donderdag 19 april 2018


Current issues organic agriculture

ARTICLES AND PRESENTATIONS ABOUT
THE THREAT FROM PESTICIDES
TO OUR HEALTH AND ENVIRONMENT

NORMS FOR PESTICIDES IN WATER AND AGRICULTURAL PRODUCTS. A CRITICAL REVIEW
Margriet SAMWEL-MANTINGH1, Henk TENNEKES2, Jelmer BUIJS3
1 Women Engage for a Common Future, WECF-International, Korte Elisabethstraat 6, 3511JG Utrecht, Netherlands (margriet.samwel@wecf.org);
2 Experimental Toxicology Services, Zutphen, Netherlands (info@toxicology.nl);
3 Buijs Agro-Services Bennekom, Netherlands (jelmerbuijs@gmail.com).
Article History:
Received 19 March 2018
Revised 25 March 2018
Accepted 28 March 2018
Keywords:
Pesticide
Maximum tolerated levels
Risks
Food
Surface water
Abstract:
There is increasing evidence that changes in the environment and in the human health have a strong relationship with the use of pesticides. Wild populations of birds, freshwater fish, amphibians, reptiles, insects and several other species are declining at an alarming speed. Society has tried to protect man and his environment with maximum tolerated levels of pesticides in soil and water and in food. However, these limits are rather a result of wishful thinking than of scientific scrutiny. The authorisation procedures for pesticides have fully ignored the impact of cumulative toxicity. The toxicity of many pesticides is determined not only by dose but also by exposure time, and in some cases, such as the neonicotinoid pesticides, toxicity is even reinforced by exposure time. The alarming truth is that the dose-time-response relationship of the most pesticides is fully unknown, since this information is not required in official authorisation procedures. The consequence of time-dependent toxicity is that for many pesticides the current maximum tolerated levels may seriously underestimate actual risk. These chemicals need to be identified and removed from the market as soon as possible. Testing should be performed by independent organisations and authorization data should become accessible for the public. At the same time, organic farming should be stimulated in which synthetic pesticides are not used altogether. Almost 185.000 organic farms in Europe prove that this is a good alternative.



