Report from the Sub-comittee on the environment and health

58
completely against future pollution of <strong>the</strong> groundwater. As a safety
measure, a warning system for pesticides has been established with a
view to enabling fast evaluation and, if necessary, removal of
authorised pesticides that are a threat to <strong>the</strong> groundwater.
At present, authorisation of pesticides in Denmark and <strong>the</strong> EU is based
on analyses of research results and assessment of <strong>the</strong> consequences for
health and <strong>the</strong> environment. This means, in particular, that <strong>the</strong> fate of <strong>the</strong>
pesticides is not subject to an analysis of <strong>the</strong> uncertainties and actual
variations that form part of an integrated mass flow analysis – in part
because such an analysis would require data concerning <strong>the</strong> actual use,
dispersal and degradation under Danish conditions. The sub-committee
recommends that an actual mass flow analysis be carried out when
pesticides are being reviewed for renewal of <strong>the</strong>ir authorisation in
pursuance of section 33(4) of <strong>the</strong> Act on Chemical <strong>Sub</strong>stances and
Products. This analysis must include both average and “worst-case”
scenarios based on measurements taken and experience gained in <strong>the</strong>
period in which <strong>the</strong> substance in question has been used. If, in this mass
flow analysis, knowledge is lacking concerning <strong>the</strong> individual flows, <strong>the</strong>
sub-committee recommends that <strong>the</strong> precautionary principle be applied
in <strong>the</strong> assessment of <strong>the</strong> substances in order to counteract or prevent any
consequences of <strong>the</strong> dispersal of <strong>the</strong> pesticides and exposure of people
and <strong>the</strong> environment.
The sub-committee recommends that <strong>the</strong> gross list drawn up with a view
to reexamining leaching of pesticides be included in recommendations
concerning substitution with less dangerous substances. The subcommittee
also recommends that new substances be assessed in relation
to <strong>the</strong> gross list and in relation to non-chemical, alternative methods.
The sub-committee also recommends that volatilisation and chemical
reactions of pesticides in <strong>the</strong> atmosphere be taken into account in
connection with authorisation of <strong>the</strong> pesticides.