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Pesticides Safety Directorate: a Draft National Strategy For The Sustainable Use
of Plant Protection Products
Response from a Research Team at the University of Warwick
This response is submitted by a research team from the University of Warwick
(Departments of Politics and International Studies and Biological Sciences and
Warwick HRI) working on a RELU project on the environmental and regulatory
sustainability of biopesticides. The views expressed represent the collective
viewpoint of the individuals named at the end of the document and should not be
taken as representing the views of the University of Warwick or any of its
departments or of the RELU programme.
Our responses to the list of consultation questions in Annex G are given below. Much
of what we have written needs to be read within the context of our response to
Question 6: Is the rationale behind developing a strategy convincing? The Draft
National Strategy covers two main interacting issues with respect to the sustainable
use of plant protection products. The first concerns efforts to minimise the use of
conventional plant protection products in order to reduce adverse effects on the
environment. The second concerns the ability to sustain plant protection in the future,
which is threatened by product withdrawals and the development of resistance to
pesticides in pest populations. We have a concern that these issues are not
distinguished sufficiently in the early stages of the report. In addition, there is an
underlying assumption to much of the Draft National Strategy that conventional
pesticides are the only real form of crop protection and that alternative methods are
likely to make only a marginal contribution. As a result, the Strategy gives
insufficient weight to the importance of Integrated Pest Management (IPM) and nonchemical methods for sustainable plant protection. Adopting an IPM approach would
enable risks to the environment from plant protection products to be reduced while at
the same time managing the threats to effective plant protection.
Q.1 Building the strategy
The Pesticides Forum was established in May 1996 to bring together organisations
that have an interest in the use and impact of pesticides. Its tasks include:
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identifying common interests
assisting in the effective dissemination of best practice
advising government on the development, promotion and implementation of
pesticides policy.
Questions need to be asked about whether the identification of common interests is
given sufficient priority, particularly in terms of pursuing a collective good rather than
defending existing vested interests which can simply become more entrenched. Is it a
sufficiently solutions oriented body?
It is interesting to compare the membership of the Pesticides Forum with the interests
identified in Q.1. Government agencies and advisory committees, conservation and
environmental groups, the agrochemical industry and farmers’ organisations would
appear to be well represented. What is surprising is the absence of any individual or
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collective retailer presence given the concerns that they have expressed about
pesticide residue issues, although it might be questioned whether they could be seen
in the same entity as technology providers. The Food Standards Agency is playing
an increasingly important role in discussions about pesticides policy but is not listed
as a member (January 2005).
The absence of organisations concerned with amenity users is also noteable. In this
connection it is worth drawing attention to the comments made by the House of
Commons Environment, Food and Rural Affairs Committee, Eighth Report of 20045, Progress on the use of pesticides: the Voluntary Initiative, para. 28: ‘An example of
how the principle of substitution might operate in practice was provided by the Royal
Horticultural Society (RHS). Its advice to gardeners is to resort to synthetic pesticides
only after first trying other options, such as resistant varieties, cultural methods,
physical barriers and biological controls.’
We suggest that the membership of the Pesticides Forum needs to be made more
comprehensive in terms of the range of bodies interested in pesticide questions. We
also consider that the development of better links may require a new approach.
Rather than simply valuing the existence of a process of consultation and discussion,
there needs to be a clear focus on policy objectives, in particular what the options are
and how they can be integrated into the policy framework.
Q.2 List of measures
Our view is that this list of measure is reasonably comprehensive and that, in general,
they are accurately described, particularly in respect of implications for plant
protection product users. However, the risks and opportunities associated with each
policy are assessed individually and focus very much on chemical pesticides with
insufficient account of alternatives, such as biological controls, which can make a
significant contribution to sustainable plant protection as part of an integrated
approach. Policies are also treated in isolation. The opportunity should be taken to
rectify this, as most of the policies are running concurrently and may therefore
interact to have substantial impacts.
For example, EU Directive (91/414/EEC), and its revision, identifies the loss of
valuable products. In addition, FSA action to reduce residues (to the limits of
detection) could impact on Retailers’ Protocols. They could demand residue levels
that have no relationship with EU and UK legislation on pesticide maximum residue
levels, the consequence could be that even fewer products are available, particularly
on minor crops. The final outcome could then be that users rely exclusively on a very
small number of products which would hasten development of resistance to those
products.
