When examining marketing authorisation applications for plant protection products, ANSES systematically assesses the risk associated with the use of these products for the applicator/operator. A new guide published by EFSA lays down guidelines for conducting these risk assessments within the European regulatory framework.
According to the general principles of the French Labour Code, the first measure to be taken for prevention involves removing the hazard at the source. This is followed by replacing what is hazardous by something that is safe or is less hazardous (substitution). When this is not possible , use should be made of collective protective measures, and ways of adapting the work station should be examined. In addition, the use of suitable, well-maintained equipment is crucial, before additional measures such as personal protection are implemented.
Nevertheless, under certain conditions of use of plant protection products, the risk is only acceptable in terms of the regulatory definition if work clothing and/or personal protective equipment (PPE) is worn. This may include protective clothing for the body, glasses, gloves or masks. The information provided on the clothing and PPE available on the market is not always sufficient to ascertain whether they offer the required level of protection in each situation.
The Agency's work
In this context, ANSES issued an internal request in order to make an inventory of the clothing and PPE for agricultural use available on the French market, and then to analyse its effectiveness when worn by applicators of plant protection products. This internal request also falls within the framework of the French Ecophyto plan on prevention of occupational risks when using plant protection products, which seeks to promote the development of personal protective equipment adapted to user needs.
It should also be noted that, following an earlier Opinion published in October 2012, the Agency now systematically asks manufacturers, in their applications for marketing authorisation of a plant protection product, to provide precise information on the types of PPE and/or work clothing they consider appropriate for the protection of workers and operators. On this basis, the Agency examines the applications and specifies in its opinions the PPE and/or protective clothing required.
In the context of this internal request, the Agency's work involved conducting several studies and analysing their results:
- an inventory of PPE and work clothing available on the market and representative of farming practices;
- the results of permeation and penetration tests conducted in the laboratory on chemical protective clothing and work clothing worn by farmers;
- a study of exposure of operators wearing PPE, conducted under real conditions, in order to estimate experimentally the level of protection offered by the PPE.
These studies show that there is a fairly diverse range of work clothing and PPE available on the French market, enabling solutions adapted to a variety of exposure situations to be offered in the distribution channels for the agricultural sector. Moreover, the results of laboratory testing show that there is PPE available on the market that offers a high level of performance, both in terms of penetration and permeation. However, this equipment is not always worn during work phases in which it is nevertheless a condition of marketing authorisation for the products used. Most of the coveralls certified as PPE, which offer good performance in terms of penetration and permeation, have a level of comfort deemed mediocre, poor or very poor by farmers, and are unsuited to the constraints inherent to certain activities.
The Agency’s recommendations
In light of the information provided by its analysis, in the Opinion it is publishing today, the Agency recommends:
- continuing the standardisation work recently reactivated at European level, on France's initiative, so as to achieve the systematic certification of work clothing and PPE used for protection from occupational exposure to plant protection products, including work coveralls, which are widely used and play a valuable role in protecting applicators;
- asking PPE manufacturers, alongside the CE certification of their equipment, to provide all information relevant to users on the performance of their equipment depending on the use, and on best practices to be observed regarding care of this equipment (washing, storage, reuse, etc.);
- for each product submitted for authorisation, the requirement for the applicant to provide results of tests on the PPE that they are recommending, conducted with their product according to the harmonised standards available, or to justify an extrapolation from existing results obtained on products with similar characteristics;
- adapting the choice of personal protective equipment to the risks involved, and to the activity to be carried out.
Lastly, while there has been progress in making farmers more aware of the importance of protecting themselves from exposure to products, especially through Certiphyto training, significant efforts still need to be made towards this goal. ANSES recommends that new initiatives be taken to raise awareness of the health issues among farmers. It recommends the adoption and widespread distribution of best practice guides for each sector.
The Agency's other work
In addition to this internal request, the Agency is working to provide better documentation of occupational exposure to plant protection products and to specify the characteristics of work clothing and/or PPE capable of providing the required level of protection.
It has set up an expert group dedicated to studying exposure of agricultural workers to pesticides. The group aims to establish an inventory of the scientific data available on certain specific exposure situations under real working conditions, primarily in order to identify potential study and research needs and to make recommendations that could help in prevention. It plans to issue its conclusions in early 2015.