NIAB - National Institute of Agricultural Botany

Orson's Oracle

Why is life like a Dulux colour chart in monochrome?

Posted on 16/08/2017 by Andrew Watson

I am a simple man. I like things to be black and white. Day follows night, e=mc2 and Game of Thrones is on at 9pm on a Monday. A book titled 50 Shades of Grey sounds like a nightmare read to me.

Take Brexit. A black and white decision was made, like it or not, but we appear to be entering a decade of greyness. Whether hard or soft, I think it will definitely be a lemon Brexit - slightly firm on the outside, soft in the middle, leaves a sour taste in mouth and why-o-why would you to chew on it in the first place?

Agricultural regulations, which I’ve been involved with for 25 years, are the ultimate grey. The ‘Ministry’ (which I’m always reminded of when I see Gringotts Bank in Harry Potter), put out definitive black and white rules on a subject and this is what the farmer has to do.

But it’s not black and white. It’s like producing a Dulux colour chart in monochrome; endless shades of grey as the rules are interpreted at a practical level, by the experts, on farm.

Look at the Nitrate Vulnerable Zones (NVZ) rules which were so vague that the farm inspectors at that time, The Environment Agency, would publish periodic semi-practical interpretations to make the rules less grey. Like it or not, at least it provided more clarity - more black and whiteness. Then independent farm inspectors came along and interpreted the rules further, and often completely differently, on an individual farm. Back to grey again.

Pesticide rules are so “grey” that it can be difficult for a farmer or advisor to interpret them correctly. Which of the numerous buffer zones applies and where does the buffer start? What water volume or spray nozzle can I use? What are the definitive legal requirements for using this pesticide product?

As some of you know, I’ve spent over a year developing the definitive black and white database of pesticide products. ActivSmart, a NIAB Digital service launched at this year’s Cereals Event, puts all the grey pesticide rules and product data into one place in sharp, defined colour. It allows users to easily compare the defined attributes of similar pesticide products; with up to 26 black and white facts on each of the 2,300 plus approved products on the database. It provides clarity; from active ingredient to maximum total dose, from arthropod buffer zone requirements to a document library. ActivSmart is the perfect project for me as I get to replace shades of grey with black and white.

However, despite ActivSmart (with all modesty) being by far the most comprehensive, up-to-date but still simple, pesticide comparison tool, there is still a nagging greyness for a small percentage of the data.

Let me give you an example. In 2017, a new buffer was very quietly introduced by the UK Chemicals Regulation Division (CRD). This 5 or 10 m ‘non-target plant’ buffer around the outside of the field currently only affects five of the 41 products containing the active ingredient clomazone currently approved in the UK (yet more unnecessary greyness). However, CRD has published two authorisations for three of the five products. One authorisation has no new buffer but the other has the buffer clearly defined. In 2017, both these legal documents are valid. As a result the manufacturers can pick which authorisation to follow, and are not required to put the new buffer requirement on the product label in 2017 so they haven’t.

Clomazone is very toxic to many plant species and there is a history of legal disputes relating to drift damage onto neighbouring crops. It is one of very few products that must be applied as a coarse spray. I have concerns about how this grey area between CRD authorisations and product labels, both of which are legal documents, could potentially be viewed by a court of law should a serious legal dispute occur.

So, to finish, can I make a plea for more decisions to be made? Around the world and increasingly in the UK, no-one, even if they have the power to do so, wants to put their head above the parapet and say this is how it will be. Personally, it gets to the point that I almost don’t care what the black and white decision is but, please, please, make it and give us all a less grey world.

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