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Cut-Offs and Candidates for Substitution: Member State view Outline • Regulatory framework for plant protection products (PPP) • Endocrine disruptors (ED), • PBT, vPvB, POP • Groundwater, Honeybees • Candidates for Substitution • Comparative Assessment • Conclusions BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 2 Introduction • New pesticide regulation entered into force in June 2011 - 1107/2009/EC – Approval actives/Authorisation products, - Annex II – Approval criteria for actives = cut-offs and for Candidates for Substitution (CfS), - No approval of a.s. at EU-level if cut-offs fulfilled (e.g. 3 PBT), - Less hazardous compounds – CfS (e.g. 2 PBT) - Regularly authorisations at zonal level but - Comparative Assessment at MS-level (Art. 50). BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 3 Endocrine disruptors • Activities at EU and national level, • DG Environment has the lead at EU-level for all types of compounds, • But differences between groups of compounds to be considered; e.g. a.s. of PPP are data rich! • Assessment scheme was expected for the end of 2013 but impact assessment still underway, • Additional data requirements for some compounds have been raised in DE, • But no final identification as ED and subsequently no authorisation in DE so far. BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 4 Endocrine disruptors • Assessment by mammalian toxicologists first, • If ED-specific properties but no negative decision to be taken in this area, environmental evaluation is triggered, • Only if endocrine endpoint most sensitive it should become relevant for decision making, • According to DE approach substances with intended endocrine MoA in non-vertebrates (e.g. insect growth regulators) not regarded as EDs because selectivity of products is preferred, • Preliminary evaluations of some substances were presented at SETAC in Milan, • In DE a paper summarising all ED-activities (health and environment) was prepared and sent to DG Env. • Overall situation currently not really clear. BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 5 PBT and other cutoffs • Activivities in OECD-group on PBTs have not made too much progress, but new start announced, • PBT-evaluation has been made over the last years for industrial chemicals at EU-level, guidance exists, • To which extent must approaches amongst industrial chemicals, biocides, plant protection products be harmonised? • Again, PPP are data rich and all data should be used if appropriate, • Implications for decision-makings different; only for PPP „cutoff“-criteria. BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 6 PBT and other cutoffs • Items under discussion: - Annex II of 1107/2009 don‘t follow a compartment approach, - Use of data from field studies for P-evaluation unclear, • Other cut-offs unclear e.g.: - UP criteria for groundwater must be fulfiled, - What to do if monitoring data are continously above 0.1 µg/l in a considerable number of cases ? - Honeybees – only UP must be fulfilled ? BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 7 Candidates for Substitution (CfS) • Preliminary criteria were developed in a small group of COM and MS in 2012, • In 2013 consultant worked through endpoint lists of active substances of products on the market at the end of 2012, • Report was made available until autum 2013, • Authorisation holders and MS checked results of study, • COM will present list of CfS in March meeting of standing committee. BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 8 Candidates for Substitution • From the draft study report it is clear that PBT criteria are most important for identifying CfS, • Approximately 80-100 compounds will become CfS, • Depending on transitional periods work for MS on Comparative Assessment (CA) will start by end of 2014, • SWE has used CA for decision-making over a long time, • Some MS have started with case studies (e.g. NL) or even circulated national guidance for conducting CA (UK), • National paper on CA in DE will be prepared subsequently to finalisation of EU-Guidance. BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 9 Comparative Assessment (CA) • Final version of EU-GD will be made available by COM in March meeting of standing committee, • Role of applicants not really clear, • Each use of product with CfS must be evaluated, • First step: Looking for alternatives in efficacy area, • Other products or non-chemical methods are available? • Resistance management, IPM relevance, importance of CfS for minor uses are important, • EPPO guidance available but more detailed criteria may be needed in future, BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 10 Comparative Assessment • How many minor uses for example balance critical major crops? • What are economic advantages/disadvantages (e.g. non-chemical methods; hoeing - herbicide)? • High number of uses/products with no alternative expected, • If alternatives are available: - relative risk to health and environment, - first look to areas of concern decisive for identifying CfS, - strength of risk mitigation measures important. • Clear differences to alternative must be determined • Otherwise no substitution • Lot of work for MS expected BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 11 Conclusions • “Cut-off”-criteria for approval of actives under 1107/2009 to be specified, • Endocrine disruption and PBT… important, not too much work on other parameter underway, • Some cut-off criteria are important for identifying CfS too, • Preliminary list of CfS will be made available by COM soon, • EU-GD are nearly finalised, • CA will be conducted at MS-level, • MS have started with work on conducting CA. BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 12 Thank you for you attention! contact: BVL, Dienststelle Braunschweig Messeweg 11/12 38104 Braunschweig Telefon: 0531 / 299-3609 E-Mail: [email protected] Internet: www.bvl.bund.de BVL, Abteilung Pflanzenschutz, Dr. Martin Streloke 13.03.2014 Seite 13