A.16)
- ECPA is supportive of a revision of the pollinator risk assessment. However, we still fail to
- see how the outdated document from 2013 will ensure appropriate risk assessment for
- pollinators and allow risk managers to take robust decisions.
- We continue to be of the opinion that the current guidance is unworkable and would mean
- that all insecticides, and a lot of herbicides, fungicides would fail the first tier laboratory risk
- assessment and trigger the need for follow up semi-field and field studies despite the fact
- that the study specifications cannot be met. Today, a year after EFSA’s decision to use de
- facto this unapproved document, we see the practical consequences with nearly all EFSA
- conclusions highlighting risks and data gaps1. This clearly demonstrates the inappropriate
- calibration of the guidance, with the protection goals sustaining the whole document being
- based on incorrect and extremely conservative assumptions. It also creates unnecessary
- complexity for many substances that can only be addressed at Member State level.
- ECPA will continue to ask that the Commission, EFSA and Member States:
- Not to adopt the guidance document as it currently stands, on the basis that it is
- not fit for purpose.
- Reject the proposed legislative changes when the proposed trigger values remain
- questionable and are not based on the most recent scientific knowledge
- Carry out a transparent assessment of the impact of the proposed measures
- before taking a final decision
- Review the progress gained in science and knowledge over the last 3 years,
- before implementing the measures currently under discussion, which lead to
- unfeasible additional data requests.
- As industry, we would welcome the opportunity to engage in a technical discussion with risk
- assessors and risk managers so that solutions to some practical issues could be jointly
- explored.
- Co-formulants
- ECPA would again highlight industry concerns with the way forward set out in the Discussion
- paper on implementation rules for the inclusion of unacceptable co-formulants in Annex III.
- We would in particular highlight the impact of duplication of work in the evaluation of coformulants
- and the potential impact of the suggested triggers which could potential restrict
- many commonly used co-formulants.
- Given the potential impact of this exercise, ECPA believes that an impact assessment is
- required to ensure a full understanding of the implications. ECPA’s aim is to ensure a
- streamlined process that avoids the duplication of effort - in line with the broader principles of
- Better Regulation. ECPA will continue to input into the Working Group discussions to support
- the development of such a streamlined process.
- Further information in the Zip file annex – ECPA letter - doc.no.26056. Also, please
- see separate published paper at https://www.ncbi.nlm.nih.gov/pubmed/27411735
- Guidance on the Establishment of the Residue Definition for Dietary Risk Assessment
- While we note that the EFSA Guidance Document on the Establishment of the Residue
- Definition for Dietary Risk Assessment is not on the agenda for the December meeting,
- ECPA would highlight some issues at this stage, ahead of a possible future discussion and
- ‘noting’ of the document. We emphasise the complexity of the evaluation scheme, and we
- would in particular stress that additional elements (e.g. QSAR tools and databases) are
- required for the workable implementation of the guidance document - proceeding without
- such tools will lead to additional toxicological testing including unnecessary vertebrate
- testing. ECPA has also noted a lack of consistency between the guidance document and the approaches in other national and international systems –impacting global harmonisation of MRLs, import tolerances and trade.
- ECPA would therefore propose a technical discussion to ensure a high level of
- understanding and consistency (i) across the Member States and, (ii) with international
- systems, as well as the provision of a suitable toolkit and respective training requirements, to
- support the implementation process.
- REFIT evaluation: Regulations 1107/2009 & 396/2005 (Agenda items A.26)
- ECPA welcomes the publication of the roadmap for the review of both Regulations. The
- review is an essential step to understand the shortcomings of the legislation and to consider
- improvement options for the future. ECPA support the roadmap work programme and
- believes that an essential element of the review will be to consider improvements options for
- - in the implementation of the current legislation and in future legislative changes.
- Further information in the Zip file annex – ECPA view on roadmap (doc.no.27064) and
- ECPA position paper on review (doc.no.22085 – July 2015)
- Stakeholder dialogue with SCoPAFF
- ECPA have recently written to DG SANTE requesting greater Stakeholder transparency and
- participation in the work of the ScoPAFF sections on ‘Phytopharmaceuticals’ and ‘Pesticide
- Residues’. While all discussions in these groups have to date been held without stakeholder
- participation, we request that this policy to reviewed, in particular to ensure greater
- consistency with other similar Standing Committees such as the Biocides Committee.
- There are two areas where we would request greater transparency:
- Documentation – create a CIRCABC section with stakeholder access for the documents
- that are to be discussed in the meeting. While complying with the EU’s transparency
- principle, such access to drafts would also enable commenting on latest versions, and
- potentially avoid waste of resources in trying to solve subsequent issues.
- Participation - Relevant non-confidential discussions in the SCoPAFF section meetings
- should be opened up to stakeholders to allow dialogue with decision makers.
- Our experience from other sectors is that the organised participation of stakeholders has
- been helpful and have provided a higher level of transparency. We look forward to greater
- transparency and greater consistency with the committee procedures in similar policy areas.
- Further information in the Zip file annex – ECPA letter to DG SANTE - doc.no.26781.
- To ensure full transparency, this letter is being published on the ECPA website and will be
- available at: http://www.ecpa.eu/transparency-policy. We would of course welcome a more
- detailed discussion with DG SANTE on these issues. If you have any questions about the
- ECPA views, please do not hesitate to contact me.
- Yours sincerely
- Euros Jones
- Director, Regulatory Affairs
Advertisement
Add Comment
Please, Sign In to add comment
Advertisement