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14 January 2009

The APVMA’s decision not to review endosulfan registrations in the light of a decision by the New Zealand regulator to de-register the chemical has drawn comment from a number of commentators.

Some of this comment has been inaccurate. For example, it has been asserted that endosulfan is being considered for a global ban under the Stockholm Convention on Persistent Organic Pollutants. It is implied that this decision will be made in October 2009. However, according to the Convention’s own processes, the earliest this could be done would be May 2011and then only if parties to the Convention supported the move.

Similarly, it has been implied that other countries have deregistered endosulfan because of adverse findings. This is not necessarily correct. In a number of countries other factors have been involved including lack of manufacturer support, high level policy decisions, and the absence of appropriate risk management systems.

A key premise of much of the debate – especially from environmental groups – has been that Australia should necessarily follow the regulatory decisions made in other countries and, indeed, is negligent if it does not so.

This is a premise that needs analysis. While there is significant dialogue between various international regulators including agreed processes and practices, there are many country-specific factors that might lead different national jurisdictions to make varying regulatory decisions. These include (but are not limited to) climate, soil type, crops that are grown, chemical use patterns, cultural practices, and environmental management arrangements.

On this basis, a decision by one country should not necessarily be seen as an imperative for others. Differences between jurisdictions may simply reflect country specific factors.

In Australia the APVMA bases its regulatory decisions on the best available scientific information and a thorough knowledge of Australian circumstances. While Australian decisions generally correlate with those of other countries there are cases where they will be different either in a conservative or progressive sense.