The difference between a risk-based and hazard-based approach
What’s the difference between a risk-based approach (used in Australia) and a hazard-based approach (used in UK and EU) to pesticide regulation?
As of December 2024, Australia has banned 24 pesticides, while the UK and EU have banned 225 pesticides, nearly 10 times more.
Having banned only 24 pesticides, Australia sits alongside Armenia, Georgia, Kyrgyzstan, Lebanon, North Macedonia, Rwanda, Togo and Zimbabwe. Egypt have banned 161 pesticides, Brazil 151, Switzerland 141, Indonesia 61, India 60, China 55, Thailand 48, Serbia 42, Canada 31, New Zealand 30. USA have banned 22.
As outlined by PAN UK, applying a risk-based approach means assessing and managing risk while the product is in use; not eliminating the source of the hazard itself. Risk mitigation measures may include recommendations for Personal Protective Equipment (PPE), label instructions, application guidelines, requirement for registration etc. This pushes the risk mitigation responsibilities onto applicators and the public, often allowing decades of harm to accumulate.
In contrast, taking a hazard-based approach means if a chemical possesses intrinsically hazardous characteristics – for instance by being able to cause Parkinson’s Disease, cancers or persistent pollution – then it is considered too dangerous to be used safely and should not be authorised. This approach is in line with the precautionary principle which states “when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically”.
Paraquat: an example of a risk-based vs hazard-based approach in practice
Paraquat entered the market in 1961, and by 1983 Sweden had banned paraquat for use as a pesticide due to its known irreversible toxic effects. Switzerland banned paraquat in 1989. The whole of EU and UK banned paraquat in 2007. In 2024, 63 years after the release of this highly hazardous pesticide, the APVMA still has paraquat under review as part of a process that has taken nearly 30 years. Allowing paraquat to remain on the market in Australia, when other countries have acted, has exposed generations of farmers to a chemical known to increase the rates of Parkinson’s Disease. This year, over 40 Australian neurologists, movement disorder specialists and professors added their signatures to a submission to the APVMA calling for the ban of paraquat. Many Australian farming lobby groups and industry bodies are lobbying for the continuation of paraquat, advocating against the overwhelming scientific evidence, and for further generations of farmers to be harmed.
With 201 more hazardous pesticides applied on Australian farms, fruit and vegetables, gardens, beaches and public spaces than in the UK or EU, the difference in practice between countries applying, or not applying, the precautionary principle, and the subsequent harm being inflicted on biodiversity, public health, waterways, drinking water, food and soils is stark.
This week, the Biodiversity Council released news of research that between one to three species of insects and other native invertebrates, such as pollinators and other beneficial species like earthworms, are becoming extinct in Australia every week. Reducing pesticide use is a key recommendation of this research.
A non-exhaustive list of pesticides banned overseas but approved and used in Australia, include:
- Alachlor – banned in 117 other countries
- Aldicarb – banned in 128 countries
- Azinphos-methyl, banned in 115 countries
- Carbaryl – banned in 48 countries
- Carbofuran – banned in 106 countries
- Chlorpyrifos – banned in 44 countries
- Dicofol – banned in 57 countries
- Diquat – banned in 35 countries
- Diuron – banned in 37 countries
- Ethylene dichloride / 1,2-dichloroethane – banned in 136 countries
- Fluazifop-P-butyl – banned in 8 countries
- Fluoroacetamide – banned in 151 countries
- Fluvalinate – banned in 37 countries
- Glyphosate – banned in 12 countries
- Hexachlorocyclohexane (HCH) alpha, beta – banned in 153 countries
- Imidacloprid – banned in 29 countries
- Mercury compounds – banned in 146 countries
- Methamidophos – banned in 116 countries
- Methyl parathion – banned in 80 countries
- Paraquat; Paraquat dichloride – banned in 72 countries
- Paraquat dimethyl sulphate (bis) – banned in 31 countries
- Phorate – banned in 87 countries
- Tributyltin compounds – banned in 113 countries
- Trichlorfon – banned in 91 countries
Products in Australia which would be banned overseas
At Australian stores like Bunnings, the pesticide product Mavrik can be bought over the counter. The active ingredient in Mavrik is Fluvalinate which is banned in 37 countries, including all of the EU, due to the harm it causes to humans and the environment. Even in the USA where it is permitted, according to Beyond Pesticides it may only be used by licenced applicators. At Bunnings, a teenager can buy it off-the-shelf.
The product Richgro Caterpillar, Grasshopper and Millipede Killer, sold in stores across Australia, contains the active ingredient, Carbaryl, which is banned in 48 countries due to the widespread evidence of harm. The American Association of Cancer Research has published research that using Carbaryl has been found to be associated with leukaemia and stomach cancer, as well as suggestive evidence of elevated risks of esophageal and tongue cancers. Australia has the highest rates of leukaemia in the world, and the highest rates of cancers in the world.
Why would Australia use this risk-based approach, rather than prioritise health and environment?
Australia is the only country in the OECD with a pesticide regulator that is majority-funded by industry (87% industry-funded in 2023-2024). APVMA call this a cost recovery funding approach. The more pesticide approvals and sales generated, the more revenue for the regulator. This conflict of interest makes it inevitable that the actions of Australia’s regulator will prioritise industry interests. Both major political parties (Labor and LNP) support this cost recovery model.
An example of this conflict of interest in practice is that the first performance measure APVMA use in their 2023-2024 Annual Report is ‘Proportion of applications finalised within legislative timeframes’. Put another way, the speed at which APVMA can get a new hazardous chemical onto the Australian market is the main metric of the Australian regulator. In 2023-2024, APVMA exceeded their performance target for this metric, with 94.6% (over target of 90%).
APVMA’s next performance measure is ‘Proportion of applications that pass quality audits under the Quality Management Framework’. APVMA failed to meet their target, with 88% (under target of 95%).
The next metric for APVMA is ‘Proportion of stakeholders who report they are satisfied with the quality of engagements with the APVMA’: they scored 40%; missing their already low target of 70%.
The next performance measure: ‘Proportion of APVMA staff who report a high level of engagement with the APVMA’, they failed to meet their target again, with 1 in 4 APVMA staff not having high engagement with their employer. There are deep cultural, capacity and personnel problems at APVMA, as demonstrated in this ABC article, which reported there have been internal formal complaints lodged every 4-6 weeks for 5 years.
Contrast all this with Sweden, whose regulator, the Swedish Chemicals Agency, define themselves as a government agency that works to ensure a non-toxic environment, and are funded by government appropriations.
Pesticide Action Australia reiterates our call for the APVMA to be reformed to a majority taxpayer-funded body, in line with all other OECD countries, implementing the hazard-based approach to pesticide regulation which prioritises Australia’s health and environment before industry interests.
Australia, we can do better. And we will. We need everyone to start taking action.
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Thanks to PAN International
Thanks to PAN International for their great work updating and releasing the 2024 Consolidated List of Banned Pesticides.
Pesticide Action Australia 