A few years ago ‘Brussels’ sat down to review the EU pesticide legislation. There were existing directives on pesticide registration (91/414), on waste (the Water Framework Directive and a Directive on hazardous waste) and on residues (regulation 396/2005 on maximum residue levels (MRLs)). ‘Brussels’ realised that there was a yawning legislative gap between registering pesticides and the consequences of pesticide use. This was the gap that was eventually filled by the Sustainable Use Directive (2009/218/EC) which covers the use of pesticides.
Just to remind you, an EU Directive is really a set of objectives which individual member states interpret and then transpose into their own regulations. The UK Plant Protection Products (Sustainable Use) Regulations 2012 was the result of the transposition of the Sustainable Use Directive.
This will not have a great impact on the use of pesticides in the UK because we have had similar legislation or audit requirements since the mid-1980s. Our advisers and those who apply pesticides are already qualified and our sprayers are regularly tested etc. However, there will be some changes in the UK as a result of this Directive. Notably, ‘grandfather rights’ to apply pesticides will disappear in November 2015 and we will have to demonstrate that we are employing Integrated Pesticide Management (IPM). Some EU member states have taken a more draconian attitude than the UK to introducing IPM by setting pesticide reduction targets; France a 50% reduction and Belgium a 25% reduction.
The question is what is IPM? It can be in the eye of the beholder. For instance, I once asked a leading proponent whether a particular farmer was practising IPM. The soil type on his farm was really only suited to continuous wheat which he grew for the breadmaking market. This restricted variety choice and he often had to grow disease susceptible varieties to meet the demands of the miller. However he used pesticides rationally. The answer from the IPM proponent was in the affirmative. However, the Sustainable Use Directive does not take such a relaxed view and has a definition of IPM in an annex. For some light Christmas relaxation, I suggest that this Directive is a better read than most.
The main IPM principles it espouses are crop rotation, cultural control, resistant varieties, clean seed, balanced nutrition, cleaning machinery, encouraging beneficial organisms, monitoring and the use of thresholds.
Perhaps there is not a lot that we can argue with in that list but the level of their primacy is critical. For instance, taken to extremes, rotation can radically reduce pesticide use but can result in a tumble in income and food production. I still look back with some anger at a talk delivered by a Danish researcher a couple of years back. The headline was that with new rotations the UK grower could reduce pesticide use by 50%. He obviously was not an economist and so seemed totally unaware of the economic damage that his proposals would cause. It all comes down to the old dilemma: farmers farm to make a living and to do that they grow only those crops most suited to their soils and climate. This is also the principle that drives world trade. The dilemma is that such an approach will to frequently conflict with what some in society expect them to do.
The Sustainable Use Directive suggests that cultural measures should be adopted if they provide satisfactory pest control. Perhaps ‘satisfactory’ needs to be defined but I am sure no UK farmer would apply a pesticide if an alternative cultural control measure was as consistently effective and as cheap to implement.
It is interesting to note that the Directive also encourages the use of reduced (to be more precise – “appropriate”) doses of pesticides. It is a bit of a breakthrough to get official recognition of appropriate doses. Advisers in some countries around the world are still threatened with legal action if they dare to suggest to farmers that a lower than label recommended dose is appropriate in a particular situation.
It is understood that the principles of IPM, as defined by the Sustainable Use Directive, will be included in the Code of Practice for using Plant Protection Products which is referenced in general cross-compliance (SMR 9). This should have little impact on the way we farm as I am sure that most UK farmers already employ the wider principles of IPM. The problem is how do they prove it? An IPM plan is being developed by the Voluntary Initiative to be incorporated into assurance schemes (do not all groan together). This plan will include a self-assessment process. Those who groaned because they thought that the new IPM plan would be yet another form to fill in will be relieved to hear that it is intended that this will replace the current Crop Protection Management Plan!