TALLINN, 19 August 2019 – The title of the article “The food eaten by Estonians is not as hazardous as the National Audit Office claimed”, published in Eesti Päevaleht on 14 August 2019, directly misleads the general public, as the National Audit Office did not express an opinion on how hazardous or safe the food eaten by Estonians is in its audit “Activities of the state in guaranteeing food safety”.

In the audit, the National Audit Office did not assess the scale of the hazards related to pesticide residues, but emphasised that information about the safety of food in Estonia is inadequate and giving justified estimates of actual safety is impossible. In the opinion of the National Audit Office, neither the Ministry of Rural Affairs (MRA) nor the Veterinary and Food Board (VFB) have spoken enough about the hazards related to pesticides, and Estonian nutrition and exercise recommendations also include modest quantities of information about pesticides. Acknowledging the risks related to food safety is important. The facts and conclusions highlighted in the report of the National Audit Office have not been refuted, the VFB and the MRA agreed with the criticism from the National Audit Office and promised to comply with the recommendations made in the audit.

The claim presented in the Päevaleht article that the fruits and vegetables that exceed the maximum residue levels are safe to eat in ordinary quantities is misleading, generalising and in contravention of the statements made by the World Health Organisation (WHO) and the European Food Safety Authority (EFSA). The opinion that all of the food available at stores is generally safe enough is not based on any analyses. It would be possible to express opinions on safety after analysing the hazards, but no such analyses of pesticide residues have been carried out in Estonia. For example, it should be analysed whether and which quantities of pesticide residues reach Estonian consumers and what their toxic effect is like, and guaranteed that no consumer groups (vegans, children, pregnant women, etc.) are at risk. The MRA admitted to the National Audit Office during the audit that no such analyses have been made and it’s possible that certain consumer groups (such as vegans) are more at risk. Secondly, maximum residue levels have also been established for prohibited substances and if these substances are found in foodstuffs, they are removed from the market only if the levels have been exceeded more than 1.5 times. The WHO has emphasised that some pesticides have properties that affect the endocrine system, that even small quantities are hazardous and contact with these substances should be avoided. Thirdly, we have no information about the effect of the interaction of pesticides. The EFSA, which develops safety norms, has also conceded that we don’t have enough information.

The explanation of the implementation of the 50% measurement uncertainty given in the article by Vello Tõugu, Programme Director of Food and Gene Technology at Tallinn University of Technology, is also incorrect. The terms “measurement uncertainty”, “maximum residue level” and “limit of determination” have been confused in the explanation given in the article. The claim that the National Audit Office wanted statistical recognition of the results that remain under the limit of determination is also untrue. In its report, the National Audit Office describes the practice used by the VFB whereby 50% is subtracted from the quantity of the residues ascertained at the laboratory and only then is the result compared with the maximum residue level. The issue that the National Audit Office had with this practice was that the VFB (NB! not the laboratory) does not inform the general public about this. It was also stated in the report that subtracting 50% from the results when assessing hazards should not be done, as it gives misleading results upon the assessment of safety (ADI and ARfD) and subtracting 50% from the result is recommended only when imposing sanctions against persons who have breached the regulations is being considered. We have to point out that the EFSA and other states (e.g. the United Kingdom) have highlighted these aspects in their respective reports.

The National Audit Office maintains that the information given to people must be transparent, understandable and true, and the way data are presented today makes the impression that food is cleaner than it actually is. The National Audit Office also maintains that it must be clear to people what information is collected about, what is done with the data and what certain claims mean. For example, the meaning of compliance, the meaning of safety, etc. The fact that safety does not equal compliance is illustrated by the case of Estonian strawberries covered by Maaleht and the example of baby food described in Eesti Ekspress. In the first case, a laboratory ascertained that strawberries contained prohibited substances (dimethoate and omethoate) in quantities that exceeded the maximum residue levels. As the results did not exceed the maximum residue levels after 50% was subtracted from the lab results and the fact that a substance is prohibited is of no importance, then the VFB deems such strawberries to be compliant pursuant to its ordinary practice and such strawberries are not removed from the market. The same has been done in respect of baby food so far – only the baby food that contains chemicals in quantities that exceed the maximum residue levels 1.5 times is deemed to be non-compliant.

The figure and explanation given in Annex D to the report of the National Audit Office help to better understand the issue of measurement uncertainly.

The National Audit Office still cannot agree with the position that food safety control should be focused on testing local food products. Protecting people must be the priority and this principle also holds a central place in EU rules. We must collect information about the food people eat and where the risks are higher, and the proportions of consumption must be taken into account when samples are taken. When we know that (figuratively) an Estonian eats three imported apples and one Estonian one, then we should take proportionally more samples of imported apples, as the risk of ingesting pesticides from them is higher. Thus, we cannot justify the situation where many imported fruit, vegetable and cereal products, such as tomatoes, apples, cucumbers, are not tested at all in some years (e.g. in 2017).

Contrary to the respective claims made by the VFB and the MRA, the European Commission also pointed out in its audit that the share of local products in food samples is too big. The National Audit Office maintains that it doesn’t matter how sample taking is divided between the VFB and the Agricultural Board (AB) or whether this is justified with the diligence of Estonia in submitting all the data it has collected to Europe.

The fact is that 67% of the samples on the basis of which the VFB the AB make conclusions about the pesticides contained in food are taken from Estonian food and the share of samples taken from organic food among them is also large, which means that the food consumption habits of Estonians are not taken into account.

In the article, Vello Tõugu wrongly claims that permitted pesticides do not cause cancer. Actually, it’s been ascertained that several active ingredients of pesticides authorised for use have toxic properties. There are 340 toxic substances among the pesticides authorised for use (385), incl. substances the ingestion of which must be limited due to their toxic properties and for which an acceptable daily intake (ADI) and acute reference dose (ARfD) have been established. Among these, 27 active ingredients are suspected of being carcinogenic, 99 are acutely toxic and many are considered or suspected of having a mutagenic impact on gametes or being reproductive toxicants. There are more than 50 substances the use of which is permitted at present, but that are pending prohibition and replacement with less toxic substances, because their ADI (i.e. acceptable daily intake) is very small and there is the risk that consumers exceed safe quantities. Substances with bioaccumulative properties, which are reproductive toxicants or known to disrupt the endocrine system, are also pending replacement. In addition to this list, there is a large number (over 800) of active ingredients of pesticides not authorised for use, which have been identified as highly toxic or which have not complied with other criteria set for authorisation for use. However, these substances are used outside Europe and food that contains them may be sold in Europe if the maximum residue levels of these substances are not exceeded. The toxicological properties of chemicals have been covered in Annex A to the report (page 56) and information can also be obtained from the pesticide database of the EU.

Airi Andresson, Director of the audit “Activities of the state in guaranteeing food safety“ of the National Audit Office

• Posted: 8/19/2019 10:42 AM
• Last Update: 8/23/2019 4:15 PM
• Last Review: 8/23/2019 4:15 PM