Government response
The Voluntary Initiative
Recommendations 1-8
1. The credibility of the Voluntary Initiative
is critically dependent on the targets that are set for it. Setting
strong and robust targets - and then meeting those goals - is
the best way of deflecting criticism of the VI and averting the
possibility of alternative measures, such as a pesticides tax.
(Paragraph 41)
The Government agrees that to judge the Voluntary
Initiative a success, the targets specified must be challenging
and rigorous and the Initiative must be clearly delivering good
environmental and biodiversity outcomes. As such the more the
Voluntary Initiative's targets can be directly related to its
environmental impact the better its success in that respect can
be judged.
But the difficulty in setting any environmental,
especially biodiversity, targets also needs to be recognised.
Any indicator for biodiversity is likely to move only slowly
and is likely to be in response to a wide range of drivers - not
just those measures introduced by the Initiative itself. To this
end the Initiative's signatories have drawn up and refined a long
list of targets and indicators covering both the roll-out of key
measures and environmental outcomes.
The Government considers progress on the Voluntary
Initiative, including how it is meeting its targets, twice a year
in the run up to the Budget and the Pre-Budget report. Since
its introduction in April 2001 the Voluntary Initiative has, through
the active participation of all its stakeholders, shown good progress
against objectives, surpassing many of the initial key targets.
2. The VI's current targets for the area of
land under Crop Protection Management Plans and for water quality
are insufficiently challenging, and should have been strengthened
earlier. We welcome the VI steering group's offer to strengthen
the target for water quality, but feel the conditional nature
of the offer undermines its credibility. We recommend that the
target for CPMPs be similarly strengthened to reflect the inclusion
of the plans in the entry-level stewardship scheme. The VI steering
group should also be able to show evidence that the CPMPs are
leading to real improvements in agricultural practice, rather
than just being a form-filling exercise. (Paragraph 42)
3. In relation to farmers seeking to improve
their environmental practice, as indicated on their CPMPs, the
Government should have regard to Professor Dent's suggestion that
agri-environment money could be used to promote such improvement.
(Paragraph 43)
Since 2001 Defra ministers and officials have kept
up the pressure on the Voluntary Initiative's signatories to devise
and commit to convincing measures of environmental outcomes with
particular reference to levels of pesticides in water and effects
on biodiversity.
Overall the Government believes that the Voluntary
Initiative has made progress in changing farmer behaviour and
has welcomed its latest proposals for strengthening its environmental
targets. But the Government sees these latest proposals as only
one step in a process of continuous improvement which, provided
it continues to be developed, should provide Government with much
of the information it needs to assess the success of the Initiative.
The Government has welcomed the Initiative's confirmation
of the river catchment target reduction of 50% from 2001 to 2006
together with a new target to keep individual pesticide peaks
below 0.5ppb from autumn 2005. The Initiative's intention of
recruiting new pilot catchments to develop and test the experiences
gained so far to see whether these can deliver similar improvements
but in a faster timescale and at a lower cost is also welcomed.
However the Government also shares the Committee's concerns over
the conditional nature of the proposal and has made it clear that
it expects the proposals to be taken forward unconditionally.
On biodiversity the Government was pleased to see
that the Steering Group has agreed that yellow hammer population
trends will be added to the current list of species indicators
for the Voluntary Initiative and that the Group is keen to assist
with the development of existing, or introduction of new, indicators
in respect of invertebrates, arable weeds, terrestrial risk, cereal
field margins and compensatory measures, and possible additional
monitoring schemes on indicator farms.
Much of the work undertaken as part of the Initiative,
such as Crop Protection Management Plans, already goes towards
attracting points awarded under the Environmental Stewardship
schemes that qualify farmers for payments for introducing environmental
benefits at levels above those of Good Farming Practice and cross-compliance
conditions. As such the Government believes that some financial
incentive is already there to encourage farmers to adopt such
practice and that it would be inappropriate to go further than
this.
4. Since the objective of the VI is to minimise
the impact of pesticides on the environment, the ability to measure
achievements in this respect is fundamental. Data problems and
delays to projects have meant that we have little irrefutable
evidence of the environmental benefits of the VI, just one year
prior to the completion of the programme. We recommend that Defra,
the Environment Agency and the VI steering group move rapidly
to put in place the necessary arrangements to allow for a proper
assessment of environmental benefits of the VI to be undertaken
in 2006. We are concerned that Defra is not only unable to provide
assurances on the environmental benefits of the VI at this time,
but appears to have little confidence in the usefulness of the
research it commissioned specifically to provide tools for this
assessment. (Paragraph 48)
The Voluntary Initiative has set itself a number
of targets and indicators against which its progress will ultimately
be measured. Although the Government agrees that the Voluntary
Initiative must be seen to be clearly delivering good environmental
and biodiversity outcomes to be considered a success it also acknowledges
the difficulty in setting any environmental, especially biodiversity,
targets.