1. Introduction
Synthetic pesticides are a recurring theme in all discussions about sustainable agriculture; that is no coincidence. There is no human being on this earth who can say exactly what impact the use of pesticides has on nature. The effects of individual active substances and metabolites (decomposition products) on the hundreds of thousands of organisms of our ecosystem are already impossible to predict or even to establish. This involves several thousand substances that also interact with each other and then have a joint effect on living organisms. Every now and then the media pays attention to the contamination of foodstuffs with pesticide residues or to the decline of the bee population. Recent examples are reports on the dramatic decline of insects, fipronil in eggs, and cocktails of various pesticides in Dutch strawberries and in honey from around the world [1].
2. Risks of pesticides
In humans, a strong increase of various hormone-related diseases and / or abnormalities such as breast and prostate cancer, increased fertility, underdeveloped sexual organs in new-borns, diabetes, and autism have been observed [2]. Also, in wild animals worldwide observations have been made about changes caused by hormone-disrupting chemicals (Endocrine Disrupting Chemicals - EDCs), such as gender reassignment and malformations. There are several synthetic pesticides that have a cancer-causing or hormone-disrupting effect. For example, prostate cancer is associated with, among others, methyl bromide, chlorpyrifos, phonophos, coumaphos, phorate and permethrin; alachlor with thyroid cancer. Thyroid tumors can be caused by amitrole, ethylenethiourea, mancozeb, acetochlor, clofentezine, fenbuconazole, fipronil, pendimethalin, pentachloronitrobenzene, prodiamine, pyrimethanil, and thiazopyr [3]. Alzheimer's disease and other diseases are also associated with chronic exposure to pesticides [4]. These are for people and nature alarming and worrying developments. Nonetheless, the responsible authorities only focus on whether or not the established norms for pesticide residues in water and food are exceeded.
Research has determined that synthetic pesticides also reduce soil biodiversity, such as fungi and bacteria that are necessary for the mineralization of bound nitrogen; This can have all kinds of consequences, such as reduced fertility of the soil and increased dependence on artificial fertilizer. According to a report recently published by the United Nations, pesticides do not contribute to food security [5]. In the same document, it is concluded that pesticides have been aggressively promoted, and their use can have very adverse consequences for the availability of food for people. Contamination of the soil can also lead to a disturbance of the balances in the soil between all kinds of organisms [6], with the result that other diseases will occur as a result (directly as a result of the use of pesticides) [7].
Many independent researchers come to the conclusion that the use of pesticides has disastrous consequences for the ecological system and poses a risk to people and nature, and does not even lead to food security.
3. Authorization procedure for pesticides and standards
The Board for the Authorization of Pesticides and Biocides [8] is in the Netherlands the authority that is responsible for the authorization of pesticides and biocides for professional and non-professional use. The current 240 authorized active ingredients can be found in different concentrations and combinations in no less than 2500 different products [8,9], and partly in veterinary medicines. The same substance may in one case be authorized as a plant protection product (pesticide) and biocide and in the other case by the Veterinary Medicines Agency as 'veterinary medicine'. Different rules apply to the authorization of veterinary medicines [38], in which transparent in vivo testing  of ecological effects is not required altogether.
For the authorization of an active substance as a pesticide, the manufacturer will document the chemical properties of the substance and carry out toxicity tests for the substance that form the basis for the authorization procedure in the EU and therefore also in the Netherlands. A product that comes on the market often contains a mix of different active substances and additives to get the right dispersion or emulsion. Possible undesirable synergistic effects between the different substances and substances are not tested by the producer or the Dutch Board for the Authorisation of Plant Protection Products and Biocides (Ctgb). Conducted toxicity tests and results are not publicly accessible.
4. Dose-effect relationships of pesticides; the big confusion
Current admission procedures and standards assume that an Acceptable Daily Intake (ADI) exists for each substance. The ADI is an estimate of the amount of a substance that a person can take on a daily basis without any significant adverse effect [10].
This approach assumes a similar dose-effect relationship for all substances. Unfortunately, this is completely incorrect, but for the sake of commercial interests, fundamental toxicological laws are completely ignored by the legislators and regulators. Dose-effect relationships can be classified in the following way:
A. Substances with a dose-dependent action and a threshold value that do not irreversibly interact with components of the body and for which an ADI can be established. There will be no damage under the ADI, even under long exposure times. Admission can be justified if the other conditions of admission can also be met, such as degradability and absence of accumulation in the food chain.
