Supplementary Memorandum by the Ministry
of Agriculture, Fisheries and Food
REPONSES TO FURTHER WRITTEN QUESTIONS FROM THE COMMITTEE
1. What other engagement prevented the Green Minister
from attending the Green Ministers Committee before Christmas?
Mr Rooker was regrettably unable to attend the
Green Ministers meeting on 18 December as he was required for
urgent meetings in MAFF. Ministers were at the point of finalising
the statement on support for the beef industry and it had been
their hope and intention to be able to make a statement on 18
December. In the event the statement was on Monday 22 December.
On 18 December Mr Rooker also had a longstanding engagement to
visit the technical experts at Marks and Spencer to discuss the
issue of salmonella in the poultry flock and solutions for its
reduction.
2. Whether MAFF will publish the findings of its
Comprehensive Spending review.
The Government will publish the facts, and the
analysis of the facts, which are relevant and important in framing
policy proposals and decisions resulting from the Comprehensive
Spending Review. Publication is likely to take several forms:
the Treasury intends to produce a central document to accompany
the announcement of the results of the Review; departments, including
MAFF, will produce such detailed documents as are appropriate
at that time or subsequently; and in some cases, departments may
need to issue White Papers on particular policies. The results
of the Review are expected to be announced within the next few
months. Any request for unpublished CSR material, once the results
of the Review have been announced, will be considered on its merits,
both on the basis of the Code of Practice on Access to Government
Information and taking into account the Government's stance on
openness.
3. What instructions or training has there been
for staff on environmental appraisal other than initial instructions
accompanying the distribution of the DoE guidance "Policy
Appraisal and the Environment (1991)".
Since the publication of Policy Appraisal
and the Environment in 1991, further guidance has been provided
by the later DoE booklet Policy Appraisal in Government Departments
and by Cabinet Office guidance on regulatory appraisal.
Multiple copies of the Government's new Policy
Guidance on Policy Appraisal and the Environment issued by
the DETR were not available to us until 27 April. As soon as they
arrived, copies were widely disseminated within MAFF, its Agencies
and NDPBs, with an accompanying note drawing attention to its
importance. As noted in the response to question 22 in the original
Memorandum. MAFF is preparing new instructions and procedures
to ensure that staff are following best practice.
It is expected that Green Ministers will be
considering further steps to encourage Departments to put the
guidance into effect. MAFF is also contributing to the DETR work
on further technical guidance for specialists.
In conducting environmental appraisals, MAFF
staff are able to call on the advice and expertise offered by
specialist colleagues including economists and the staff of the
Farming and Rural Conservation Agency. Officials also liaise with
colleagues in DETR and other Departments as appropriate.
Additional training is being designed for MAFF
officials to develop a greater understanding of the environmental
implications of policy making, including environmental appraisal.
The induction training for new entrants is also being redesigned
to include appropriate material.
4. An example of an environmental appraisal.
Environmental appraisals vary in size and complexity
according to the issue being appraised.
We are providing the enclosed copies of two
documents arising out of the Environmentally Sensitive Area Scheme
as examples of the type of appraisal carried out on MAFF's environmental
policies. This Scheme, which offers incentive payments for farmers
to carry out environmental protection and enhancement work in
designated areas of England, is reviewed on a 5-year rolling timescale.
For each review, a detailed report on monitoring work (such as
measurement of landscape components and grassland species composition)
is published at the start of the review. This provides the evidence
against which the success of each ESA can be judged, and both
statutory agencies and local interests (including farmers, local
authorities and conservation organisations) are invited to put
forward comments on the future of the scheme.
An economic evaluation is also produced to check
that the scheme is delivering additionality in terms of altered
farmer behaviour. The internal evaluation (or re-appraisal) process
leads to the production of a consultation document, setting out
the rationale for the scheme, including economic pressures on
farmers. The final stage in the cycle is to confirm (or otherwise)
the proposed changes in the light of comments from consultees
before the changes are finally submitted to the European Commission
for approval.
Also enclosed are copies of two EU Commission
Directives amending the Pesticides Authorisation Directive (91/414/EEC)
laying down data requirements in relation to the two key environmental
issues (Fate and Behaviour in the Environment and Ecotoxicology)
which show the breadth of information required for a pesticide
approval. A single copy of the bulky evaluation for the pesticide
Imidacloprid has been provided, for information, to the Clerk
of the Committee to illustrate the testing undertaken and the
results generated and their interpretation. Chapters 6 (Fate and
Behaviour) and 12 (Ecotoxicology) are the relevant sections.[2]
Effective environmental appraisal requires a
sound basis in science. The MAFF research and development programme
seeks to enhance understanding of the environmental effects of
farming systems. The results generated through the R&D programme
underpin the advice provided to farmers, notably in the Codes
of Good Agricultural Practice, on such issues as the targeting
of pesticide and fertiliser inputs in space and time, the management
of cropping systems and the development of new crop varieties
with, for example, improved disease resistance. R&D results
are also used to support policy appraisal, development and evaluation.
