Report from the Sub-comittee on the environment and health

The sub-committee’s
recommendations
concerning
proportionality
Conclusions concerning
coformulants
The sub-committee’s
recommendations
concerning coformulants
• The content of nitrate in drinking water in Denmark is a bigger health
problem today than <strong>the</strong> pesticide residues in drinking water owing to a
low safety margin in connection with <strong>the</strong> formation of nitrite in water
used for newborn infant formulae.
• The use of veterinary drugs and growth promoters involves a risk of
<strong>the</strong> development of resistant microorganisms, and too little is as yet
known about <strong>the</strong> possible effect of manure on cultivated land to assess
veterinary drugs and growth promoters in relation to pesticides. Some
of <strong>the</strong> leachable growth promoters that are used have properties that
are reminiscent of pesticides, but <strong>the</strong>ir behaviour in <strong>the</strong> soil has not
yet been sufficiently clarified to assess a possible risk of leaching to
<strong>the</strong> groundwater.
• A number of naturally occurring substances are to a limited extent
used as pesticides. The substances in question are relatively easily
degradable, so <strong>the</strong>ir action time is short, but <strong>the</strong> sub-committee finds
that <strong>the</strong>re is in principle no difference between <strong>the</strong>se substances and
syn<strong>the</strong>tic pesticides. The sub-committee concludes that, compared
with natural substances, pesticides have a considerably greater
potential for environmentally harmful effects because of <strong>the</strong> way <strong>the</strong>y
are used, relatively low degradability and <strong>the</strong>ir chemically
determined, intensified mode of action. With respect to human health,
<strong>the</strong> sub-committee finds that some naturally occurring constituents of
plants can present a risk and that, for example, in connection with
“Novel Food” products or GMO products, <strong>the</strong>y should be subjected to
a risk analysis in line with pesticides.
In view of <strong>the</strong> widespread occurrence of small quantities of many
chemicals in all compartments, <strong>the</strong> effects of which should perhaps be
added toge<strong>the</strong>r to give a realistic picture, <strong>the</strong> sub-committee
recommends, in accordance with <strong>the</strong> precautionary principle, that <strong>the</strong>
total chemical load on <strong>the</strong> environment be reduced as much as possible in
order to reduce <strong>the</strong> exposure of both humans and <strong>the</strong> environment.
The sub-committee has, in particular, assessed <strong>the</strong> coformulants that are
added to pesticide formulations. These coformulants are not covered by
an authorisation scheme of <strong>the</strong> same scope as in <strong>the</strong> case of active
pesticide ingredients. Coformulants are a very large group of substances,
which may vary between different batches of a product or between
different types of <strong>the</strong> same product. The coformulants are normally less
harmful to <strong>the</strong> environment and health than <strong>the</strong> active ingredients.
However, <strong>the</strong>y often occur in large concentrations and some of <strong>the</strong>m are
harmful to <strong>the</strong> environment and/or health, e.g. acutely or chronically
toxic substances. Some of <strong>the</strong> substances can thus be more harmful to <strong>the</strong>
environment or health than <strong>the</strong> active ingredient to which <strong>the</strong>y are added.
A few of <strong>the</strong>m are included in <strong>the</strong> Danish Environmental Protection
Agency’s Blacklist.
The sub-committee recommends that <strong>the</strong> authorisation scheme be
expanded so that <strong>the</strong> requirements concerning coformulants approach <strong>the</strong>
requirements made concerning active ingredients. This includes banning
all carcinogenic substances. However, <strong>the</strong> coformulants are also used for
o<strong>the</strong>r purposes than pesticide formulations. The regulations governing
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