B. Substances with a dose- and time-dependent action without threshold, which enter into irreversible interactions with components of the body leading to accumulating adverse effects. The product of the daily dose d and exposure duration (until the occurrence of a harmful effect) t is constant: d.t = constant. This dose-effect relationship is called Haber's rule. These substances show cumulative toxicity and it is completely impossible to calculate an ADI for this. Admission is irresponsible!
C. Substances with a dose- and time-dependent action without a threshold value, which enter into irreversible interactions with components of the body whose harmful effect not only accumulates but is also strengthened by time.
This dose-action relationship is now known as the Druckrey-Küpfmüller equation and can be mathematically represented by the equation;
d.tn = constant, where n> 1. This equation  explains the harmful effects of very low exposure concentrations of a poison at long exposure times. The lower the exposure level, the lower the total dose required for an adverse effect. These substances show cumulative toxicity and it is completely impossible to calculate an ADI for this. Admission is irresponsible!
D. Substances with an unclarified (or unpublished) dose-effect relationship. Admission is irresponsible!
4.1. Examples of dose-effect relationships of active substances
The dose–response relationship of the neonicotinoid insecticides imidacloprid and thiacloprid was described in 2009 by Francisco Sánchez-Bayo for arthropods [11]. This was not only dependent on the dose, but also on the duration of exposure. It was also shown that the lower the exposure concentration, the lower the total dose needed for the harmful effect (see table 1 and table 2).
In the following table pesticides, mentioned in this article, are classified according to their dose / time effect relationship. The dose / time effect relationship of most pesticides has not been clarified because the current toxicological research only aims at establishing a No-Observed Adverse Effect Level (NOAEL) as the basis for the calculation of the ADI. Dose / time effect relationships are almost always left out of consideration.
Understanding the dose / time effect relationships is essential for establishing standards for permissible concentrations of pesticides. ADIs and MRLs (Maximum Residue Limit) can only be prepared for substances of category A. Given the fact that dose / time effect relationships in the preparation of ADIs and MRLs have been completely ignored, there can be no question of any confidence in the harmlessness of substances, which belong to categories B, C and D, even in concentrations below the ADI and MRL.
5. Overview of legal standards for water and agricultural products
5.1. Surface water
Depending on the toxicity and on the occurrence of residues in surface water in practice, maximum permissible eco-toxicological EU standards have been established for active substances. However, the toxicity tests include a limited number of aquatic organisms. Before the introduction of the Water Framework Directive (WFD), there was the national MTR, Maximum Permissible Risk, in the Netherlands. With the introduction of the European WFD (Water Framework Directive 2000/60 / EC), the Environmental Quality Standard (EQS) is for the EU Member States the applicable standard for many substances. At the EQS there are two standards, respectively the:
• Annual average EQS (AA-EQS) and
• Maximum Acceptable Concentration (MAC) or EQS [12].
The AA-EQS represents the concentration of the substance in the environment that should provide protection against adverse effects from long-term exposure to that substance.
Table 1: Mortality of arthropods due to exposure to neonicotinoid insecticides (Sanchez-Bayo, 2009 [11])
Model organism
Test substance
Concentration (C) in µg.L-1
Time up to 50% mortality (T) in days
C x T product in
µg.L-1.days
Cypridopsis vidua
Imidacloprid
4
5.2
20.8
16
3.0
48
64
3.3
211.2
250
2.3
575
1,000
2.0
2,000
4,000
0.9
3,600
Daphnia magna
Imidacloprid
750
69.7
52,275
2,220
18.6
41,292
6,700
15.0
100,500
20,000
18.4
368,000
60,000
3.0
180,000
Sympetrum striolatum
Thiacloprid
7.2
20,6
148.3
8.0
17.2
137.6
12.7
13.0
165.1
113.3
3.2
362.6
Table 2. Dose / time effect relationship of the pesticides mentioned in this article
Dose-effect relation [13]
Pesticide
A: dose dependent
Of the substances mentioned in this article no substance is known to have a dose-effect relationship that is strictly dependent on the dose level only
B: d . t  = constant
The effect is determined  by the total dose, and independent of its distribution over time
azinphos-methyl, carbaryl, carbofuran, fenitrothion, fipronil, methidathion, permethrin, phenthoate, phosmet, thiacloprid
C: d. tn= constant
The lower the exposure level, the lower the total dose required for the effect
cartap, imidacloprid, thiacloprid, clothianidin, thiamethoxam
D: not clarified
methyl bromide, chlorpyrifos, fonofos, coumaphos, phorate, permethrin, alachlor, amitrol, ethylene thiourea, mancozeb, acetochlor, clofentezine, fenbuconazole, pendimethalin, pentachloronitrobenzene, prodiamine, pyrimethanil, thiazopyr, Endosulfan, DDT, Endrin, glyfosaat, linuron, acetamiprid, abamectin, aldicarb, amitraz, azinphosethyl, azinphosmethyl, azoxystrobin, captafol, captan, carbendazim, chlorothalonil, chloridazon, chlorotoluron, chlorpyrifos-methyl, chlorpyrifos, cyprodinil, deltamethrin, dicamba, dichlorprop, Imazalil, iprodion, spinosad , azadirchtin, pyrethrine, dieldrin, hexachloorbenzeen



