Supplementary memorandum submitted by
the British Agrochemicals Association Ltd (BAA)
1. HOW CAN
THE BAA AND
NFU RECONCILE THE
CONCLUSIONS OF
THE MORLEY
REPORT IN
RELATION TO
COST-EFFECTIVE
SAVINGS WITH
THE VIEWPOINT
PUT FORWARD
DURING THE
HEARING?
The BAA and NFU asserted that there was limited
scope to make additional savings in the use of pesticides compared
to the recent evolutionary declines. This may have caused some
confusion for the Committee because the questions asked were assumed
to relate to immediate reductions in pesticide use. In our evidence,
we pointed out that over the decade 1986-96 there was a reduction
in the amounts of pesticide used of approximately 5,100 tonnes
or 19 per cent. This trend is expected to continue and reflects
advances in chemistry, application technology and the greater
understanding of pest and disease problems. The introduction of
Integrated Crop Management systems has also assisted the reduction
of pesticide use. However ICM is now used on the majority of farms
to a greater or lesser degree and there may be limited scope for
its expansion.
The BAA and NFU jointly commissioned the study
by Morley Agricultural Consultants Ltd to analyse the "Private
Costs and Benefits of Pesticide Minimisation" by RPA Ltd
and Entec Ltd. This was a report produced for the DETR in March
1997.
In the "Morley" report the authors
conclude that future savings of £100.25 million are available
to farmers with the full implementation of integrated farming
systems and new application technology. These are broadly in line
with current industry estimates of a continuing 20 per cent market
decline over the next decade. The value of the UK pesticide market
in 1998 was £480.3 million.
These figures illustrate a general trend upon
the uptake by farmers of improved technology and best practice
techniques for pesticide minimisation. However, it will become
increasingly more difficult to achieve successive reductions in
the amounts of active ingredients used unless technology and the
development of new molecules continue. They only occur as a result
of a dynamic agrochemical industry being able to invest in continuing
programmes of scientific innovation.
It remains our view that beyond these there
is little scope for "additional" pesticide reductions.
We cannot over-stress that pesticides are an essential part of
the production process if food quantity and quality is to be maintained.
Current economic drivers mean that farmers already take significant
steps to minimise pesticide use consistent with adequate crop
protection.
2. WOULD THE
NFU AND BAA ACCEPT
THAT SUCH
(ENVIRONMENTAL) INDICATORS
AS DO
EXIST ALL
APPEAR TO
BE MOVING
IN THE
"WRONG" DIRECTION?
It is unfortunate that the Government appear
to be basing their consideration of a pesticide tax on the mistaken
assumptions that there is an overuse of pesticides in UK agriculture
and that all pesticides are harmful to the environment. They have
stated that research exists to support these claims but most of
this appears to be based on comments made within the ECOTEC study.
It remains clear that a simple measure of the weight of pesticide
applied to agricultural land gives only a limited picture of the
actual effects of pesticide use in farming.
The Government has accepted wild bird species
as good indicators of the broad state of wildlife and the countryside,
because birds are wide ranging in habitat distribution and tend
to be at or near the top of the food chain. It is worth emphasising
that they are indicators of the broad state of the countryside.
Being mobile and near to the top of the food chain means that
changes in their population sizes and distribution are a result
of many complex factors and of interactions of these factors.
It is clear that some bird populations have been affected by the
major changes in agricultural production such as the increased
dependence on winter-sown crops.
It is likely that there will be problems in
the use of relatively few "indicator" species as a shorthand
method of assessing environmental impact. Of the 20 "indicator"
bird species, population changes attributable to pesticide use
have only been claimed for two of the species. Other farmland
species have increased or remained stable and it appears erroneous
to make broad judgements based on supposition. The problem here
is the separation of cause and effect that may be difficult without
further detailed study. Observation alone cannot provide all the
answers.
In any proper consideration of biodiversity
it would be appropriate to consider a range of species or genera
at different levels in the food chain. Independent studies conducted
by the Game Conservancy Trust and ADAS Ltd have used invertebrates
as indicators of environmental impacts. Predatory invertebrates
such as carabid and staphylinid beetles and spiders are indictors
of direct effects of pesticides on their own populations as well
as indirect effects resulting from impacts on their food species
or habitats. The SCARAB and TALISMAN studies have indicated the
massive range in numbers and population mixes from field to field
that result from factors such as climate, microclimate, soil type
and geographical aspect. The studies also show that invertebrate
populations recover from most annual crop cycles or pesticide
application programmes within a relatively short time.
In summary, it is clear that the situation is
a very complex one. A great deal of emphasis has been placed on
the "headline" effects on a limited number of selected
species . On this basis it would be wrong to conclude that all
such indicators are moving in the "wrong" direction.
The British Agrochemicals Association supports the use of indicators
necessary for sustainable development. However, much detailed
research work will be required to identify a range of appropriate
indicator species to provide a fuller picture of agricultural
impacts upon biodiversity.
3. DO THE
BAA AND NFU CONSIDER
THAT THE
INDIRECT EFFECTS
OF PESTICIDE
USE ARE
SUFFICIENTLY UNDERSTOOD
AT PRESENT,
PARTICULARLY IN
THE LIGHT
OF THE
EVIDENCE FROM
SUCH BIODIVERSITY
INDICATORS AS
DO EXIST,
TO REJECT
THE "PRECAUTIONARY
PRINCIPLE" AND
CONCLUDE THAT
PESTICIDE USE
CARRIES NO
ENVIRONMENTAL RISK?
IF THIS
IS THE
CASE, WHY
ARE THEY
IN FAVOUR
OF FURTHER
REDUCTIONS BY
FARMERS IN
THE USE
OF PESTICIDES?
The direct effects of pesticides are examined
in the complex requirements of the present regulatory process.
The eco-toxicological characteristics of pesticides are evaluated
as part of the data package that is required from the pesticide
manufacturers by the Pesticide Safety Directorate. The "precautionary
principle" is well applied to these "direct" ecological
efffects. However, given the rigorous nature of these present
regulatory evaluations we do not believe that the "polluter
pays" principle should be applied to pesticide use.
Indirect effects relating to pesticide use tend
to occur as complexes and it is more difficult to separate (and
study) them. When indirect effects are understood they tend to
be incorporated in to the data requirement of the regulatory authority.
The data requirements of the PSD may be a matter for further investigation
in future committee enquiries.
Pesticides have been used in agricultural production
for more that 60 years. In this time relatively few "indirect"
adverse effects have been identified. If the precautionary principle
were applied too liberally there would be major adverse impacts
on crop production without any tangible environmental gains. This
has much to do with the practical difference between risk and
hazard.
The agrochemical industry accepts that further
studies on suspected indirect effects are probably required. However,
the complex nature of this issue means that it may be difficult
to obtain reliable and constructive information without a huge
investment of resources. Drawing meaningful conclusions with broad
application to agricultural production may also prove difficult.
Agrochemical manufacturers constantly seek new
molecules with specific modes of action that may be used at relatively
low rates against well-defined target species. Farmers are especially
interested in using lower rates of pesticide in order to save
on costs. However, they are also required to produce adequate
supplies of food grown to a consistently high level of quality.
The newer technologies of improved spray decision making systems,
precision farming techniques and the use of appropriate genetically
modified crops will all assist the targeted reductions on pesticide
use in the future.
| 
