AQWCW1ICALS ON TM=
I - PRESENT SITUATION
1 - Legislations : U.S.A., Germany and Italy
U.S.A. - Establishes maximp Residues Limits (MM)
for 16'pesticides (4 are considered tffrporary).
-Does not establish MRL for pesticides approved to be
used in the U.S.A.
-Does not establish criteria for the iffportation of
tobacco with pesticides residues giich are not
registered in the U.S.A. and for which an ML has not
been established.
-The limits refer to tobacco leaf.
G UAW - Establishes tK for 11 pesticides and recamvnds
maxinn arcunts for 71, which are standards for the
German tobacco industry.
-Establishes the limit of less than 0,01 pprr for
non-registered pest IC I C@es in Germany.
-The limits refer to tobacco products.
BATCo document for Province of British Columbia 16 April 1999

ITALY Establishes Maximum Residues Limits (MRL) for residues
of 69 pesticides.
Establishes the limit of less than 0,01 ppm for
residues for non-registered pesticides in Italy.
- Considers tobacco under the legislation for
food-stuff of vegetal and animal or,
- The limits refer to tobacco products.
Jh-
BATCo document for Province of British Columbia 16 April 1999

2 Tobacco-producing countries like Zimbabwe and Canada hay
approved the use on tobacco of agrochemicals not registers
in the U.S.A.
in registering modern tobacco agroch err I Ca Is in th.
3 - Di
U.S.A. and re-registration of products in use due to th,
complicated toxicological studies and high costs involved.
4 - The nonexistence of an independent international forum foi
discussion of matters with respect to the restriction in usin(
tobacco agrochemicals.
5 Reduced number of standard analytical methods approved bj
international regulatory entities for agrochemicals residues ot
tobacco.
Xh.
BATCo document for Province of British Columbia 16 April 1999

11 - PREDICTED FUTURE SITUATION
1) An increase of restrictions in the use of agrocherr I Ca Is by the
different countries and establishment of the EEC legislation.
Use of political and non-technical criteria for the
establishment of the MRL.
"Clean tobacco' concept may be adopted.
Improvement of the analytical methods may induce the
MRL to an even lower level.
2) No economical feasibility of the re-registration of pesticides
already being used and registration of new pesticides for
tobacco. The consequence is the reduced number and a high
incidence of old-fashioned pesticides for use on tobacco.
The causes are:
The tobacco crop has low economical significance for
the pesticides manufacturers.
High registration costs of new pesticides-
in the U.K. and $40 rri I I ion
approximately E30 rri
in the U.S.A.
More complicated toxicological tests for the tobacco
are required.
'ble connection of pesticides residues with smoking and
3) Possi
health issues.
BATCO document for Province of British Columbia 16 April 1999

III - SOUZA CRUZ SUGGESTIONS
A) B.A.T. IAternal Actions :
1) To centralize all pertinent information related with
agrochemicals, such as registration, legislation, and other
important matters, on the chairman of the Ingredient Review
Panel (IRP) which would be in charge of evaluating and
circulating them to all B.A.T. companies.
2) Regarding the use of agrochemicals, the IRP must have the
following points among its purposes, as proposed during the
first IRP meeting:
a) Recommend appropriate criteria for assessing the suitability
of agricultural chemicals for use on tobacco. A suggestion
presented by Souza Cruz is being evaluated by IRP.
representatives;
b) Establish a list of agricultural chemicals which may be used
on tobacco;
c) Record any limits which should be advised or applied to the
use of individual agricultural chemicals;
d) Identify any agricultural chemicals which the Panel
considers should not be used on tobacco on the grounds of
potential adverse reaction;
e) Exchange information on developments in legislation which
could affect decisions on the usability of agricultural
chemicals on tobacco;
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BATCo document for Province of British Columbia 16 April 1999

3) The IRP should coordinate the establishment of B.A.T. 's point
of view to be taken to CORESTA on the following points:
a) To identify CORESTA as an international forum to discuss the
subject: Pesticides on Tobacco;
b) To settle a new technical sub-group under the
Phytopathology group at CORESTA with the objective
described in Item B 2 - External Actions;
O To propose new responsibilities for the sub-group on
Pesticide Residues as described in Item B 3 -
External Actions.
4) Souza Cruz R&D department has facilities for analyses of
pesticides residues which could be used by B.A.T. group.
companies.
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BATCo document for Province of British Columbia 16 April 1999

B) Exterpal Actions :
1) To identify CORESTA as an international forum to discuss the
subject of pesticides on tobacco.
2) To settle a new technical sub-group at CORESTA, under the
Phytopathology group, f o rmed by toxicologists and
specialLiStS in pesticides, with the following objective:
To propose criteria of toxicological evaluation for the
registration and re-registration of pesticides for use
on tobacco.
To propose criteria for the determination of maximum
limits of pesticide residues (MRL) on tobacco.
To establish MRL for the main pesticides recommended for use
on tobacco, which should be used as a standard for the
tobacco industries in the world.
3) The present sub-group on pesticide residues should be
responsible for:
. To standardize and approve analytical methods.
. To establish concepts of CORESTA official laboratories for
pesticides residues determination.
To establish a CORESTA bank for pesticides analytical
standards.
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BATCo document for Province of British Columbia 16 April 1999