The MTR and the AA-EQS focus on the risks associated with chronic exposure via consumption of fish (products) and / or crustaceans [14]. The MAC-EQS is aimed at the protection of aquatic organisms with a short-term peak exposure. Individual MAC-EQS and AA-EQS standards are not established for all substances. In those cases where the EQS standard is missing, the MTR standard for the substance in question is used. The legal standards for active substances in surface water can be found in, among other things, the fact sheets of the Pesticides Atlas [15]. For surface water no standard for the sum for individual pesticides has been set, as has been done for drinking water.
It appears that despite all ecotoxicological standards, aquatic organisms are insufficiently protected against pesticides. In the Netherlands, in 2015 only 5% of the regional water bodies had a final rate of "good" for the biological quality assessment [16]. Is this poor quality caused by the occurrence of norm exceedances, synergistic effects of the many substances found in the water [17]? Or do we clearly see the effects of disregarding the dose / time effect relationships in the toxicity assessment of substances. Or are there still other factors that play a role?
5.2. Drinking water
The acceptable norm for pesticides in drinking water are laid down in Directive 98/83 / EC and are applicable for all EU Member States. With a few exceptions, one and the same norm of 0.1 μg/ l has been set for the individual active substances and there is a norm for the total pesticides of 0.5μg/l. The norm of 0.1μg/l was established at a time when for many pesticides the detection limit was 0.1 μg/l and was considered as preventive standard for drinking water quality and human health. The norms require a revision, because a concentration of 0.1 μg /l for substances such as neonicotinoids is also dangerous if this water returns to the environment later.
5.3. Agricultural products for human consumption
A working group of the European Commission intends to prepare for each active substance a toxicological risk assessment for public health. For this risk assessment, an estimate is made of the amount of substance that a person can take for life on a daily basis without any noticeable effect on health [10]. This amount of substance (mg per kg body weight - mg/kg BM) is called the Acceptable Daily Intake (ADI). For the majority of the pesticides, an ADI has been established. E.g. for fipronil the ADI is 0 - 0.0002 mg/kg body weight and for Imidacloprid 0 - 0.06 mg/kg body weight [18]. This means that a person weighing 50 kg daily could take up to 0.01 mg of fipronil and 3 mg of imidacloprid via food without any noticeable effect on his or her health.
There is also an Acute Reference Dose (ARfD). The ARfD is an estimate for the amount of a substance in food that someone can take within 24 hours without significant health effects. One-off consumption (of one portion) of certain crops with relatively high residues of plant protection products (above the ADI) can sometimes lead to acute problems. These acute problems would not be noticed with the average consumption calculation [19].
The MRLs are laid down in the regulation for maximum residue levels in foodstuffs EC 396/2005. For pesticides for which no standard has been set, the MRL of 0.01 mg /kg is usually used. No MRL or ADI has been set for the sum of the various pesticides. If the MRL of a given substance does not exceed the ADI and ARfD, the MRL can be included in Regulation EC 396/2005, and the substance may be authorized in the European Union.
5.4 Packed (jar) food for infants and toddlers
Because of their thin skin, low weight and rapid metabolism, babies form a vulnerable group. As a precautionary measure, therefore, within the European Union, Directive 2006/125 / EC regulates the quality of packaged (jar) food for infants and toddlers (up to 3 years) in the EU. Jars with food for infants and toddlers must not contain more than 0.01 mg / kg of an active substance. However, no MRL for the sum of the various substances has been established. This means also that 1205 times as much of the insecticide imidacloprid in baby food is allowed than in surface water!
This means that conventionally produced foods for infants and toddlers do not comply with the precautionary principle (see table 5) and thus may pose a risk for this vulnerable group. Pesticides pass through the placenta [20] and therefore pregnant women must also be counted among the vulnerable group. In organic farming, the use of synthetic pesticides is in principle not permitted. In this way, these foodstuffs comply with the precautionary principle concerning pesticide residues. Even with regard to residues in these organic foods, however, transparency is hard to find; measurement data from the NVWA (Dutch Food and Consumer Product Safety Authority), the Dutch inspection body for organic agriculture (SKAL) and from Bionext[1] are all inaccessible to the public.
5.5. Livestock feed
In the directive for animal feed (Directive (EC) 2002/32) maximum limits for undesirable substances such as organochlorine pesticides Endosulfan, DDT or Endrin, are laid down for animal feed and feed materials. These substances which are very persistent, easily soluble in fats are now banned for agricultural use, but occur independently of the agricultural method in the food chain (through use in the past in the Netherlands and through current use abroad). For the other pesticides the MRLs for foodstuffs are used. These are laid down in Regulation (EC) 396/2005. Specific feed such as raw feed (hay, straw, feed corn, (silage) grass, fodder beet, etc.) are missing in this Regulation [21].
In contrast, in the Codex Alimentarius MRLs have been established for a number of specific pesticides in a number of animal feed. The establishment of standards is facilitated by the FAO and WHO [22]. The Codex Alimentarius is a basis for the EU for setting MRLs.
6. What is the significance in case standards are exceeded?
In the EFSA Journal 2017 [23] is mentioned that among the unprocessed plant products analysed in the 2015 EU-coordinated control programme (EUCP), the highest MRL exceedance rate was identified for broccoli (3.4% of the samples), followed by table grapes (1.7%), sweet peppers (0.8%), peas without pods (0.6%), wheat (0.6%), aubergines (0.4%) and bananas (0.3%). Moreover the foods with the highest percentage of samples with multiple residues were bananas (58.4%), table grapes (58.3%) and sweet peppers (24.4%). Table 5 presents for bananas some selected MRLs, whereas the extreme high MRL of 15 mg chlorothalonil /kg bananas is remarkable. Chlorothalonil is a fungicide of which the dose / time effect relationship is not clarified (see table 2) and is included in the Pesticide Action Network (PAN) International List of Highly Hazardous Pesticides [24].
The Dutch Food and Consumer Product Safety Authority (NVWA) provides a summary of the extent to which the legal MRLs in the tested products were exceeded in 2015. For example, of the strawberries grown in the Netherlands, 2.6% on average exceeded the set standard and contained on average 6.7 different pesticide residues; In the Dutch apples tested, no MRLs were exceeded, but an average of 3.1 different residues were found in these apples.
However, what amount of pesticide residues can legally be present in these popular fruits? As shown in table 4 and 5, the MRLs shown are mainly related to what remains in practice on residues of the active substance on or in the product. For those pesticides for which an MRL has not been specifically established, an MRL of 0.01 mg/kg is generally applicable. For the individual agricultural products, however, no MRL is set for the sum of the different residues, while the synergistic effect of the prevailing cocktails on pesticide residues and their metabolites in and on foodstuffs is unknown.
So when it is reported that a product such as apples doesn’t contain pesticide concentrations that exceed legal standards, it says little about the actual total amount of residues found. See Table 5 with examples of quantities of individual residues allowed in apples and strawberries (the table shows only a small selection of active substances and the MRLs for apples and strawberries). For example in one kg of apples, 6 mg iprodion is legally permitted and in one kg of strawberries 20 mg; on the other hand, one kg of apples may contain 2 mg imazalil and one kg of strawberries 0.05 mg.
The established standards are often not logical. Another example: is there an explanation why 0.1 μg/l of fipronil may be present in drinking water, whereas for this highly toxic substance the environmental quality standard is nearly a thousand times lower and in root and tuber crops almost a million times higher than in surface water? It is also not logical that the MRL for fipronil in milk is higher than in eggs. See table 4. The consequence of these MRL values for foodstuffs is that in principle many products in the supermarket can be acutely toxic to our ecosystem and are considered safe by the regulations for our health! After all, only 8.3 ng/l of imidacloprid is allowed in surface water and 0.1 mg/l in milk (12048 times as much). This discrepancy applies to almost all foods.
In general, a very strict norm for aquatic environments is set, which does not seem to have any relationship with the norms for our internal ecosystem (our metabolism). However, there are pesticides such as imidacloprid and thiacloprid for which there is no safe MTR or EQS for the ecosystem. These two substances are very persistent and bind virtually irreversibly to nervous system receptors in insects, and their toxicity is reinforced by exposure time [25]. These highly toxic insecticides are found in large quantities in the surface water [26] and in agricultural products. They are widely used in areas with bulb and greenhouse cultivation, in horticulture and in arable farming. Furthermore, they are used in ants bait boxes, neckbands for cats, dog shampoos, etc.[27, 28]
7. Examples of environmental quality standards for pesticides in surface water and in agricultural products