Countryside and Rights of Way Act 2000: The statement “…… it is important to
ensure that the future use of pesticides does not lead to further declines in, or recovery
of, biodiversity.” Surely the statement regarding recovery of biodiversity is incorrect.
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Q.3 Comments on the action plans
Biodiversity Action Plan
The term “biodiversity” is used in its widest sense throughout the document, meaning
wildlife in general, which is to be commended. The diversity and abundance of
species are broadly to be encouraged both through the delivery of ecological stability
and the aesthetic benefits that a diversity of species contributes to appreciation of the
countryside. The abundance of signature species, such as the skylark, has been
identified by the government as a PSA target as a measure of sustainability. An
opportunity arises to use this as an education vehicle to illustrate the broader
interaction between species that is essential to the delivery of larger number of
skylarks. In this context the Action Plan might benefit from measures that are
directed in part towards education.
Plant protection products are used extensively, though not exclusively, in areas of
intensive arable, vegetable and fruit production. It is in these areas that a biodiversity
action plan may have greatest impact. However, the extensive areas of grass
production should not be ignored as they also have a valuable contribution to make to
biodiversity.
Plant Protection Products Availability Action Plan
The aim of this Action Plan is to produce measures that ensure the availability of
plant protection products. The Action Plan takes into account the issues that threaten
the future availability of products, and a logical series of measures have been put
forward. It is interesting, however, that the contribution of non-chemical methods and
IPM to sustainable plant protection receives little attention in the introduction to the
Action Plan, particularly with respect to delaying the onset of pesticide resistance
(paragraph 4.29). Instead, it is suggested (paragraph 4.28) that the rapid development
of resistance is avoided by using a range of chemical pesticides. This approach is
unlikely to be sustainable. However, there are good opportunities to promote
sustainable plant protection, and indeed a range of appropriate measures are
highlighted in the Action Plan proper.
The general approach taken to biopesticides in the strategy document is evident in
paragraph 1.3 where emphasis is placed on the limits to their use, inconsistency in
their effectiveness and hazards for people and the environment that are stated to be
difficult to predict. This is not to deny the need for further scientific research on
environmental risks and such research forms part of our own work. However, a more
positive approach to the potential contribution of alternative methods and support
tools (such as pest and disease forecasting) to IPM might help to realise their
contribution more speedily.
We welcome the suggestion that fast-track registration for biological pesticides could
be introduced without compromising safety. This was a need identified in the 2002
report of the Regulatory Impact Team of the Cabinet Office that referred to
‘regulation-inspired market failure’. Subsequently, the PSD ‘agreed to launch a pilot
scheme to investigate the best practice for processing applications for bio-pesticides.’
Such efforts need to be given a higher priority. The proposed fast track system for
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biological pesticides should be extended to other low risk plant protection agents,
such as semiochemicals. It would be beneficial to provide a definition of biological
pesticides, as the term can have different meanings. For example, some authors use
the term to refer to living organisms, while others use it to refer to any plant
protection agent based on a living organism or a product of a living organism (the
latter are also referred to as ‘biologically-based agents’).
The rules on proving the efficacy and consistency of a product could be adapted for
non-chemical agents, which by themselves may have lower efficacy compared to a
chemical, but which can make significant contributions to sustainable plant protection
when used as part of an IPM system. This is particularly the case for biopesticides.
Increasing the use of mutual recognition would be a significant step forward to
increasing the availability of minor use products.
We also welcome the suggestion that there should be an exploration of the availability
of alternative plant protection technologies to see what can be done to encourage
these to come on to the market. This measure is overarching to the following other
measures: (a) introduction of a fast track registration system; (b) the promotion of
disease (and pest)-resistant crops; (c) R & D on prevention and control of pests, weed
control and decision support systems. Such an exploration should cover issues of
both market failure and regulatory failure. Account also needs to be taken of the
lower cost of producing a biological compared with a chemical pesticide.
