Memorandum submitted by the Food Standards
Agency (Z06)
INTRODUCTION
1. This memorandum:
— Outlines the FSA's role, responsibilities
and powers with respect to pesticides;
— Provides details of the Agency's
policy on genetically modified and organic foods;
— Summarises specific pesticide initiatives
in relation to both consumer safety and choice which the Agency
is taking forward;
— Comments on the implications the
Voluntary Initiative for the FSA initiatives; and
— Comments on the broader development
of pesticide policy in the future.
THE AGENCY'S
ROLE AND
POWERS
2. The Food Standards Agency, which was
established on 1 April 2000, is a UK-wide non-Ministerial Department
set up under the Food Standards Act 1999. The Agency is accountable
to the Westminster Parliament and, because food safety and standards
are devolved matters, to the devolved administrations in each
case through the relevant Health Ministers. For legislative purposes
the Food Standards Agency operates through the Secretary of State
for Health in England, and through Scottish Ministers, the National
Assembly for Wales and Northern Ireland departments for the respective
devolved administrations. The Agency has the right to publish
its advice to any Minister or Government Agency.
3. The main objective of the Agency in carrying
out its functions is to protect public health from risks arising
in connection with the consumption of food, and otherwise to protect
consumer interests in relation to food. The UK Government policy
lead on pesticides, however, lies with the Pesticides Safety Directorate
(PSD) because policy implications of pesticide use extend beyond
just food safety issues, and cover environmental and worker protection
issues. The Agency therefore has an important watchdog role from
the point of food safety in the authorisation and surveillance
of pesticides. It must be consulted by the PSD on any food safety
issue or any national or EU regulatory or international discussions.
It can also carry out surveillance for pesticide residues in food,
if it considers this necessary. But responsibility for the UK's
national pesticide surveillance programme for food and drink rests
with PSD. This programme is overseen by the Pesticides Residues
Committee—an independent expert Committee—which advises
Ministers and the Chief Executives of the FSA and PSD. The purpose
of the surveillance programme is threefold:
— To back up the statutory approvals
process for pesticides by checking that no unexpected residues
are occurring;
— To check that residues do not exceed
statutory maximum residue levels; and
— To check the human dietary intakes
of residues are within acceptable levels.
4. In its approach to pesticide residues,
the Agency:
— endorses the current risk-based
approach, noting that it is precautionary and relies upon prior
approval of substances based on comprehensive safety evaluations,
backed up by surveys of residues in food;
— acknowledges scientific uncertainties,
particularly in relation to the safety assessment of mixtures;
and
— recognises that consumers expect
residue levels to be kept to a minimum, even if higher levels
would not be harmful.
5. The Agency also has responsibility for
two key pesticide initiatives which seek to address (i) consumer
concern about the health effects from exposure to mixtures of
pesticides—the so called "cocktail effect"; and
(ii) consumer preference for foods produced in ways that minimise
pesticide residues. These are outlined in brief below.
THE "COCKTAIL
EFFECT": MIXTURES
OF PESTICIDES
AND SIMILAR
SUBSTANCES
6. In recognition of the fact that pesticide
risk assessments are usually carried out on individual substances
and in response to consumer concerns about the implications to
health of exposure to mixtures of pesticides from a range of sources,
the Agency asked the Committee on Toxicity of Chemicals in Food,
Consumer Products and the Environment (COT) to undertake a review
of risk assessment of mixtures of pesticides and similar substances.
The review looked at what sort of combined effects could result
from exposure to residues of more than one pesticide and/or veterinary
drug—the so called "cocktail effect"—and
whether these combinations could result in unanticipated adverse
effects on human health.
7. The COT report, published in October
2002, concluded that the probability of any health hazard due
to exposure to mixtures of chemicals, each present at a low level
(as is the case in food), is likely to be small, and children
and pregnant or nursing women are unlikely to be more vulnerable
to the effects of mixtures than the general population. However,
good estimates of human exposure to groups of chemicals are not
available, particularly if exposure through routes other than
food is considered. The COT considered that the body of evidence
is limited and it is possible that some interactions are not readily
predictable. It recommended certain changes to the regulatory
approvals process to take into account the possible implications
of such exposure and recommended further research. These fall
under the broad headings of regulatory, surveillance, research
and public information issues.
8. An action plan to implement the COT's
recommendations has been drawn up with those Agencies and Departments
with responsibilities both for the approval of agricultural pesticides,
biocides and veterinary medicines and the surveillance of their
residues in food. This has been the subject of a UK-wide public
consultation. The detailed action plan, COT recommendations, and
a summary of responses to the consultation are available on the
Agency's website (www.food.gov.uk).
9. Work on delivering the plan has already
begun. Key research has been commissioned, and although still
in the early stages, this will provide the necessary information
and tools to enable risk assessment of mixtures of pesticides
(and similar substances) to be undertaken for substances of concern.
As regulation of agricultural and non-agricultural pesticides
is governed by EC legislation, the UK cannot unilaterally add
requirements to the authorisation process of these substances.
