PAN UK analyses new pest management options 

Many hazardous pesticides will disappear from the EU market in 2003. David Buffin of PAN UK told the Conference that non-chemical replacements need to be found which are safe for human health and the environment and that are acceptable to consumers. 

David Buffin of PAN UK. Photo: Billy Ridgers

Historically Pesticide Action Network (PAN) has focused on identifying which pesticides are not safe. We have been critical of the way in which the risks associated with pesticides have been judged. Pesticides are after all broadcast wholesale into our environment with the intention of killing or distorting pests or otherwise harming living organisms. 
    Risk assessment, the basis of pesticide regulation, is an inexact science. It discounts the cumulative risks from pesticide exposures at home and at work, and overlooks additive and synergistic effects of multiple low-level pesticide exposure. It fails to take account of conditions in developing countries, where regulators are often guided by decisions taken by the well-resourced regulatory bodies of Europe and the United States. 
    Over the 14 years that PAN UK has existed, there has been a regular flow of reports of problems associated with pesticides which we have highlighted. 
    To give one example, a recent study from the US has established that levels of the herbicide atrazine as low as 0.1 parts per billion in water are sufficient to demasculinise frogs. An analysis performed by the Environment Agency shows that 10 sites in England and Wales had concentrations of atrazine higher than this level, and computer modeling predicted a further 13 catchment sites could be affected.

European pesticides clear out 
In recent years, a number of hazardous pesticides have come off the market. During 2003 a total of 320 pesticides that are not fully backed-up with modern testing requirements will begin to be phased out in the European Union. While almost one-third of these may be obsolete, for many of the others farmers and growers need help identifying less hazardous alternatives. In some cases the shortage of registered alternatives will mean that chemicals that do not meet the strict new standards need to remain on the market. By 2008 there may only be 300 pesticides on the European market compared with 850 in the early 1990s.
    Regardless of public interest group concerns about environmental or health impacts, many pesticides will leave the market place in any event and their use will have to be replaced with something, particularly in the horticulture sector, which will be most affected. It is our job to make sure their replacements are safe and acceptable to society as a whole. 

Concerns with the current systems
Pesticide registration systems throughout the world largely rely on methods of analysing the risk of each pesticide independently of other options. Users have no means of knowing which chemical or product carries the least risk to health or the environment. The scope for non-chemical approaches is not considered. 
    If we are to achieve the safest and most sustainable approaches to pest management, we must find a way that encourages the wide-spread adoption of non-chemical approaches. At present pesticide approval is based on a consideration of the hazards of the active ingredient and an assessment of the risk of harm of the product in use, both to human health and the environment. In the UK, this process proceeds product-by-product with no consideration given to the relative merits of other products or active ingredients that may be used to control the same pest, disease or weed. 
    For example, the organophosphate chlorfenvinphos has had its approval extended for use on vegetable pests including cabbage root fly, while garlic granules remain unapproved although they may offer an alternative with lower risk to human health and the environment.

Safer pest management 
By failing to promote the least hazardous or risky approach to pest management current regulation does not take proper account of the precautionary principle. It increases the risk of long-term harm to human health and the environment. The most effective implementation of the precautionary principle is to remove from use substances where there is uncertainty over adverse effects through the adoption of the substitution principle – the elimination of hazardous substances by replacing them with less hazardous or non-hazardous alternatives. 
    Comparative assessment is the regulatory process to achieve substitution. It encourages:

• precautionary approaches when regulating pest management in food production
• the simultaneous consideration of the risk of harm to human health and/or the environment of active substances with the same or similar fields of use
• approval of the least risky substance or product, and consequently its substitution for those that are more risky

Comparative assessment can be a mandatory requirement in the approvals process, or it can underpin detailed information for users to enable them to select from alternative products. With pesticides, the scope for comparative assessment depends on there being an overlap between similar uses of different products or active substances. This is not necessarily always the case. The situation can be made more complex where resistance management is necessary or where products have specific fields of use (for example during stages of crop growth, or where crops are grown on different soil types). 
    Choosing the safest approach is complicated by differential risks. A product or substance may pose a lower risk to human health, but a higher risk to the environment. Too often regulators address the environmental impacts in isolation from the health effects. For example in the UK, two multi-stakeholder groups, the Pesticide Forum and the Voluntary Initiatives to reduce the environmental impacts of pesticides, focus largely on environmental issues.