In recognition of this the Voluntary Initiative's
indicators are a mixture of environmental outcome and activity
measures. Examples of environmental outcomes are those indicators
for the detection of pesticides in water and changes in wildlife
population trends for corn bunting, grey partridge, and yellow
hammer. Examples of indicators for activity measures include
the number of spray operators on the National Register of Sprayer
Operators and the number of sprayers tested under the National
Sprayer Testing Scheme.
In addition to the Initiative's own indicators and
targets Defra awarded a contract to produce an evaluation model
to help provide a framework for evaluating the success of the
Initiative and for comparing it with alternative approaches to
the problem of reducing negative impacts of pesticides on the
environment. The evaluation project was awarded to a team from
Newcastle University. The project has three main components:
- an economic assessment, based on the results
of focus group interviews, of the perceived costs to farmers of
generating particular benefits under the Voluntary Initiative
as against other instruments such as a pesticides tax;
- modelling of levels of pesticides in the environment
in various agricultural practice scenarios; and
- ecological network analysis to look at the effects
of pesticide use and present a new insight into ways to minimise
ecological damage.
The evaluation project has produced some useful results
in its own right but before the tools produced by Newcastle University
can be given practical application it will first be necessary
to have further work done on them to develop them further. This
work will be put into the public domain once it has, in line with
normal Defra procedures, been through a scientific peer review
process. Although the Pesticides Safety Directorate considers
that the Newcastle study would not make a major contribution to
the evaluation of the Voluntary Initiative it does believe that
if it is further developed it could well be useful in considering
possible successor projects.
5. The incorporation of some VI measures into
the requirements of assurance schemes was worthwhile. Nevertheless,
the VI must cover the significant numbers of farmers operating
outside the schemes. Setting challenging targets for levels of
participation by farmers is an important aspect; so too is engagement
with non-farming sectors. However, the VI can never be sufficiently
comprehensive so as to include all pesticide users. Therefore,
we recommend that the Government strengthen enforcement of existing
regulations in the amenity sector and, if this does not succeed
in bringing about the desired improvement in practice, that the
Government then consider introducing further regulatory measures.
(Paragraph 53)
6. Local authorities have a particular responsibility
to ensure that their contracts are carried out only by suitably
trained operators, using equipment that has been properly checked.
The Government should ensure that this responsibility is communicated
clearly to local authorities by central government. Prior to
the introduction of any legislation, the Government should work
with local authorities to agree a code of practice on the use
of pesticides. This code should apply across all types of local
authority. (Paragraph 54)
The Government does not believe that strengthening
enforcement of the existing pesticides regulations in the amenity
sector is warranted at the present time. Firstly, the UK amenity
pesticide sector is small both in terms of value and, more importantly,
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. Also although from time to time there have been allegations
of misuse of pesticides in the amenity sector no hard evidence
that problems have been actually occurring in practice has been
forthcoming.
There is also a common misconception that the use
of pesticides in the amenity sector is relatively unregulated.
However pesticides used in this sector have to undergo the same
rigorous prior approval procedures as those used in agriculture.
Under these the Government must approve pesticides before they
can be sold or used. In considering approval for use of a pesticide
in the amenity sector issues such as toxicity, operator exposure,
pesticide chemistry, environmental fate and behaviour, ecotoxicology
and efficacy are all examined as part of the approval process.
Under this process statutory conditions of use can be applied
to pesticides to ensure they can be used safely with respect to
people, animals and the environment.
However despite this the use of pesticides in the
amenity sector does have the potential to cause environmental
pollution. For example a number of pesticides used solely or
mainly in this sector are often found in water. In recognition
of this the Government believes that it is no longer acceptable
for the amenity use of plant protection products to be scrutinised
less closely than their use in agriculture. Therefore an action
plan for the amenity sector has been included in the draft national
strategy for the sustainable use of plant protection products
which is currently out to public consultation.
Controls on the amenity sector will also be strengthened
by the incorporation of the existing voluntary code for amenity
users into the revised statutory 'Code of Practice for the Safe
Use of Pesticides on Farms and Holdings' - the so called 'Green
Code'. Since the introduction of statutory controls on pesticides,
advice and guidance to farmers and growers on how to meet their
responsibilities under the pesticides and health and safety legislation
has been provided in this statutory Code of Practice. However
a new statutory Code - the 'Code
of Practice for Using Plant Protection Products' is in the process
of being produced which combines a revised 'Green Code' along
with parts of the voluntary code of practice for users of pesticides
in amenity situations and the voluntary code of practice for users
of pesticides in forestry.