Also, much of the UK's food supply is imported and hence standards
for imported foods must be as rigorous as for home-produced. Any
necessary changes to EC legislation and international standards
(eg the European Commission and the Codex Alimentarius Commission)
will be assessed, and pursued with the relevant bodies.
PESTICIDE RESIDUES
MINIMISATION—PROMOTING
CONSUMER CHOICE
10. The Government's central policy on pesticides
is to avoid risks to people's health and to limit risks to the
environment from the use of pesticides. While it is accepted that
the use of pesticides will involve an inevitable risk to the environment,
consumer health risks are not acceptable. The Agency supports
the use of the current risk-based system of assessment, and believes
that food containing residues up to the statutory legal limit
(the Maximum Residue Level; MRL) is not harmful. Maximum Residue
Levels for pesticides are generally set well below safety limits
and reflect good agricultural practices.
11. Qualitative research undertaken for
the Agency's Consumer Attitudes survey[1]2003
has shown however that (when prompted) concern about pesticides
relative to other issues has remained relatively constant: at
46% in 2003, compared to 44-50% between 2000-02. The potential
risk to health is a primary concern for consumers. Our research
also reveals a need for better consumer information on pesticides
and the regulatory controls in place.
12. The Agency considers that levels of
pesticides currently found in food are not a safety concern, and
would take immediate action if this were not the case. Nevertheless
when consumers are informed about the safety controls that exist
to ensure that pesticide levels in food are safe, the majority
(68%)[2]consider
that reducing residues further than the current safe levels is
important. This preference is widely recognised in the marketplace,
and has resulted in the development by retailers of a range of
individual initiatives to reduce or eliminate certain pesticide
residues in foods.
13. In fulfilling its role to act in consumers'
interests, the Agency has adopted a pesticide residues minimisation
policy that will help to promote consumer choice by offering those
consumers whose preference is for food without residues a wider
selection of foodstuffs to choose from.
14. The Agency's Board approved a detailed
action plan to minimise pesticide residue in May 2004. This focuses
on what the Agency could do to support the food industry in successfully
delivering its existing pesticide minimisation initiatives.
15. The core activities that form the basis
of the plan are:
— drawing together documentation that
provides examples of best practice for growers and disseminating
it to retailers and assurance schemes. The guidance, which is
currently being developed, will draw from the best practices available,
and encompass methods currently available within different production
systems, (conventional and organic) as appropriate. The Agency
will work with stakeholders on ways to measure the uptake of best
practice and report back to the Board in the second half of 2005;
— continued work with government departments
and non-governmental organisations to promote measures that may
minimise residues and meet consumers' preferences;
— exploring options for reducing residues
in imported food.
16. Consumers also want information about the
regulatory controls that apply to pesticides:
— explanations of terms such as Maximum
Residue Limits; and
— information about the benefits which
assurance schemes deliver.
17. The action plan therefore includes a
consumer information dimension. We will be working with stakeholders
to provide consumers with the information they need to make informed
choices.
18. In developing the detailed action plan,
the Agency has taken an open and consultative approach. Extensive
meetings have been held with stakeholders including retailers,
associations representing growers, producers and processors, government
departments and non-governmental organisations including those
representing consumers interests.
19. The Agency's best practice guidance
will be the subject of a public consultation in mid-2005, and
the practical and economic implications of the Agency's recommendations
for individual crops will be carefully assessed to minimise any
potential cost implications for stakeholders.
20. Although the drivers of the Agency's
and the Voluntary Initiative's policies—consumer preference
and a reduction in environmental risk—are different they
share mutual aims of promoting good agricultural practices and
an integrated approach to the management of the crop, pests and
environment. The technologies involved in reducing the environmental
impact of pesticides may equally serve consumer interests by reducing
residues in food.
ORGANIC FOOD
21. Organic food contains fewer residues
of pesticides used in conventional agriculture, so buying organic
is one way to reduce the chances that food contains pesticide
residues. However, based on an assessment of the available evidence,
the Agency does not believe that organic food is significantly
different in terms of food safety or nutrition from food produced
conventionally. The Agency recognises the contribution that organic
food makes to extending consumer choice. The price premium associated
with organic food however means that it is not accessible to all
consumers.
GENETICALLY MODIFIED
FOODS
22. It is recognised that the use of genetically
modified (GM) crops has potential in pest control. In respect
of GM foods, the Agency is in favour of rigorous safety assessment
and consumer choice. Under EU legislation (EC Regulation No 1829/2003
on genetically modified food and feed) all GM foods must be rigorously
assessed for safety before being permitted onto the market. The
safety assessment is based on a wide body of scientific evidence
submitted in support of each application and provides assurance
that any approved GM food is as safe as its non-GM conventional
counterpart. GM foods must also be labelled at the point of sale
to ensure that consumers can exercise informed choice.
