Report from the Sub-comittee on the environment and health

The sub-committee’s
considerations concerning
use of <strong>the</strong> precautionary
principle in <strong>the</strong> health area
11.6 The sub-committee’s conclusions and recommendations
concerning <strong>the</strong> precautionary principle
The sub-committee has operated with two different approaches to <strong>the</strong>
precautionary principle – a risk assessment approach and a zero value
approach.
Use of <strong>the</strong> risk assessment approach can imply a "conservative" (=
"cautious") assessment based on concrete empirical evidence, whereas
<strong>the</strong> zero value approach can be based on initially value-determined
quality requirements that may only be deviated <strong>from</strong> after an assessment
based on definable protection requirements.
If <strong>the</strong> risk assessment approach can be based on sufficient scientific data
to ensure complete protection of health and <strong>the</strong> environment, <strong>the</strong> use of
uncertainty factors can be said 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 based on existing knowledge. However, <strong>the</strong>re are still
unsolved questions about <strong>the</strong> possible inadequacy of uncertainty factors
and <strong>the</strong> general questions concerning uncertainties due to lack of
knowledge or indeterminacy related to <strong>the</strong> role of pesticides in society.
The sub-committee has specifically examined possible applications of
<strong>the</strong> precautionary principle beyond <strong>the</strong> existing authorisation scheme,
which can be described as a scientifically based risk assessment.
The sub-committee has discussed whe<strong>the</strong>r <strong>the</strong> zero value approach could
be used within an authorisation scheme for pesticides – in <strong>the</strong> following
areas, for example – if it were found desirable to use this approach in <strong>the</strong>
health area.
1. Reduction of <strong>the</strong> limit value for pesticide residues in food products to
<strong>the</strong> lowest detection limit applying 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 that meet requirements concerning zero mobility or only
negligible mobility in soil.
3. No authorisation of substances classified as carcinogenic in cat3,
mutagenic in cat3 or reproductive effect in cat3.
4. Wider powers to impose restrictions on use with a view to avoiding
direct application on crops, trees and bushes in <strong>the</strong>ir seed- and fruitand
berry-bearing periods. Treatment after <strong>the</strong>se periods implies direct
application of chemicals to what will be <strong>the</strong> edible crop. Spraying
practice should thus be changed with a view to reducing <strong>the</strong> residual
contents found today to below <strong>the</strong> detection limit. In o<strong>the</strong>r words, <strong>the</strong>
precautionary principle should be applied as it is in <strong>the</strong> case of <strong>the</strong>
limit for drinking water.
It must be stressed that <strong>the</strong> sub-committee has not carried out an
assessment of 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:
223