The "Cocktail-effect" Do pesticides play a role?

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The "Cocktail-effect" Do pesticides play a role? /////////// Martin Larsson Researcher & Regulatory Scientist Bayer Crop Science, Denmark 9 November 2018

Talking points Why are we discussing potential health effects of pesticides? What do we know? Single compound risk Combined risk (cocktail-effect) Do pesticides play a role when other chemicals are considered as well? Conclusion and perspective 2

Why are we discussing potential health effects of pesticides? Ekoeffekten by COOP Sweden Currency-adjusted Group outlook for 2018 confirmed Campaigns by COOP, the second largest supermarket chain in Sweden and Denmark. 3

Why are we discussing potential health effects of pesticides? Ekoeffekten, by COOP Sweden We know very little about the long term effects of consuming foods that have been sprayed (with pesticides) Chemicals in combination may be far more dangerous than each single chemical on its own 4

We know very little about the long term effects of consuming foods that have been sprayed (with pesticides) Toxicological testing package for a synthetic chemical pesticide 5

The ADI concept Assessing the long term dietary consumer risk Overall (lowest) NOAEL = No Observed Adverse Effect Level Divided by safety factor of minimum 100* *minimum 100 by EU law, regulation 1107/2009 ADI = Acceptable Daily Intake = A daily intake with consumed food that is considered safe for the entire lifetime 6

Assessing the long term consumer risk Increasing exposure and risk LOAEL Variable hidden safety factor ADI Regulatory safety factor of minimum 100 Variable hidden safety factor Explanations MRL: Maximum Residue Level (maximum contents of a pesticide residue to be legally permitted in or on food commodities) ADI: Acceptable Daily Intake (Estimate of the amount of a substance in food, which can be ingested daily over a lifetime by humans without appreciable health risk) 7 Very low exposure and risk MRL Actual residues are typically below the MRL, i.e. in this range NOAEL: No Observable Adverse Effect Level (the greatest concentration of an agent, that causes no detectable adverse alteration of morphology, functional capacity, growth, development or lifespan of the target. LOAEL: Lowest Observable Adverse Effect Level (similar to NOAEL, but where an effect is seen)

Assessing consumer risk for the single compound Conclusions from the National Pesticide Residue Monitoring Programmes 2017 2016 2015 2014.. Denmark The food safety authority considers that the pesticide residues that occur in foods on the Danish market should not give cause for health concern among consumers. Intake of fruits and vegetables is healthy. Europe 2018.. Europeans continue to eat food that is largely free of pesticide residues or which contains levels of residues within legal limits, the latest monitoring figures show The reporting countries analysed 84,657 samples for 791 pesticides 97.6% of samples for products from EU/EEA countries were within legal limits. 92.9% of samples for products from non-eu countries were within legal limits. 98.7% of samples for products from organic farming were within legal limits. EFSA performed an acute (short-term) and chronic (long-term) dietary risk assessment, based on the results of the EUCP programme. In both cases the health risks to consumers were considered to be low. 8

So, what is the problem?? Chemicals in combination may be far more dangerous than each single chemical on its own 9

Chemicals in combination may be far more dangerous than each single chemical in its own Case 1: The joint effect of several chemicals is larger than that predicted from additivity of the individual chemicals (synergy) 1 + 1 = 3 Not relevant for consumer exposure to pesticide residues. Far below effect level, there will be no synergies either! (Boobis et al. 2008, others) Case 2: The joint effect of several chemicals is no more than that of the single most toxic chemical. The chemicals do not share target and do not interact: 1 + 1 = 1 Case 3: The chemicals have a common target: the joint is effect additive 1 + 1 = 2 10 /// Bayer Company Profile /// First Quarter of 2018 /// As of June 1, 2018

Additive risk from combined pesticide exposure What do we know? Chronic risk in consumer from intake of dietary pesticide residues full diet study deterministic* Study Facts Population: Danish Age: 4-75 Subpopulations: Male, Female, Child (4-6), Vegetarian, Domestic Foods Consumer Diet Data: Full diet, National Dietary Habits Survey, DTU 2010 (n=2700) Residue Data: Danish National Pesticide Residue Monitoring Programme Data Period: 2004-2011 Toxicity data: ADI, (chronic long term) Model: Hazard Index, deterministic model. No CAG:s CAG = Cumulative Assessment Group % ADI 100 90 80 70 60 50 40 30 20 10 0 Average Consumer Consumer Preferring Danish Foods Jensen et al, 2015 Food and Chemical Toxicology vol. 83 (2015) p. 300-307 *Deterministic lower tier (first stage) worst case, simpler input and output. 11

