Biopesticides: Environmental
and Regulatory Sustainability
Wyn Grant with Justin Greaves
Crop production and pest
management: the challenges
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Pesticide product withdrawals
Pesticide resistance
Zero detectable residues
Sustainable food chain: economic,
environmental, social
• Integrated Pest Management (IPM)
Biopesticides: mass produced biologically based
agents used for the control of plant pests
• Living organisms (natural enemies)
• Micro-organisms
• (Arthropods & nematodes)*
• Naturally occurring substances (‘biochemicals’)
• Plant extracts.
• Semiochemicals (pheromones & allelochemicals).
• Commodity substances.
*Not regulated by Plant Protection Products (PPP) legislation.
Pests = arthropods, plant pathogens & weeds.
Plant protection product
registration system
• Two-tier system of registration
(legislation under revision in co-decision
process)
• Active ingredients at EU level, products
at member state level
• National authorisations PSD
• Mutual recognition not working
Biopesticide products
registered in UK (5 in pipeline)
Insecticide
Microorganism
Bt
Microorganism
non-BT
Baculovirus
1
Total
3
1
Fungicide
4
1
4
Biopesticide PPP active
substances listed on Annex 1
• 40 insecticides (27 pheromones, 8
microorganisms, 5 baculovirus)
• 20 fungicides (all microorganism nonBt)
• 1 Nematicide, 6 Repellants (all
botanical), 2 others (both botanical)
• Includes substances voted with entry
into force date of 1 May 2009
Biopesticides and IPM
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Often very specific
Compatible with other control agents
Little or no residue
Inexpensive to develop
Natural enemies used in ecologicallybased IPM
• Lower potency than synthetic pesticides
But uptake has been low & potential
benefits are not yet being realised
• Economics (market size, external costs).
• Efficacy (potency, application, formulation).
• IPM (integration, best use of biological
characteristics).
• Regulation (system principles, design &
operation).
• How can research help? Theory & application.
Work of natural scientists
• Ecology of insect pathogenic fungi
• Genetic structure of natural populations
• Ecological factors determining the
occurrence of natural populations
• Theoretical basis for understanding fate,
behaviour and environmental impact of
biopesticides strains
Focus of political scientists
• Regulatory state perspective (Moran)
• Underlying design principles
• Stakeholder relationships (policy
networks)
• Role of retailers
• Inform regulatory process, including
training of regulators
Regulatory innovation
• Forthcoming paper by Justin Greaves in
Public Policy and Administration
• Regulatory innovation a contradiction in
terms as regulators are cautious and
risk averse
• Combination of exogenous and
endogenous pressures induces change
Improved knowledge base and
chain
• Better understanding of ecology of
microbial control agents
• Availability of expertise for PSD and
ACP
• A more effective knowledge chain
linking, e.g., growers and researchers
Underlying principles (1)
• Biopesticides have a key and specific
role to play in crop protection as part of
IPM – problems of resistance and
reduced availability
• Biopesticides should be regulated –
because something is ‘natural’ does not
mean that it is safe
Underlying principles (2)
• The regulatory system must support
sustainability objectives
• This includes economic sustainability
• The ability of SMEs to succeed and
growers to have the right plant
protection tools
Underlying principles (3)
• Pest management should be
ecologically based
• Biopesticides offer benefits to
conventional and organic farmers
• Credibility with all stakeholder groups
and especially consumers is key –
problem of name
Stakeholder involvement
• Weak, immature and poorly integrated
policy network
• REBECA (EC policy action) helped, but
follow on?
• Further organisational development of
IBMA
• Where is constituency of support?
A quasi-governmental
champion
• Provided in USA by Biopesticides and
Pollution Prevention Division of EPA
• PSD as regulatory agency not really
equipped for an advocacy role
• Possible role for Natural England?
• Risk of case being sidelined
Organisation of PSD
• Now part of HSE, a work in progress
• Continue to develop work of
Biopesticides Champion and team
• Still uncertainties about organisational
culture
• They have been trained, now they need
more customers
Efficacy testing
• Submission of data not required in US
• Needed for marketing purposes and to
protect product reputation
• Work of Biopesticides Steering Group of
OECD
• Support REBECA proposal to allow
applicants to defer efficacy testing
Biopesticides scheme
• A welcome development, but still
outreach challenges
• Importance of early pre-submission
meetings
• Distinctive approval number for
Biopesticides?
• ‘Grey market’ of leaf enhancers, plant
strengtheners etc.
Role of retailers
• Reflect consumer concerns
• Ask for requirements that go beyond
approvals system
• Variations between retailers increase
complexity for growers
• Prohibit rather than promote specific
products – which is difficult for them
European dimension
• Revision of 91/414 not complete
• Concerns about way in which EFSA
operates
• Development of informal networks
between regulators
• Eco zone proposal has attracted some
criticism
Assistance with costs
• Still a gap between product ideas and
an approved product on the market
• Some products may not be viable
• Market failure in terms of positive
externalities not being realised
• Constraints of EU state aid rules
Visit our web site
• http://http://www2.warwick.ac.uk/fac/soc
/pais/biopesticides/
• Thanks to project team – Dave
Chandler, Justin Greaves, Gillian
Prince, Mark Tatchell