This new code is an important development
as it will help all professional users of pesticides, whether
they work in agriculture, horticulture, forestry or the amenity
sector, to understand and operate within the legislation. The
new Code's statutory basis means that it can be used in evidence
if anyone is taken to Court for a breach in pesticide, health
and safety at work or protection of groundwater legislation.
The new code has been approved
by the Health and Safety Commission and will be submitted to Ministers
for their approval to go to publication later this year. The
aim is to have the new code in operation this autumn.
The production of a leaflet giving guidance and advice on best
environmental practice to those using pesticides in the amenity
sector will be published in parallel.
There is also the role of the Voluntary Initiative
for pesticides itself. The Voluntary Initiative's initial programme
of measures was heavily geared towards agriculture - where pesticide
use is greatest - but included a commitment to examine the needs
of the amenity sector. Industry bodies carried out an exercise
to identify areas where amenity use poses a risk to the environment
and an Amenity Stewardship Forum was set up last year to bring
together bodies with an interest in improving practices.
7. It is regrettable that the Government co-operated
so little with the VI at the beginning of the programme. Despite
HM Treasury's initial welcome for the initiative, in 2000, the
evidence we received indicates that the Government, and in particular
Defra, did not engage meaningfully with the VI. Government agreement
on the VI's targets, at that stage, would have assisted the initiative
in planning for the achievement of those targets. We recommend
that Defra continues to foster its newfound partnership with the
VI. To this end, the Government should provide financial support
for the national roll-out of the water catchment projects, and
help to facilitate ongoing professional training, using rural
development funds. (Paragraph 61)
The Government accepts that after perhaps a less
than perfect start great progress has since been made in building
up close and good working relationships with the Voluntary Initiative's
steering group and is keen to see these continue.
The Government does not believe it would be appropriate
to find 'new money' to fund the activities of the Voluntary Initiative.
The initiative was proposed by the farming and agrochemicals
industries in 2000, whilst a possible pesticides tax was being
considered, and was put forward as an alternative means of achieving
the Government's environmental objectives. Through the VI the
onus is on farmers and producers to reduce the environmental impact
of their actions in line with the polluter pays principle. However
that is not to say that existing funds and funding mechanisms
should not be used by the Voluntary Initiative to take forward
some of its measures. For example, a key component of the Voluntary
Initiative is Crop Protection Management Plans (CPMPs). It should
be noted that these are the same plans which farmers can adopt
(as option EM4) under the Entry Level Scheme of Environmental
Stewardship which is an England Rural Development Programme (ERDP)
scheme.
Defra, under the sustainable arable link programme
already jointly funds with industry a pest and pesticides research
programme that covers a number of the areas that the Initiative
is involved with. These include projects dealing with such matters
as alternatives to chemical control, weed management support systems,
and Sustainable Arable Farming For an Improved Environment (the
SAFFIE project), to name a few. The total annual project spend
on these LINK projects for 2004/5 was £9.9 million. Defra
also manages and funds a number of other R&D programmes that
contribute to pesticides minimisation. These include projects
covering horticulture, arable crops and alternatives to pesticides.
The Pesticides Safety Directorate itself spent £1.5 million
of its £5.5 million R&D budget in 2004/5 on projects
covering work on alternatives to pesticides.
As for financial support for the national roll-out
of the water catchment projects, it might be possible that existing
funds allocated to Defra to tackle diffuse water pollution from
agriculture could be used for this purpose. Defra has an allocation
of £10 million in 2006-07 and £15 million in 2007-2008
to spend in England on tackling diffuse water pollution from agriculture
under its catchment-sensitive farming delivery programme. Defra
is currently in the process of considering how these monies might
best be spent, possibly through the establishment of a catchment
support function for each River Basin District, within Natural
England. The Government will therefore invite the Voluntary Initiative
steering group to approach Defra with a view to exploring the
possibility of using some of these funds to support the national
roll-out of the Initiative's water catchment projects.
The Government agrees that it is useful to explore
the use of rural development funds to facilitate ongoing professional
training. To this end officials from the Pesticides Safety Directorate
(PSD) met with members of the NPTC (formerly the National Proficiency
Test Council) in August 2004 to discuss the possibility of using
Vocational Training Scheme funds to support the National Register
of Sprayer Operators. The register is one of the key components
of the Voluntary Initiative for pesticides and provides a continuous
professional development scheme to improve sprayer operator training
and certification.