THE VOLUNTARY
INITIATIVE
23. The Agency has observer status on the
Steering Group of the Voluntary Initiative (VI). Although the
focus of the VI is on minimising the environmental impacts of
pesticides, we recognise that the specific measures adopted by
the Initiative could have secondary effects that may affect food
residue levels. The development of Crop Protection Management
Plans encourages pre-planning of pest management strategies with
the potential for more judicious use of pesticides. Improvements
in spray technology and training for spray operators (National
Register of Spray Operators, the National Spray Testing Scheme)
and spray retention research could in some cases also make a positive
contribution by reducing pesticide application rates, although
this is not the objectives of these measures. Because the measures
undertaken by industry are verifiable, they also have the potential
to demonstrate to consumers that good practice is being followed,
although this would be subject to increased awareness of the Initiative
among consumers and their acceptance of the targets as sufficiently
robust.
24. It does not appear possible to de-couple
the potential effect on food residues of measures under the Voluntary
Initiative from those of other existing initiatives of retailers
and assurance schemes. Nor is it possible to use data from the
UK's surveillance programme to identify a baseline from which
to measure trends in residues. The quality of the data available
does not allow for a fair and comparable assessment of trends
in pesticide prevalence, and the quantity of data is insufficient
to provide the necessary statistical power to detect small changes
in prevalence. This problem of identifying the tangible impact
of the VI's measures appears to apply equally to environmental
benefits, although this is now being addressed through the use
of indicator farms and the LEAF audit projects.
25. Despite the difficulties in demonstrating
robust environmental and biodiversity benefits, the effect of
the Initiative in raising awareness of pesticide issues, and encouraging
best practice, including integrated approaches to crop, pest and
farm management represent important progress towards systems with
a reduced reliance on chemical controls.
26. The incorporation of some VI measures
into the requirements of assurance schemes (Crop Protection Management
Plans, integrated crop management, registration with the National
Register of Spray Operators, and testing within the National Sprayer
Testing Scheme) is welcomed by the Agency as a highly effective
way of ensuring widespread adoption of these measures, since membership
of assurance schemes by farmers is a pre-requisite for suppliers
to the retailer sector. Similarly, the Agency is promoting pesticide
residue minimisation via assurance schemes. More challenging will
be encouraging uptake of the VI measures amongst those farmers
whose produce is destined for the wholesale market/ food processing
sectors and who are not affiliated with any assurance schemes.
The VI, and any measure of its success, should not therefore ignore
this important group of producers.
FUTURE DEVELOPMENTS
27. The Agency supports the measures taken
by the Voluntary Initiative and believes they have the potential
to make an effective contribution to reducing pesticide risk to
the environment, and have an important part to play within a broader
pesticide strategy. The Agency would therefore like to see the
continuation of the Voluntary Initiative beyond 2006.
28. The Voluntary Initiative has promoted
an unprecedented degree of co-operation between Government Departments
and other non-governmental bodies (NGOs) towards an environmental
goal. There are however a wide range of pesticide initiatives
in existence which reflect drivers ranging from legislative compliance,
economic factors and market issues such as food residues and consumer
concern. As the breadth of pesticide strategies has increased
so there is a risk of duplication of effort, and farmers receiving
conflicting information about the approaches they should adopt
and which issues should be considered a priority.
29. While the Agency is committed to working
closely with other Government departments and other bodies in
respect to pesticide minimisation and the development of best
practice, the challenge for the future is to develop a unifying
policy that recognises and simultaneously promotes benefits for
the environment, farmer, and consumer while enabling farmers to
respond to market needs. The national pesticide strategy could
offer the opportunity to achieve this, if the interests of all
stakeholders were fully reflected and addressed by the strategy.
THE NATIONAL
PESTICIDE STRATEGY
The national pesticide strategy will set out
how hazards, risks and dependence on chemical control of agriculture
pests and diseases may be reduced. It is being developed in response
to the European Commission's communication about a thematic strategy
on the sustainable use of pesticides—formal proposals have
yet to be published. The drivers for this document were many,
and include consumer concern. The thematic strategy seeks to address
concerns that the existing regulatory controls, while addressing
the beginning and end-life stages of pesticides, do not adequately
provide for the determination of the risks posed during the use
phase of plant protection products.
The main objectives of the Thematic Strategy
are to reduce the impacts of pesticides on human health and the
environment, and more generally to achieve a more sustainable
use of pesticides, as well as a significant overall reduction
in risks, but also a reduction of the use of pesticides consistent
with the necessary crop protection.
In particular the objectives of the strategy
are :
1. To minimise the hazards and risks to health
and environment from the use of pesticides;
2. To improve controls on the use and distribution
of pesticides.
3. To reduce the levels of harmful active
substances, in particular by replacing the most dangerous by safer
(including non-chemical) alternatives;
4. To encourage the use of low-input or pesticide
free crop farming; and
5. To establish a transparent system for
reporting and monitoring progress including the development of
appropriate indicators.
The Commission's Directorate General for the
Environment is in the process of preparing proposals regarding
these measures.
8 October 2004
1 Consumer Attitudes to Food Standards (Report Published
February 2004). Back
2
Research published in Agency Board Paper FSA 04/05/02: Available
at: www.food.gov.uk/aboutus/ourboard/boardmeetings/boardmeetbranch2004/boardmeeting051304/boardagenda130504. Back
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