Luuk van Duijn, Ctgb:

Stricter pesticide demand explained by bureaucracy

There is less and less allowed and more and more demanded, is a common statement when it comes to allowed pesticides. One of the reasons for this is that 'confirmatory data' or common sense, is no longer in control but rather research 'strangled with data', which is never enough in the eyes of the authorities. You can also imagine that if it's already complicated for conventional pesticides, it can be even more complicated for 'biologicals' (bacteria, viruses, fungi etc).

This is the problem that Luuk van Duijn, secretary/director of Ctgb, touches upon in his foreword in the Ctgb newsletter this month. New, stricter policies often aren't well thought out and lead to new, unforeseen problems. He explains this in his column:

"The demands made for substances to be used as the active chemical in pesticides, are rapidly increasing. Not just due to the application of comparative assessment (which agents with substances with certain characteristics have to be subjected to) or the application of the criteria for hormone disrupting chemicals, on all fronts. It has long been common to work with 'confirmatory data', figures that are lacking, but are assumed to be able to be supplied later to confirm what we already know. The use of confirmatory is now less and less accepted. This means that all of the data has to be provided, which in turn means that almost and entire new folder has to be created on substances that have been on the market for years. This is decided by EFSA and the European Commission in the application or renewal procedure, resulting in more data being requested at the end of the procedure, without the procedure knowing to supply it beforehand. A stalemate for those requesting it and the member state reporting on it.

The Ctgb believes this isn't correct procedure, you can't change the rules during the game. What we're running into more and more is that this same approach, logically, is being applied to biologicals as well, and the effect is certainly as dramatic there. Many biologicals are generally small, non-pathogen bacteria, fungus or viruses that disappear soon after use, because they don't survive on the plant or in the soil. You can often judge this based on related organisms. Or you could look at it from a chemistry point of view, they are extremely complex and contain a large amount of substances. If you demand everything is completely proven before a substance can be used, you are suddenly ramping up the demand for biologicals. This is what's happening now. Closing up all the loopholes and no longer allowing expert judgement could be fatal for this group. Add to this that biologicals often have a small market and the size of file demands can determine whether or not they apply, I believe the concept of collateral damage has its place here."

Click here for more information on the Ctgb

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