Industry’s View on EFSA’s Contributionsto Pesticides Regulation                        J.-P. Busnardo, DuPont             ...
Content   Processes   Active substances peer reviews   MRLs   Scientific Guidance
Processes    Creation of PSC welcome    Creation of Pesticides Unit welcome    Creation of application desk welcome    Sho...
Peer Review of Active Substances  Timelines overall respected  Science:  – Robust …  – …often conservative  Some important...
Other issues in active substanceevaluations    Amending active substance approvals    POPs-PBT    Scientific peer review o...
Residues – MRL Reasoned Opinions    Timelines overall respected (new MRLs)    Article 12    – Much delayed (but largely un...
Residues – Annual Report    Very useful !    Comprehensive    Carefully written    – Limits misuse/misinterpretation
Scientific Guidance  Authors are not users!  Often disconnected from use context  Limited evaluation of guidance to be rep...
Conclusions    Processes    Active substances    MRLs    Residue annual report    Scientific Guidance
Thank You !
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J.P Busnardo - ECPA industry feedback

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J.P Busnardo - ECPA industry feedback

  1. 1. Industry’s View on EFSA’s Contributionsto Pesticides Regulation J.-P. Busnardo, DuPont ECPA/IBMA Workshop Parma, April 2012
  2. 2. Content Processes Active substances peer reviews MRLs Scientific Guidance
  3. 3. Processes Creation of PSC welcome Creation of Pesticides Unit welcome Creation of application desk welcome Should participate in Global Joint Reviews Ability to submit new information unnecessarily restricted (process design, not under EFSA control)
  4. 4. Peer Review of Active Substances Timelines overall respected Science: – Robust … – …often conservative Some important EFSA comments arrive late in review process – Little/no time left to applicant for adapting – Commenting opportunity only after report issued
  5. 5. Other issues in active substanceevaluations Amending active substance approvals POPs-PBT Scientific peer review open literature
  6. 6. Residues – MRL Reasoned Opinions Timelines overall respected (new MRLs) Article 12 – Much delayed (but largely unavoidable) – Too many GAPs reviewed? Science – Robust… – … somewhat conservative Guidelines followed – Outcome predictable
  7. 7. Residues – Annual Report Very useful ! Comprehensive Carefully written – Limits misuse/misinterpretation
  8. 8. Scientific Guidance Authors are not users! Often disconnected from use context Limited evaluation of guidance to be replaced – No systematic justification – No impact assessment Too often unnecessarily: – Conservative – Complex No mechanism for MS to amend EFSA opinion Need to be peer reviewed by MS and properly enforced
  9. 9. Conclusions Processes Active substances MRLs Residue annual report Scientific Guidance
  10. 10. Thank You !

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