Dear Friends;
 
You may be aware that the European Union is currently considering a new regulatory regime for pesticides used in agriculture.  The rationale for the new regulations, which will come into force in Fall/Autumn 2008, is to reduce pesticide residues on produce and to limit exposure to chemicals that may cause cancer or act as endocrine disruptors.  Essentially the regulations change the way that chemicals are assessed, moving from risk based assessments which evaluate the way in which chemicals are used in the real-world to hazard-based assessments which is based solely on laboratory data of toxicity, carcinogenicity and endocrine disruption.  The regulations take no account of the real-world application of the chemicals and do not account for the risk of NOT using pesticides.
 
According to numerous reports, the implications of the regulations could be very significant for the agricultural sector.  The Economist reports that all but one pyrethroid would be taken off the market in addition to other pesticides. (Economist, July 5th, "Regulating pesticides: A balance of risks") The consequences for food production in the EU would be dramatic, with estimates of yield losses of 29%, 33%, and 20% for wheat, potatoes, and cereals. Reductions in food production at a time of record prices would have obvious and dramatic implications for access to food, especially for the poor.  
 
A largely unreported issue is the consequences of the regulation on public health and in particular malaria control in poor countries.  If enacted, the regulations could shrink the pesticides market, driving up prices and taking some public health insecticides off the market completely. Such an event will affect indoor residual spraying (IRS) programs, long-lasting insecticidal nets (LLINs) as well as efforts to control mosquito larvae. Furthermore the regulations could affect ongoing and much needed research to develop new vector control insecticides.  The new EU proposals will also drive through changes to Maximum Residue Limits (MRLs) (according to Regulation EC 396/2005) on produce and animal products.  New, more stringent MRLs could limit the use of insecticides in vector control out of fear that even the smallest residues will result in the rejection of export produce.  The regulations will clearly have a dramatic impact on health and development more generally in many malarial countries.
 
We therefore urge you to consider adding your name to the letter below.  We feel it is imperative that the public health community come together to defend the use of insecticides to protect human health.  As it stands, regulations on insecticides provide adequate protection for human health.  The existing regulations are also a significant barrier to research and development of new chemicals.
 
As the regulations are set to come into force in the Fall/Autumn of 2008, we ask you to respond as soon as possible by emailing This email address is being protected from spam bots, you need Javascript enabled to view it   with your name, affiliation and contact email address.  Should you be unable to respond on behalf of your organization, please consider signing in your personal capacity.  In your response, please indicate whether you would NOT like to receive email updates of the progress of the regulations.  
 
Thank you for your assistance and your consideration of this letter.
 
Yours faithfully
 
 
Richard Tren
Africa Fighting Malaria
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+1 202 223 3298
www.fightingmalaria.org

New EU Pesticide Regulations and the Implications for Vector-Borne Disease Control

New European Union Commission regulations concerning the use of crop protection products are currently being progressed for acceptance in Fall/Autumn 2008. The EU Commission and the more stringent EU Parliament proposals will have significant consequences for agriculture in the EU.  The new regulations will change the way in which pesticides are regulated, moving from risk-based assessments (based on the real world application of pesticides) to hazard-based assessments (based on laboratory data).  This could result in the removal of numerous pesticides from use in the EU; one assessment concludes that 85% of pesticides will be affected under EU Parliament proposals. 

Due to maximum residue limits (MRLs) on imported produce, the regulations will also affect agriculture and development in countries that export produce to the EU. A potentially disastrous consequence of the new rules will be to limit the use of insecticides in public health programs in many developing countries.  Control of malaria and other tropical diseases could be severely affected along with agriculture-led wealth creation and development in some of the poorest nations on earth.

Our concerns arise for several reasons:

1. The EU regulations will reduce the range of insecticides available for public health at a time when insecticide resistance demands as wide a range of different chemical groups as possible.                                                                       

Once enacted, the market and supply of effective insecticides will shrink, which will result in price hikes for public health insecticides.  The production of certain insecticides, such as some organophosphates and pyrethroids, could cease altogether as production would be financially unviable for the smaller public health market.  Insecticides used in indoor house spraying programs, on mosquito nets and for larval control form the pillars of malaria control programs and are the focus of current UN efforts to control the disease globally. 

1. The EU has practically zero tolerance of residues of deregistered pesticides and revisions to the MRL rules in line with the new regulations will affect pesticide use in countries exporting to the EU. 

Some malarial countries have halted the use of DDT (a highly effective disease control insecticide banned in the EU) out of fears that residues on export produce due to leakage of product into agriculture would result in rejection of entire export shipments.  Such actions have harmed malaria control forcing poor people to pay a high price for existing EU regulations. The proposed new regulations could result in a similar situation with the remaining classes of insecticides. These regulations will act as a new non-tariff trade barrier, paralyzing some of Africa’s most highly effective malaria control programs based on fears that even the smallest residues will harm agricultural exports.  As a result the costs and complexity of malaria control by insecticide spraying will rise significantly, limiting the scope and malaria control programs and thereby endangering lives from a preventable disease.

1. Moving away from risk-based assessments to hazard-based assessments will reduce research and development of new insecticides.                                                                                                                                             

The regulations are unscientific in nature and put in place new standards that are impossibly high. Even though the proposed regulations cover plant protection products, they would make it virtually impossible to register new products for vector control which are drawn from the agricultural sector. New candidate chemicals currently being investigated for pest control applications will not be progressed under these regulations. 

The unintended consequences of regulations and anti-insecticide activism has already severely limited the range of insecticides available for public health programs and increased the costs of disease control.  The proposed new regulations set a dangerous precedent for the regulation of chemicals around the world and show a worrying lack of concern for the real risks to health and development to which most people in developing countries are exposed. They not only ignore real-world risks of chemical use but also ignore the risks of NOT using insecticides to protect crops and human health.  In most developing countries, agricultural pests and disease-spreading insects pose a far greater and more immediate threat to human health than insecticides.   We therefore request the European Commission and the European Parliament to respond to this letter, detailing how they will revise their proposals to retain the present risk-assessment basis of plant protection chemical regulation, and so prevent the impact of this regulation on public health and people’s lives and development in countries far beyond the European Union.

 Read more about the DDT campaign initiated by the MFI in 1999: Malaria Advocacy - The Beginnings