FOOD RESIDUES

FOOD RESIDUES IN FRUITS AND VEGETABLES
The last EU monitoring report on pesticide residue in food published in 2005 with 2003 data, shows a frequency of samples with residues above the Maximum Residue Levels (MRLs) of 5.5% and a frequency of samples with residues at or below the MRLs of 38%. Thus, the frequency of samples with detected residues amounts to 44% of the total number of samples in 2003. These values haven't changed since 2002, but since 1999 they have increased from 36% to 44% of all samples in EU.

The highest level of exceedances in the EU co-ordinated monitoring was found in peppers (6%), grapes (5%), cucumber (3%) and aubergines (3%). Among the most common substances found exceeding the MRLs (methomyl, methiocarb, metalaxil, methamidophos, benomyl-group, acefate, dimethoate, endosulfan, bromopropylane, chorpyrifos, captan+folpec, imazalil and maneb-group), there are 7 acute toxic, 7 cholinesterase inhibitors, 6 potential groundwater contaminants, 5 suspected endocrine disruptors, 6 carcinogens or possible carcinogens and 4 developmental or reproductive toxins, according to classifications by various governmental and international agencies.

Because most residue limits are set on the basis of adult bodyweight, children can consume a disproportionate level of pesticide residues. At the residue levels found across Europe, a toddler would consume 147% of the conventional acceptable daily intake of chlorpyriphos in table grapes, 164% of methamidophos in sweet peppers, over two times the level of endosulfan and over five times the level of triazophos in sweet peppers and a staggering ten times over of the acceptable level of methomyl (1.035%) in table grapes. All these pesticides are known hazardous substances. The evaluation of acute risk was carried out in the EU monitoring report for pesticide with acute toxicity and were acute Reference Doses (aRfD) have been set. These data are based on a consumption model for the UK, if a toddler living in other European regions consume a higher amount of fruits and vegetables these results highly underestimate their risks. If, instead, the German consumption model is used, the residue of 0,68mg/kg methamidophos in sweet pepper results in a percentage aRfD of 4.283% which is, thus 42 times too high. The Commission report gives a 164% aRfD for the same residue.

The number of samples containing multiple residues also increased greatly since 1999 and is now 20,5% of all samples. The health risks of combined (additive) effects are (mostly) ignored within the official risk assessment up to now.

These results show a complete failure of the EU in controlling the level of pesticides in our food.

MRL HARMONIZATION PROGRAMME
Since 1993, the EU has been implementing a programme to establish harmonized maximum residue levels (MRLs) which restrict levels of pesticide residues in foodstuffs sold in Europe. MRLs for foodstuffs are established both nationally and internationally with the key objectives of:

1. controlling the correct use of pesticides in terms of the registered use;

2. permitting the free circulation of food commodities that have been treated with approved pesticides and comply with the established MRLs;

3. minimizing the exposure of consumers to harmful or unnecessary intake of pesticide residues.

MRL levels are established by balancing four different types of data: (1) levels of residues resulting from pesticides applied following a defined schedule, ‘good agricultural practice’ (GAP), which takes into account operator safety and environmental impact as well as efficacy; (2) the persistence of residues of the particular pesticide in the given crop; (3) the toxicity of the chemical; and (4) how much of the final product is typically eaten by the consumer. The stated aims of the EU harmonisation programme are to iron out current inconsistencies in national MRLs in the different member states, by establishing common and obligatory MRLs for all active ingredients approved for use within the EU, based on systematic and scientific procedures. The relevant EU directives establish obligatory MRLs for specific crop/active ingredient combinations where sufficient data is available, and also specifies what data is required to establish an MRL where data are not currently available.

COMMISSION PROPOSAL (2003)

The Commission proposal was for a simplification and harmonisation of the arrangements for protecting public health against toxic effects of pesticide residues. The current position is that member states have responsible for setting temporary (provisional) Maximum Residue Levels (MRLs) for new chemicals. Member states have then to notify their conclusions to Brussels and other member states, which may then respond - for example, by adopting them themselves. The member states also play an important role in the production of the monographs necessary to substantiate their action. Under the Commissions proposal, these tasks would be taken over by the EFSA. Risk assessment, under the proposal, will become a responsibility of EFSA, which will use its network and institutes in member states to provide an opinion on the safety of the MRL for a particular pesticide.