In the Directive 2008/105/EC are  (Annual Average-) Environmental Quality Standards, Maximum Allowable Concentrations for pesticides in surface water are defined. Some examples of the different standards and the values for five selected pesticides are presented in table 3. A Maximum Permissible Concentration (MPC) for fipronil in Dutch surface water has been set at 0.07 ng / L (Table 3). As a result of limitations in analytical methodology, with detection limits usually at 10 ng/L or higher, Dutch Water Boards have been unable to measure fipronil in surface water at concentrations up to 150 times above EQS, creating blind spots in most areas of the country. However, the EQS for glyphosate is so high that the set MAC–EQS is seldomly exceeded.
Table 3. Examples of standards for some pesticides in surface water (µg/l) [15]
Active agents
AA-EQS μg/l
MAC-EQS μg/l
MPC μg/l
Imidacloprid
0.0083*
0.2
--
Glyfosate
--
77
--
Fipronil
--
--
0.00007 ug/l *
Linuron
0.17
0.20
--
MCPA
1.4
15
--
*: The analytical possibilities are limited; many laboratories can not measure these concentrations.
-: No concentration for the relevant standard is mentioned in the relevant fact sheet
               AA-EQS: Annual Average-Environmental Quality Standard
                                                 MAC-EQS: Maximum Allowable Concentration - Environmental Quality Standard
                                                         MPC: Maximum Permissible Concentration
Table 4 shows examples of maximum residue levels for the pesticides glyphosate, fipronil and imidacloprid in some selected agricultural products. The major deficiency of these MRLs is that the dose-response characteristics of these pesticides in mammals are unknown. We simply don’t know whether cumulative toxicity, as seen with fipronil and imidacloprid in arthropods, could occur in mammals as well. If so, the MRLs would underestimate actual risk. For the cultivation of several types of cattle feed and fodder, glyphosate is worldwide applied as an herbicide. The set standards are not always logical. For example, although in general the annual human consumption of milk is higher than for eggs, for the highly hazardous insecticide fipronil the MRL in milk is higher than in one kg eggs. These examples and those in table 5 show also that most MRLs of fresh products don´t meet the standards of pesticide residues of 0,01 mg/kg in packed food for infants and toddlers. This means, that the consumption of non-packed food of non-organic origin poses a risk for infants and for toddlers.





