In this article, the NFU's senior regulatory affairs adviser Chris Hartfield looks at the current issues.
The NFU thinks the Pesticide Usage Survey (PUS) needs radical change because, while it measures use (in terms or weight of plant protection products (PPPs) applied and area applied to), it does not factor in risk – the thing we are aiming to reduce.
The government and industry both need a new pesticide use monitoring programme that demonstrates change over time in the level of risk associated with PPP use, and in turn, responsibility in PPP use.
The increasingly strict and prohibitive regulatory regime has reduced the number of active substances available by more than 50% in the past 30 years. PUS data shows that use over this time has decreased by more than two thirds, in part due to regulation stopping use of widely used actives and the lower rates of use of modern products. However, over the same period, area treated has increased by more than 60%.
This concerns those who argue ‘lighter’ and more toxic pesticides are being applied across more land, with greater risks to health and the environment. In fact, the shift to using lower risk, more specific plant protection products (a result of the tightening regulatory regime) will have resulted in an increase in area of use over time, but the current PUS does not help explain this.
The reasonable expectation is that replacement of older chemistry with lower risk chemistry, the increase in precision application, lower rates of use, and uptake of alternatives and IPM will mean, over time, environmental loading and risk from pesticide use has reduced. But we have no independent, well-evidenced data to demonstrate this.
What is the NFU doing?
To help us to make evidence-based responses about pesticide risk and move towards being able to measure changes in the level of risk from pesticides use over time, the NFU and the Voluntary Initiative (VI) funded researchers Fera to critically review pesticide risk indicators (PRI) that go beyond ‘quantity only’ measures (like the PUS). You can read the full report here, and a summary document here.
The NFU and the VI have fed the Fera findings into the NAP and PUS reviews. The government’s draft NAP aspires to establish a set of targets for reducing the risks associated with pesticide use by the end of 2022.
The focus on risk is a good starting point, but for any target to be meaningful, it will be essential for it to be based on a robustly science and risk-based PRI and comprehensive recording of pesticide use.
Fera review results
The Fera research (to critically review pesticide risk indicators that go beyond ‘quantity only’ measures) found:
- Quantity only indicators (like the PUS) treat all pesticides as equal, which is no good for describing how pesticide impacts can be lowered by switching to alternatives.
- Data availability is key to developing meaningful PRIs. In terms of recording PPP use, the PUS is not comprehensive enough to fill this need.
- A key example of a PRI – the Danish Pesticide Load Indicator (which is linked to pesticide taxation) has seen reductions in non-target impact but no corresponding reductions in amount of PPP used.
- French Ecophyto schemes are notable for government investment in training and technical guidance provided to farmers, including the DEPHY network of 1,900 demonstration farms (planned to be expanded to 3,000), which has been successful in communicating ways to reduce PPP use while maintaining productivity.
- To develop and adopt a PRI, there is a need for carefully managed stakeholder engagement, transparency and clear communication.