Memorandum submitted by Amenity Forum
(Z26)
We have to point out that PAN-UK, one of our
members is on this occasion unable to support the views expressed
in this document.
EXECUTIVE SUMMARY
The formation of the Amenity Forum is a very
important and much needed development for the Amenity Horticulture
industry and is a result of the Voluntary Initiative (VI). Amenity
Horticulture is a complex sector that embraces local government
departments, government agencies, sport and leisure, landscape,
industrial and utility organisations. The sector requires pesticides
as an integral component of inputs to the services it provides
to industry, sport and the wider public. An important future objective
for the Amenity Forum is to represent this diverse sector as a
consultative body to government departments and others for the
formation of future policies, legislation and guidance.
The sector is not a large user of pesticides
and in most cases they are a small component of the costs involved
in site preparation or maintenance. However, the need to observe
best practice is vital as pesticides application often takes place
in public places. The sector recognises that the use of pesticides
in specific areas can result in residues occurring in water. This
issue has and will receive the close attention of the Amenity
Forum. Communication and execution of "Best Practice"
through integrated management will be encouraged through members.
The membership will be extended to ensure that all groups with
an interest in amenity horticulture are represented. Particular
emphasis will be placed on gaining the full participation of the
relevant local authority departments.
Some government agencies and NGOs will have
observer status.
THE ADOPTION
AND RELEVANCE
OF THE
VOLUNTARY INITIATIVE
TO THE
AMENITY HORTICULTURE
INDUSTRY
1. The Amenity Horticulture Industry
Amenity Horticulture is a diverse and complex
sector. It comprises Local Authorities (who have responsibilities
for parks, footpaths, schools and various leisure sites); highways;
rail networks; airports; golf, soccer, cricket and other sport
sites; industrial and retail sites; gas, oil and electricity utilities;
amenity woodland; recreational and ornamental water; canals, reservoirs
and rivers; water treatment and sewerage sites; landscape construction;
Government sites, eg MOD. To provide the required inputs the amenity
sector is serviced by manufacturers and distributors of chemicals,
equipment suppliers, ground maintenance contractors, landscape
construction and maintenance companies, advisors and consultants.
Due to the nature of the work public expenditure, tenders and
contracts are often an important component of the process. Consequently
key personnel groups are the specifiers who prepare tenders and
managers who have responsibility for contract operations and monitoring
of standards. Training, competence standards and qualification
for those involved in contract specifications and supervision
of pesticides application are provided by BASIS (Registration),
NPTC (National Proficiency Tests Council) and Lantra (Sector Skills
Council for the Environmental and Land-Based Sector). The sector
is adequately regulated and non-governmental organisations play
an important role.
2. Why are pesticides required by Amenity
horticulture?
The industries involved often have wide responsibilities
and have a challenge to achieve "best value" whilst
following "best practice". Safety is a prime objective,
eg local authorities have to maintain paths weed free to maintain
visibility on the highway (weed growth on verges and bends etc),
avoid trip points or on highways to ensure that warning or direction
signs are clearly visible. Unwanted weed growth may encourage
the accumulation of litter, harbour vermin and on certain industrial
sites create a fire hazard. Often the use of pesticides offers
efficiency as a result of managing larger areas per day, longer
lasting control and lower maintenance. There are legal requirements
on individual organisations and local government to control certain
weeds under The Noxious Weeds Act (1959), The Wildlife and Countryside
Act (1981) and the Ragwort Control Act 2003. The aesthetic value
of landscape has to be developed and maintained by weed and other
pest management often by the use of integrated cultural and chemical
techniques. Achieving a high standard of safety, efficient working
conditions and maintaining a socially acceptable landscape can
be economically attained by good and careful use of pesticides
as part of the management process.
3. How much pesticide is used in amenity
horticulture?
The UK amenity pesticide sector is small both
in terms of value and the volume of pesticide used. The Crop Protection
Association's most recent statistics show that at manufacturing
selling price the sector was worth an estimated 4% of the professional
pesticide market.
As a guide the cost of pesticide contributes
2-5% of a contract with end-users such as local authorities and
industrial sites.
