Biopesticides, regulatory
innovation & the regulatory state
Dr Justin Greaves, University of
• Bureaucrats are (understandably) risk averse.
This does not create an encouraging
environment for regulatory innovation.
• This presentation considers the possibility of
regulatory innovation in the area of pesticides.
• It looks, in particular, at how the Pesticides
Safety Directorate (PSD) can be encouraged to
innovate, particularly in the area of
What are biopesticides?
• Biopesticides are mass produced
biologically based agents used for the
control of plant pests. They include:
- Living Organisms (natural enemies)
invertebrates, nematodes and micro-organisms
- Naturally Occurring substances
plant abstracts; Semiochemicals (eg: insect pheromones)
- Genes (USA)
Plant Incorporated Products
Levels of analysis
• At the outset, a ‘levels of analysis’ problem.
• Macro level or grand theory: the debate about
Weberian bureaucratic theory.
• Middle-range theory: ‘The Regulatory State’
(Moran) and work on innovation by Downs et al.
• Micro level analysis : the role of PSD and ACP in
their approach towards biopesticides.
Bureaucratic theory
• Systems of regulation can have unintended
consequences. Bureaucratic theory points to a
tendency for mechanisms to displace goals, for
processes to become more important than
outcomes. There may be consideration of policy
instruments in isolation from their wider effects.
• There could also be budget maximisation effects
(see, Niskanen, 1971).
Moran: the Regulatory State
• Displacement of ‘command’ state (‘Keynesian
welfare’ state) by regulatory state.
• Involves more indirect forms of state control
(which do not, however, necessarily reduce state
• See in ideal typical terms as progressive.
Replacement of self-regulation which was seen
to fail both in terms of economic efficiency and
public accountability.
What is Regulatory Innovation?
• Part of the ‘reinventing government’
• It is important to distinguish between
‘change’ and ‘innovation’.
• Regulatory innovation is innovation in
any aspect of the regulatory system or
regulatory regime (Black, 2005).
Forces of Inertia and Change
• Policy network theory: policy networks are good
at managing incremental change, but tend only
to innovate in conditions of crisis and exogenous
• Bureaucracies have to cope with considerable
forces of inertia but there are also forces of
change (see Downs 1967).
• Downs points to three forces of change: the
desire to do a good job, aggrandizement, and
self defence against pressure from external
• Dept of Politics &
International Studies.
Wyn Grant, Justin Greaves.
• Warwick HRI.
Dave Chandler, Gill Prince.
• Dept of Biological
Mark Tatchell.
Background to our research
• Consumers are concerned about the health
effects of pesticide residues on food. This
concern is picked up by retailers who often push
for pesticide reductions more rigorous than
those required by regulators.
• Alternative methods are required in order to
develop systems of crop protection which are
• Reduced availability of substances/problems of
pesticide resistance.
Warwick Project Objectives (1)
Main aims:
– Assess limitations of chemical
pesticide regulatory system for
– Compare public policies on
pesticide reduction.
New a.i. registrations
– Identify processes that may
sustain regulatory innovation.
reduced risk conventional
Registration in the USA
1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006
Warwick Project Objectives (2)
Main aims:
– Understand the effect of habitat type (e.g, woodland v.
arable) on biodiversity of natural populations of insect
pathogenic fungi.
– Fungal life history: how do insect pathogenic fungi
survive in soils?
– Impact of spraying on indigenous fungal populations.
Microbial biopesticides
• The project is concerned with microbial bioinsecticides, based on entomopathogens, for the
control of insect pests.
• These exhibit desirable biologically-based
properties (eg: specificity, reproductive potential,
low impact on non-toxic residues, compatibility
with other natural enemies, limited toxic
• However, they could have unwanted indirect
effects (eg: on naturally occurring microbial
agents occupying the same niche).
Regulatory failure & biopesticides
• Microbial biopesticides have been commercially
available for over twenty years but represent
less than 1% of the global market (90% of world
sales = BT).
• ‘Market failure’ hypothesis; market size is too
small to provide economies of scale and
encourage firms to enter (RELU project at
Imperial College, Wye).
• Regulatory failure hypothesis (Warwick):
systematic problems arising in regulation along
with specific problems (the use of a chemical
pesticide driven regulatory model by PSD).
Some problems with the regulatory
• The pilot scheme has resulted in a
reduced registration fee for biopesticides
but arguably it is still too high.
• The big cost is the testing required to meet
registration requirements.
• The United States EPA tests for safety but
not efficacy. One option, therefore, would
be to reduce efficacy testing in the EU.
How do the levels of analysis link
up with the project?
• Under the chemical pesticides regulatory
model, specific and short-term goals may
prevail over long-term aims of environmental
protection and social benefits.
• “Our analysis is influenced, at least as a point
of departure, by models of the regulatory state”
(Grant, 2005).
• The key link is with the regulatory innovation
The barriers to innovation
• Regulatory innovation may not be helped by the
relatively weak policy network for biopesticides.
• The biopesticides industry is small, largely made
up of SMEs, still undergoing organisational
development, and does not have the policy
resources of the agrochemical industry.
• PSD has to operate in a general climate in which
regulatory innovation has been impeded by
events such as BSE.
Pressures for change (1)
• Defra wants to encourage use of biopesticides
for sustainability goals. Given slow progress, the
core executive intervened.
• The Cabinet Office approached PSD resulting in
a new Biopesticides scheme.
• Exogenous pressure has worked alongside an
endogenous steer from within the policy side of
PSD. This has been picked up by some on the
approvals side.
• PSD could go further and have a separate
biopesticides unit (as in the US). A unit or
mission could help PSD to innovate.
Pressures for change (2)
• Systematic reviews of provision (eg: Hampton
• UK Treasury concerns about the cost & powers
of regulators could encourage ‘a lighter
regulatory touch’ for biopesticides.
• The Royal Commission on Environmental
Protection (RCEP) report on Crop Spraying
(2005) recommended that responsibility for
pesticides policy be separate from the approval
of pesticides.
• Implications of REACH (new chemicals
• Risk averseness helps explain why biopesticides
have not been used more.
• Whilst some progress has been made,
substantial innovation is still required.
• Regulatory Innovation for biopesticides requires
exogenous and endogenous pressure.
• We aim to draw up design principles for a
regulatory system that better facilitates the use
of environmentally friendly pest control agents.
Directed at decision-makers & it will hopefully
stimulate reform.
Please visit our website :
Prof Wyn Grant
Prof Mark Tatchell
Dr David Chandler
Gillian Prince
(University of Warwick)

Biopesticides, regulatory innovation & the regulatory state Dr Justin Greaves, University of Warwick