NORMS FOR PESTICIDES IN WATER AND AGRICULTURAL PRODUCTS. A CRITICAL REVIEW
Margriet
SAMWEL-MANTINGH1, Henk TENNEKES2, Jelmer BUIJS3
1 Women Engage for a Common Future, WECF-International,
Korte Elisabethstraat 6, 3511JG Utrecht, Netherlands (margriet.samwel@wecf.org);
2 Experimental Toxicology Services, Zutphen, Netherlands
(info@toxicology.nl);
3 Buijs Agro-Services Bennekom, Netherlands (jelmerbuijs@gmail.com).
available at: http://sciedtech.eu/download/margriet-samwel-mantingh-henk-tennekes-jelmer-buijs-norms-for-pesticides-in-water-and-agricultural-products-a-critical-review-recent-advances-in-food-science-2018-11-63-74/?wpdmdl=2062
Article
History:
Received 19 March 2018
Revised 25 March 2018
Accepted 28 March 2018
Keywords:
Pesticide
Maximum
tolerated levels
Risks
Food
Surface
water
|
Abstract:
There is increasing evidence that
changes in the environment and in the human health have a strong relationship
with the use of pesticides. Wild populations of birds, freshwater fish,
amphibians, reptiles, insects and several other species are declining at an
alarming speed. Society has tried to protect man and his environment with
maximum tolerated levels of pesticides in soil and water and in food.
However, these limits are rather a result of wishful thinking than of
scientific scrutiny. The authorisation procedures for pesticides have fully
ignored the impact of cumulative toxicity. The toxicity of many pesticides is
determined not only by dose but also by exposure time, and in some cases,
such as the neonicotinoid pesticides, toxicity is even reinforced by exposure
time. The alarming truth is that the dose-time-response relationship of the most
pesticides is fully unknown, since this information is not required in
official authorisation procedures. The consequence of time-dependent toxicity
is that for many pesticides the current maximum tolerated levels may
seriously underestimate actual risk. These chemicals need to be identified
and removed from the market as soon as possible. Testing should be performed
by independent organisations and authorization data should become accessible
for the public. At the same time, organic farming should be stimulated in
which synthetic pesticides are not used altogether. Almost 185.000 organic
farms in Europe prove that this is a good alternative.
|
1.
Introduction
Synthetic pesticides are a
recurring theme in all discussions about sustainable agriculture; that is no
coincidence. There is no human being on this earth who can say exactly what
impact the use of pesticides has on nature. The effects of individual active
substances and metabolites (decomposition products) on the hundreds of
thousands of organisms of our ecosystem are already impossible to predict or even
to establish. This involves several thousand substances that also interact with
each other and then have a joint effect on living organisms. Every now and then
the media pays attention to the contamination of foodstuffs with pesticide
residues or to the decline of the bee population. Recent examples are reports
on the dramatic decline of insects, fipronil in eggs, and cocktails of various
pesticides in Dutch strawberries and in honey from around the world [1].
2.
Risks of pesticides
In humans, a
strong increase of various hormone-related diseases and / or abnormalities such
as breast and prostate cancer, increased fertility, underdeveloped sexual
organs in new-borns, diabetes, and autism have been observed [2]. Also, in wild
animals worldwide observations have been made about changes caused by
hormone-disrupting chemicals (Endocrine Disrupting Chemicals - EDCs), such as
gender reassignment and malformations. There are several synthetic pesticides
that have a cancer-causing or hormone-disrupting effect. For example, prostate
cancer is associated with, among others, methyl bromide, chlorpyrifos,
phonophos, coumaphos, phorate and permethrin; alachlor with thyroid cancer.
Thyroid tumors can be caused by amitrole, ethylenethiourea, mancozeb,
acetochlor, clofentezine, fenbuconazole, fipronil, pendimethalin,
pentachloronitrobenzene, prodiamine, pyrimethanil, and thiazopyr [3].
Alzheimer's disease and other diseases are also associated with chronic
exposure to pesticides [4]. These are for people and nature alarming and
worrying developments. Nonetheless, the responsible authorities only focus on
whether or not the established norms for pesticide residues in water and food
are exceeded.
