10 Public Interest Demands to re-orientate policy and Risk Assessment
RITE Is A Safe Solution To A Broken And Compromised Pesticides Assessment System. The Current Assessment Agencies - The US Environmental Protection Agency, The World Health Organisation and the European Commission - are riddled with conflicts of interest and organisational barriers that result in skewed 'evidence based science' that has little real world application. Current risk assessment appears impotent and profoundly unable to account for increasing environmental exposures and biological and chemical complexity. RITE forms a framework for independent and transparent risk assessment:
2. Pesticide groups (and their breakdown products, metabolites) with similar adverse effects must undergo cumulative testing. Impose an extra safety factor to take into account additional environmental exposure.
3. Stop industry from selecting studies that form the literature review for toxicity assessment. Conduct a wide-ranging literature reveiw, and accept research by scientists financially independent from the final risk assessment decision and rapidly move towards a system in which all the testing is done by such independent scientists.
6. Ensure formulation mixtures are tested at the delicate 'environmentally relevant' levels that may adversely affect the endocrine system and/or epigenetically influence DNA.
7. Move to a new organisational model. Current challenges faced by risk assessment agencies demonstrate that the increasing complexity of risk assessment and quantities of chemicals to manage is not reflected by budgetary increases nor adoption of 21st century scientific understand of low dose harm from chemical synergies. RITE recommends establishment of an independent, publicly managed organisation employing independent scientists to conduct transparently conducted research for toxicology and risk assessment. (And no liability to pesticides organisations for its decisions).
8. Industry will pay fees for assessment of its products which reflect the rigors of 21st century scientific enquiry. The pesticide assessment fee structure will cover research, risk assessment and organisational costs. Fees would be required for new products and regular reassessments.
10. Ensure a wide range of expertise is involved in assessing the risks of pesticides, e.g. Embryologists, endocrinologists, neurodevelopmental experts, ecologists and soil biologists.
The guidelines and protocols that form the framework to derive the scientific studies considered by the major regulatory agencies, are failing to keep step with scientific knowledge. Guidelines and protocols are a form of subordinate legislation that must be consistent with the purpose of the statutory rules under which they have been developed.
It is well known that chemicals harm at chronic, low dose effects. That the synergies of chemicals that the population - including the developing baby - is exposed to can be damaging. Risk assessment fails to account for the fact that chemicals can impact many pathways in the body, work synergistically and that dose effects may follow a non-linear path. I.e. the hormone system may respond to low dose effects, potentially exerting more harm on the body than a higher dose.
Regulators have never researched formulation effects to the microbiome; nor for example, consider the cumulative exposure of fungicide mixtures applied to cereal crops. Also ignored are early stage effects (via Hallmarks) that can lead to development of cancer, and effects that may come from the complete mix of chemical exposures - regarding pesticides - commonly neonicotinoids, fungicides, insecticides and herbicides may be applied to a single crop. Epigenetics too, are not taken into account. Neonatal, infant and childhood exposures calculations do not allow for 'windows' of vulnerability. I child is not simply a proportion in weight of an adult.
The data gaps are staggering if 21st century scientific understanding of the pathways to disease is to be taken into account.
These regulators - and the countries that allow these regulators to influence their own government policies fail account for complexity - they fail to protect health. Yet the chemicals they approve into the environment number in the hundreds of thousands.
By relying on narrow linear models - endpoints - current systems of risk assessment are profoundly out of touch with new science.
The close connections between industry and regulators is well documented, and the lag to develop guidelines is believed by many to be a result of industry influence. Pesticides organisations select the studies they would like regulators to see - there is no requirement for disclosure of all studies. The revolving door of science and policy further entrenches guidelines, protocols and science lag. Regulators assess risk to arrive at protocol and guideline derived 'evidence based' decisions in favour of the industry studies that so happily subscribe to their own guidelines.
Emasculated regulators are not well financed, they rely on small budgets and are unable to keep up with the enormous amount of chemicals requiring risk assessment - the mounting chemical load has overwhelmed their resources. The reticence of science advisers & chief scientists in these matters - contributes to mistrust and concern that governments and regulators patently lack the desire or the ability to put public health before trade based interests.
At the World Science Forum (WSF) in Budapest in 2015, delegates called for:
“..The need to define the principles, processes and application of science advice and to address the theoretical and practical questions regarding the independence, transparency, visibility and accountability of those who receive and provide advice has never been more important…………We call for concerted action of scientists and policy-makers to define and promulgate universal principles for developing and communicating science to inform and evaluate policy based on responsibility, integrity, independence, and accountability.”
This was followed by the INGSA 'Science and Policy-Making: towards a new dialogue' conference September 2016.
Today, corporate science appears to be at the heart of critical policy and risk assessment decisions these guardians of public health make. This has resulted in biased and lagging decision-making and contributes to unsound policies and unsafe pesticide exposure at the levels we currently consume.
RITE is 10 demands for transparent change in the processes and methods used to assess pesticides for toxicity.
A platform for developing a new international assessment agency and pesticide assessment system structured to transparently place the welfare of the global population first.