Organic farming expert joins UK pesticides committee

On 30 March 2000 Christopher Stopes, a consultant in organic farming, attended his first meeting as member of the UK’s Advisory Committee on Pesticides (ACP), the body that recommends to government ministers whether or not pesticides are safe to use. He discussed his aspirations with David Buffin.

Over the last year, the ACP has repeatedly reviewed the persistent organochlorine lindane, increasingly restricting its use – but not totally banning it, in line with some other European regulatory agencies. PAN UK, along with other public interest groups, has been following this process with interest because of concern over old hazardous pesticides. More recently, the ACP has started reviewing anticholinesterase compounds (organophosphate and carbamate pesticides) which have caused so much controversy in recent years because of their acute and possible chronic human neurotoxicity. 
    At the same time, the ACP will have to look increasingly towards reviewing more biopesticides, and botanicals (chemicals based on natural extracts) that are potentially less harmful to human health and the environment. 
    As well as opening up its membership, the ACP is becoming more transparent in its dealing with the public. Baroness Hayman, Minister of State at the Ministry of Agriculture, Fisheries and Food, has recently agreed that the minutes of discussion will be published on the web. This will include a detailed attributable record of the discussion held during ACP meetings, something that may cause disquiet among the pesticide companies (see box). 

What difference do you hope to make on your appointment to the ACP?
I provide the ACP with a fresh perspective – I have experience and understanding of farming systems that do not rely on synthetic fertilisers and pesticides. I hope to encourage policies that will lead to the reduced use of chemicals on conventional farms, by promoting some of the practices organic farmers routinely use – for example, rotation, or crop variety choice. I hope that farmers in general will follow the organic approach and take a more holistic approach to pest control, leading to a natural decrease in pest and disease attack, or competition from weeds.

It is early days yet, but as a new member of the committee, what are your initial impressions?
I am really encouraged by the drive for transparency and opening up the procedures of the committee and in the decisions that are made. I think that the strength of advice that is provided by all the relevant regulatory departments gives some cause for confidence for the improved regulation of pesticides. 

Is there such a thing as a safe (synthetic) pesticide – a chemical that will not damage the environment widely or human health?
We should not simply draw the line at looking for safe pesticides. Many naturally derived products may well be safer than synthetic pesticides. We should be researching and developing husbandry practices and exploiting natural products that have evolved over time as an integral part of living systems. Farmers should work within the natural system thus obviating the need for a direct input, regardless of whether it is a natural or synthetic pesticide. With crop rotation and variety choice there seems to me immense scope to apply our understanding of the way in which systems avoid falling prey to pests and diseases.

Should the ACP follow the substitution principle and recommend registration of a less hazardous active ingredient over a more hazardous chemical where this possibility exists?
At the moment, the ACP regulates on a narrow toxicological basis of what is presented to it for approval. It does not take any active view over the need of a particular chemical. The principle of substitution requires the ACP to take a view of whether one chemical is needed more than another. I think its terms of reference should include the promotion of the substitution principle – a less toxic or potentially dangerous compound should be preferred over one that is currently approved that may be considered to be more dangerous. This would, of course, require a change in primary legislation that I believe would be beneficial.

One of the pesticides the ACP has been examining is the organochlorine lindane. Why do you think this chemical has been banned in some other EU countries and not in the UK?
Lindane is considered a possible human carcinogen by the International Agency for the Research on Cancer, the US Environmental Protection Agency and the European Union. It causes cancer in laboratory animals, but we have no actual proof one way or the other whether it causes cancer in humans. After 40 years of use around the world, there is still a substantial lack of data about its impact on the environment. With all this uncertainty, I think that the precautionary principle should apply in this case. 
    Our position in the UK is different from other European Union countries such as Sweden, Denmark, Germany and the Netherlands where lindane has been banned. In the UK regulators keep asking the manufacturers for more and more data, whereas in Sweden, they made their minds up back in 1989. They were concerned enough from the limited data that was available, and because there are too many gaps in the scientific understanding of the chemical. We should ask why these differences of opinion occur. After all, we are essentially reviewing the same data. 
    The ACP has persistently considered there are no grounds for a ban or revocation of the use of lindane from the scientific point of view. I have some sympathy with the view taken by these other EU Member States, and I hope that increasingly we follow their route of viewing risk assessment and risk management. 