At the August 2004 meeting representatives from the
NPTC discussed with PSD officials its proposal for 'recognised'
training that it hoped would receive funding from the Vocational
Training Scheme. PSD discussed the NPTC's proposals with them
and provided them with scheme literature, copies of the relevant
application forms, and a list of Defra contacts. The competitive
nature of the scheme was explained to the NPTC and it was emphasised
that although PSD would assist and support the NPTC in their application
that would not in any way guarantee that their application would
be successful: it was stressed that the NPTC would need to put
forward a thorough and robust application that met the scheme's
criteria. No further approach to PSD has been made by the NPTC
since the meeting but the Directorate's offer of assistance remains
open to them.
8. It is crucial that the benefits of the
VI are not lost after April 2006. The initiative should continue,
at least until the Government has developed and fully implemented
a national pesticides strategy. Even then, we believe that there
will be a continuing need for the establishment of a centre of
best practice for the use of pesticides; the experience acquired
through operating the initiative's programme leaves the VI steering
group well placed to fulfil this requirement. As more of the
VI's measures are encompassed by other schemes - such as food
assurance and environmental stewardship - we consider that the
initiative should evolve to focus more on catchment-sensitive
farming and other water issues. (Paragraph 64)
It is already clear at this stage that the Initiative
has created and rolled out several schemes that will be very valuable
in helping to ensure good practice in the use of pesticides.
The Government therefore agrees with the Committee that it would
not be acceptable for this progress to be lost after 2006.
What happens after April 2006 will depend largely
on the Initiative producing meaningful, challenging and stretching
water and biodiversity benefits by which it can be judged. We
will need to consider, with the Initiative Steering Group, how
the Initiative proposes keeping the momentum going beyond 2006.
But such considerations do not automatically rule out what role
fiscal measures might play in addition to complementary measures.
Defra officials are working on a framework for evaluating
the Initiative and discussions within Government as to how best
to measure the success of the Initiative and what might succeed
it have already begun. An initial meeting to discuss the issues
surrounding the future of the Initiative was held last October
between all those departments and agencies with an interest in
pesticides. A further meeting is to be held this summer following
which future options will be discussed with members of the Voluntary
Initiative Steering Group. The Steering Group itself has also
started to formally consider a likely successor to the Voluntary
Initiative with this particular issue being a major topic at its
December 2004 meeting.
The Government's assessment of what has or has not
worked in the Initiative will be an important factor in shaping
its view of what should happen next. But account will also need
to be taken of other factors including:
- the forthcoming EU Thematic strategy for the
sustainable use of pesticides. This is likely to include requirements
on training, sprayer checking, promotion of Integrated Crop Management
and collection/disposal of packaging waste and surplus pesticides.
For most of these issues it seems likely that Member States will
be expected to put measures in place rather than the EU setting
central rules. A judgement will need to be made as to whether
Initiative measures such as the National Sprayer Testing Scheme
can fulfil the requirements of the strategy or whether they need
to be superseded by statutory measures;
- CAP Reform. Cross-compliance and new stewardship
schemes (not identical across the UK) may provide opportunities
to help give incentives to voluntary schemes to reduce the environmental
impacts of pesticide use;
- Water Framework Directive. This will require
considerable changes to farming practices in at least some catchments.
The problems and solutions will not be uniform across the UK
and a combination of flexible regulation and voluntary action
may well be the most effective way of delivering the Directive's
requirements;
- stakeholder views and capabilities. The Voluntary
Initiative does appear to have developed the understanding of
industry stakeholders as to what is needed and what can be done.
But perhaps the key factor in determining the role
for a successor to the Voluntary Initiative is the part that it
could play in developing the Government's draft national strategy
for the sustainable use of plant protection products - the so
called 'National Pesticide Strategy.' It was recognised in the
recent consultation on the strategy that the Government would
look to build on its relationships with key stakeholder initiatives
such as the Voluntary Initiative so as to forge even stronger
constructive links to ensure that there is co-ordination in the
approaches used to minimise the impact of plant protection products
on the environment. As such the Government views a successor
to the Voluntary Initiative as essential and integral to developing
the strategy. The Voluntary Initiative Steering Group has responded
positively to the strategy consultation in welcoming many aspects
of the proposed strategy and particularly the proposal to integrate
many existing Initiative measures in a future strategy.
A possible pesticides tax
Recommendations 9-11
9. We recognise that there is a possibility
that a pesticide tax will be imposed. However, considerably more
work is needed to explore the possible design of such a tax before
we can adopt a firm position with regards to its imposition.
(Paragraph 82)
10. Conceptually, a properly designed banded
approach to pesticide taxation seems advantageous, since it should
create an incentive for pesticide users to switch to less environmentally
hazardous products. However, before the potential of such an
approach can be properly assessed, several practical issues, including
possible administrative complexity, need to be resolved. We
recommend that the Government undertake research to define the
criteria and methodology for categorising pesticides into different
bands. Furthermore, if the Government regards a banded pesticides
tax as a credible policy option, it must also carry out a detailed
evaluation of the administrative costs that would be involved.
