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Activist critique based on misinterpretation of agvet chemical regulatory system

18 July 2010

The joint National Toxics Network (NTN)/WWF report released today (external site) selectively and incorrectly interprets the significance and nature of the decisions made by national and international regulatory agencies.

The 120+ chemicals NTN/WWF has identified are used throughout the world for a variety of uses as authorised and controlled by different national regulators. The majority of those identified, for example, are permitted in countries such as the United States, Canada, New Zealand and South Africa.  This information is publicly available and can be found, among other places, on the environmental movement’s own pesticide database (www.pesticideinfo.org).

Many chemicals NTN/WWF claim to have been prohibited in the European Union because of risks to human health and the environment have, in fact, not gone through any formal human health or environmental assessment. Many were withdrawn prior to assessment by registrants for commercial reasons. Others were excluded pending the development of additional scientific data. The European Union has published information outlining the outcome of this review process (external site).

The NTN/WWF identified a number of chemicals that have identified hazards of various sorts such as those that are potentially carcinogenic or thought to be endocrine disruptors. These, and other hazards that chemicals may present, are well known in regulatory circles. All agricultural chemicals present hazards of some sort. The APVMA’s role is to systematically assess each of these chemicals and determine if they can be used safely subject to a range of legally enforceable risk mitigation measures. If they can, they are permitted. If not, they are refused market access. The NTN/WWF sought to highlight the raw hazards of particular chemicals but did not evaluate the effectiveness of APVMA measures to effectively manage the risk these chemicals present. It is indeed true that the inherent properties of a chemical are universal but it is the exposure that determines whether people or the environment are at risk.

Notwithstanding these issues, comparisons between the APVMA and other national regulators on the basis of the chemicals each permits to be used are rarely meaningful or valid. Each regulator works under different legislative frameworks, has different regulatory tools at their disposal, and typically responds to different climatic conditions, crops, use patterns and cultural practices.  On this basis it would be very unusual for different national regulators to make exactly the same decisions as regulators in other countries.

The APVMA’s legislative brief, noting the benefits obtained from the use of agricultural chemicals, is to determine those that can be safely used in Australia subject to any conditions the APVMA may impose. The measure of the APVMA’s success is not the degree to which it follows or leads other regulators but its effectiveness in managing risks to human health, the environment and trade in Australia. The NTN/WWF critique did not address this issue. It did not provide any credible scientific evidence that Australians or the Australian environment are being exposed to harm.

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