Governments should try for 100 per cent pure water
The Codex Committee is supposed to focus on health, not trade. But the general perception is that trade dominates the agenda and therefore the commission's standards for acceptable daily intake of pesticides and their maximum residue levels are not stringent.
ccpr's main purpose is to set maximum residue levels (mrls). If the acceptable daily intake (adi) exceeds in any one of the five regional diets (Middle Eastern, Far Eastern, African, Latin American, and European), then we will never accept such an mrl. The first issue is that an mrl must always be safe.
The commission's other purpose is to facilitate international trade through good and fair practices. By developing Codex standards, we help countries in fair trade. This is very important for developing countries when they export vegetables and fruits to, let's say, Europe. If the commodities are within the Codex mrls, then the importing countries have to take this fact into consideration.
But what is the primary issue, trade or health?
First, it is protection of health. At the same time, the purpose is promoting fair trade practices.
You normally depend on data provided by pesticide companies. How do you evaluate its credibility?
In step one of Codex's procedure, we decide on the compounds for which we have to develop mrls. This is decided by the ad hoc working group on priorities, which meets before the ccpr meeting. The selected compounds are then put on the priority list of the Joint Food and Agriculture Organization-World Health Organization Meeting on Pesticide Residues (jmpr). Then member states are asked to supply the data on these compounds.
The states usually approach these compounds' manufacturers, who then give their dossiers to the jmpr. These are very voluminous dossiers, having more than thousands of pages and including all information on toxicology, field trials and other issues. The jmpr's who panel studies all the dossiers a manufacturer has sent and the fao panel looks into field trials. Based on the recommendations of these panels, jmpr makes rules. Each year there is a two-week jmpr meeting in Rome or in Geneva, at the end of which manufacturers are invited to clarify things that toxicologists have found in their papers.
So it is really a review of all documents by a lot of toxicologists.
Does jmpr generate its own data?
No. jmpr's task is to establish acute reference dose (arfd; the amount of pesticides lethal in short-term exposures based on animal studies) and adi, which are the basis of mrls.
If a pesticide causes poisoning, what is Codex's role? Do you review that particular compound?
Yes. We do that if there is new data from a producer that there are problems with a pesticide. If new information on toxicity comes up and new effects are found, we do not support the compound. Codex then decides to withdraw the existing mrls.
But should not the manufacturing companies be held liable for the harm caused by their chemicals? And should not they be held responsible for compensation and clean up?
I cannot really comment on that.
adis set by jmpr are far higher then those set by the United States Environment Protection Agency (usepa). JMPR and usepa evaluated Malathion, but jmpr's adi was ten times higher. Why this difference when the us is both part of jmpr and ccpr?
This is a difficult question because I am not a toxicologist and not involved in the who panel. But there can be some differences; that is true. This happens even between Europe and jmpr because the latter considers human studies but the European Commission doesn't. In Europe, arfd is based on animal studies. That can lead to a difference. But usually, arfd established by jmpr is in line with usepa or eu's standards.
The consumption of processed and multi-constituent food is increasing but Codex fixes mrls only for raw agriculture commodities and not for processed food. How you plan to address this issue?
We now have a rule that the mrl for a raw agricultural commodity is also applicable for processed food. So if you have an mrl of two milligramme per kilogramme (mg/kg) for tomatoes, then this two mg/kg also applies to tomato juice. But if there is concentration of food, for example from fresh to dried vegetables, then you have to develop the mrl for processed food. But in eu they have a different rule. They say if there is a dilution of a raw agricultural commodity then you have to take into account the dilution. If it is an mrl of two mg/kg for tomato, eu policy is to have an mrl of one mg/kg for the tomato juice. In Codex we do not do that, but there are a lot of commodities for which we have mrls of processed food of lower value than that of raw agriculture commodity.
So we are not acting in line with our own policy, but that may change.
What about multi-constituent foods?
That's quite simple. If you have an mrl of two mg/kg for tomato and there is a product for children with 20 per cent tomato in it, then for that processed food mrl cannot be higher than one fifth of the tomato mrl. Basically, you can carry forward the mrl in proportion. But that is not Codex policy yet. We normally have mrls for raw commodities because most of the international trade is in precisely raw commodities.
But processed food consumption is increasing globally. Does cac have a plan to have a formula for such foods?
Perhaps in the future.
Theoretical Maximum Daily Intake (tmdi) is an over estimation of the exposure to pesticides. But if adi breaches tmdi, are mrls set up again? We found that tmdi for certain pesticides in India was three to seven times of the jmpr adi. What should be done in this case?
Well, then we have an unacceptable mrl. I think that's not a situation I support; they have to do recalculations and perhaps have to adjust the mrls. They should go back to the drawing board.
who says pesticides in water should be tolerated but not accepted. They therefore have a tolerable daily intake and not an adi for water. So shouldn't pesticide in water be a focus since it's a big problem?
It is a problem in India and other countries and it worries me too. I am not involved in water analysis, but in the eu and in The Netherlands there is a general mrl for all pesticides in water. What governments should try to do is have 100 per cent pure water. With purification technologies, I think it is possible to have almost no pesticides in packaged drinking water.
We recently had a controversy in India regarding pesticides in soft drinks. A parliamentary committee concluded that soft drinks contained pesticides and endangered health. Does the same situation exist in other countries?
Well, I do not know. I can't speak for other countries. But the problem does not exist in The Netherlands.
The amount of pesticides found in the soft drinks was seventy times than those allowed by eu water standards.
This is an infringement of the principle of law and it unacceptable. There can be a controversy about the levels of pesticides found, but you cannot say that it (pesticides in soft drinks) is okay. They have to be taken out and you cannot leave them as it is. It is unacceptable.
So what should be the standard for pesticides in soft drinks?
Soft drinks should be free of pesticides because as such they do not use raw agricultural commodities and thus no pesticides can be allowed in them.
But soft drinks companies claim that pesticides can get in through the sugar they use
If there is any carry over of pesticides from sugar or other such inputs derived from raw agriculture commodities, then the standard should be in proportion to the amount of the particular input.
What are your views on the participation of developing countries like India in the ccpr or cac process. We have seen that developed countries more or less run the show.
I believe that developing countries should attend ccpr and other Codex committee meetings. That is very important. In fact, there is a special who fund in which developed countries have put in a lot of money to help developing countries attend cac meetings.
But their participation is still poor.
Yes, and it should be increased. That is why we are happy that we had a ccpr meeting in India this time, and we will go to other developing countries.
Many of the non-governmental organisations (ngos) listed in the ccpr list are manufacturing industry bodies. Is the ccpr meeting dominated by the industries?
No, I don't think so. We have ngos but they are only observers. ngos are not allowed to vote.
Your comments on the project for setting up interim mrls.
The interim mrls process has only been developed for certain chemicals. jmpr has a heavy workload and sometimes it takes six to eight years before we have a new Codex mrl. That's hardly acceptable; everybody wants safe chemicals. So that's why we have this pilot project of having interim mrls.
How long does it take for jmpr to set up an adi when a new molecule is introduced?
If a new molecule is introduced in the eu, then it will be marked to the eu. After one year, it also goes to the ccpr working group's priority list. But the group is so busy that even if the molecule is placed on the priority list now, it will come on jmpr's agenda in 2007. That is the problem. We feel jmpr needs more people, especially more from the developing countries.