5. A further explanation of when the presumption
in favour of publishing an environmental appraisal applies: the
reason for it not applying in other circumstances; and whether
this approach has been discussed in the Green Ministers' Committee.
The presumption is that environmental appraisals
will be published in line with current and future legislation
on freedom of information. Detailed arrangements in Departments
are likely to be discussed by Green Ministers in due course.
6. Whether there has been a review of the authorisation
of lindane.
By way of background, it may help the Committee
to know that approval of any pesticide requires the consent of
Ministers in five Government Departments. Before any new pesticide
is first approved, it is subject to rigorous evaluation to ensure
that, when used properly, it presents no unacceptable risks to
people or to the environment. Uncertainties are allowed for by
the observance of a precautionary approach, including the use
of conservative assumptions and substantial safety factors.
Original approvals are reconsidered periodically
for two reasons. First, regulatory science is a continually developing
field and the review process ensures that the supporting data
continues to meet modern standards. Second, new information may
come to light. The regulatory authorities are alert to this possibility.
Monitoring schemes are in place to look out for incidents involving
people and wildlife and to monitor residue levels in food. Companies
are required to notify any adverse data which they generate or
which comes to their attention. And the regulatory authorities
are always prepared to consider information from other sources.
In evaluating information in a review, the same
standards of scientific evaluation are followed as for a new evaluation.
The same substantial and precautionary safety factors are also
used in decision-making. If concerns are identified, a pesticide
approval may be withdrawn at any time. The Government would not
hesitate to act if a real risk to human health or the environment
was identified.
Lindane is approved for use in 30 countries
including the UK, where it has been used widely as an agricultural
pesticide for many years. In 1996, the independent Advisory Committee
on Pesticides (ACP) examined a very substantial body of evidence
on the toxicology of lindane in the course of a review of its
agricultural uses; the Committee concluded that approvals should
continue as there was no evidence of an unacceptable risk to human
health. The ACP also reviewed lindane's non-agricultural uses
in 1992 when the same conclusions were reached. Evaluation documents
for lindane, as for all pesticides reviewed by the ACP, are published
and are available from the Pesticides Safety Directorate in York.
There is a very substantial body of evidence
indicating that lindane presents no unacceptable risks when used
in accordance with statutory conditions of use. There is also
no epidemiological evidence suggesting an increased risk of breast
cancer, even amongst those who work with the compound and, therefore,
are potentially exposed to much higher levels than experienced
by consumers generally. The Department of Health's independent
Committee on Carcinogenicity of Chemicals in Food. Consumer Products
and the Environment reviewed the available data on breast cancer
in women and levels of lindane in serum and breast fat tissue
at its meeting on 16 March 1995. The Committee concluded that
there was no clear evidence of an association between serum and
fat levels of lindane and breast cancer at the present time, and
recommended that the matter be kept under review.
Whilst the balance of scientific advice is that
insufficient evidence has been presented to justify withdrawal
of lindane, the regulatory authorities are always ready to consider
new findings. Lindane is currently the subject of a review under
EC pesticides legislation and the UK Government has shared its
findings and conclusions with the Austrian authorities who are
responsible for carrying out the first assessment for the Community.
7. Whether mahogany was used in the refurbishment
of Nobel House and if so whether alternatives were considered
and what steps were taken to check the certificate of origin and
sustainability of forest management.
The specification for the fit out works at Nobel
House required that the timber used should match that which already
existed in the rooms concerned, primarily oak and walnut. A little
mahogany was used in furniture and we were assured by the suppliers
that this came from renewable resources.
8. How big the MAFF vehicle fleet is and the extent
to which it is, or could be converted to use liquid petroleum
gas.
There are approximately 300 official vehicles.
The majority run on diesel and the Ministry is not planning to
convert them to liquefied petroleum gas because of the cost involved
and the practicalities of refuelling. Many travelling staff are
based in country areas where the availability of LPG filling stations
is scarce.
9. Whether there has been any review of the work
of the Sea Fisheries Committees, their status and funding, in
particular whether a statutory basis for them has been considered.
The Sea Fisheries Committees have a valuable
role in inshore fisheries management. Their responsibilities are
kept under review and the Association of Sea Fisheries Committees
meets the Fisheries Minister each year. Their funding is a matter
for local agreement between the Committees and their constituent
local authorities.
The current statutory basis of the Sea Fisheries
Committees is the Sea Fisheries Regulation Act 1966.
2 Not printed. Back
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