1. The Consumer Council welcomes the proposed amendments to the Pesticides Ordinance. The Council believes that adoption of a product registration system alongside with enhanced control on product labeling can be more effective in monitoring the supply of pesticides in the market, and in facilitating the safe use of pesticides.
Improvements to the registration system
2. It is beyond the capacity of the average consumers to assess the combined effect of different ingredients of varying concentration under the current system. The Council therefore supports requiring importers or manufacturers of pesticides to submit technical data to the Agriculture, Fisheries and Conservation Department (AFCD) for safety evaluation, including both active and inert ingredients, concentrations, formulation and intended use.
3. The Council also welcomes AFCD assessing the accuracy of labels of all pesticide products before they are registered and placed on the market. Proper labeling is instrumental to consumer choice amongst different products and can reduce chances of misuse.
4. The consultation paper refers to the problem of complication in medical diagnosis in the event of medical emergency involving pesticides. The Council considers that the data collected under the proposed product registration system will be very useful and can be critical in such cases of medical emergency. The Council suggests that provision be made for AFCD to disclose the necessary information to clinics and hospitals treating patients in emergency, so as to assist medical diagnosis. Alternatively, consideration can be given to maintaining a database of essential product information including ingredients, concentration, etc. with access granted only to medical professionals in restricted circumstances.
Control of Use of Pesticides
5. The extensive use of pesticides can pose concern with health / safety or impact on the environment. The Council supports the proposed measures to control the use of pesticides including issuing license to pesticide application service providers, requiring registration of pesticide applicators and restricting access to restricted pesticides.
Facilitation of Trade of Non-restricted Pesticides
6. It is now proposed to repeal the current licensing requirement for pesticide retailers who only sell Part I domestic pesticides in ready-to-use form. Though toxicity of and health hazards posed by Part I domestic pesticides are expected to be low, inappropriate storage may lead to safety problems. The Council therefore suggests that guideline be issued to retailers on storage condition, including temperature and quantity, as well as safety precautions to be taken. It will also be necessary to educate the general public about proper usage, storage and disposal of pesticides, to prevent the onset of accidents and to protect the environment.
