Memorandum submitted by the Crop Protection
Association (SFS 22)
EXECUTIVE SUMMARY
Crop protection plays a vital role in helping
to ensure food security.
The use of crop protection products helps farmers
to grow a reliable, abundant supply of high quality, safe, affordable
food. Without them the UK would become more dependent on imported
food.
With the increasing cost of research and development
and the demands of the regulatory system it is becoming more and
more difficult to discover new crop protection products and bring
them to market. Farming and associated industries operate in a
global marketplace and unwarranted constraints on the use of pesticides
in the EU and UK will put us at a competitive disadvantage and
so threaten our ability to maintain local production.
We need to keep as wide a range of crop protection
products available as possible to enable farmers to manage pest
resistance and to help provide solutions to new pest problems
that will develop with climate change. It is important to ensure
that regulatory decisions and any further restrictions on the
use of pesticides are based on evidence rather than politically
motivated.
1. The Crop Protection Association represents
companies involved in the manufacture and supply of plant protection
products for use in agriculture, horticulture, forestry, amenity
areas and gardens. We have 23 member companies, covering
more than 90% of the UK pesticide market with sales of £500 million.
2. Technology is key to increasing food
production in the UK and elsewhere. Advances in mechanisation,
fertilisers, plant breeding, crop protection and potentially biotechnology
all play a role.
3. Crop protection is essential to ensure
that crop yields are maximised. Without protection we would lose
more than 40% of crop yield pre-harvest and a further 10% post-harvest.
Currently pesticides (herbicides, insecticides and fungicides)
are the main and most effective means of crop protection. They
play a vital role therefore in ensuring a reliable, plentiful
supply of high quality, affordable food, ie food security.
4. Talking about food security, Hilary Benn
said on 6 January 2009 at the Oxford Farming Conference:
"I want British agriculture to produce
as much food as possible. No ifs, no buts. And the only requirements
should be first that consumers want what is produced and, second
that the way our food is grown both sustains our environment and
safeguards our landscape."
We agree with this. There is an increasing demand
for home grown produce. In order to meet this demand, pesticides,
used in a responsible way in conjunction with crop rotations and
cultural controls in an integrated crop management system, are
a key part of sustainable farming in the UK.
5. Mr Benn also said:
"We could produce more fruit and vegetables
here in the UK—the market is there, so what is holding us
back? If there is a demand then production should follow."
This suggests that, although he has been "arguing
against the pesticides regulation which could hit yields by limiting
the crops that can successfully be grown in the UK for no recognizable
benefit to human health", he does not fully understand
the challenges faced by growers in the UK.
6. As a result of the EU review programme
for pesticides under directive 91/414/EEC, around 60% of active
substances in the EU were lost due to the prohibitively high cost
of generating new data required. This led to gaps in the products
available for use on so-called minor crops (i.e. virtually anything
other than cereals).
7. This situation is likely to be exacerbated
by the proposed EU Regulation on the Placing of Plant Protection
Products on the Market which is nearing final agreement. At a
time when there is so much concern about food security, we believe
it is irresponsible to introduce legislation which could make
it more difficult to produce food in Europe and whose impact has
not been properly assessed.
8. The whole food chain in the UK has been
calling for a thorough EU-wide impact assessment of the proposed
Regulation. The Prime Minister and Defra ministers have supported
this (see attached correspondence)[75]
but have been unable so far to obtain support from their counterparts
across Europe.
9. In the absence of an EU-wide assessment
of the impact of the proposed hazard cut-off criteria in the Regulation,
two impact assessments were conducted by the UK Pesticides Safety
Directorate (PSD).
10. In its most recent assessment (December
2008) (http://www.pesticides.gov.uk/environment.asp?id=1980&link=%2Fuploadedfiles%2FWeb%5FAssets%2FPSD%2FRevised%5FImpact%5FReport
%5F1%5FDec%5F2008%28final%29%2Epdf),PSD found that up
to 14% of the pesticide substances assessed could be removed by
the criteria in the common position of the Council adopted in
September 2008 but much depends upon the definition of endocrine
disruptors which is uncertain. This loss of products could make
it difficult to grow certain crops in the UK and so make us more
reliant on imports. In addition it reduces the range of substances
available for resistance management and limits the potential solutions
available to deal with new pest problems arising from climate
change.
11. The question has been asked "why
doesn't the industry just find more new products?" Unfortunately
it's not that simple. Companies commit heavily to research programmes
but it takes nine years and £150 million to research,
develop and register a new pesticide. This long lead time makes
it difficult to respond to changing needs and the high cost means
that companies focus on major crops in order to recoup their investment.
12. Companies must also have a predictable
regulatory system to give them the confidence to make such major
investments. Therefore legislation such as the proposed Regulation
which introduces new and undefined regulatory criteria poses a
threat to the introduction of new products. Whilst it will not
help us in this particular case, we welcome Hilary Benn's statement
at Oxford that he is "working hard in Europe to try to
get the principles of better regulation recognized and implemented".
13. Once a crop protection product is authorised
for sale, it is important that it is used properly. We therefore
support measures which reduce risk and promote responsible use.
Use reduction targets, which are proposed as an option in the
EU Sustainable Use Directive soon to be agreed, achieve neither.
14. Under good agricultural practice, pesticides
should only be used when they are needed and in the amount required
to do the job effectively. Imposing arbitrary reduction targets
just makes it more difficult for farmers to control pests and
to avoid the development of resistance. Risk reduction is achieved
by focussing on how the products are used not how much.
15. We strongly support the measures under
the Voluntary Initiative (VI) to promote responsible use and minimize
any impact of pesticides on the environment. Some of these measures
will soon be enshrined in EU legislation under the Sustainable
Use Directive e.g. sprayer testing, operator training and we hope
that the Government will recognize the VI schemes as meeting the
Directive's requirements in these areas.
16. There has recently been an increasing
emphasis in Defra policy on alternatives to pesticides. Whilst
it is important to consider all options to secure our food supply,
we feel that there should not be a presumption against pesticides.
17. Synthetic chemistry will remain an important
tool for farmers and growers for the foreseeable future and we
need to ensure that we have:
— a predictable, transparent, science-based
regulatory system to encourage innovation;
— investment in work to develop suitable
solutions to enable continued production of fruit and vegetables
in the UK (including the use of existing pesticides); and
— responsible use within an integrated
farming system.
Crop Protection Association UK Ltd
January 2009
75 Not printed. Back
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