you wrote:
>i would appreciate it if andrew manale or anyone else could
>elaborate on the comment that the ec (eu) standard for pesticides
>in drinking water is not risk based
>thanks,
>craig
as our institute also is involved in residue analysis, i can
(after some talk with our chemists and toxicologists, i
myslef am no expert in pesticide analytics) positively confirm, that
most of the levels allowed in drinking
water evidently are not BASED on toxicological evaluation, but on
the "state of the art" of analytical methods and equipment, meaning
what is the lowest measureable concentration (also considering the
price and the availablity of such equipment). i would call that
minimisation of risk
unfortunately this CANNOT be GENERALIZED, as another fact will
prove the contrary:
there were residue levels for certain herbicides and nitrate in
drinking water. after seeing the tendency, that agriculture
simply fixed the facts and contaminated the groundwater with these
components, more and more water distribution services would have
been forced to close. consequence: cities with two alternatives
a) no drinking water at all
b) drinking water with residues well above the levels
fixed by law
and what was EU legislature's response to that ?? after heavy
lobbying of several groups (chemical industry AND farmers) in
Bruxelles they simply "fixed" the problem by rising the maximim
levels to a value now twice as high as before..
thus they did not solve the problem, they changed the
difference between the definition of "legal" and "illegal". and
that was nothing but an ECONOMICAL evaluation and certainly NOT
risk-based.
but remember : at both levels risk was NOT the most important
consideration (although it certainly was part of the
decision, but in both cases ADI (acceptable daily intake) and ld50%
were quite high).
unsolved:
a) often the risk is not even known (tank mixtures, risks
that cannot be evaluated by dissection and microscopy of
organs)
b) i have very large difficulties to explain, why according to
legislative standards an american should be 10 times more sensible
to a certain component than an european (or vice versa). which
proves
- either, that these values are not always based on hard scientific
facts but rather (in the positive case) on precaution or (in
the negative ones) on settled or given economic facts.
- or governments have differents opinions on the value of their
citizens.
in summary: they are NOT ALWAYS risk-based !
Klaus Wiegand
Landwirtschaftl. Untersuchungs- u. Forschungsanstalt (LUFA)
(Governm. Inst. for Agricult. & Environm. Res.)
67346 Speyer, Obere Langgasse 40 (GERMANY)
Dept. of Seed Sci., Microscop. Analysis & Plant Pathol.
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