(Paragraph 83)
11. We welcome the Treasury's open-mindedness
about the prospect of revenue recycling, or hypothecation, for
environmental taxes. Funds are needed to pay for the full spectrum
of measures required to minimise the environmental impact of pesticides.
To raise revenue to pay for these measures, we recommend that
the Government should consider a hypothecated tax on pesticides.
We strongly believe that the only justifiable reason for imposing
a pesticides tax would be to raise funds to pay exclusively for
pesticide mitigation action. If the revenues raised from such
a tax were not hypothecated, then the adverse financial impacts
on farmers would make levying a tax unjust. (Paragraph 84)
To cover the potential case that the Voluntary Initiative
might fail to deliver the required environmental benefits within
a reasonable timescale, the Government has continued to keep the
options for a tax or economic instrument under review. The Government
agrees that there are complex issues around the design of a potential
pesticides tax and has continued to look at these. In particular,
a study of key design issues for potential economic instruments
carried out on behalf of Defra by Risk and Policy Analysts Limited
(RPA) was published in September 2004.
The review by RPA, building on ECOTEC's work in 1999,
examined the design of a banded tax that would differentiate between
pesticides on the basis of risk and encourage switching toward
less environmentally-hazardous products. It also examined the
varying degrees of administrative complexity associated with the
various tax options (e.g., banded, unbanded, 'ad valorem', 'per
kg', 'per dose' and an approach based on bands derived using application
rates 'kg/ha'). The Government will continue to take the issue
of banding, and implications for administrative costs, into consideration
in any assessment of a possible pesticides tax.
The Government does not agree that the only justifiable
reason for imposing a pesticides tax would be to raise funds to
pay exclusively for pesticide mitigation action. A tax could
be justified on polluter pays grounds and could bring positive
environmental benefits by encouraging farmers to apply pesticides
more efficiently and reducing the volume of pesticides used, though
this depends on the extent to which a reduction in pesticide quantities
used feeds through to environmental benefits. Furthermore, an
effective banded tax that encouraged farmers to switch from more
harmful to less harmful products would also deliver environmental
benefits. Although spending measures can help to bolster the
environmental impact of a tax by, for example, facilitating changes
in behaviour, direct hypothecation from a tax is generally not
desirable as it can distort the efficient allocation of public
resources. However the design of any tax does need to take into
account distributional effects and impacts on competitiveness.
Revenue recycling is one potential way in which to do this.
National pesticides strategy
Recommendations 12-15
12. We are unconvinced by Defra's justification
for the lengthy delay in launching its national pesticides strategy.
Despite promising, in February 2003, that the development of
the plan would be a "priority", the Government did not
publish the plan until February 2005 - a time lapse of two years.
The delay indicates to us that the sustainable use of pesticides
has not been given the priority it deserves. We recommend that
the Government publish its final strategy document, as a matter
of urgency, to establish a clear policy framework within which
the VI, or its successor, can operate. (Paragraph 90)
The Government does not agree that the sustainable
use of pesticides has not been given the priority it deserves.
Pesticides are amongst the most regulated chemicals in the world
and at the heart of the UK's system for regulating them is the
rigorous prior approval procedure whereby the Government must
approve pesticides before they can be sold or used.
In addition, the present regulatory system not only
aims to ensure that pesticides are available to those who need
them but that proper use of approved products carries no unacceptable
risk to people or to the environment. Another key element of
current pesticide policy is that of pesticide 'minimisation',
i.e. procedures and policies in place for minimising the hazards
and risks to the environment from the use of pesticides without
putting necessary crop protection at risk. Producing a strategy
for the sustainable use of plant protection products is the latest
step in this minimisation policy.
Although the Government would have liked to have
published its 'final' draft strategy earlier, stakeholders have
been engaged in developing the strategy since July 2003 when their
views on the scope and content of a possible strategy were first
sought. Following that, a working draft of the strategy was sent
to the Pesticides Forum, the Advisory Committee on Pesticides
and the Pesticide Residues Committee as well relevant parts of
Defra, other government departments, and the devolved administrations.
As a result of this wide consultation, many helpful
comments were received resulting in a much improved strategy document
being produced, which now includes draft action plans, targets
and indicators. The resultant strategy also provided a better
fit with Defra's wider food and farming strategy.
In conclusion, although the draft strategy only emerged
in March 2005, stakeholders have in fact been involved in its
development for nearly 2 years now. The Government believes that
it is far better to produce a better end product rather than sacrificing
quality in putting an inferior version out earlier to public consultation.
