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!

Pesticides: breakthrough on cumulative risk assessment

EFSA announces: “Pesticides: breakthrough on cumulative risk assessment”

EFSA announced a breakthrough on cumulative risk assessment recently, you find the annoncement here: EFSA and its European partners have taken a major step forward in their work on assessing the cumulative risks from exposure to pesticides.

MCRA_150This is a major step in cumulative and probabilistic risk assessment (RA) in the field of dietary safety. I follow this topic with big interest and gained knowledge about the possibilities and limitations in this approach.

The background for the requirement of cumulative RA is legislated by:

Reg. (EC) No. 1107/2009, Art. 4: “residues of plant protection products … shall not have any harmful effects on human health, including that of vulnerable groups, … ,taking into account known cumulative and synergistic effects”

Up to now dietary risk assessments are conducted using deterministic models, i.e. point estimates of exposure vs hazard. Probabilistic models are under development in order to assess the variability of exposures (probabilistic risk assessment) and the exposure to chemicals with common effects to target organs (cumulative risk assessment). With support of the EU (ACROPOLIS project) a web-based software platform called MCRA (Monte Carlo Risk Assessment) was developed by RIVM to conduct probabilistic exposure and risk assessment of chemicals in the diet according to EFSA guidance documents.

EU provided further founding to the MCRA project (EU project EuroMix). Further cumulative assessment groups of molecules will be established.

The topic is highly complex and certain “black-boxes” in the software tool MCRA are not verifyable. With the announcement from EFSA input data to the model (consumption, background residues from market-bask surveys, variability factors, etc.) will become available to the industry and NGOs.

EFSA is establishing a data warehouse and thereby seeking transparency in order to gain trust of consumers.

Is it all about shareholder value?

Is it all about shareholder value?

News popped up from the critical shareholder community of Syngenta (www.kritische-syngenta-aktionaere.com). Mr Folke Rauscher published an article in the Basler Zeitung, here the link from the Handelszeitung. The solution suggested by the critical shareholder community is not very complex: replace the SYN management board in order to increase share value.

Syngenta’s credo is “Bringing plant protection to life”. I think that agrochemicals, with all the pros and cons, are required for a growing community on our planet. The industry is under pressure, and more pressure in order to serve shareholders is not required.

Benzovindiflupyr (Solatenol), a new SYN molecule, was recently approved in the EU, the peer review from EFSA you find here: EFSA Journal 2015;13(3):4043. I think this is a big milestone, well done folks! Benzovindiflupyr is a modern fugicide and a very interesting molecule for mixture products in order to address resistance issues. There is big potential in this molecule.

However, the shareholders want money, the only and single focus. No interest in products, solutions or suggestions for the future in this important business.

Thanks, Mr Rauscher..

Consolidation in the agrochemical business

Consolidation in the agrochemical business

People interested in the agrochemical business heared about the merger of DuPont and Dow Chemical by the end of 2015. We also followed the news about possible mergers or take-offs of Syngenta. After Syngenta denied an offer from Monsanto (CEO Mike Mack left the company thereafter under pressure from investors), ChemChina is now interested in a 70% share of Syngenta.

ChemChina is a state-owned company and the liberal newspaper NZZ reports about a paradoxon in liberality to sell a Swiss company to China. And it was the Basler Zeitung in an article (BZ 02/01/2016, PDF) who warned about selling SYN to a Chinese state owned company (“..these communists..”). We all know that a well-known CH politician owns the majority of the BZ – he is often in national and international news, earned his billions also in the chemical industry.

Questions arise: what will happen with the agrochemical sections of DuPont and DOW? Big players such as Bayer Crop Science or BASF might be interested in split-offs, and for sure Syngenta as well. Fact is that SYN share prices are comparable to a roller coaster, here the last years development:

As a specialist in dietary safety I trust in the safety of agrochemical products, I rarely buy organic food. I also believe that modern agrochemical products are required to provide food for a growing population on our planet. However I do not appreciate the pressure from major investors to dominate and control the future of the responsible companies in the field.

The GAME OVER referendum in Switzerland intends to stop the dealing with nutritional products on stock markets. The Swiss government recommends a NO to the referendum, since nutritional products are not included in the SMI (do not forget we have NESTLE here). Anyway, I support this idea and Switzerland could take a exemplary role in this issue.