Cumulative Assessment Groups: new EFSA publications

Cumulative Assessment Groups: new EFSA publications

The story is going on: EFSA published two ‘external’ scientific reports with relevance in the field of cumulative risk assessment (CRA). As a prerequisite for CRA, chemical substances that may have harmful effects to consumers have to be grouped in so called Cumulative Assessment Groups (CAGs), based on their effects to target organs (common adverse effects). Up to now, two CAGs are established in the EU, based on effects on the nervous and thyroid systems. These CAGs defined so far include >100 substances.

Let’s come to the new publications:

  • Title: MCRA made scalable for large Cumulative Assessment Groups (EFSA Supporting publication 2016:EN-910, published 27 January 2016).
    • Using data provided by EFSA, it was shown that the web-based software tool MCRA allows Screening to run  a  large CAG of 96 compounds.
    • MCRA 8.1. has been implemented in the flexible environment for high-performance computing at RIVM (Dutch National Institute for Public Health and the Environment).
    • Contributions to the exposure results can be seen both in terms of food-as-eaten (e.g. white bread) and foods-as-measured (e.g. wheat).
    • Drill-down can be made into the exact foods and compounds contributing for simulated individuals or individual-days in the upper tail of exposure. MCRA is probabilistic, and the exposure of 1 Million individuals can be simulated. You will find exposures exceeding toxicologigal reference values (ADI, ARfD), and with the drill-down you can identify the person-days exceeding these toxicoliocigal reference values of intake. The risk assessment is done by risk assessors (such as the EFSA, industry or consultants), the acceptability of the exposure is decided by risk Managers (EU commission).
  • Title: Toxicological data collection and analysis to support grouping of pesticide active substances for cumulative risk assessment of effects on the nervous system, liver, adrenal, eye, reproduction and development and thyroid system (EFSA Supporting publication 2016:EN-999., published 17 February 2016).
    • Contributing institutions: RIVM (Dutch National Institute for Public Health and the Environment), ICPS (International Centre for Pesticides and Health Risk Prevention), ANSES (French agency for food, environmental and occupational health & safety).
    • The report provides news to the data collection (according to the methodology agreed
      by EFSA, 2013) required for the establishment of new CAGs  The spreadsheets with the reviewed data are available on the EFSA website.
    • Based on the collection table of each organ/system, preliminary CAGs have been proposed by the consortium. From the active substances scrutinised, the GAGs include:
      • Nervous system: 67 out of 129 substances,
      • Thyroid: 57 out of 129 substances,
      • Reproductive and development system: 124 out of 129 substances,
      • Liver: 106 out of 129 substances,
      • Adrenal system:  96 out of 416 substances,
      • Eye: 79 out of 416 substances.

It must be kept in mind that certain substances may be included in several CRAs. This approach follows the concept of effects to target organs, i.e. dose addition. This concept does not cover the field of common metabolites, such as in the group of triazole fungicides.

My opinion: as risk assessors, we will be confronted with cumulative RA by end 2016/early 2017. I see a demanding task well implemented by EFSA and national institutions. Dietary (or better: ‘consumer’, since it will include intake by biocides and other sources) RA will implement a lot of work for calculations and reporting. Interestingly, model calculations have shown that the exposure by biocides in home-use is much more relevant than the exposure by food intake. A big discussion is going on for the setting of MRLs for biocidal products. However the border between agrochemical products, biocides and veterany health products is not cleary defined.

To finalise this post: I recently did a search for “glyphosate mode of action” in google. A webpage popped up: https://netzfrauen.org. Very interesting, especially the following statement:

[Zwischenbemerkung der Übersetzerin: Bei manchen Übersetzungen kann ich als Übersetzer nur kotzen. Dies ist ein Beispiel dafür. „Glyphosat schützt den Boden“ … wer so etwas behauptet, hat noch nie das Sterben eines Ackers nach einer Glyphosatbehandlung gesehen … sämtliche Pflanzen sind … tot. Gesunde Kräuter wie Kamille, Löwenzahn, Rotklee – alles weg. Und da sollen die so wichtigen Mikroorganismen des Bodens überleben? Organismen, die nun wirklich wichtig für die Qualität der Humusschicht sind? Wie absurd ist das denn?]

Well, I am very interested in easy solutions, whereever these are applicable. But i know that these are not available in the field of food production and safety for a growing population. I am critical against pesticides and companies involved in agrochemistry. But we should discuss with arguments, not with emotions. I ask myself, where the founding of the “netzfrauen” blog comes from. The statements published on their website remembers me to the philosophy of the political party in Germany called AfD: “easy solitions for complex problems”. This trend is very dangerous.

Syngenta sold to ChemChina

Syngenta sold to ChemChina

It was foreseeable that ChemChina will buy Syngenta, since today in the morning it is (almost) fact. There was a big hectic on the markets about the future of Syngenta in the past, and this hectic in the agrochemical business was fired by the merger of DuPont and Dow Chemicals.

In spring/summer 2015 the US company Monsanto concretised the interest in a merger with Syngenta. The deal was blocked by the management of Syngenta. The pressure from the shareholders was increasing: www.kritische-syngenta-aktionaere.com.

What are the major pros and cons for the solution with ChemChina compared to a merger with Monasanto?

Pros:

  • ChemChina has to date no interest to change or manipulate a well working company such as Syngenta. ChemChina has a primary interest in technology tansfer.
  • Syngenta will have an advantage for the Chinese marktet, with good subsidaries in Asia in general. Former big growing and future markets such as South America (focus Brasil) are developing very slow now.
  • Almost no regulatory hurders (‘market dominance’) due to little overlap between Syngenta and ChemChina.
  • Monsanto has a bad reputation world-wide. The company is mainly engaged in the business with GMO (gen manipulated organism) seeds for maize, soybean, cotton and others. The so called ’round-up’ technology makes plants resistant to the herbicide glyphosate. The technology is old, and Monsanto has little knowledge in the development of modern pesticides. I am sure that many of my former colleagues at SYN would have been ashamed to work for a company such as Monsanto.
  • Monsanto is a US company. We recently had an example of US business culture in Switzerland: following the take-over of Alstom the US company General Electric announced in Mid January to cancel 1300 of a total of 5500 jobs in Switzerland. The US maxime in business leadership has again proven to be: “save money, consolidate, maximize profit – do not care about knowledge and employees”. Happy that we do not have the Monsanto managers sitting in Basel.
  • I agree that China wants to find solutions to feed their growing population, they need a big step forward in the agrochemical business, also for the safety of the consumers and the evironment. They do not want to be dependent on other states in food production, such as US does not want to be dependent on oil imports from the near east. And now it is exactly the US where the biggest fraid is coming from concerning the aquisition.

Cons:

  • ChemChina is a Chinese state government owned company. Who will take the decisions for the future, what about the flow of information in the future?
  • The general question: should we sell our knowledge to China, and thereby loose our jobs in the long term? I think this is not a real problem, they would find the knowledge anyway, we are in the age of ‘post-globalisation’.

To conclude: i agree with this take-over, it was for sure the better solution than a merger with Monsanto. Let’s see how things develop, the consolidation in the Agro-Business has not finished. It has started. Let’s have a look to Bayer, DuPont, Dow, Monsanto and BASF. I wonder!