4. What are the potential environmental problems?
The use of pesticides (mainly herbicides) in
some amenity situations, eg hard surfaces can result in residues
in surface and groundwater. These can be removed before entering
drinking water supplies by the treatment processes used by water
companies. However, the equipment is expensive to build and costly
to run. Clearly the important step is to ensure that such residues
are minimised at the point of use by observing best practice in
the choice of product, application systems and timing of treatments.
This calls for professional advice and highly trained operators
in the field in addition to proper storage and disposal of waste.
Control of weeds, pests and disease of plants
through chemical, cultural or integrated management may have some
impact on plants in the area and thus wildlife habitats. In amenity
horticulture the management may require total control, eg of all
weeds in an oil refinery or selective control, eg weeds in ornamentals
or a fungal disease in turf. The risks to wildlife are minimised
through the Government's Approval process and the conditions of
use on the label. The important point is to keep all treatments
within the target area. It should be recorded that in some cases
the management of vegetation is necessary to improve biodiversity,
eg where invasive weeds have become established.
5. How is the Voluntary Initiative providing
the solution?
Consideration of the industry requirements and
where the environmental problems may occur shows that the objective
must be correct advice for users to arrive at the right product
being applied by skilled operators in a well-planned integrated
programme. At an amenity horticulture workshop held in the early
stages of the VI key critical factors were identified. The priority
areas of use were agreed and the basis for an action plan was
determined.
The priority areas of use with their potential
environmental impact were:
— Local authority usage on hard surfaces
to maintain highways and footpaths.
— Rail use on hard surfaces; water
contamination.
— Industrial use on hard surfaces;
water contamination.
— Private amenity grass areas (eg sport,
landscape); biodiversity.
— Local authority usage on amenity
grass areas; biodiversity.
— Industrial sites with permeable surfaces;
water contamination.
— Local authority use on hard surfaces;
biodiversity.
— Rail usage on hard surfaces; biodiversity.
One clear strategic conclusion was that co-operation
across the sector was essential to achieve the desired protection
of the environment. A three-part action plan was prepared to gather
relevant information, manage training and develop communication
and stewardship. In the course of planning the formation of an
Amenity Forum evolved to meet the strategic co-operation requirement.
Members of the Amenity Forum support the VI and consider this
organisation with its Terms of Reference to be more focussed on
the issue and more likely to achieve success in comparison to
the imposition of a tax.
6. Where has the Amenity Forum supported
the VI?
Bearing in mind that the Amenity Forum has only
been established since February 2003 it has already made several
contributions to the objectives of the VI.
— Communicated to all member organisations
the process for removing obsolete pesticide.
— Supported the VI action to have the
non-statutory "Orange Code" incorporated into the new
planned Approved Code of Practice.
— Members have been active in the drafting
and provided contributions to the consultation.
— The Amenity Forum has spent considerable
time reviewing and commenting on the plans prepared by BASIS and
NPTC in their respective roles to set standards and qualifications
for advisors and operators.
— Members have commented to Defra on
their review of diffuse pollution from non-agricultural sources.
— The Chairman has reported to the
Pesticide Forum and there is a proposal that the Amenity Forum
should represent the Amenity Horticulture sector on this important
Government Forum.
The existence of the Amenity Forum has demonstrated
the ability to communicate a number of important topics to the
wider amenity groups eg pesticide residues in water, CHIP regulations,
the role and importance of the National Sprayer Testing Scheme
(NSTS).
As an independent organisation the Amenity Forum
could have a future role in reviewing all methods of weed and
pest management in this important sector. Integrated management
will be a key objective.
The long term plan is to develop the "consultative"
activity for amenity horticulture with regulators and policy makers.
At the same time communication across the whole sector and the
wider public will be a key objective. The Amenity Forum will encourage
wider membership to ensure that the diverse amenity horticulture
sector is covered. There will be particular emphasis on the participation
of the relevant local authority departments in view of their role
as major customers and their wide responsibilities within the
community. The Chairman is a member of the NRoSO Advisory Board
and has accepted an invitation to join the Board of BASIS. There
are strong and important links between the Amenity Forum and the
Sector Skills Council, Lantra. At the recent SALTEX exhibition,
a major event for the amenity industry the VI and its objectives
were communicated at a presentation by the Amenity Forum. Contacts
have been established with a number of groups to cascade relevant
information, eg WRAP and CABE Space.
8 October 2004
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