Advisory Committee on Pesticides Annual Report 2001

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Section E: UK Review Programme legitimate difficulty. The <strong>Committee</strong> agreed that currently there were no grounds for revocation of the existing product. It agreed that approval for the product should be allowed to continue subject to a commitment within two months to produce the necessary data identified in accordance with agreed deadlines. In addition, the <strong>Committee</strong> agreed that the company should be required to produce a further report on the potential for reformulation of its product. Some time after the <strong>Committee</strong>’s consideration of this subject, the approval holder reported that it was currently unable to comply with the requirements. Therefore the <strong>Committee</strong> agreed that this remaining product should also be revoked. It was also noted that the position with respect to PSD approvals needed to be considered and it was concluded that a short period should be provided for approval holders for products registered with PSD to provide commitments to produce the relevant data. On the basis of the evidence provided by the main data holder on behalf of the PSD approval holders of their support for dichlorophen, both in the UK and under the EU programme, the <strong>Committee</strong> recommended that approvals be allowed to continue pending submission of the specified data. 57 Dichlorvos Dichlorvos is an organophosphorus compound currently approved for use as an insecticide against crawling and flying insects in non-agricultural pesticides. It is one of the chemicals included in the review of organophosphorus and carbamate compounds. Twelve approval holders submitted data on the active substance and approved products to the review. At its meetings in April and May 2001, the ACP considered the available physicochemical, toxicological and efficacy data on dichlorvos and recommended in May 2001 that Ministers be advised that: a) approval for all aerosols containing dichlorvos be revoked based on the unacceptable toxicity-exposure ratios (TERs) derived for primary and secondary exposures from professional and amateur use; b) approval for residential uses of slow release controllable and noncontrollable cassettes containing dichlorvos be revoked based on the unacceptable TERs derived for secondary exposures from professional and amateur use;
<strong>Advisory</strong> <strong>Committee</strong> on Pesticides Annual Report 2001 c) approval for the professional use of slow-release strips and controllable and non-controllable cassettes containing dichlorvos in museums be retained subject to the fulfilment of physicochemical, operator exposure and efficacy data requirements; d) approval for the use of slow-release strips in pheromone traps in areas where food may be stored, prepared or consumed be suspended pending the provision of information on food residues; and e) approval for the use of slow release strips in pheromone traps in areas where food is not present be retained subject to the fulfilment of physicochemical and efficacy data requirements. A review of the agricultural uses of dichlorvos was also considered by the ACP at the same time (see page 42). 58 The ACP also noted that dichlorvos was under discussion by the <strong>Committee</strong> on Mutagenicity of Chemicals in Food, Consumer Products and the Environment (CoM), and recognised that their recommendations would perhaps require modification in accordance with the COM’s findings. At the July 2001 ACP meeting, the <strong>Committee</strong> considered the implications of the COM’s possible conclusions, and agreed to advise Ministers as follows: a) If the COM’s final conclusions were that dichlorvos was an in-vivo mutagen, and it could not exclude the possibility that the occurrence of tumours in animal tests of carcinogenicity resulted from a genotoxic mechanism, there should be immediate revocation of all uses (both agricultural and non-agricultural). b) Alternatively, if the COM concluded that dichlorvos was an in-vivo mutagen, but that the tumours observed in animal tests did not result from a genotoxic mechanism, or if it could not confirm that dichlorvos was an in-vivo mutagen, or if it took the view that dichlorvos was not an in-vivo mutagen, then the ACP’s previous recommendations would be maintained. The COM concluded, following a second meeting in July 2001, that dichlorvos should be regarded as an in-vivo mutagen (i.e. capable of inducing mutations in living animals) at site of contact and that it could not exclude the possibility of it acting as a genotoxic carcinogen. The COM statement on dichlorvos was finalised in late July 2001. Consequently the ACP recommended to Ministers that, as a precautionary measure, it would be prudent to revoke, with immediate effect, all agricultural
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Advisory Committee on Pesticides Annual Report 2001

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