Biopesticides: the way ahead
Wyn Grant & David Chandler
University of Warwick
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RELU project team at Warwick
• Dept of Politics &
International Studies.
Wyn Grant, Justin Greaves.
• Warwick HRI.
Dave Chandler, Gill Prince.
• Dept of Biological
Sciences.
Mark Tatchell.
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RELU research on microbial biopesticides:
innovation though political & natural science
• Strengths & weaknesses of biopesticide
regulation.
• Research on ecology of microbial agents.
• Evaluate costs & benefits in a holistic way.
• Data requirements & regulatory process.
• Regulatory innovation.
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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.
• Genes (USA).
• Plant incorporated products.
*Not regulated by Plant Protection Products (PPP) legislation.
Pests = arthropods, plant pathogens & weeds.
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Problems with chemical pesticides: resistance
& product availability
1600
No. registered compounds
600
No. arthropod species
500
400
300
200
100
0
1400
1200
1000
800
600
400
200
1900 1920 1940 1960 1980 2000 2020
0
1900 1920 1940 1960 1980 2000 2020
year
year
Insecticide resistance (world) & insecticide availability in USA (Hajek, 2004)
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Pesticides: problems & opportunities
• Pesticide resistance.
• Product withdrawals.
• Zero detectable residues.
• Treat modern pesticides as
a precious resource.
• Sustainable, integrated
pest management (IPM).
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Why are biopesticides useful?
• Often v. specific.
– ‘inherently less toxic than conventional pesticides’ (EPA).
• Compatible with other control agents.
• Little or no residue.
• Inexpensive to develop.
• Natural enemies used in ecologically-based IPM.
• Social benefits.
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How many products are there?
USA: biopesticides
Microbial products
a.i.s
products
USA
150 - 210
biochemicals
160
860
Europe
60
microbials
80
210
Germany
10
PIPs
10
25
France
15
Netherlands
15
UK
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(data: US EPA 2006)
(data: EPA 2006, Agri-Food Canada 2005;
PSD 2006)
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Biopesticides : chemical clones or
biological control agents? (Waage, 1997)
• Tendency to follow a chemical pesticide model.
• Danger of ignoring beneficial ecological attributes.
– Technological vs. ecological IPM.
– Inundation ↔ inoculation.
– Lack of underpinning information in some cases.
• Focuses attention on costs.
• Can’t evaluate contribution to sustainability (costs &
benefits) in a holistic way.
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In the EU, microbes & biochemicals are
registered as plant protection products
• National authorisations (PSD).
• Harmonisation of arrangements:
– Directive 91/414
– Active substances added to Annex I
(existing & new substances).
– Mutual recognition.
– Tailored requirements for biopesticides.
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Biopesticides: why regulation is needed
• Because it’s natural doesn’t mean it’s
safe, need to ‘set bar high’.
• Costs of regulatory failure are high, BSE
episode cast a long shadow and stifled
regulatory innovation.
• Public money invested in discoveries
that never reach the market.
• Need a system of regulation that will
lead to more products on market.
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A political maturity problem
• Policy network/community theory is a tool
used by political scientists to understand
dynamics of a policy arena.
• Applied in analysis of dairy industry,
chemical industry, fire service policy,
Premiership football etc.
• Biological control agents have the weakest
network I have encountered.
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Why a lack of sophistication?
• Small industry largely made up of SMEs.
• Failure to appreciate ‘politics of possible’,
seize ‘windows of opportunity’.
• IBMA does not have resources of crop
protection industry, still undergoing
organisational development.
• Little coalition building with environmental
groups.
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Institutional displacement
• There is a role for government in helping
new industries that bring positive public
benefits related to policy goals.
• US Environmental Protection Agency has
20 in microbial pesticides branch, 23 in
biochemical pesticides branch.
• Institutions do matter – they shape how
people act.
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Lessons from EPA
• ‘15 years ago nobody paid us any attention.
Staff who were really interested, staff at a
senior level within the Agency.’
• ‘We think outside the box’.
• ‘Upper management tells us, spread the
technology. Get it out there.’
• ‘We do things differently from rest of office,
we have a one stop shop.’
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PSD Structure
• Great strides made by PSD – pilot project
leads to Biopesticides Scheme.
• Should not separate out policy function from
approvals.
• Risks of being just a technical regulator
talking to technical people.
• Need a dedicated division within PSD on
EPA model.
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Pre-submission meetings
• These are a vital part of the new
arrangements.
• But some small firms are not taking
advantage – lack of information, suspicion
of the regulator?
• Emphasis on outreach needed.
• More general outreach issue is lack of state
extension service.
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Mutual recognition (EU)
• Commission admits this is not working.
• We are supposed to have an internal
market.
• Would help to overcome problem of small
market size.
• Need to support 91/414 revision that
creates three ‘eco zones’ within EU.
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For debate (1) – why is efficacy an issue?
• Efficacy could be 50% of registration costs
for biologicals, 10% for chemicals.
• ‘Chemicals can use quite small treatment
plots but biologicals need larger plots to get
statistical significance because individual
replicates are more variable’.
• Efficacy trials don’t always work first time,
e.g., in one set of trials pest didn’t turn up
two times out of three.
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So why not let the market decide?
• EPA requires applicants to test efficacy but
does not (normally) review data unless
there is a risk to human health and safety.
• California dropped efficacy requirement in
2006, advisers did not rely on DPR data but
on field experience.
• DPR thought it could speed the registration
process without efficacy data.
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The case for efficacy data
• Needed for marketing purposes, how do you
write the label?
• PSD flexible on label claims, no preconceived
levels of effectiveness required.
• Canada PMRA emphasises value dimension:
– only products making a significant contribution
approved at lowest application frequency.
– also to protect users from deceptive claims
(‘snake oil’).
• Key question: № of tests & over what time
period (because they are expensive).
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For debate (2) - subsidies
• IR-4 programme in US, mission is to
provide safe & effective pest management
solutions for growers of speciality crops.
• Biopesticides programme started in 1982,
expanded in 1994.
• Funded 43 projects since 1994 amounting
to $2.85M, also gives regulatory advice.
• Works closely as a partner with EPA.
• Supported growth of trade association.
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Genoeg (NL) – using pesticides in an
effective way
• 1st project 2001-5 facilitated five
applications.
• Second project hopes to help ten, but not all
consultancy time used.
• Government provides grant for half of
registration costs to maximum of €100,000.
• Environmental movement and organic
farmers represented on steering committee.
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The case for subsidies
• Biopesticides bring public benefits and help
to achieve sustainability goals.
• However, is there a market failure that can
be remedied by government intervention?
• Brings us back to issue of profile and
political displacement of sector.
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http://www2.warwick.ac.uk/fac/soc/pais/biopesticides/
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