Additive risk from combined pesticide exposure What do we know? Chronic risk in consumer from intake of dietary pesticide residues full diet study deterministic* 100 90 Study Facts Population: Danish Age: 4-75 Subpopulations: Male, Female, Child (4-6), Vegetarian, Domestic Foods Consumer Diet Data: Full diet National Dietary Habits Survey, DTU 2010 (n=2700) Residue Data: Danish Farmer Spraying Journal Data, Danish and EU Monitoring Programme Data Period: 2013-2014 Toxicity data: ADI, (chronic long term) Model: Hazard Index, deterministic model. More accurate estimation of <LOQ (left censored) data through incorporation of agronomic data (spraying journals and pesticide use survey). No CAG:s % ADI 80 70 60 50 40 30 20 10 0 Average Consumer, Larsson et al 2018 Average Consumer, Jensen et al 2015 Larsson et al., 2018 Food and Chemical Toxicology vol. 111 (2018) p. 207-267 *Deterministic lower tier (first stage) worst case, simpler input and output. 12

Additive risk from combined pesticide exposure What do we know? Chronic risk in consumer from intake of dietary pesticide residues full diet study deterministic* 100 90 Study Facts Population: Danish Age: 4-75 Subpopulations: Male, Female, Child (4-6), Vegetarian, Domestic Foods Consumer Diet Data: Full diet National Dietary Habits Survey, DTU 2010 (n=2700) Residue Data: Danish Farmer Spraying Journal Data, Danish and EU Monitoring Programme Data Period: 2013-2014 Toxicity data: ADI, (chronic long term) Model: Hazard Index, deterministic model. More accurate estimation of <LOQ (left censored) data through incorporation of agronomic data (spraying journals and pesticide use survey). No CAG:s % ADI 80 70 60 50 40 30 20 10 0 Average Consumer, Larsson et al 2018 Average Consumer, Jensen et al 2015 Larsson et al., 2018 Food and Chemical Toxicology vol. 111 (2018) p. 207-267 *Deterministic lower tier (first stage) worst case, simpler input and output. 13

Additive risk from combined pesticide exposure What do we know? Chronic risk in consumer intake of dietary pesticide residues fruit and vegetables deterministic* 100 90 Study Facts: Population: Swedish Subpopulations: Adults, Men, Women Diet Data: Riksmaten 2010-2011, Livsmedelsverket Residue Data: Swedish national monitoring programme. Data Period: 2013-2015 Toxicity data: ADI, based on NOAEL for thyroid effect Model: Hazard Index, deterministic model. % ADI 80 70 60 50 40 30 20 10 0 Adults Men Women Hazard Index, Pesticides with effect on Thyroid EFSA CAG for pesticides with effect on the thyroid. *Deterministic lower tier (first stage) worst case, simpler input and output. 14

15 Probabilistic modelling

Additive risk from combined pesticide exposure What do we know? Chronic risk in consumer intake of dietary pesticide residues 30 widely consumed commodities + drinking water probabilistic* CAGs covering acute effects on the nervous system Study Facts: Population: Dutch Subpopulations: Child (2-6), Young (7-17) Adult (18-69) Elderly (70+) Diet Data: Dutch National Food Consumption Survey Residue Data: Dutch national monitoring programme + EUCP data Data Period: 2014-2016 (dutch data), 2011-2013 (EUCP data) Toxicity data: MOE (margin of exposure), acute & chronic Model: RPF (relative potency factor, MCRA probabilistic model. EFSA CAG s thyroid and nervous system RIVM Letter report 2018-0018 P.E. Boon et al. *Probabilistic higher tier, realistic, complex requiring computer simulation. Greater ability to characterize uncertainty and variability. 16

Additive risk from combined pesticide exposure What do we know? RIVM Letter report 2018-0018, P.E. Boon et al. Two CAGs, acute effects on nervous system Two CAGs, chronic effects on thyroid 17

Additive risk from combined pesticide exposure What do we know? RIVM Letter report 2018-0018, P.E. Boon et al. 18 MRL for pirimicarb was reduced in 2016.

