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The French Ministry of Ecology and Sustainable Development and French Ministry of Health and Social Protection requested the opinion of the French Agency for Environmental Health Safety (Afsse) concerning the health risks for the population and the consequences for ecosystems of the aerial spraying of anti-parasitic products. |
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estimate if the minimum safety distance of 50 m stipulated in article 6 [of the ministerial order on the aerial application of the products mentioned in article L.253-1 of the French Rural Code] is sufficient, given the means of dispersion of these products, particularly depending on weather conditions;
establish if the spraying ban should be extended to other substances than products classified as toxic or very toxic;
determine if the prior declaration timeframes should be adapted according to the types of production concerned and the predictable nature of the action;
determine if the inspection and approval procedures need reinforcing.
search for existing scientific data was targeted on the cross-checking of the themes “pesticides” and “aerial spraying”;
use of the method and terminology of the health risk assessment (ERS) comes essentially from guides available at international (US-EPA, etc.) and national (InVS, Ineris) level, guides commonly used in the environmental health field;
the method adopted distinguishes the effects on the normal population (adults) and sensitive population (children) and considers additional channels of exposure and periods of time to the minimum regulatory stipulations;
the “drift” phenomenon associated with the spraying of pesticides by aircraft has been identified as the major critical point of aerial spraying techniques; it therefore forms the main input data for risk assessments;
the drift is estimated according to the practice of aerial spraying for plant protection. Anti-vector control (against mosquitoes, for example) has not been the subject of quantitative assessments, the working group considered it to be outside of the scope of this solicited request;
the quantitative assessments conducted are based on feedback from field practices in mainland France and overseas départements and territories. They do not claim to cover all pesticide applications by aircraft and cannot be generalised or extrapolated;
lastly, the working group stressed that the risk assessments it had to conduct in response to the solicited request were not intended to replace the marketing authorisation procedure for products used.
the assessment of risks associated, on the one hand, with metabolites of the substances studied and, on the other, with their gaseous phase resulting from their spraying and therefore involves a certain number of simplifications compared with the real situation;
the synergetic effects (which increase toxicity) or antagonistic effects (which decrease toxicity) of various products to which both populations and ecosystems are exposed. 
based on the hypotheses adopted, the drift of anti-parasitic products at 50 metres associated with the aerial spraying of active substances used for plant protection does not pose a significant risk for the health of surrounding populations, even for children: indeed, estimations remain less than the reference values traditionally used;
based on the scenarios adopted, for the drift of anti-parasitic products at 50 metres, the risk is acceptable with regard to the reference values traditionally used for ecosystems in 35 to 50% of cases only and depending on the organism concerned. Increasing the “safety” distance from 50 to 100 metres is not likely to provide significantly more effective protection for the organisms considered. Treating with light wind (2m/s) or equipment that limits the drift increases the percentage of scenarios that may be associated with an acceptable risk at 50 metres, but is not enough for the risk to be acceptable at all times.
that minimum safety distances be established for each preparation in the framework of a specific agricultural application by aircraft;
that local management on a case-by-case basis be implemented for particularly vulnerable areas. For example, in the United Kingdom, the person ordering the aerial spraying must consult the competent authority 72 hours beforehand if a natural reserve or site of special scientific interest is located less than 1500m from the zone to be sprayed. Moreover, beekeepers in the zone must be informed at least 48 hours beforehand. In Canada, compliance on a case-by-case basis of a buffer zone is based on the sole professional judgement of applicators who may, for this purpose, use drift models (including Agdrift). They should also be aware of local establishments that are vulnerable (schools, hospitals, etc.), although logically this does not just concern aerial spraying;
that products be specifically and systematically assessed for a spraying method by aircraft when this means of application is appropriate, as part of the marketing authorisation procedure which is the suitable regulatory framework. Like in Canada, this implies that a product which would not be labelled specifically (and therefore assessed) for spraying by aircraft, with a suitable means of application, could no longer be sprayed in this manner;
that a cost-benefit analysis of aerial spraying compared with land spraying, for a certain number of contextual scenarios to be defined, be conducted systematically and develop within a structured and standardised framework;
that for predictable interventions, an initial declaration of principle sent to its addressee by post be filled in at the start of the crop season, or 72 hours before spraying, clearly specifying the products used and doses per hectare planned;
that a second declaration be faxed (or e-mailed), 24 hours before spraying, confirming the application;
that for unpredictable interventions, the provisions stipulated in the ministerial order of 5 March 2004 continue to apply;
the drafting of a good practices guide for the aircraft application procedure, which may meet both the safety and traceability objectives of practices, without making the regulatory framework more complex;
that experimental benchmarking on aerial and land drift be carried out.
experimental benchmarking on aerial drift and land drift;
modelling of the drift of anti-parasitic products with account taken of the evaporation of multi-component drops.