Table 4. Examples of MRLs for glyphosate, fipronil and imidacloprid in some agricultural products for human consumption and for animal feed (milligrams per kg)
Agricultural product
Glyfosate
mg/kg
Fipronil mg/kg
 Imidacloprid mg/kg
Root and tuber crops, like carrots, beetroot; except sugar beet [29]
0.1
0.005
0.5
Pome fruit, including apples and pears [29]
0.1
0.005
0.5
Milk [29]
0.05
0.008
0.1
Bird eggs [29]
0.05
0.005
0.05
Alfalfa fodder [22]
500
--
--
Barley straw and cattle feed (dry) [22]
400
--
1
Maize cattle feed (dry) [22]
150
0.1
0.2
Maize [22]
5
0.01
--
-- no norm established
 


Pesticide MRLs apply to 315 fresh products and to the same products after processing. In case of processed products the MRLs are adjusted in order to take account of dilution or concentration during processing. Legislation covers pesticides currently or formerly used in agriculture in, or outside, the EU. This are over 1300 active ingredients [30]. In table 5 a small selection of the MRLs of pesticide residues in the popular fruits apples, strawberries and bananas is shown. The MRL for one and the same active substance can differ between different products with a factor 1000, for instance in case of azoxystrobin. This is also the case for the MRL for iprodione in strawberries and bananas.


Table 5. Examples of MRLs established for apples, strawberries and bananas (milligrams per kg) [31]
Active agents
Apples
mg/kg
Strawberries
mg/kg
Bananas
mg/kg

