Sustainable Use Directive – Environmental NGO Asks
Introduction
This document is authored by a group of environmental NGOs working together to ensure that
crop protection products have minimal impacts on biodiversity in the UK. This document
therefore addresses measures required for the adequate protection of biodiversity and does
not address measures solely required for human health protection, such as advance warning
of spraying.
Outlined within this document are a series of Asks that relate to the Sustainable Use Directive.
This European Directive promotes best practice for the storage, use and disposal of pesticides
in UK. The UK government consulted on its implementation just over a year ago and the
government’s response to this consultation was recently published. This response was very
weak suggesting no, or very small changes to existing pesticide mitigation measures in the UK
despite the number of opportunities provided by the Directive to further reduce pesticide
impacts. The government is required to implement the Directive by 25th November 2011. We
believe that the government is failing to deliver adequately to protect biodiversity from
pesticides impacts and so highlighted here a number of Asks to strengthen implementation of
the Directive to benefit biodiversity.
The NGOs that support this document are: Buglife – The Invertebrate Conservation Trust,
Bumblebee Conservation Trust, CHEM Trust, PAN UK and RSPB.
See the key Asks outlined below on pages 1 and 2, with more detailed background information
on Asks provided on pages 3 to 5.
Phased reduction of most toxic substance (relates to Article 4)
 Process to allow the identification or flagging of most harmful pesticides to biodiversity
 Phase out/suspension plans for pesticides
 A focus on developing alternatives to those pesticides that will be phased out by the
new EU Regulation and those deemed toxic to bees and other pollinators
Awareness raising (relates to Article 7)
 Leaflets which are offered prior to product sale
 Posters near the products and
 Labelling on the product
Water protection (relates to Article 11)
 Targeted voluntary safeguard zones in pesticide vulnerable areas for WFD, EU Habitats
directive catchments and other biodiverse areas, backed by the possibility of regulation
should a voluntary approach prove unsuccessful
 Voluntary safeguard zones should be well supported by advice, training and
assessments
 A ban on blanket spraying on hard surfaces
Page 1 of 5
Integrated pest management (IPM) (relates to Article 14)
 Develop a clear definition of IPM that puts the onus on non-chemical methods and
builds on the principles set out in Annex III to deliver real reductions in pesticide use in
practice
 Development of crop and sector specific IPM protocols
 The development of extension and outreach services to assist farmers in implementing
IPM
 The addition of a new IPM implementation group as a sub-group of the Pesticides
Forum
 Mandatory training in IPM for all sectors
 Funding for research into IPM
Page 2 of 5
More detailed background information on Asks:
Water protection (relates to Article 11)
Our water habitats are fragile and a number of EU Directives are in place to offer them
protection including the Water Framework Directive (WFD) and EU Habitat Directive. Existing
voluntary actions are demonstrably failing to deliver compliance with these EU regulations.
This is exemplified by voluntary initiatives such as catchment sensitive farming, which have
shown that many stakeholders in target areas are just not aware of the necessary voluntary
measures, despite the considerable efforts made to appraise them. Catchments containing
aquatic Special Areas of Conservation (SAC) and SSSIs remain vulnerable to pollution as
compulsory powers to stop or control damaging activities is limited to their boundaries which
often do not include the surrounding catchment and so are vulnerable to pollution from
upstream or beyond their boundaries. For example, protected species such as White-clawed
crayfish are vulnerable to pesticide pollution but the SACs designated to protect them do not
include areas of the catchment where pesticides are used.
Pesticide pollution is also a significant cost-driver for the water industry with some compounds,
such as metaldehyde being effectively untreatable. The WFD requires drinking water sources
to be defined as Protected Areas and sets rigorous conditions to ensure that raw water quality
does not deteriorate to the point where it requires additional treatment.
We believe voluntary safeguard zones should be implemented in pesticide vulnerable
catchments, defined by WFD/EU Habitat Directive requirements, or in catchments where a
specific problem has been identified as causing or threatening a decline in drinking water
quality and/or biodiversity. These voluntary safeguard zones should be well supported with
advice, training and assessments, and they should preferably cover entire catchments to be
effective. The effectiveness of such an approach must be carefully monitored for effectiveness
and the possibility of regulation must be considered if voluntary approaches do not achieve the
results necessary in the timeframe.
In addition, to protect the aquatic environment there should be a ban on blanket spraying on
hard surfaces, as this leads to a high level of run off and regular contamination of water
habitats.
