Consultation on the sustainable use of plant protection products – a draft national strategy

http://www.pesticides.gov.uk/environment.asp

Response from Organic Centre Wales
prepared by Tony Little

General

We would like to make the following general comments regarding the approach to use of pesticides we advocate, and the priority areas for the draft strategy. While these comments are made with organic systems in mind, they have a great deal of relevance for non-organic growers.  

Our response focuses on the environmental aspects of pesticide use. We fully appreciate the importance of the implications for human health, but feel that others are better placed to comment on this aspect. 

We consider the following to be guiding principles:

• Pesticides should be used only as a last resort, when other methods have failed manage pests to acceptable levels. This is a principle of organic systems, is consistent with, but goes further than the minimisation policy referred to in the consultation documents and implies an end to prophylactic treatments.
• Where pesticide use is justified, the environmental impact must be minimised. There are several aspects to this including:

o        The physio-chemical properties should be such that they pose minimal risks to the environment (in both terrestrial and aquatic habitats).

o        Active ingredients should be intrinsically highly specific (i.e. a minimal impact on non target species), and non persistent

o        The timing, placement and application methods should aim to reduce risks to non target species. For example, applications could be timed to avoid susceptible life stages of key beneficial and non-target insects, and selective baits, which can limit expose to non-target species should be used when possible.

·         The use of alternatives to pesticides, including and especially those based on biological systems, should be used when possible and appropriate. 

In the wider context:

• The government should consider a more holistic approach to pest management issues. A ‘pest management’ directorate, with a wider remit than simply regulating pesticides, would be better placed to minimise pesticide usage by promoting a wider, integrated approach to pest management.

·         All action plans need to be supported by a knowledge transfer/ training programme. Effective and environmentally sensitive use of pesticides requires a great deal of knowledge and management time – without practical help for farmers and growers, the action plans are unlikely to make a significant impact.

 Question 1: Can you think of any new or existing targets or indicators (either environmental or activity based) that you would like to see included?

The document implies monitoring of terrestrial population indicators is limited to vertebrate species. We consider that invertebrate and plant species should also be monitored because: 

• The vast majority of applications are targeted against either invertebrates (insects and molluscs) or plants. It is therefore likely that these species are directly affected by pesticide usage and therefore need to be monitored.
• They fulfil a wide range of absolutely crucial functions, which collectively help to regulate, support and sustain ecosystems in ways we only partly understand.
• There are big implications for biodiversity. In the case of invertebrates, insects alone account for quarter of the known species in the animal kingdom, and even this is likely to be an underestimate considering many species are yet to be discovered and described.

Question 3: We would welcome any comments on the lists of measures in the table below. Are they accurately described particularly in respect of implications for plant protection product users? Are there any important measures missing.

The table, indeed the document as a whole, is written very much from an English point of view. PSD is a UK wide organisation, and the list needs to take account activity in the devolved nations. In the case of Wales it should include reference to Agri-environment Schemes Tir Gofal and Tir Cynnal. Similarly, the section on organic farming reflects situation in England but does not include developments in the other nations. The Scots may feel similarly aggrieved! The Organic Farming Scheme is also an agri-environment scheme and should be listed as such in the table

Question 4: Please let us know what you make of any or all of our outline action plans the scope sufficiently comprehensive at this point in time? Would you like to suggest any additional issues, outcomes or measures, or do you see environmental or economic disadvantages from those proposed.

Biodiversity action plan

• The species monitored to assess non- target impacts should be expanded as per our response to Question 1.
• The use of highly specific, non-persistent active ingredients should be encouraged as described in ‘general’ section of our response. A pesticides tax, as proposed in 4.13, could help in this regard, rewarding the use of less damaging products, and penalising the use of more damaging active ingredients.
• The use of alternatives as described below should be encouraged where possible and appropriate.
• The timing, placement and application method to minimise side effects as per the general section of our response, should be encouraged.

Plant protection Products Availability Action Plan

Our response to this action plan draws heavily on work commissioned by the Welsh Assembly Government and carried out by Organic Centre Wales: ‘UK and EU policy for approval of pesticides suitable for organic systems: Implications for Wales’. For a copy of the report visit http://www.organic.aber.ac.uk/library/pesticideregulation.pdf

A National Pesticide Policy should be developed so that regulatory and commercial barriers impeding the development of alternatives to pesticides are minimised. This should include: 

·         Using agri-environment policy to promote biological control techniques (use of predators and pathogens to manage pest and diseases) much more actively. 

·         Identifying clear criteria for ‘environmentally acceptable’ pesticides, and promote their use and availability. They could then be used for several purposes, for example, determining the level of any proposed pesticide tax. They would also help organic regulators to decide which substances are permitted in organic systems, and would also help with the identification and development of new useful substances with minimal environmental impact.  

·        Implementation of the 4^th Stage Review in a way that may remove obstacles to the use of for ‘environmentally acceptable’ pesticides. For details see visit http://www.organic.aber.ac.uk/library/pesticideregulation.pdf 

·        A review of the regulatory requirements with regard to efficacy and label claims to take account of the fact that products based on biological systems are much more variable with regard to efficacy, and are most effective as part of an integrated programme.