I
ANALYTICAL METHODS.STANDARDIZED BY CORESTA/ISO
a) Existing
Maleic hydrazide (suckercide)
Organochlorine (insecticide)
Dithiocarbamate (fungicide)
b) To be introduced
Pendimenthalin (herbicide)
Flumetralin (suckercide)
n-Decanol (suckercide)
Methoprene (insecticide)
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BATCo document for Province of British Columbia 16 April 1999

ANALYSES WHICH SOUZA CRUZ PESTICIDE RESIDUE ANALYSIS LABORATORY
IS ABLE TO DO:
a) Existing
Organochlorine Dithiocarbawate
Aldrin measured as
Dieldrin CS2 total)
Endrin
. Heptachlor Maneb
. Heptachlor epoxide Zineb
Endosulfan I and II Mancozeb
Endosulfan sulfate Propineb
Chlordane (Alpha and gamma isomers)
Oxichlordane Permethrin
DDT.'s (o,p-' and p,p.' isomers) Cyperrrethrin
DDD-'s (o.p.' and p,p.' isomers) Formothion
DDE's (o,p.' and p,p..' isomers) 2,4 - D
Toxaphene 2,4,5-T
Methoxichlor Dicarpba
HCB Carbaryl
Lindane Acephate
Mirex Metharridophos
BHC.'s (Alpha,beta and delta isomers) Flumetralin
Butralin
Pendimenthalin
Maleic hydrazide
b) Being developed
Methoprene
Cyhalothrin
Carbosulfan
Carbofuran
Sethoxydin
Fluazifop-butyl
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BATCo document for Province of British Columbia 16 April 1999

0
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REDUCTION OF "OTHER NOXAE"
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STRATEGIC OBJECTIVE
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To reduce minor constituents of mainstream smoke
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Authorities. Reductions must be relative to PMWNF
or nicotine deliveries to give improvements over
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current techniques such as filter ventilation.
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The noxae should not be re-distributed to sidestream
> smoke.
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"GENERALLY RECOGNIZED AS SAFER
(GRAS)PRODUCTS
3 STRATEGIES
1. GENERAL DELIVERY REDUCTION
M TRADITIONAL LOW DELIVERY APPROACH
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0 2. IDENTIFY RISK ASSOCIATED SUBSTANCES
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to TOBACCO COMBUSTION NOT THE PRIMARY
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IDENTIFICATION OF RISK ASSOCIATED
r+ SUBSTANCES PROBLEMS
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< 1. SMOKE CONTAINS THOUSANDS OF
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2. NON ADDITIVE EFFECTS
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IRRITATION BY SMOKE
> 4. AT LEAST 3 DISEASE TYPES
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5. PROOF THAT SELECTIVE REMOVAL OF
SOME SUBSTANCES LESSENS RISK
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(D CONCLUSIONS
0 EVEN IF SELECTIVE REDUCTION OF A NUMBER OF
TARGET NOXAE WERE ACHIEVED, THERE IS LESS
CHANCE OF SUCH PRODUCTS BEING ACCEPTED AS
"GRAS" COMPARED WITH GREENDOT AND NOVA
PRODUCTS WHICH REDUCED ALL TOBACCO SMOKE
=r DELIVERIES AND HENCE REDUCED UNKNOWN AS
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0 WELL AS KNOWN NOXAE
*HOWEVER SELECTIVE REDUCTION SHOULD HAVE
> APPLICATION IF SPECIFIC SMOKE SUBSTANCES
BECOME "LEAGUE TABLE" TARGETS
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SUGGESTED "OTHER NOXAE" GOALS
MAINTAIN A COMPANY KNOWLEDGE BASE, SUPPORTED
BY OUR OWN RESEARCH, ON THE HEALTH CONTENTIOUS
SUBSTANCES IN SMOKE AND THE FACTORS WHICH
0 INFLUENCE THEIR LEVELS. HENCE INTERACTION WITH
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REGULATORY AUTHORITIES ETC.
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0 AS EXTENSION, PROVIDE BACKGROUND INFORMATION
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s ON THE OPPORTUNITIES FOR, AND LIMITATIONS TO, THE
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SELECTIVE REMOVAL OF SPECIFIC NOXAE
AS EXTENSION, DEVELOP PRODUCTS GIVING
SELECTIVE REDUCTIONS IN SPECIFIC NOXAE, IF
REQUIRED FOR "LEAGUE TABLES" ETC.
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