Multiple factors contribute to overestimation of risk RIVM Letter report 2018-0018, P.E. Boon et al. Erring on the safe side in risk assessment leads to overestimation of risk. 19

Additive risk from combined pesticide exposure What do we know? Chronic risk in consumer intake of dietary pesticide residues 4 endocrine disrupting pesticides probabilistic 20 Study Facts: Population: Danish Subpopulations: Women of childbearing potential Diet Data: Danish National Food Consumption Survey Residue Data: Danish and Swedish monitoring Data Period: 2006-2009 Toxicity data: MOE (margin of exposure), acute & chronic Model: RPF (relative potency factor,) probabilistic model. Four fungicides: epoxiconazole, prochloraz, procymidone and tebuconazole, all suspected of acting as endocrine disrupters. For women of childbearing age, the high-end cumulative exposure (99.9th percentile) was 9% of the Adjusted Reference Value (ARV) for nipple retention and 1% of the ARV for the effect on increased gestation period. In other words, the safety margin to bench mark dose (NOAEL) was 10.000 for nipple retention and 100.000 for increased gestation period. Conclusion: no reason for concern in relation to cumulative acute risk for Danish consumers to the four endocrine disrupting pesticides. But EU will ban these substances as EDs anyway?!?

So, what is the Problem?? Pesticides in combination with other chemicals may pose a risk for health 21

Pesticides in combination with other chemicals may pose a risk for health Larsson et al. Food and Chemical Toxicology 2018 Mar. 113:345-346 22

23 Pesticides in combination with other chemicals may pose a risk for health

Pesticides in combination with other chemicals may pose a risk for health Comprehensive 433 pages report issued in 2017 Objective: assess the risk of overall exposure of children under 3 years and pregnant women/ unborn children to endocrine disrupting (ED)- and chronic neurotoxic substances. Summary ED: paracetamol highest risk compound, but EMA says Not sufficient evidence for link with antiandrogenic effect Neurotox: Lead by far highest risk compound A number of pesticides suspected as ED are omitted because of low exposure Publisher: Danish Environmental Protection Agency Editors: Poul Bo Larsen, DHI Julie Boberg, DTU Food Pia Brunn Poulsen, Force Thit Aarøe Mørck, DHI Helle Buchardt Boyd, DHI Dorthe Nørgaard Andersen, DHI Marta Axelstad, DTU Food Ulla Hass, DTU Food 24

Results: ED (high exposure scenario) RCR = exposure (μg/kg/d) / DNEL (μg/kg/d). Safety Factor for DNEL pesticide: 100 RCR = exposure at ADI level 25

Results: ED (high exposure scenario) Will health improve if EU bans all the ED -pesticides?? RCR = exposure (μg/kg/d) / DNEL (μg/kg/d). Safety Factor for DNEL pesticide: 100 RCR = exposure at ADI level 26

Results: Neurotoxic substances (high exposure scenario) RCR RCR = exposure (μg/kg/d) / DNEL (μg/kg/d). Safety Factor for DNEL pesticide: 100 RCR = exposure at ADI level 27 Northern zone countries letter to EU commission: Amend regulation 1107 to ban these pesticides

Conclusion and perspective Concern over health effect of pesticide residues mainly driven by campaigns by commercial and political interests From a scientific point of view, adverse health effects resulting of pesticide residues in foods is very unlikely. Pesticide residues in foods are unlikely to contribute significantly to any cocktail of chemicals (natural or man-made) implied in any disease etiology Science and regulation has made significant progress and soon EFSA is expected to publish comprehensive probabilistic risk assessments for EU populations. 28

Thank you for your attention! ///////////

ADI: how do we know the consumer intake does not exceed ADI level? Set an MRL 1. Define how to use the pesticide to control the weed/disease/pest: example: use 1 x 1 L/ha in growthstage BBCH 20 2. Measure the (eventual) pesticide residue that occurs in the crop with this pesticide usage (GLP studies) 3. 3) Assess consumer risk assesment to ensure ADI level is not exceeded adding all food that may contain residues at the most probable level (STMR= supervised trials median residue) that could be consummed daily and for a lifetime. 4. 4) If the ADI is not exceeded, the MRL can be set and the use authorized Enforce the MRL Control sampling programmes: 1) By government (FVST in Denmark) 2) By suppliers/producers, internal quality control ADI = Acceptable Daily Intake = Overall (lowest) NOAEL divided by safety factor of min 100* *minimum 100 by EU law, regulation 1107/2009 MRL = Maximum Residue Level 31 Note! MRL may be far lower (but not higher) than ADI, as MRL set from the agronomically required use pattern