Research has
determined that synthetic pesticides also reduce soil biodiversity, such as
fungi and bacteria that are necessary for the mineralization of bound nitrogen;
This can have all kinds of consequences, such as reduced fertility of the soil
and increased dependence on artificial fertilizer. According to a report
recently published by the United Nations, pesticides do not contribute to food
security [5]. In the same document, it is concluded that pesticides have been
aggressively promoted, and their use can have very adverse consequences for the
availability of food for people. Contamination of the soil can also lead to a
disturbance of the balances in the soil between all kinds of organisms [6],
with the result that other diseases will occur as a result (directly as a
result of the use of pesticides) [7].
Many independent researchers come to the conclusion that the use of
pesticides has disastrous consequences for the ecological system and poses a
risk to people and nature, and does not even lead to food security.
3.
Authorization procedure for pesticides and standards
The Board for the Authorization of Pesticides and Biocides [8] is in the
Netherlands the authority that is responsible for the authorization of
pesticides and biocides for professional and non-professional use. The current
240 authorized active ingredients can be found in different concentrations and
combinations in no less than 2500 different products, and partly in veterinary
medicines. The same substance may in one case be authorized as a plant
protection product (pesticide) and biocide and in the other case by the
Veterinary Medicines Agency as 'veterinary medicine'. Different rules apply to
the authorization of veterinary medicines [9], in which testing of ecological
effects is not required.
For the
authorization of an active substance as a pesticide, the manufacturer will
document the chemical properties of the substance and carry out toxicity tests
for the substance that form the basis for the authorization procedure in the EU
and therefore also in the Netherlands. A product that comes on the market often
contains a mix of different active substances and additives to get the right
dispersion or emulsion. Possible undesirable synergistic effects between the
different substances and substances are not tested by the producer or the
approval authority (Ctgb). Conducted toxicity tests and results are not publicly
accessible.
4.
Dose-effect relationships of pesticides; the big confusion
Current admission
procedures and standards assume that an Acceptable Daily Intake (ADI) exists
for each substance. The ADI is an estimate of the amount of a substance that a
person can take on a daily basis without any significant adverse effect [10].
This approach assumes a similar dose-effect relationship for all
substances. Unfortunately, this is completely incorrect, but for the sake of
commercial interests, fundamental toxicological laws are completely ignored by
the legislators and regulators. Dose-effect relationships can be classified in
the following way:
A. Substances with
a dose-dependent action and a threshold value that do not irreversibly interact
with components of the body and for which an ADI can be established. There will
be no damage under the ADI, even under long exposure times. Admission
can be justified if the other conditions of admission can also be met, such as
degradability and absence of accumulation in the food chain.
B. Substances with a dose- and time-dependent action
without threshold, which enter into irreversible interactions with components
of the body leading to accumulating adverse effects. The product of the daily
dose d and exposure duration (until
the occurrence of a harmful effect) t
is constant: d.t = constant. This
dose-effect relationship is called Haber's rule. These substances show
cumulative toxicity and it is completely impossible to calculate an ADI for
this. Admission is irresponsible!
C. Substances with a dose- and time-dependent action
without a threshold value, which enter into irreversible interactions with
components of the body whose harmful effect not only accumulates but is also
strengthened by time.
This dose-action relationship is now known as the
Druckrey-Küpfmüller equation and can be mathematically represented by the
equation;
d.tn = constant, where n> 1. This
equation explains the harmful effects of
very low exposure concentrations of a poison at long exposure times. The lower
the exposure level, the lower the total dose required for an adverse effect.
These substances show cumulative toxicity and it is completely impossible to
calculate an ADI for this. Admission is irresponsible!
D. Substances with an unclarified (or unpublished)
dose-effect relationship. Admission is irresponsible!
4.1.
Examples of dose-effect relationships of active substances
The dose–response
relationship of the neonicotinoid insecticides imidacloprid and thiacloprid was
described in 2009 by Francisco Sánchez-Bayo for arthropods [11]. This was not
only dependent on the dose, but also on the duration of exposure. It was also
shown that the lower the exposure concentration, the lower the total dose
needed for the harmful effect (see table 1 and table 2).
In the following
table pesticides, mentioned in this article, are classified according to their
dose / time effect relationship. The dose / time effect relationship of most
pesticides has not been clarified because the current toxicological research
only aims at establishing a No-Observed Adverse Effect Level (NOAEL) as the
basis for the calculation of the ADI. Dose / time effect relationships are
almost always left out of consideration.