acetamiprid
0.8
0.5
0,4

abamectin*
0.03
0.15
0,01

aldicarb*
0.02
0.02
0.02

amitraz
0.05
0.05
0.05

azinphosethyl*
0.02
0.02
0.02

azinphosmethyl*
0.05
0.05
0.05

azoxystrobin
0.01
10.0
2.0

captafol*
0.02
0.02
0.02

captan
10.0
1.5
0.03

carbendazim*
0.2
0,1
0.1

chloridazon
0.1
0.1
0.1

chlorothalonil*
2.0
4,0
15.0

chlorotoluron*
0.05
0.01
0.01

chlorpyrifos-methyl*
0.5
0.5
0.05

chlorpyrifos*
0.01
0.5
3.0

cyprodinil
2.0
5.0
0.02

deltamethrin*
0.2
0.2
0.01

dicamba
0.1
0.05
0.05

dichlorprop
0.02
0.02
0.02

glyphosate*
0.1
0.1
0.1

Imazalil*
2.0
0.05
2.0

imidacloprid*
0.5
0.5
0.05

iprodione*
6.0
20.0
0.01

*classified by Pesticide Action Network as very toxic to humans and / or environment [24]



8. Insufficient safety to consumers and the environment
Based on the foregoing, it is clear that the current system of standards and control mechanisms offers insufficient safety to consumers and the environment. A continuation of the current policy will lead to a further disruption of our ecosystem and in the short term also of the economy. Recent research has made it clear that populations of meadow birds and insects [32] are disappearing at a very high rate. In the short term, the legislator must ensure that all pesticides from categories B, C, D in Table 2 are taken from the market until further research by independent bodies has clarified their dose-effect relationship. The standards for residues in foodstuffs should be based on levels that agricultural products have today without the use of these substances (todays background level), so that the precautionary principle is applied to all consumers.
Many still say that we cannot do without pesticides. There were in 2015 almost 185,000 organic farms in Europe [33] that prove that we can work without all those risky means of plant protection, and on average earn even better than conventional farms. Many studies have shown that the world can be fed by agriculture without pesticides, under the condition that we reduce our consumption of meat and the waste of food is reduced [34, 35].
It is also true that improvements can also be made in organic farming, also with regard to unintentional contamination with pesticides [36,37]. Transparency is also a prerequisite there. For conventional farming the authorization procedure for pesticides, many of which are classified as very dangerous for humans and / or nature, must be fundamentally changed. Toxicity testing and results of all authorized means of plant protection must be made public. New substances may only be authorised if they have a strictly dose-dependent dose-effect relationship and meet all other admission criteria.
Farmers who want to switch to organic farming must at least receive sufficient financial and technical support during the years of conversion. Technical and practical knowledge is now abundantly available at farms that already work organically, in research institutions and in extension services.
8. Conclusions
The authorization procedures of pesticides do not take into account the actual dose/time/effect relationships of pesticides, and as a result the authorizations carry enormous risks for people and the environment. Authorisation procedures are based on strictly separate worlds; the human body and nature. In reality, the human body is part of nature. The authorization does not consider any synergistic toxic effects of additives that are added to pesticides that come onto the market. The synergistic effects of different pesticides are not taken into account in authorisation. In authorisation procedures, by definition, the unbelievable complexity of nature cannot be considered.
Animal medicines are in the EU authorized without any in vivo ecotoxicological testing. Thus, these medicines and their metabolites end up in our ecosystem without any public control, Therefor, new authorization procedures must be elaborated, which take into account ecological safety and transparancy.
In the case of authorisation of various substances (such as neonicotinoids), the Ctgb evidently disregarded the rules that apply to the Ctgb officially: before a plant protection product or biocide can be authorized, the Ctgb assesses whether the product is safe for humans, animals and for the  environment. Neonicotinoids are poorly degradable, can leach and are highly toxic to many organisms.
References
[1] Mitchell et al., A worldwide survey of neonicotinoids in honey; 2017; 358: 109–111.  Science. Available at:  https://www.farmlandbirds.net/sites/default/files/2017-10/mitchell171006.pdf
[2] United Nations Environment Programme and the World Health Organization. State of the science of endocrine disrupting chemicals -2012./ Editors: Åke Bergman, Jerrold J. Heindel, Susan Jobling, Karen A. Kidd and R. Thomas Zoeller; 2013: vii – ix.
[3] United Nations Environment Programme and the World Health Organization, 2013. State of the science of endocrine disrupting chemicals -2012. / editors: Åke Bergman, Jerrold J. Heindel, Susan Jobling, Karen A. Kidd and R. Thomas Zoeller; 2013: 133-4, 197.
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