The consultation period on Defra’s draft National Action Plan (NAP) for the sustainable use of pesticides has just ended.
Commenting on the draft, Dr Colin Ruscoe, Chairman, BCPC says, “BCPC welcomes Defra’s balanced and pragmatic approach. This includes the intention to continue the present direction and initiatives for supporting good practice, e.g. the Catchment Sensitive Farming programme. Continuing the existing successful policies also has the benefit of not increasing the regulatory burden on business.”
“BCPC is pleased to see that there is no intention to aim for pesticide use reduction per se – since this does not correlate with reduction of risk – but to continue the monitoring sales and usage data, and of pesticide residues” says Dr Ruscoe. “But although monitoring residues in relation to internationally agreed MRLs is useful, great care must be taken in presenting such results, making clear the purpose and significance of the MRLs. Too often, the presence of any detectable residue above the MRLs is misrepresented as ‘a danger to health’ by the media.
“However, some aspects of the National Action Plan are of concern to BCPC,” explains Dr Ruscoe. “The UK’s approach to operator training, combining mandatory training and continuing professional development (CPD), has been highly successful in raising standards and reducing risks. CPD is not required by the draft National Action Plan – but it is desirable, to maintain standards in our rapidly changing technological and regulatory environment.”
“BCPC supports the focus on protecting water courses, and on improvement of amenity and amateur usage; some amenity applications are potentially high risk and very visible to the public” says Dr Ruscoe. “However, this sector is generally not well dealt with. For example, there is nothing comparable to the crop assurance schemes that could drive an inspection regime for sprayers used in amenity applications. In some high risk situations, sprayers need to be tested more frequently than specified in the Sustainable Use Directive.”
“Reference is made to the suite of UK pesticide indicators and we are pleased to see that there is no plan to proliferate indicators,” comments Dr Ruscoe. “However BCPC stresses that caution needs to be used in applying some of the existing indicators. The Pesticide Forum Indicators Group uses the Farmland Birds Index, in recognition that there may be indirect effects from pesticides – but many other factors can have much greater effects on this index, including changes in land use such as the balance between winter and spring cropping. Other wildlife indices are being developed and these may be more suitable for assessing pesticide impacts.”
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