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Pesticide registration in the Netherlands is the responsibility of four governmental departments dealing with (1) agriculture, (2) public health, (3) environment, and (4) occupational health and safety. It is the responsibility of the Directorate-General of Labour (DGA) within the Ministry of Social Affairs and Employment to direct the evaluation of occupational toxicity and exposure data. Further, DGA maintains via the Labour Inspectorate standards of application technology; procedures for storage, mixing and loading; sound hazard communication; and the quality of protective measures. The ultimate goal is to achieve a quality of health and safety in agriculture comparable to other work places where toxic materials are used. Therefore, consistency with premanufacturing notification policy, for example, is obligatory.
As far as labor protection is concerned, the registration process of pesticides starts with toxicology. The relevant adverse effects determined in experimental animals are further evaluated if dose levels at which these effects occur indicate serious risk during or after occupational exposure via the dermal, inhalation, or secondary oral route. Quantitative exposure assessment is then carried out. Currently, a systematic approach for gaining exposure data is being developed in the Netherlands. This process is a multistep system consisting of (1) theoretical estimation of exposure, (2) using mathematical models and generic data, (3) personal dermal monitoring, (4) environmental (air) monitoring and personal air monitoring, and (5) biomonitoring.
Higher levels in the system are triggered if results at lower levels seem to have serious implications. In certain situations, a combination of elements from different levels within one study may have advantages. The exposure data then are challenged by an extrapolated human threshold dosage-level in order to rationally decide on registration. This approach of weighing possible risks is carried out for all relevant differential applications. Special attention is paid to indoor applications, like thermically isolated warehouses.
When the decision to register a pesticide has been made, different instruments may be used to control the actual exposure by defining the application technology and using warnings on the label, ergonomic packaging, and protective clothing. The Labour Inspectorate may add special protective measures to these demands for separate locations. During the registration, DGA may ask for further testing either in toxicology or exposure issues. The field data reported by the Labour Inspectorate provide feed-back on registration decisions. Efforts to answer questions concerning pesticide application and regulation are preferentially to be improved by a joint effort of the pesticide industry, the farmers, their organizations, and the registration authorities, all cooperating for better labor protection.
protective clothing, pesticide registration, exposure analysis, toxicology, occupational health
Toxicologist, Ministry of Social Affairs and Employment, Directorate-General of Labour (DGA),