Understanding the
dose / time effect relationships is essential for establishing standards for
permissible concentrations of pesticides. ADIs and MRLs (Maximum Residue Limit)
can only be prepared for substances of category A. Given the fact that dose /
time effect relationships in the preparation of ADIs and MRLs have been
completely ignored, there can be no question of any confidence in the
harmlessness of substances, which belong to categories B, C and D, even in
concentrations below the ADI and MRL.
5.
Overview of legal standards for water and agricultural products
5.1.
Surface water
Depending on the
toxicity and on the occurrence of residues in surface water in practice,
maximum permissible eco-toxicological EU standards have been established for
active substances. However, the toxicity tests include a limited number of
aquatic organisms. Before the introduction of the Water Framework Directive
(WFD), there was the national MTR, Maximum Permissible Risk, in the Netherlands.
With the introduction of the European WFD (Water Framework Directive 2000/60 /
EC), the Environmental Quality Standard (EQS) is for the EU Member States the
applicable standard for many substances. At the EQS there are two standards,
respectively the:
• Annual average EQS (AA-EQS) and
• Maximum Acceptable Concentration (MAC) or EQS [12].
The AA-EQS
represents the concentration of the substance in the environment that should
provide protection against adverse effects from long-term exposure to that
substance.
Table 1: Mortality of
arthropods due to exposure to neonicotinoid insecticides (Sanchez-Bayo, 2009
[11])
Model organism
|
Test substance
|
Concentration (C) in µg.L-1
|
Time up to 50% mortality (T) in days
|
C x T product in
µg.L-1.days |
Cypridopsis vidua
|
Imidacloprid
|
4
|
5.2
|
20.8
|
16
|
3.0
|
48
|
||
64
|
3.3
|
211.2
|
||
250
|
2.3
|
575
|
||
1,000
|
2.0
|
2,000
|
||
4,000
|
0.9
|
3,600
|
||
Daphnia magna
|
Imidacloprid
|
750
|
69.7
|
52,275
|
2,220
|
18.6
|
41,292
|
||
6,700
|
15.0
|
100,500
|
||
20,000
|
18.4
|
368,000
|
||
60,000
|
3.0
|
180,000
|
||
Sympetrum striolatum
|
Thiacloprid
|
7.2
|
20,6
|
148.3
|
8.0
|
17.2
|
137.6
|
||
12.7
|
13.0
|
165.1
|
||
113.3
|
3.2
|
362.6
|
Table 2. Dose / time effect relationship of the
pesticides mentioned in this article
Dose-effect relation [13]
|
Pesticide
|
A: dose dependent
|
Of the substances mentioned
in this article no substance is known to have a dose-effect relationship that
is strictly dependent on the dose level only
|
B: d . t = constant
The
effect is determined by the total dose,
and independent of its distribution over time
|
azinphos-methyl, carbaryl,
carbofuran, fenitrothion, fipronil, methidathion, permethrin, phenthoate,
phosmet, thiacloprid
|
C: d. tn=
constant
The
lower the exposure level, the lower the total dose required for the effect
|
cartap, imidacloprid,
thiacloprid, clothianidin, thiamethoxam
|
D: not clarified
|
methyl bromide,
chlorpyrifos, fonofos, coumaphos, phorate, permethrin, alachlor, amitrol,
ethylene thiourea, mancozeb, acetochlor, clofentezine, fenbuconazole,
pendimethalin, pentachloronitrobenzene, prodiamine, pyrimethanil, thiazopyr,
Endosulfan, DDT, Endrin, glyfosaat, linuron, acetamiprid, abamectin,
aldicarb, amitraz, azinphosethyl, azinphosmethyl, azoxystrobin, captafol,
captan, carbendazim, chlorothalonil, chloridazon, chlorotoluron,
chlorpyrifos-methyl, chlorpyrifos, cyprodinil, deltamethrin, dicamba,
dichlorprop, Imazalil, iprodion, spinosad , azadirchtin, pyrethrine,
dieldrin, hexachloorbenzeen
|
The
MTR and the AA-EQS focus on the risks associated with chronic exposure via
consumption of fish (products) and / or crustaceans [14]. The MAC-EQS is aimed
at the protection of aquatic organisms with a short-term peak exposure.
Individual MAC-EQS and AA-EQS standards are not established for all substances.
