Report from the Sub-comittee on the environment and health

166
If <strong>the</strong> risk assessment approach could be based on a sufficient quantity of
scientific data to ensure complete protection of health and <strong>the</strong>
environment, <strong>the</strong>n, for example, <strong>the</strong> use of uncertainty factors (UH)
could be held to be a satisfactory implementation of <strong>the</strong> precautionary
principle. Such an approach would thus mean that <strong>the</strong> precautionary
principle did not add anything to <strong>the</strong> traditional risk assessment. The
authorisation scheme thus seeks to implement <strong>the</strong> precautionary
principle, using all data and taking account of negative consequences of
uncertain or unforeseen exposure, incorrect use, etc. With this approach,
<strong>the</strong>re should be no need for greater use of <strong>the</strong> precautionary principle,
although this nei<strong>the</strong>r solves <strong>the</strong> problem of <strong>the</strong> possible inadequacy of <strong>the</strong>
uncertainty factors nor answers questions about uncertainties as a
consequence of lack of knowledge or indeterminacy related to <strong>the</strong> role of
pesticides in society.
Conversely, <strong>the</strong> zero value approach would not answer directly <strong>the</strong>
question of <strong>the</strong> actual size of uncertainty factors, but would be based on a
value-determined requirement concerning a zero risk society.
The zero value approach could tentatively be used within an
authorisation scheme for pesticides in <strong>the</strong> following areas:
1. reduction of <strong>the</strong> limit value for pesticide residues in food products to
<strong>the</strong> lowest detection level at any time
2. reduction of <strong>the</strong> limit value for pesticides in groundwater to <strong>the</strong> lowest
possible detection limit at any time or authorisation only of pesticides
meeting a requirement of no or negligible mobility in soil
3. no authorisation of substances classified as Carc3, Mut3 and Rep3
4. no authorisation of substances subject to greater distance requirements
than 6 m to watercourses and lakes
5. greater possibility of restricting use with a view to avoiding <strong>the</strong> use of
pesticides directly on crops, trees and bushes in <strong>the</strong>ir seed-bearing,
fruit-bearing and berry-bearing periods.
It must be stressed that it has not been assessed whe<strong>the</strong>r <strong>the</strong> zero value
approach should be used for <strong>the</strong> above-mentioned examples, since that
would require a dialogue between <strong>the</strong> following players:
1. scientific experts to define <strong>the</strong> limit for what can be predicted and
isolate what cannot be elucidated
2. an administrative instance to decide what can be operationalised
3. political decision-makers, i.e. non-experts, to make <strong>the</strong> final decision
on behalf of <strong>the</strong> public, partly on <strong>the</strong> basis of trust in <strong>the</strong> scientific
knowledge and partly on <strong>the</strong> basis of ethical and political
considerations.
It should also be noted that in <strong>the</strong> foregoing examples use is made of
limit values fixed on <strong>the</strong> basis of <strong>the</strong> currently achievable analytical
detection limit. Therefore, as a consequence of continuing technological
development, <strong>the</strong> limit values will regularly be reduced, ending near
zero. This could ultimately lead to a total ban on <strong>the</strong> use of pesticides.