Including non-chemical control 
Where pest, disease or weed control can be achieved by non-chemical methods, for example by crop husbandry, rotation or variety choice, this non-chemical method should be included in a broader comparative assessment. The approach could prioritise methods that are significantly less risky and cost effective. Only non-chemical methods have the scope to remove the risk of the use of hazardous substances from the food chain and the environment. On what basis could the substitution of chemical by non-chemical methods be considered?

UK review 2001
In June 2001, the Advisory Committee on Pesticides (ACP) considered the scope for the introduction of comparative assessment into the regulation of pesticides in the UK. The Committee has provided an evaluation of alternative approaches to implementation, and Ministers will consider this advice during the ongoing re-negotiation of the European Directive 91/414. The ACP’s evaluation showed a clear split between industry and public interest groups. The agrochemical industry consistently argued against the regulatory deployment of comparative assessment whilst the other interest groups offered support. 

European stakeholder meeting
At a recent stakeholder workshop held by the European Commission (EC) in Greece in July 2002, participants included representatives of the agrochemical industry, the EC Member States and environmental public interest groups. Most, though not all, stake-holders considered that comparative assessment should be applied at the product level within each member state.
    Under a mandatory regulatory procedure, an active substance or product would be either approved or substituted by a lower risk product or substance. Producers would not have access to a substance or product that had a safer alternative. Or, comparative assessment could be a ‘semi-regulatory’ tool, where the substance or product is assigned to a low, medium or high band. This banding would require or enable users to select a product of lower risk. The greatest benefit would arise from the mandatory application of comparative assessment and substitution, which would help to establish a level playing field across Europe. A semi-regulatory approach may not be evenly applied throughout Europe – some member states may apply it vigorously, others hardly at all. More importantly, it would be difficult to enforce.

The benefits of comparative assessment
Comparative assessment may be complex to implement, but it is crucial for developing safer methods of pest management. It forms the cornerstone of precaution in practice. Although there may be conflicting priorities in balancing the concerns of human health or the environment, comparative assessment will force regulators to make qualified and transparent judgements which will help provide a practical approach to risk management with widespread public support. Comparative assessment would be a mandatory part of the pesticide approvals process. This approach has the support of a diverse range of stake-holders, and although it may place a greater burden on regulators and on the agrochemical industry, it will stimulate the search and commercial development of least risky solutions to pest management problems. 

PAN UK recommendations
Foremost, substitution and comparative assessment strategies must be included in the revision of EU Directive 91/414. Comparative assessment has to be a central part of a Pesticide Use Reduction Programme for the UK. There is an opportunity to include national use reduction programmes throughout the EU as part of negotiations under the Thematic Strategy for the sustainable use of pesticides of the 6th Environmental Action Plan.
    In the UK, we call on the government to rename the Pesticide Safety Directorate the Pest Management Directorate with a broad remit on pest management in the field rather than its narrow focus on one of the inputs – chemicals. Substitution, including recommending non-chemical alternatives, would form a key pillar at the new PMD. Many pesticides are used for cosmetic reasons – to remove blemishes and beautify fruit and vegetables. The invigorated Directorate with a changed mindset would be able to deliver substantial reductions in pesticide use. 
    Ministers currently receive independent advice from an Advisory Committee on Pesticides. The remit of this body should also be widened to become the Advisory Committee on Pest Management. 
    In order to encourage innovation the government needs to establish a ‘Safer Alternatives Innovation Forum’ that has a budget to promote research, development and extension. The Forum will then be free to develop measures to promote advice and policy development to achieve a reduction in pesticide use and the promotion of least-toxic and bio-rational approaches to pest management.

Conclusions
The PAN UK Pesticide Challenge Conference is only part of a process, and it is important to consider how to move the debate forward in 2003. This conference sets a number of challenges for stakeholders:

• the challenge for the pesticide industry is to develop safer pest management techniques that have public support
• the challenge to the food retail industry – to help reduce the use of unnecessary cosmetic pesticide application
• the challenge to farmers is to be ready to innovate
• the challenge to the consumer/environmental lobby is to think more carefully about what we want from the food supply chain

Edited presentation to the Pesticide Challenge conference, November 2003, David Buffin, Co-ordinator UK and Europe Programme and Editor Pesticides News, PAN UK, davidbuffin@pan-uk.org

[This article first appeared in Pesticides News No. 58, December 2002, pages 4-5]