Risk assessment for harmful substances is done for decades now on a substance-by-substance basis. From a scientific point of view, this is a fundamentally flawed approach since in everyday life no one is exposed to a single substance but to a multitude of substances at the same time through body burden, home, food, air, personal care, etc. PAN-Europe and its members have been trying to include cumulative risk assessment in decision-taking for many years, especially since it has become an obligation in the Residue Regulation 396/2005.
Now, more than 10 years after this obligation, cumulative effects on food are still not accounted for. The PAN report, A poisonous injection demonstrates the reason for this. In the first years, the panels of Food Authority EFSA (who had to develop a guideline) with a lot of industry-linked experts managed to play down the importance of cumulative effects and delay the guidance; this only changed when Commission intervened in 2011. Many years were wasted on useless studies and now more independent scientists were involved. A new threat to the topic is a risk assessment method (probabilistic modelling) that again might be able to water down the rules.
There is a clear reluctance in the traditional expert community to admit that they were wrong for >25 years to base safety claims on the toxicity of a single pesticide but it is clear that the health standards for food (MRL, maximum residue level) need to be made stricter to protect the public including the vulnerable against the harms of the every-day poisonous cocktail in our food.
- EFSA Intervention on PPR Cumulative risk assessment
- SANCO Intervention on PPR Cumulative risk assessment
- Preventing harmful effects of multiple chemical exposures on human health, a proposal of Pesticide Action Network Europe
- Letter to Commissioner Borg on Cumulative risk assessment of pesticide residues
- Pesticide Residue Regulation 396/2005
- "Have we lost our heads" (Natuur en Milieu/Consumentenbond, 2001)
- EFSA "Scientific Colloquium" on cumulative risk assessment (2006)
- EFSA PPR-panel on existing methods for cumulative risk assessments (2008)
- EFSA PPR-panel to test possible methodologies for cumulative risk assessment of triazoles (2009)
- Danish communication adopted by Environmental Council (2009)
- Kortenkamp, state-of-the-art of mixture toxicity (2009)
- EFSA Working Group-Thresholds of Toxicological Concerns (2009)