What scope is there for more effective PAN EU action on synthetic pesticides?
It seems to me very important that we understand and respect the way in which different countries regulate. It is possible that in the UK we could be operating a more precautionary regulatory procedure. Other countries may do better, whilst others, in some respects may do worse. We have a responsibility to look critically at the way in which different countries regulate pesticides, because there may be lessons we can learn from them. 

Do you think the ACP should review more naturally-based pesticides that are acceptable to UK and international organic standards?
I think it is important that the pesticides used by organic farmers are subject to the same sort of review process that is expected of conventional/synthetic pesticides. This process is very slow at the moment. 
    EU and national legislation controlling organic standards operate alongside legislation controlling the use of pesticides in agriculture generally and although there is a move towards harmonisation (in Europe and internationally), there are differences in the organic pesticides, which are acceptable between countries, that will persist for some time. This has important implications for the operation of organic production systems in different countries and may affect the viability of certain crops and enterprises. Furthermore due to these various differences it is inevitable that, during their production, organic foods will have been exposed to different types and amounts of organically approved pesticide active ingredients that may also have implications for trade in organic food between countries operating under different conditions and national legislation.
    Because of the way that the regulatory process operates, it is not possible for organic farmers in the UK to use many of the naturally-based substances. I think we should take much more notice of what happens in other EU Member States and the US. In both cases there are procedures for fast-track approval of naturally derived substances that I believe are safe from a human health and environmental point of view. I would hope that since we could trust our partners in Europe and also the US to regulate in a way that is both safe and effective – we should adopt similar practices in the UK. It is clear that there are important inconsistencies between the EU Organic Regulation, national organic standards; as well as EU and national rules concerning pesticide approval. 
    Recent UK research has evaluated the efficacy of some organically acceptable active ingredients for control against mildew (Peronospora ssp.) in several species of vegetable in glasshouse trials(1,2). These have shown that several plant oils and extracts, such as fennel oil, mint oil, and mycosin, can be effective in the control of fungal disease. 
    These botanicals represent a potentially valuable source of active ingredients that may be effective and safe from both an environmental and a human health point of view. However, approval for use under national pesticide rules requires urgent attention and, as a new member of the ACP, I hope to help speed-up this process.
    There are reports(3) that the plant oils from several species have insecticidal activity, and interest in this area of work is evident from internet-based ethnobotanical and phytochemical databases (eg www.arsgrin.gov.duke). A review of botanicals by Pinniger(4) highlights that only 20 substances are approved in the EU, and of these, only two (including the most dangerous and undesirable) are approved for use in the UK. Many apparently benign substances with fungicidal and insecticidal activity are not approved for use in the UK.
    In some EU member states, such substances are permitted for use, highlighting the necessity to achieve a common standard through Europe where an uneven access to products is inevitably leading to distortions in the relative production potential of certain vegetable and fruit crops.

So how can we move forward towards greater EU harmony?
Many products considered acceptable under the EU Regulation have proven effective against key plant pests and diseases – in some cases where appropriate cultural or biological control is not possible.
    I propose that we develop an appropriate pan-European Response relevant to the organic sector to overcome some of the barriers to using effective and organically acceptable active ingredients. I hope my involvement with the ACP can help assist in the development of more economically viable and environmentally benign production systems to the benefit of both organic and conventional producers in the UK.

References
J Clarkson, S Fox, R Kennedy and C Stopes, On top of mildew organically, Grower Magazine, 19 August 1999, 24.
2. M Lawson, R Kennedy and C Stopes, Evaluation of garlic oil and other chemicals for control of downy mildew (Peronospora parasitica) in organic production of Brassicas, Annals of Applied Biology, Tests of Agrochemicals and Cultivars supp. 19, 1998.
3. N Price, Aromatherapy for pests? Pesticidal products form plant oils, Focus on Biopesticides Plus, Royal Society of Chemistry, London, UK, February 2000, 1-3.
4. DB Pinniger, Natural pesticides for organic farming, Final Report to ARP Division, MAFF (OF 0130), Central Science Laboratory, York, UK, May 1996.

Christopher Stopes is a freelance consultant in food and farming, serving on the UK Register of Organic Standards Certification Committee, c.stopes@ecostopes.co.uk

[This article first appeared in Pesticides News No. 48, June 2000, pages 10-11]