And, as explained above, this has not in any way compromised sustainable
pesticide use. Nevertheless, now that the draft strategy has
appeared, we believe that it will have a key role in developing
policy for sustainable pesticide use for the foreseeable future.
13. We welcome the inclusion in the draft
national pesticides strategy of an action plan addressing the
use of pesticides in the amenity sector. The amenity sector has
participated very little in the VI, and has therefore been left
behind in the adoption of best practice. We recommend that the
Government bring forward this action plan as a matter of priority.
The amenity use of pesticides should be controlled in the same
way as agricultural use. (Paragraph 96)
The Government agrees that it is only right that
the amenity use of pesticides should be controlled in the same
way as agricultural use. However, as stated above in the
response to recommendation 1, there is already a large degree
of commonality between the regulation of pesticides in both the
amenity and agricultural sectors. Before a pesticide can be used
in either sector they have to undergo the same rigorous prior
approval procedures and pesticides approved for use in amenity
situations like their agricultural counterparts can, and do, have
statutory conditions applied to their use to ensure they can be
used safely with respect to people, animals and the environment.
However it is true to say that the amenity uses of
pesticides have historically received less attention than farm
uses but this will be addressed to a large extent by the proposed
new statutory 'Code of Practice
for Using Plant Protection Products' which combines a revised
code for agricultural uses with parts of the voluntary code of
practice for users of pesticides in amenity situations and the
voluntary code of practice for users of pesticides in forestry.
This new code is an important development as it will help all
professional users of pesticides, whether they work in agriculture,
horticulture, forestry or the amenity sector, to understand and
operate within the pesticides and health and safety legislation.
The Pesticides Safety Directorate is also in the processing of
producing a leaflet on best environmental practice for those using
pesticides in the amenity sector. This leaflet will specifically
highlight the relevance of the new code to amenity users and more
generally raise the profile of this sector.
There is also the role of the Voluntary Initiative
itself where an Amenity Stewardship Forum was set up last year
to bring together bodies with an interest in improving practices.
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 Voluntary Initiative:
- communicated to all member organisations the
process for removing obsolete pesticides;
- supported the Voluntary Initiative action to
have the non-statutory amenity code incorporated into the new
planned 'Code of Practice for
Using Plant Protection Products';
- spent considerable time reviewing and commenting
on the plans prepared by BASIS and NPTC in their respective roles
to set standards and qualifications for those selling and supplying
pesticides (BASIS) and those using them (NPTC);
- has commented to Defra on their review of diffuse
pollution from non-agricultural sources; and
- the Chairman has reported to the Pesticide Forum
and there is a proposal that the Amenity Forum should represent
the amenity horticulture sector on the Pesticides Forum.
Nevertheless, despite all the above initiatives,
the draft national strategy recognises that it is no longer acceptable
for amenity use to be scrutinised any less closely than agricultural
use and it therefore includes an action plan for the amenity sector.
The public consultation on the strategy ended on the 30th
June. All the comments received will be taken into account in
preparing the final strategy and its associated action plans,
targets and indicators.
This consultation should enable the Government to
refine the impacts and initial costs of implementing the strategy,
both for itself and other stakeholders. These will be important
considerations in finalising the strategy's action plans - including
that for amenity use. Although this work will be taken forward
as quickly as possible, the issues involved are undoubtedly complex
and it is essential that the strategy considers the variety of
economic and competition issues faced by pesticide users alongside
their environmental challenges.
Input from stakeholders to this process will be essential
if they are to sign up to a strategy that will deliver measurable
benefits whilst imposing the minimum additional burden necessary
to achieve this. Much will depend on the response of stakeholders
to the consultation. In addition it is also likely that a further
round of consultations may need to be undertaken for some/all
of the action plans as these are taken forward.
14. We recommend that the Government move
to legislate to make some elements of the VI mandatory - in particular,
the initiative's schemes for sprayer testing and operator registration.
This would force pesticide users not already participating in
these schemes to take action, in particular, non-agricultural
users. Since forthcoming EU legislation is likely to make sprayer
testing and operator registration compulsory, such an approach
should not compromise the competitiveness of UK agriculture.
(Paragraph 101)
UK legislation already requires that all pesticide
users are appropriately trained and that users of agricultural
pesticides are certified. The Voluntary Initiative goes beyond
this by encouraging pesticide users and their advisers to extend
their training by undertaking continuous professional development
and has a voluntary testing scheme for sprayers.
Whether such voluntary measures should be placed
on a statutory basis needs careful consideration. Regulation
is appropriate for some issues but alternative approaches may
be better for others. A statutory approach can be very effective
but does not give maximum scope for innovative ways to reach desired
outcomes. Also legislation is often unpopular and, unless EU
wide, can disadvantage UK businesses. On the other hand although
a voluntary approach can have the benefits of being less bureaucratic,
less costly to administer, more flexible and generate 'ownership'
it also has to be recognised that uptake can be low and it can
be hard to reach those people whose behaviours most need to be
changed.
