Majority of the plant protection products (PPPs) entering the Czech market are classified as hazardous to human health; i.e. one or more hazard classes are assigned to it.
As long as all the recommendations stated on the label of a product, presented in the safety sheet, all the common safety recommendations regarding PPPs application are followed and as long as questionable products are not used, use of these hazardous products can be carried out in a way safe for human health.

Until recently, only operators (i.e. workers directly handling PPPs) were considered in potential risk from exposure to PPPs. However, such reasoning contradicts the modern understanding of human health protection.

Besides direct operators, other stakeholders might potentially be at risk from improper manipulation with PPPs due to:

• direct handling of PPPs (storage, mixing, application, maintenance of application equipment, cleanup of eventual spills, etc.),
• accidental presence at the site of application during the application,
• entering the sites of application (as professionals - inspection, harvesting, etc. or as non-professionals - especially in areas abundantly visited by general public or susceptible groups of people),
• abundant presence in treated areas (residents),
• human and/or animal consumers of plant products (plants themselves or goods produced from plants),
• consumption of drinking water potentially contaminated by PPPs.

This article focuses on protecting the health of residents with respect to requirements on PPPs’ labels.

The responsibility for protecting the health of residents from potential adverse effects of PPPs lies explicitly on those making decisions over the nature of applications of PPPs and secondly, on those carrying out the actual application.

Nevertheless, a certain responsibility lies also on suppliers of PPPs which assess potential risks and suggest mitigation measures in the form of PPPs’ labelling.

Requirements on labelling of PPPs resulting from NIPH’s assessment regarding the protection of the health of residents and persons accidentally occuring at treated sites, eventually consumers:

1) Buffer zone / Distances safe for human health

Possible options that NIPH applies in their assessments:

■ The distance between the border of a treated area must not be shorter than 5 (3  or 10) meters from an area used/visited by susceptible groups of residents.
Under the risk management process, either a distance of 5 (rarely 3 or 10 meters) is selected and subsequently stated on a label of a product.
Older version of the sentence used for this purpose:
The distance between the border of a treated area must not be shorter than 5 (10) meters from an area used/visited by the general public.

■ Safe distance between the border of a treated agricultural land and the border of an area used/visited by the general public must not be shorter than 5 meters.
Different version of the sentence used for this purpose:
Safe distance of an area not treated by a PPP from the border of treated agricultural land, meadow or pasture land is 5 meters in order to protect the health of local residents.

■ Safe distance of an area not treated by this product from the border of a treated area is 20 meters.
The last of the variants is applied at rather hazardous PPPs (e.g. those toxic for reproduction cat. 1). These products often contain active substances which do not meet the criteria laid down by the article 4 par. 1 of the Regulation (EC) No 1107/2009 but remain in use under Regulation (EU) No 540/2011 until reassessment.
With respect to protection of the health of all groups of stakeholders (as listed above), the safe distance ought to be 20 meters from the border of a treated area (e.g. as laid down by requirements of §18 Decree of the Government No 361/2007 Coll. as amended.
It can be expected that these hazardous products will be withdrawn from the market in the foreseeable future.

Update:
Safe distances must be kept ALWAYS, even in cases where products are applied at times when no bypassers are expected (e.g. overnight applications).
Safe distances must be kept ALWAYS, even in cases where there are no residential areas in the vicinity of  treated areas (e.g. to-be-treated field within a field).

2) Obligation on information

■ There is an information obligation before using a PPP to notify neighbours who might possibly be exposed to product drift during application of a product and neighbours who requested getting informed prior to PPP application.
Note: this sentence is stated on several PPPs’ labels which are considerably hazardous. Namely, these products are classified as toxic for reproduction, category 1. Predominantly, they are the same products with an obligatory safe distance of 20 meters (see above).

Both compulsory safe distance for public health protection as well as information obligation are relatively new. NIPH has been applying these safety measures more abundantly since 2015 at processes of new authorisation, re-assessment of an effective authorisation and a change in authorisation. It follows Article 31 Column 4 (points a) and b)) of Regulation (EC) No 1107/2009 (regarding the safety measures for protecting the health of residents) and Article 44 Column 1 and 3 (point d)) of the same Regulation (he Member State shall withdraw or amend the authorisation, as appropriate, where: (d) on the basis of developments in scientific and technical knowledge, the manner of use and amounts used can be modified). The obligation to inform the general public (persons who might possibly be exposed to a product drift) is stated also in Article 10 of 2009/128/EC.

It was found that similar safety measures are required or will be required by other EU Member States, as well. For example, the efforts to apply these measures are greater in Poland than in the CR.

Local residents are defined by Regulation (EU) No 284/2013 persons living or working in a close vicinity of areas treated by PPPs or those regularly visiting any institution located in a close vicinity of treated areas but not persons visiting treated areas in order to pursuit (occupational) activities in a treated area or with treated plants. Explicitly, they fall into a category of susceptible persons according to a definition in Regulation (EC) No 1107/2009.

IN THIS CONTEXT, areas visited/used by the general public or susceptible persons are for example public parks or gardens, open areas in municipalities, public graveyards, sport fields, recreational areas, school premises, playgrounds, health care and medical facilities’ premises, cultural institutions, as well as houses and their premises, including gardens, driveways and accessways used by residents.

Under risk management process, several factors and their combinations are considered:

■ exposure assessments for particular groups of persons,
■ particular type of products’ application (way of application, number of applications, duration of a pre-/post-emergent application)
■ type of a crop and its height during application,
■ classification of a product with respect to route of exposure and the hazard class,
■ sometimes, percentage in content of a hazardous substances resulting in a classification,
■ eventually, other individual factors.

Products classified in hazard categories 1 or 2 or for exceptional aerial applications are evaluated on an individual basis.

Autor: Z. Trávníčková and coll. (posted 13. 7. 2016; last version 17. 4. 2018)