In those cases where the EQS standard is missing, the MTR standard for the
substance in question is used. The legal standards for active substances in
surface water can be found in, among other things, the fact sheets of the
Pesticides Atlas [15]. For surface water no standard for the sum for individual
pesticides has been set, as done for drinking water.
It appears that despite all ecotoxicological standards, aquatic
organisms are insufficiently protected against pesticides. In the Netherlands,
in 2015 only 5% of the regional water bodies had a final rate of
"good" for the biological quality assessment [16]. Is this poor
quality caused by the occurrence of norm exceedances, synergistic effects of
the many substances found in the water [17]? Or do we clearly see the effects
of disregarding the dose / time effect relationships in the toxicity assessment
of substances. Or are there still other factors that play a role?
5.2. Drinking water
The acceptable
norm for pesticides in drinking water are laid down in Directive 98/83 / EC and
are applicable for all EU Member States. With a few exceptions, one and the
same norm of 0.1 μg/ l has been set for the individual active substances and
there is a norm for the total pesticides of 0.5μg/l. The norm of 0.1μg/l was
established at a time when for many pesticides the detection limit was 0.1 μg/l
and was considered as preventive standard for drinking water quality and human
health. The norms require a revision, because a concentration of 0.1 μg /l for
substances such as neonicotinoids is also dangerous if this water returns to
the environment later.
5.3.
Agricultural products for human consumption
A working group of
the European Commission intends to prepare for each active substance a
toxicological risk assessment for public health. For this risk assessment, an
estimate is made of the amount of substance that a person can take for life on
a daily basis without any noticeable effect on health [10]. This amount of
substance (mg per kg body weight - mg/kg BM) is called the Acceptable Daily
Intake (ADI). For the majority of the pesticides, an ADI has been established.
E.g. for fipronil the ADI is 0 - 0.0002 mg/kg bw and for Imidacloprid 0 - 0.06
mg/kg bw [18]. This means that a person weighing 50 kg daily could take up to
0.01 mg of fipronil and 3 mg of imidacloprid via food without any noticeable
effect on his or her health.
There is also an Acute Reference Dose (ARfD). The ARfD is an estimate
for the amount of a substance in food that someone can take within 24 hours
without significant health effects. One-off consumption (of one portion) of
certain crops with relatively high residues of plant protection products (above
the ADI) can sometimes lead to acute problems. These acute problems would not
be noticed with the average consumption calculation [19].
The MRLs are laid
down in the regulation for maximum residue levels in foodstuffs EC 396/2005.
For pesticides for which no standard has been set, the MRL of 0.01 mg /kg is
usually used. No MRL or ADI has been set for the sum of the various pesticides.
If the MRL of a given substance does not exceed the ADI and ARfD, the MRL can
be included in Regulation EC 396/2005, and the substance may be authorized in
the European Union.
5.4 Packed (jar) food for infants
and toddlers
Because of their
thin skin, low weight and rapid metabolism, babies form a vulnerable group. As
a precautionary measure, therefore, within the European Union, Directive 2006/125
/ EC regulates the quality of packaged (jar) food for infants and toddlers (up
to 3 years) in the EU. Jars with food for infants and toddlers must not contain
more than 0.01 mg / kg of an active substance. However, no MRL for the sum of
the various substances has been established. This means also that 1205 times as
much of the insecticide imidacloprid in baby food is allowed than in surface
water!
This means that
conventionally produced foods for infants and toddlers do not comply with the
precautionary principle (see table 5) and thus may pose a risk for this
vulnerable group. Pesticides pass through the placenta [20] and therefore
pregnant women must also be counted among the vulnerable group. In organic
farming, the use of synthetic pesticides is in principle not permitted. In this
way, these foodstuffs comply with the precautionary principle concerning
pesticide residues. Even with regard to residues in these organic foods,
however, transparency is hard to find; measurement data from the NVWA (Dutch
Food and Consumer Product Safety Authority), the Dutch inspection body for
organic agriculture (SKAL) and from Bionext[1] are all inaccessible to
the public.
5.5. Livestock feed
In the directive
for animal feed (Directive (EC) 2002/32) maximum limits for undesirable
substances such as organochlorine pesticides Endosulfan, DDT or Endrin, are
laid down for animal feed and feed materials. These substances which are very
persistent, easily soluble in fats are now banned for agricultural use, but
occur independently of the agricultural method in the food chain (through use
in the past in the Netherlands and through current use abroad). For the other pesticides
the MRLs for foodstuffs are used. These are laid down in Regulation (EC)
396/2005. Specific feed such as raw feed (hay, straw, feed corn, (silage)
grass, fodder beet, etc.) are missing in this Regulation [21].