Amenity Sector and Amateur Use Action Plan
It is clear that the amenity and amateur use of pesticides is controlled and regulated
rather differently to their use in agricultural businesses, and that the use of plant
protection products in these sectors is considerable. However, how comfortably do
amenity and amateur usage fit together in the same action plan? The logic may be
that the targets for some amateurs and amenity practitioners may be the same (e.g.
lawns, gardens, hard areas), but the mechanisms to implement in the two sectors are
likely to be very different. The use of products in the amenity sector is largely in
professional hands, while gardens are managed by amateurs. It will be very difficult
to bring these under the same umbrella in a way that does not put unreasonable
demands on the amateur. That said, if the action plan is directed more at education
and best practice then advantages may accrue from combining these sectors within a
single action plan.
The figures presented in paragraph 1.4 identify a large market for plant protection
products in the amateur sector. Amateurs frequently apply a different set of
economics to their hobby than to a business and are prepared to pay higher prices.
This may provide a substantial opportunity for the wider usage of biologically-based
plant protection products. Provided products are safe, amateurs could determine the
efficiency of such products for themselves if the regulatory process so allowed
Q.4 Other measures that could be introduced
We do not have any specific comments on this question, but would not in general
favour current Voluntary Initiative measures being put on a statutory basis at least
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until the VI has been in operation for a longer period. We agree with the
recommendation of the House of Commons Environment, Food and Rural Affairs
Committee that a proper assessment of the environmental benefits of the VI be
undertaken in 2006.
Rural development policy is a distinct policy arena, but account should be taken of the
potential contribution of micro scale or ‘cottage’ production of biopesticides.
Q.5 Targets and indicators
The aims set out in Part 2 of the document are very clear and are to be commended.
However, far too many targets and indicators are then set out in Part 3. A more
parsimonious and consolidated list of targets and indicators is required which would
allow real progress to be measured without delivery become bogged down in the
achievement of a myriad of indicators. Many of these might turn to be contradictory
or incompatible with each other.
Indeed, the specification of targets and indicators needs to be placed within the
context of a growing realisation that their over use in public policy generally may be
counter productive and actually frustrate the achievement of desired outcomes.
Targets can even have perverse effects. For example, targets for processing patients
in the accident and emergency areas of hospitals within a given time period have led
to patients being detained longer in ambulances before being admitted which reduces
the availability of ambulances. Targets for train arrival times have led to journey
times being extended.
It should not be supposed that these difficulties have no relevance to appropriate
indicators and targets in relation to pesticides, quite apart from the special problems
that arise from the fact that biodiversity targets move slowly. Consideration should
be given to taking advice from other areas of public policy and from public policy
specialists on target specification.
Q 6: Rationale behind the strategy
The Strategy contains a large amount of information and addresses many of the
complex issues affecting the sustainable use of plant protection products. The logical
basis for the Strategy is sound but it would be strengthened by giving more
consideration to how ‘sustainability’ is defined and used. This will make it easier to
firm up the desired outcomes and measures for the Action Plans. It is interesting that
the report does not explicitly refer to the Brundtland Commission definition of
sustainability, which is used elsewhere by Defra. Referring to this definition would be
a way of linking to other policies on sustainability within the UK government.
The Strategy defines the sustainable use of plant protection products as ‘minimising
the hazards and risks to the environment from the use of plant protection products
without compromising necessary crop protection’. This definition focuses attention
on the effects of plant protection products on the environment and their impact on
natural resources. The Strategy is primarily concerned with reducing the adverse
effects of pesticides on the environment (although it is worth noting that pesticides
can also have positive effects on the environment, such as controlling non-indigenous
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invasive species). However, as mentioned previously, the Strategy is also concerned
with the need to sustain plant protection in the future in the face of threats caused by
product withdrawals and the development of resistance to pesticides in pest
populations. The Strategy would be strengthened if these two interacting issues were
identified at the outset of the report. This would give greater focus to the role of IPM
in minimising the adverse effects of pesticides on the environment and ensuring
effective plant protection in the future. While conventional chemicals remain an
important component, IPM utilises additional tools such as biological, physical and
cultural controls, host plant resistance, and decision support systems. IPM is essential
if the onset of pesticide resistance is to be delayed. It also leads to reduced pesticide
inputs, lower impact on wildlife, and less chance of pest resurgence and / or
secondary pests developing.
In conclusion, there is a good opportunity to build IPM into the report, which will
contribute to achieving sustainability goals across a range of Action Plans.
David Chandler
Wyn Grant
Justin Greaves
Gillian Prince
Mark Tatchell