The Regulation of Pesticides in the EU : From Risk to Hazard Assessment

Emanuela Bozzini

Regulation 1107/2009 on the placing on the market of 'plant protection products' - i.e. pesticides - introduced a significant policy change: the risk-based approach at the core of previous Directive 414/1991 was substituted by an hazard-based approach. The old risk-based approach was based on the idea that we can assess and manage risks, so that carcinogen or pollutant substances might still be permitted if the risk associated with them is assessed to be low or manageable. The hazard-based approach instead implies that if an active substance is found to be intrinsically dangerous, for instance to cause cancer or persistent pollution, then no risks will be taken and its use will be outrightly banned with no need of further assessment. In short, the hazard-based approach stipulates that there are risks that are unacceptable and cannot be managed. The new approach is therefore more restrictive and its introduction in EU regulation proved very controversial. The paper uses an advocacy coalition framework to explain the adoption of the hazard-based model in EU pesticide policy. The analysis traces back the debate among opposing coalitions of actors, starting from 2001 - when the first evaluation of the old legislation was made public - to 2009 when the new regulation was eventually approved. On the basis of policy documents and interviews with actors involved in the policy formulation process, the paper sheds light on the complex set of conditions that made such significant change possible.

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