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Date: Mon, 13 Oct 2003 15:46:34 +0200
Reply-To: PSA Forum
Sender: PSA Forum
From: "Jeuring, H.J. (Hans)"
Subject: Comments on Paper 2a
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I'd like ro give a reaction on paper 2a, Legal arrangements and to some remarks made by Edward Groth.

I really think that recommendations from formally established bodies like JECFA and JMPR have more impact in Codex and at the national level than those from ad hoc consultations. It is a fact that authorities a lot of countries are following the discussions in JMPR and CCPR with a lot of interest. A lot of countries take over the results of risk management (CCPR) in their own legislation directly, or refer to Codex Limits (such as the EU). The JMPR had provided in the past high quality independent evaluations of residues and their safety to consumers. I think that 'transparancy' (or lack of) is not the problem.

The big problem with the MRL-setting process in JMPR and CCPR is the lengthy process, ranging from 4 to 8 years, that is required for the elaboration of Codex Maximum Residue Limits for newly introduced, often safer, pesticides. During this period, in those countries where such pesticides had been registrered for use, farmers and exporters were reluctant to use them because importing countries that applied Codex MRLs as the basis for their national regulation would reject commodities containing residues of the new pesticides. So, the big problem is 'lack of speed of MRL-setting'. And this is mainly a consequence of the heavy work load of JMPR.

This issue was already discussed in the 2002 CCPR meeting. A lot of options to solve this problem were discussed.
And as a result of this discussion a pilot project has started using National MRLs as Interim Time-limited Codex MRLs for saver replacement pesticides pending JMPR Review. Also a pilot study on work sharing (which was also an option) is running at the moment. A lot of other options are mentioned in the CCPR-report (Alinorm 03/24).

JMPR usually meets two weeks in every year. A lot of compounds are discussed then for which the members of JMPR have to do a huge lot of home work (usually during the evenings and weekends) without payment. This is really an unsustainable way of working.
I am therefore of the opinion that the budget of JMPR must be raised in the future in order to speed up the MRL-setting process. Worksharing and other the Interim MRL-pilot may also be usefull instruments in the future but we have to wait the outcomes of these projects.

Hans Jeuring
Food and Consumer Product Safety Authority
The Netherlands
e-mail: hans.jeuring@vwa.nl