In arriving at a decision it will obviously be essential
to look at the costs and benefits (covering economic, social and
environmental impacts of the different options) for both the statutory
and voluntary options. However the Government believes that it
would be premature to take a final position on this until such
a time as the details of the EC Commission's proposals for a thematic
strategy on the sustainable use of plant protection products is
known. It is the Commission's intention to publish these this
autumn. Clearly once the Commission's proposals are known a judgement
will need to be made as to whether Initiative measures such as
the National Sprayer Testing Scheme can fulfil the requirements
of the Commission's strategy or whether they need to be superseded
by statutory measures.
15. It is important that the scope of the
national pesticides strategy is wide enough to enable the Government
to explore how complementary policies can play a role in reducing
pesticide impacts. Agri-environment schemes and cross compliance
measures can - and should - complement and encourage a greater
uptake of measures in the VI. We recommend that the Government
look at ways in which different policy instruments can complement
each other in achieving a reduction in the environmental impacts
of pesticides. (Paragraph 108)
The Government agrees with this recommendation.
As well as proposing new measures and building upon the existing
minimisation policy to achieve a broader impact, the proposed
strategy also attempts to take full account of existing and proposed
controls and other regulations that affect or influence the use
of plant protection products. This is one of the reasons why
the relevant parts of Defra, other government departments, and
the devolved administrations have all been involved in developing
the strategy from the outset and why they have been included in
a further internal government consultation which is running in
parallel to the present public consultation exercise.
Therefore, in developing and implementing the strategy,
an assessment of existing policies and instruments that influence
the use of plant protection products is being undertaken. This
assessment includes not only existing pesticide policies such
as minimisation but also related environmental and agri-environmental
policies. To this end the more significant measures that will
affect pesticide use are outlined in a set of tables included
in the draft strategy. These tables are reproduced in the Annex
attached to this response.
It is envisaged that by incorporating existing legislation
and policies that the strategy will provide for the first time
a coherent view of those measures that will affect pesticide use
and of the implications for crop protection, production and the
continued development of safe crop protection measures.
Possible health effects
Recommendation 16
16. The possible health effects of pesticides
were not the primary focus of our inquiry. However, it is generally
acknowledged that pesticides have the capacity to harm human health.
The Government's independent advisory committees, the CoC and
the ACP, have recommended further research into possible links
between pesticide use and human disease. The potential effects
of pesticides on human health, together with the public concern
surrounding this issue, make it even more important that the national
pesticides strategy be developed and implemented. (Paragraph 118)
Although the Government sees it as imperative to
develop and implement its national strategy it would wish to stress
that the strategy is not intended to replace the existing rigorous
system of pesticide regulation. Rather the purpose of developing
the strategy is to act as a driver to enhance environmental
protection within the context of the sustainable use of plant
protection products.
The safety of people is one of the two principal
aims of UK pesticide policy; the other being the protection of
the environment. To this end all pesticides must be approved
before they can be marketed or used, and only those that pose
no unacceptable risks to human beings, non-target species or the
wider environment will be given approval. In order to obtain approval,
applicants have to provide an extensive package of scientific
data which are rigorously evaluated by the Pesticides Safety Directorate
and/or the Health & Safety Executive.
The components of such a data package would, amongst
other things, include data on the pesticide's potential toxicity
in humans, dietary intake through residues in food, and the exposure
of operators, workers and members of the public. Data on potential
toxicity are required for the active ingredient, the product as
a whole, and also any important metabolites of the active ingredient
to which humans might be exposed. In assessing the risks from
pesticide residues in food, account is taken of all foodstuffs
in which significant residues might occur and any significant
concentrations of toxic metabolites that might occur. The exposure
of people to pesticides during their application or through contact
with crops or other materials that have been treated with them
takes into account many factors including the physical form of
the pesticide product (e.g. liquid or granules) and the method,
frequency and duration with which it is used.
The evaluations undertaken by the Pesticides Safety
Directorate and the Health & Safety Executive are closely
scrutinised by the independent experts of the Advisory Committee
on Pesticides. The Advisory Committee makes recommendations as
to whether a pesticide can be approved for use and, if so, under
what conditions. Only when Ministers are satisfied on the basis
of the Advisory Committee's expert advice that a pesticide can
be used safely will authority be given to put it on the market.
Provided that pesticides are used in accordance with their statutory
conditions of approval, they should pose no unacceptable risk.