In contrast, in
the Codex Alimentarius MRLs have been established for a number of specific
pesticides in a number of animal feed. The establishment of standards is
facilitated by the FAO and WHO [22]. The Codex Alimentarius is a basis for the
EU for setting MRLs.
6. What is the significance in case
standards are exceeded?
In the EFSA Journal
2017 [23] is mentioned that among the unprocessed plant products analysed in
the 2015 EU-coordinated control programme (EUCP), the highest MRL exceedance
rate was identified for broccoli (3.4% of the samples), followed by table
grapes (1.7%), sweet peppers (0.8%), peas without pods (0.6%), wheat (0.6%),
aubergines (0.4%) and bananas (0.3%). Moreover the foods with the highest
percentage of samples with multiple residues were bananas (58.4%), table grapes
(58.3%) and sweet peppers (24.4%). Table 5 presents for bananas some selected
MRLs, whereas the extreme high MRL of 15 mg chlorothalonil /kg bananas is remarkable.
Chlorothalonil is a fungicide of which the dose / time effect relationship is
not clarified (see table 2) and is included in the Pesticide Action Network (PAN) International List of Highly Hazardous
Pesticides [24].
The Dutch Food and
Consumer Product Safety Authority (NVWA) provides a summary of the extent to
which the legal MRLs in the tested products were exceeded in 2015. For example,
of the strawberries grown in the Netherlands, 2.6% on average exceeded the set
standard and contained on average 6.7 different pesticide residues; In the
Dutch apples tested, no MRLs were exceeded, but an average of 3.1 different
residues were found in these apples.
However, what
amount of pesticide residues can legally be present in these popular fruits? As
shown in table 4 and 5, the MRLs shown are mainly related to what remains in
practice on residues of the active substance on or in the product. For those
pesticides for which an MRL has not been specifically established, an MRL of
0.01 mg/kg is generally applicable. For the individual agricultural products,
however, no MRL is set for the sum of the different residues, while the
synergistic effect of the prevailing cocktails on pesticide residues and their
metabolites in and on foodstuffs is unknown.
So when it is
reported that a product such as apples doesn’t contain pesticide concentrations
that exceed legal standards, it says little about the actual total amount of
residues found. See Table 5 with examples of quantities of individual residues
allowed in apples and strawberries (the table shows only a small selection of
active substances and the MRLs for apples and strawberries). For example in one
kg of apples, 6 mg iprodion is legally permitted and in one kg of strawberries
20 mg; on the other hand, one kg of apples may contain 2 mg imazalil and one kg
of strawberries 0.05 mg.
The established
standards are often not logical. Another example: is there an explanation why
0.1 μg/l of fipronil may be present in drinking water, whereas for this highly
toxic substance the environmental quality standard is nearly a thousand times
lower and in root and tuber crops almost a million times higher than in surface
water? It is also not logical that the MRL for fipronil in milk is higher than
in eggs. See table 4. The consequence of
these MRL values for foodstuffs is that in principle many products in the
supermarket can be acutely toxic to our ecosystem and are considered safe by
the regulations for our health! After all, only 8.3 ng/l of imidacloprid is
allowed in surface water and 0.1 mg/l in milk (12048 times as much). This
discrepancy applies to almost all foods.
In general, a very
strict norm for aquatic environments is set, which does not seem to have any
relationship with the norms for our internal ecosystem (our metabolism).
However, there are pesticides such as imidacloprid and thiacloprid for which
there is no safe MTR or EQS for the ecosystem. These two substances are very
persistent and bind virtually irreversibly to nervous system receptors in
insects, and their toxicity is reinforced by exposure time [25]. These highly
toxic insecticides are found in large quantities in the surface water [26] and
in agricultural products. They are widely used in areas with bulb and
greenhouse cultivation, in horticulture and in arable farming. Furthermore,
they are used in ants bait boxes, neckbands for cats, dog shampoos, etc.[27, 28]
7.
