With a heavy agenda, shorter workdays, and a virtual format due to the COVID-19 pandemic, participants at the 17th Meeting of the Rotterdam Convention’s Chemical Review Committee (CRC-17) reviewed notifications of final regulatory action (FRA) on four of the seven pesticides on its agenda: terbufos, thiodicarb, iprodione, and methidathion. The Committee did not open discussion on the other three chemicals: chlorfenvinphos, carbaryl, and methyl parathion, due to time constraints.
On terbufos and iprodione, the CRC concluded that FRA notifications meet the criteria for listing banned or severely restricted chemicals. The Committee will undertake intersessional work to prepare draft decision guidance documents on these substances for consideration at CRC-18. It will then forward this guidance to the Conference of the Parties (COP) and recommend listing them in Convention Annex III (banned or severely restricted chemicals and pesticides).
On thiodicarb and methidathion, the CRC was unable to conclude its work during this meeting and will continue discussions at CRC-18.
CRC-17’s work also included discussion of whether information Mozambique had submitted in its notifications was sufficient to fulfill the Convention’s requirements detailed in Annex I, including properties, identification, and uses of a substance, as well as Annex II criteria for listing banned or severely restricted chemicals. More specifically, a key concern across all four of Mozambique’s notifications was whether a general survey of agricultural workers, central to Mozambique’s decision to take FRA, provided sufficient evidence to constitute a valid risk evaluation. This issue revealed a deep divide among participants’ expectations and raised questions about standards for evidence and accessibility of the Rotterdam Convention for low-income countries.
The CRC is responsible for determining whether notifications of FRA meet the criteria set out in Annexes I and II of the Rotterdam Convention. Discussions at CRC-17 revolved around what constitutes a risk evaluation, with some expressing strong preferences for more extensive data than had been provided in many notifications. Others argued the Convention requires only a simple risk evaluation, specifically to enable countries with limited capacity to submit FRA notifications. Many participants questioned the feasibility of attaining information in conditions where chemicals are not tightly controlled. For example, in many countries, pesticides are sold informally in markets, with farmers and farmworkers purchasing small quantities in unlabeled bags. Participants could not reach consensus on what constituted a risk evaluation.
CRC-18 will convene in the latter half of 2022 and will continue reviewing the four FRA notifications of final regulatory action submitted by Mozambique, in addition to notifications submitted by China and Uruguay on methyl parathion, as well as any new notifications submitted intersessionally.
The Rotterdam Convention COP is scheduled to convene face-to face in June 2022, jointly and back-to-back with the COPs to the Basel and Stockholm Conventions.