The Pesticides Safety Directorate (PSD) and Defra
also undertake an extensive Research & Development (R&D)
programme into pesticides. Three recent examples of such R&D
commissioned by PSD that may be of interest to the sub committee
are:
- A mechanistic study on the association between
pesticide exposure and Parkinson's disease;
- An epidemiological study on the association between
pesticide exposure and Parkinson's disease; and
- An epidemiological study on cohorts in pesticides
manufacturing plants regarding possible link to prostrate cancer.
Details of all these projects can be found on the
Defra website. The tender process for all three has just finished
and the Pesticides Safety Directorate is currently in the process
of considering the tender proposals. In addition the Directorate
is currently funding, or part funding, various other human health
related projects including:
- A Biological Monitoring of
pesticide exposures (end date: 31st August 2005);
- An investigation into the gastrointestinal effects
of organophosphate and carbamate pesticide residues on young children.
(end date: 31st May 2006);
- An investigation into the potential impact of
tank mixing on the dermal penetration of pesticide active substances
(end date: 31st January 2006); and
- Occupational exposure through inadvertent ingestion.
PSD funding of this ended on 28th February 2005.
Conclusion
Recommendations 17-18
17. We consider it vital that the Government
now makes significant progress with its strategic approach to
the sustainable use of pesticides and show a clear commitment
to prioritise pesticides issues. Such a commitment is necessary
to help allay the public concerns that surround the use of pesticides.
We are frustrated at the lack of effort being made to devise
a means of measuring progress made by the policies intended to
control pesticide use. The Government is still struggling to
develop an appropriate benchmarking exercise or baseline position
against which to judge its pesticide policies. (Paragraph 119)
The Government does not believe that pesticide issues
have in any way been given a low priority. As previously stated
in this response, pesticides are amongst the most regulated of
all chemicals and the UK has had in place for a number of years
a rigorous system of regulation. At its centre is the pesticides
approvals process under which no pesticide may be sold, or used
unless Ministers are satisfied that it carries no unacceptable
risk to people or the environment.
This regulatory approach is backed up by the Government's
policy of "pesticide minimisation", i.e. a set of non-statutory
measures to help and encourage users to reduce to a minimum the
impact of pesticides on the environment consistent with the requirements
of crop protection. There are various parts to the minimisation
policy including a research and development programme, advice
to pesticide users and the work of the Pesticides Forum (which
brings together stakeholder organisations with an interest in
pesticide use to develop and promote best practice) and the industry
led Voluntary Initiative for pesticides which aim to reduce the
environmental damage caused by pesticides.
Nevertheless, the Government shares the sub committee's
desire to adopt a more strategic approach to the sustainable use
of pesticides and that is why it has produced its draft national
strategy for the sustainable use of plant protection products
which should assess the current state of play of the various pressures
on pesticide use and set a direction for the future. The strategy
contains an entire section devoted to targets and indicators and
recognises the particular importance these will play in respect
of the economic and environmental aspects of the strategy's draft
action plans.
However, for some time now, the Government has funded
the development of a number of indicators that reflect the impact
of Government and industry efforts to reduce the adverse environmental
impacts of pesticide use. These indicators have been produced
in liaison with the Pesticides Forum and have subsequently been
adopted by the Voluntary Initiative for Pesticides. Given that
these have already been developed and have mechanisms in place
to capture and analyse the data/information, it is recommended
that in addition to new targets being developed some of these
existing ones be utilised to help determine how far the strategy
is achieving its objectives.
18. Exerting pressure on the VI to deliver
results that are convincing to those outside the agricultural
and agrochemical industry is very important. The process of parliamentary
scrutiny can help those involved in the initiative avoid a sense
of complacency, as the VI enters the final year of its programme.
We may wish to return to this issue in the future. If we do,
we expect to find not only that the Government has finalised its
national pesticide strategy, but that it has taken decisive steps
towards achieving widespread implementation of the strategy. (Paragraph
120)
The Government believes that its national strategy
for pesticides will bring many benefits including:
- environmental and economic gains
- providing a longer term focus for the regulation
of plant protection products
- providing a focus for assessing the impact of
wider policy initiatives on plant protection product use
- involvement of, and commitment to, a shared vision
for the sustainable use of plant protection products from both
Government and all stakeholders including farmers and consumers
- continuous responsive decision making on plant
protection product issues reducing the risks posed by them to
people and the environment whilst at the same time delivering
benefits to farmers
- providing a link between policy initiatives and
delivery
Progress on finalising and implementing the strategy
will be dependent upon the results of the public consultation
but the Government will aim to take the various elements forward
as quickly as possible. Details of the consultation itself (and
any others that might follow on the action plans) will, in line
with Defra's and PSD's policy on openness be made publicly available
through the Defra Information Resource Centre in London.
Department for Environment, Food and Rural Affairs
August 2005
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