Imazapyr:
Banned or Regulated in Europe?
(Ed note) While walking the Halfway to Hell's Gate THP near Comptche in Mendocino County with about 15 community members, the RPF stated (in an answer) that Imazapyr wasn't actually banned in Europe. And that got me to researching... and often, it seems, that there are those who are concerned about herbicide use, who excite a trend towards some perceived truth, but inaccuracy leaves any argument to fail in the moment.
And as to the use of Imazapyr, or a ban on it's use in Europe, the RPF is correct.
In
2003, the European Union (EU) took positive steps to regulate the
safety of pesticides. Several hundred pesticide active ingredients
were withdrawn from the European marketplace in accordance with
Council Directive 91/41/EEC Directive. In addition, European
Regulation No 304/2003, which implements the Rotterdam Convention on
Prior Informed Consent (PIC Convention) requiring certain
notifications for banned or severely restricted pesticides.
The
active ingredients that were withdrawn from registration were to be
phased out in Europe. These active ingredients may no longer be sold
after 24 July 2003. Farmers and users had until 31 December 2003 to
either use or dispose of stocks. An active ingredient can qualify as
an essential use product, and may still be used for a limited purpose
if “additional technical evidence has been provided demonstrating
the essential need for further use of the active substance and the
absence of an efficient alternative. It's use as such should be
restricted to the control of harmful organisms for which no efficient
alternatives exist.”
According
to the European Union an essential use product may be used until 30
June 2007 provided that:
-it
does not have any harmful effect on human or animal health and no
unacceptable influence on the environment
-it
is relabeled in order to match the restricted conditions
-Member
States impose all appropriate risk mitigation measures to reduce any
possible risks
-alternatives
are being seriously sought
Many
of the non-sponsored active ingredients are dangerous to both human
health and the environment and will still be exported or sold in
other areas of the world. Information regarding the hazards of these
active ingredients should be shared with other countries so that they
too may make informed decisions about registration.
The
EU Directive 91/414 -
The Directive
regulates the registration, sale, and approval of plant protection
products in the European Union. One of the key objectives is to
review all active substances used in pesticides to determine the risk
or harm to human health and the environment.
Responsibility
for conducting health and safety testing lies with the producer.
Currently
320 active ingredients are being withdrawn rather than being tested.
The rationale for not sponsoring an active ingredient varies. Some of
the actives are considered obsolete by the World Health Organization
(WHO) – such as benodanil, carbophenothion, and prothiocarb. Others
are no longer profitable for the manufacturers or are no longer
registered in individual Member States. In addition, some of the
active ingredients have known environmental or health effects that
would preclude them from being re-registered, and therefore the
manufacturers have decided it is not in their interest to conduct
further testing but simply to withdraw the registrations.
Imazapyr
Defining
a ban
The (Prior Informed Consent) PIC Convention defines a banned chemical as a chemical all uses of which, within one or more categories, have been prohibited by final regulatory action in order to protect human health or the environment. It includes a chemical that has been refused approval for first-time use or has been withdrawn by industry either from the domestic market or from further consideration in the domestic approval process and where there is clear evidence that such action has been taken in order to protect human health or the environment.
Regulation
304/2003 implementing the PIC Convention defines a banned chemical as
a chemical that has been withdrawn by industry either from the
Community market or from further consideration in a notification,
registration, or approval process and where there is evidence that
the chemical raises concerns for human health and the environment.
This definition takes in many of the actives being withdrawn in
2003.
Even
an active ingredient still permitted under the essential usage
exemption may qualify for incorporation into the PIC Convention if it
poses health or environmental problems. Under the Regulation
304/2003, an active ingredient restricted to an essential use falls
within the definition of a severely restricted chemical:
A severely restricted chemical is a chemical that has, for virtually all uses, been ... withdrawn by industry either from the Community market or from further consideration in a notification, registration or approval process; and where there is evidence that the chemical raises concern for human health or the environment.
Substances
Banned In The Eu Market
Pesticides
with essential uses have not been given EU-wide approval. Certain
countries have been given an extension
(or derogation) for one or more essential uses for the active
ingredient on specific crops. Member States are expected to explore
alternatives to their use and to report on progress in substituting
less harmful products or methods.
As
shown on the page at the
link above, a table
presents pesticides banned or severely restricted in EU as a
consequence of the application of Directive 79/117/EEC, Council
Regulation 805/2004/EC and Directive 91/414/EEC (49 in total).
Directive
79/117/EEC can be regarded as the predecessor of Directive 91/414/EEC
and concerns the prohibition of active substances which, even if
applied in an appropriate manner could give rise to harmful effects.
Council Regulation 850/2004/EC regards persistent organic pollutants
(POPs) and implements the Stockholm Convention in EU.
Council
Regulation 304/2003/EC concerns the export and import of dangerous
chemicals and implements the Rotterdam Convention.
It
provides for the notification to
importers of any products banned under Directive 79/117/EEC or
included in a Prior Informed Consent (PIC) list of the Rotterdam
Convention.
The
Regulation does not itself ban any chemicals, but with amending
Directives (1212/2003 and 775/2004) reflects the regulatory status of
chemicals under other EU legislation (79/117/EEC, 91/414/EEC,
850/2004/EEC or the Biocides Directive).
Essential
Uses
Pesticides have been given a ‘derogation’ or exemption for what farmers and growers have convinced the regulators are essential uses. Each EU country has nominated specified pesticides (for example 14 for the UK) that will only be permitted for use on specified crops.
Imazapyr
can
be procured for essential
use 835/04, 2076/2002.
To
find out more visit The Pesticide Action
Network (PAN) Pesticide Database - a one-stop location for toxicity
and regulatory information for pesticides.
Here
is a direct link to the EU partners data!
And
the “List of Lists” which is a catalog of lists of pesticides
identifying those associated with particularly harmful health or
environmental impacts which can be downloaded free from the PAN UK
website.
North
America Pesticide Hazards
Database
PAN North America’s on-line database is easy to use and contains a wealth of information on health and environmental impacts, from US EPA and other sources, and is searchable by active ingredient and product name.
And
on a final note, updated to 2014, Imazapyr,
Identification, toxicity, use, water pollution potential, ecological
toxicity and regulatory information:
I
don't personally see the need for use of herbicides in the Redwood
Region. Older, larger trees, larger diameters, slower growth at older
ages – the returns are larger volumes per acre.
Tan
Oaks (which can live to be 800 years) are part of the nutrient rich
feedstock for forest soils in the natural succession of
re-colonization of the cut-over, burned landscape from which our
rivers flow.
Employ
People, Not Poisons.
Tomas
DiFiore