Key Asks:
 Targeted voluntary safeguard zones in pesticide vulnerable areas for WFD, EU
Habitats directive catchments and other biodiverse areas, backed by the possibility of
regulation should a voluntary approach prove unsuccessful
 Voluntary safeguard zones should be well supported by advice, training and
assessments
 A ban on blanket spraying on hard surfaces
Phased reduction of most toxic substance (relates to Article 4)
Reduction targets are an effective way of reducing impacts of the most harmful pesticides that
won’t make it through the next stage of chemical reviews, and/or where there is evidence of
concern their biodiversity impacts. This will allow a gradual phase out and help to instigate
substitution to less harmful control methods/chemicals; or a temporary suspension allowing for
Page 3 of 5
investigations and/or research. These targets should be defined, by chemical type, its usage
and impacts; for example a product that is a high risk to pollinators (nectar/pollen feeding
insects) should have higher reduction or temporary suspension on flowering crops. These
may be chemicals with suggested impacts that weren’t apparent during the approvals process,
but where evidence of impacts have become apparent post the original approval. For
example, in the case of neonicotinoid pesticides, a review of the original approval process has
shown that the original tests were significantly flawed and increasing scientific evidence
suggests the potential for environmental impacts on honey bees and other non-target
invertebrates.
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Process to allow the identification or flagging of most harmful pesticides to biodiversity
Phase out/suspension plans for pesticides
A focus on developing alternatives to those pesticides that will be phased out by the
new EU Regulation and those deemed toxic to bees and other pollinators
Awareness raising (relates to Article 7)
Access to information is essential to allow the public to make more informed decisions about
the pesticides they use.
People need to know about the risks to their health and the risks to wildlife and the
environment. This information provided should cover the potential hazards to people and
wildlife, what the alternatives of using pesticides may be; how products should be stored,
handled and applied, as well as how to dispose of them safely. Information about the
application of products should cover the means of application, including rates and favourable
conditions for application.
To ensure that people receive and absorb this information it should be provided in a number of
different forms including a comprehensive website. In addition to the website, the public
should be targeted at the point of sale through
 Leaflets which are offered prior to the sales transaction,
 Posters near the products and
 Labelling on the product
In its response, the Government states that it will ‘encourage distributors of non-professional
products to provide relevant information at the point of sale.’ We feel that this approach is
insufficient and therefore call on the government to make this provision of information
mandatory, to ensure the public are able to make the best decisions in tackling pest problems.
By helping people in their decision making we can reduce the incidents of harm to people,
wildlife and the environment.
Integrated pest management (IPM) (relates to Article 14)
Integrated Pest Management (IPM) is a system of pest, disease and weed control that only
uses pesticides as a last resort when other measures have failed. Proper uptake of IPM and its
general philosophy could lead to a substantial reduction in pesticide use in all sectors.
Article 14 of the SUD requires that Member States take all necessary measures to promote
low pesticide-input pest management, giving, wherever possible, priority to non-chemical
methods. Furthermore, Member States should ensure that the general principles of IPM as set
out in Annex III of the Directive are implemented by all professional users by 1st January 2014.
Page 4 of 5
However, there is no clear consensus on what actually constitutes IPM; definitions range from
simply following the instructions on the label of a pesticide container to using pesticides only as
an absolute last resort. The principles in Annex III are a good starting point but we believe that
to achieve significant reductions in pesticide use a more progressive definition needs to be
adopted.
Confusion over definitions is not helped by the government insisting in its response to the
public consultation that; “most farmers and growers already have a good overall awareness of
IPM.” This is not the same thing as actually implementing a strict IPM regime. In fact we
believe the government is being very complacent in its assessment that UK arable and
horticulture growers already practice IPM to a standard that would satisfy the requirements of
SUD. IPM is a continuum of improving practice and decreasing reliance on pesticides, by
using more non-chemical methods and developing cropping systems that better prevent pest,
disease and weed incidence and encourage natural cortertntrol processes. The government
response contradicts findings from the RELU research programme, funded by public money
and DEFRA that most British arable farmers use only a limited number of IPM techniques and
are not benefiting from a fully integrated approach.
We are calling on the government to:
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Develop a clear definition of IPM that puts the onus on non-chemical methods and
builds on the principles set out in Annex III to deliver real reductions in pesticide use in
practice
Development of crop and sector specific IPM protocols
The development of extension and outreach services to assist farmers in implementing
IPM
The addition of a new IPM implementation group as a sub-group of the Pesticides
Forum
Mandatory training in IPM for all sectors
Funding for research into IPM
Page 5 of 5