Examples of environmental quality standards for pesticides in surface water and
in agricultural products
In
the Directive 2008/105/EC are (Annual
Average-) Environmental Quality Standards, Maximum Allowable Concentrations for
pesticides in surface water are defined. Some examples of the different standards and the
values for five selected pesticides are presented in table 3. A
Maximum Permissible Concentration (MPC) for fipronil in Dutch surface water has been set at
0.07 ng / L (Table 3). As a result of limitations in analytical methodology,
with detection limits usually at 10 ng/L or higher, Dutch Water Boards have
been unable to measure fipronil in surface water at concentrations up to 150
times above EQS, creating blind spots in most areas of the country. However,
the EQS for glyphosate is so high that the set MAC–EQS is seldomly exceeded.
Table 3. Examples of
standards for some pesticides in surface water (µg/l) [15]
Active agents
|
AA-EQS μg/l
|
MAC-EQS
μg/l
|
MPC
μg/l
|
Imidacloprid
|
0.0083*
|
0.2
|
--
|
Glyfosate
|
--
|
77
|
--
|
Fipronil
|
--
|
--
|
0.00007 ug/l *
|
Linuron
|
0.17
|
0.20
|
--
|
MCPA
|
1.4
|
15
|
--
|
*: The analytical
possibilities are limited; many laboratories can not measure these concentrations.
-: No concentration for
the relevant standard is mentioned in the relevant fact sheet
AA-EQS:
Annual Average-Environmental Quality Standard
MAC-EQS: Maximum Allowable Concentration - Environmental Quality
Standard
MPC: Maximum Permissible Concentration
Table 4
shows examples of maximum residue levels for the pesticides glyphosate,
fipronil and imidacloprid in some selected agricultural products. The major deficiency
of these MRLs is that the dose-response characteristics of these pesticides in
mammals are unknown. We simply don’t know whether cumulative toxicity, as seen
with fipronil and imidacloprid in arthropods, could occur in mammals as well.
If so, the MRLs would underestimate actual risk. For the cultivation of several types of cattle feed and fodder, glyphosate
is worldwide applied as an herbicide. The set standards are not always logical.
For example, although in general the annual human consumption of milk is higher
than for eggs, for the highly hazardous insecticide fipronil the MRL in milk is
higher than in one kg eggs. These examples and those in table 5 show also that
most MRLs of fresh products don´t meet the standards of pesticide residues of
0,01 mg/kg in packed food for infants and toddlers. This means, that the
consumption of non-packed food of non-organic origin poses a risk for infants
and for toddlers.
Table 4. Examples of
MRLs for glyphosate, fipronil and imidacloprid in some agricultural products
for human consumption and for animal feed (milligrams per kg)
Agraricultural product
|
Glyfosate
mg/kg
|
Fipronil
mg/kg
|
Imidacloprid
mg/kg
|
Root
and tuber crops, like carrots, beetroot; except sugar beet [29]
|
0.1
|
0.005
|
0.5
|
Pome
fruit, including apples and pears [29]
|
0.1
|
0.005
|
0.5
|
Milk [29]
|
0.05
|
0.008
|
0.1
|
Bird eggs [29]
|
0.05
|
0.005
|
0.05
|
Alfalfa fodder [22]
|
500
|
--
|
--
|
Barley straw and cattle feed (dry) [22]
|
400
|
--
|
1
|
Maize cattle feed (dry) [22]
|
150
|
0.1
|
0.2
|
Maize [22]
|
5
|
0.01
|
--
|
--
no norm established
Pesticide MRLs apply to 315 fresh
products and to the same products after processing. In case of processed
products the MRLs are adjusted in order to take account of dilution or
concentration during processing. Legislation covers pesticides currently or
formerly used in agriculture in, or outside, the EU. This are over 1300 active
ingredients [30]. In table 5 a small selection of the MRLs of pesticide
residues in the popular fruits apples, strawberries and bananas is shown. The
MRL for one and the same active substance can differ between different products
with a factor 1000, for instance in case of azoxystrobin. This is also the case
for the MRL for iprodione in strawberries and bananas.