The proposed method to establish MRLs is in accordance with the approach already used in most member states. The MRL is first fixed at the lowest residue level measured in the various crops under conditions of Good Agricultural Practice (GAP). However, as is noted in the Commission’s proposal, GAP with authorised use of pesticides varies between member states (e.g. due to climate) and may give rise to different residue levels. The EC proposal is to use the highest levels (‘critical’ GAP) to set MRLs, unless this level is not considered safe for the consumers. This proposal means that member states using GAP developed to minimize the use of pesticides will then use the higher MRLs applied in countries using less environmentally desirable methods. Then EFSA will combine these data with available toxicity data to determine the safety of each MRL. This evaluation could be complicated, since a high MRL for a food item (such as chilli) consumed only in small amounts may be less problematic than a lower MRL for an item (such as carrots) sometimes consumed in substantial amounts.
PAN Europe welcomed the EU Commission's initiative to harmonise maximum residue limits (MRLs) and a limit of 0.01 mg/kg being set for pesticides which are non-authorized or not allowed in the European Union. The proposal, however, contained significant deficiencies and ought to be revised and improved accordingly. Our main comments were:

1. Good Agriculture Practice (GAP) should be defined as ICM (Integrated Crop Management) as a minimum standard to prevent environmentally less desirable methods of farming;
2. Temporary MRLs could be harmful to consumers and are not necessary;
3. Consumers should be protected against additive and synergistic effects of combined residues in total food and exposure from other environmental sources.
4. Transparency and participation in evaluation and decision-making processes in MRL-setting should be secured.
In addition, PAN Europe believed that another objective must be to protect environment and human health – especially vulnerable groups such as foetuses, infants and children – according to the precautionary principle. MRL-setting at the lowest level possible can contribute to the protection of consumers and the environment at the same time. You can read the full PAN Europe position here.

CURRENT SITUATION REGARDING MRL LEGISLATION

The Commission proposal for a new pesticides residue directive aiming to harmonise MRLs across the EU was discussed in March and April 2004 by European Parliament members. PAN Europe network members were very critical of the Commission proposal and submitted suggested amendments to ensure better consumer protection. Debate over proposals in the new European Pesticide Residue Directive came to an end at the 2nd reading in the European Parliament in November 2004. Successful consensus talks were held between European Parliament and Council, and the consensus amendments were passed in the plenary voting on 15 December 2004.

PAN Europe positions were instrumental in getting stricter amendments into this directive, including:
- getting "known" cumulative and synergistic effects considered;
- taking children and the unborn as the most sensitive group to protect;
- taking all sources of exposure into account;
- making a review of all "available" recent scientific literature mandatory;
- evaluating immunotoxicity, endocrine disruption and developmental toxicity;
- setting standards at the lowest (strictest) level;
- making naming and shaming of companies exceeding standards optional for Member States

The EU is now developing a list of products of plant and animal origin for which EU-wide MRLs should be set in next 18 months. It will compile all current national MRLs and select the most appropriate ones for use at EU level.

LINKS

- EC Regulation No 396/2005 on maximum residue levels of pesticides in or on food and feed and plant or animal origin

- DG Health and Consumer Protection web page: complete list of MRL legislation http://europa.eu.int/comm/food/plant/protection/pesticides/legislation_en.htm

- DG Health and Consumer Protection web page: annual EU-wide pesticide residue monitoring reports http://europa.eu.int/comm/food/fvo/specialreports/pesticides_index_en.htm

- PAN Germany pesticide residues in Europe project: http://www.pesticide-residues.org/

- Greenpeace Germany residues projects and actions (in German) http://www.greenpeace.de

- Global 2000 pesticide reduction in supermarkets in Austria (in German) http://www.global2000.at