Table 5. Examples of
MRLs established for apples, strawberries and bananas (milligrams per kg) [31]
Active agents
|
Apples
mg/kg
|
Strawberries
mg/kg
|
Bananas
mg/kg
|
|
acetamiprid
|
0.8
|
0.5
|
0,4
|
|
abamectin*
|
0.03
|
0.15
|
0,01
|
|
aldicarb*
|
0.02
|
0.02
|
0.02
|
|
amitraz
|
0.05
|
0.05
|
0.05
|
|
azinphosethyl*
|
0.02
|
0.02
|
0.02
|
|
azinphosmethyl*
|
0.05
|
0.05
|
0.05
|
|
azoxystrobin
|
0.01
|
10.0
|
2.0
|
|
captafol*
|
0.02
|
0.02
|
0.02
|
|
captan
|
10.0
|
1.5
|
0.03
|
|
carbendazim*
|
0.2
|
0,1
|
0.1
|
|
chloridazon
|
0.1
|
0.1
|
0.1
|
|
chlorothalonil*
|
2.0
|
4,0
|
15.0
|
|
chlorotoluron*
|
0.05
|
0.01
|
0.01
|
|
chlorpyrifos-methyl*
|
0.5
|
0.5
|
0.05
|
|
chlorpyrifos*
|
0.01
|
0.5
|
3.0
|
|
cyprodinil
|
2.0
|
5.0
|
0.02
|
|
deltamethrin*
|
0.2
|
0.2
|
0.01
|
|
dicamba
|
0.1
|
0.05
|
0.05
|
|
dichlorprop
|
0.02
|
0.02
|
0.02
|
|
glyphosate*
|
0.1
|
0.1
|
0.1
|
|
Imazalil*
|
2.0
|
0.05
|
2.0
|
|
imidacloprid*
|
0.5
|
0.5
|
0.05
|
|
iprodione*
|
6.0
|
20.0
|
0.01
|
*classified by Pesticide Action
Network as very toxic to humans and / or environment [24]
8. Insufficient safety to consumers
and the environment
Based on the
foregoing, it is clear that the current system of standards and control
mechanisms offers insufficient safety to consumers and the environment. A
continuation of the current policy will lead to a further disruption of our
ecosystem and in the short term also of the economy. Recent research has made
it clear that populations of meadow birds and insects [32] are disappearing at
a very high rate. In the short term, the legislator must ensure that all
pesticides from categories B, C, D in Table 2 are taken from the market until
further research by independent bodies has clarified their dose-effect
relationship. The standards for residues in foodstuffs should be based on
levels that agricultural products have today without the use of these substances
(todays background level), so that the precautionary principle is applied to
all consumers.
Many still say
that we cannot do without pesticides. There were in 2015 almost 185,000 organic
farms in Europe [33] that prove that we can work without all those risky means
of plant protection, and on average earn even better than conventional farms.
Many studies have shown that the world can be fed by agriculture without
pesticides, under the condition that we reduce our consumption of meat and the
waste of food is reduced [34, 35].
It is also true
that improvements can also be made in organic farming, also with regard to
unintentional contamination with pesticides [36,37]. Transparency is also a
prerequisite there. For conventional farming the authorization procedure for
pesticides, many of which are classified as very dangerous for humans and / or
nature, must be fundamentally changed. Toxicity testing and results of all
authorized means of plant protection must be made public. New substances may
only be authorised if they have a strictly dose-dependent dose-effect
relationship and meet all other admission criteria.
Farmers who want
to switch to organic farming must at least receive sufficient financial and
technical support during the years of conversion. Technical and practical
knowledge is now abundantly available at farms that already work organically,
in research institutions and in extension services.
8. Conclusions
The authorization
procedures of pesticides do not take into account the actual dose/time/effect
relationships of pesticides, and as a result the authorizations carry enormous
risks for people and the environment. Authorisation procedures are based on
strictly separate worlds; the human body and nature. In reality, the human body
is part of nature. The authorization does not consider any synergistic toxic
effects of additives that are added to pesticides that come onto the market. The
synergistic effects of different pesticides are not taken into account in
authorisation. In authorisation procedures, by definition, the unbelievable
complexity of nature cannot be considered.
Animal medicines
are in the EU authorized without any transparant ecotoxicological testing. Thus,
these medicines and their metabolites end up in our ecosystem without any public
control, Therefor, new authorization procedures must be elaborated, which take
into account ecological safety and transparancy.
In the case of
authorisation of various substances (such as neonicotinoids), the Ctgb
evidently disregarded the rules that apply to the Ctgb officially: before a
plant protection product or biocide can be authorized, the Ctgb assesses
whether the product is safe for humans, animals and for the environment. Neonicotinoids are poorly
degradable, can leach and are highly toxic to many organisms.
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