European Union (EU) environmental legislation has promised significant improvements to the environment. Under its Sixth Environment Action Programme, the Commission developed a strategy for the ‘Sustainable Use of Pesticides’, to reduce their adverse health and environmental impacts1. In 2002, the EU proposed that each Member State should develop a national strategy on pesticides2. In February 2005, the UK Pesticide Safety Directorate, an agency of the Department of the Environment, Food and Rural Affairs (Defra), published its draft strategy for consultation3. The draft has failed to provide a clear plan for more sustainable agricultural production, and conflicts with the government’s own definition of sustainability. The proposed action plans do not address the important need to reduce pesticide use, risks and dependence. The draft strategy identified existing measures for reducing environmental impacts of pesticides, and outlined many potential new measures but contained no concrete proposals. It suggested that measures should be delivered in five action plans, targeting particular impacts or users (water, biodiversity, product availability, amenity and amateur use, and targeted use reduction). The Pesticide Safety Directorate (PSD) directly consulted over 1,000 individuals and organisations about the strategy including farmers, the farming and horticultural industries, the agrochemical industry, other government departments, NGOs and research centres. The revised strategy is expected later this month. It is not anticipated that detailed action plans will be published, but it is hoped that the scope and the framework for the strategy will be made clear. In advance of its publication, we review the main points in PAN UK’s response to the draft, and outline our proposed alternative strategy. Critique of government proposals

Sustainable pesticide use? 
The definition of ‘sustainable’ given in the document betrays a lack understanding of real ‘sustainability’. It places more emphasis on crop protection than environmental protection: ‘Sustainable use means, in particular, minimising the hazards and risks to the environment from the use of plant protection products without compromising necessary crop protection’ — and excludes other well-recognised essential components of sustainability. However, without compromises in crop protection to achieve reductions in health and environment impacts, there will be no driver for change: the extent of environmental damage that has occurred over the last 50 years has arisen because of the policy of maximising crop yields at all costs. Other departments within Defra take a much broader view4. The Sustainable Development Unit has established five principles of sustainability:

A strategy that is designed to improve sustainability should address all five principles. The draft strategy that currently exists fails on several counts

There is an assumption throughout the draft strategy that pesticide use will continue without much change – ‘chemical controls will have a prominent and important role in crop protection for the foreseeable future’. However, reducing our dependence on pesticides is a crucial part of sustainable agriculture, and is likely to be a requirement under the EU Thematic Strategy. It should therefore be a fundamental component of the UK strategy. While some level of chemical control is likely to be necessary for the foreseeable future, we should aim to achieve a diminishing role for chemicals in pest management. Contrary to what the draft suggests, growers do not need pesticides, they need tools and techniques, one of which may be pesticides; government should not encourage an agrochemicals industry, but rather a pest management industry. True sustainability requires a move away from synthetic chemical pesticides. To achieve this, it is important that the strategy is embedded in the context of ‘sustainable agriculture’. PAN UK has proposed a National Strategy for Sustainable Pest Management, which would reflect a much wider remit than the draft strategy published by PSD. 

Risks to public health
The risks to public health of pesticide use are not adequately reflected in the draft document, and this has been highlighted in the recent Royal Commission on Environmental Pollution report5 (see page 8).The draft strategy stated that ‘the regulatory system is designed to ensure that pesticides constitute no danger to the health of people when used correctly’. There is huge confusion about the use of terms such as ‘safe’ or ‘no danger’ in relation to pesticides. According to Professor David Coggon6, the outgoing chairman of the Advisory Committee on Pesticides, our current regulatory system provides ‘a high level of reassurance that serious toxic risks to humans will not occur’. This is rather less clear-cut than ‘no danger’ and has a considerable degree of subjectivity – how high is a high level of reassurance, and how serious is serious toxic risk? While there are remaining uncertainties and unknowns ‘no danger’ cannot be ensured. Since a residual risk to the environment is accepted, it is illogical to assume there is no residual risk to people – particularly when pesticides are tested on at-risk indicator species whereas there is no data for people who might be considered particularly vulnerable. Public concern over health effects of pesticides is acknowledged in the draft document but there is nothing aimed at addressing this concern. There is an increasing body of scientific evidence that indicates an association between pesticide exposure and illness, which is not even acknowledged. The Royal Commission report suggests that the link between chronic ill health and pesticide exposure is plausible, if not proven, and recommends the National Strategy ‘should give full recognition to the need to safeguard human health’.

Draft action plans
The most important parts of the draft document, in terms of the delivering change, are the five action plans. These focus on water, biodiversity, product availability, amenity and amateur use, and targeted use reduction. The rationale for the five chosen action plans is not clear: some relate to impacts (biodiversity and water); one relates to the end users (amenity and amateur use) and the others appear to be randomly-chosen issues. Neither public health nor food residues are covered. The current thrust of the product availability action plan, which is to assure continued pesticide use. We would argue that it is not ‘imperative that growers have a range of products with which to protect their crops’, but rather that they have a range of pest management techniques. Targeting individual pesticides for use reduction might only result in users choosing different chemicals that could be either better or worse, and could switch the problem from water to biodiversity or public health. There needs to be a straightforward use reduction strategy that applies to all pesticides, so that we work towards chemical use being replaced by non-chemical alternatives. Much of the recent focus on pesticide use, for example the industry-led Voluntary Initiative, has been relevant only to agriculture so it is important that issues of amenity and amateur use are also addressed. However, there should be a much greater emphasis on amateur use than in the draft strategy and it is desirable to separate amateur from professional amenity use, since the measures and techniques to change behaviour of professional users are likely to be different from those that will influence amateurs. 

PAN UK’s proposed strategy for sustainable pest management
In response to the consultation PAN UK submitted an ‘alternative’ strategy.

Aims and objectives 
The aim of the strategy should be to improve the sustainability of pest management by:

These aims should make clear the degree of reduction of risks and pesticide dependence to be aimed for, and the timescale over which they are to be achieved. PAN UK proposes that the ultimate aim should be to eliminate adverse impacts of pesticides, recognising that this is a long term aim. Reduction targets on shorter timescales are proposed for example

PAN UK’s proposed ‘action plans’ 
PAN UK proposes that there should be a set of action plans in order to reduce the impacts that the strategy aims to address (water quality, food residues, public health and biodiversity). Each of the action plans should have a component relating to end user, that is agriculture and horticulture, home and garden, amenity. There should also be an action plan to ensure that the necessary research and development is undertaken. However, as resources are likely to be limited, then clearly individual action plans to tackle the symptoms, rather than the cause, of the problem are not likely to be the most cost-effective way forward. There are difficulties in being able to identify and measure all pesticide impacts – currently this is not possible for anything other than water and food residues, where there is at least some level of regular monitoring. Addressing the root of pesticide impacts — dependence on a high level of toxic chemical pesticide usage — will be a much more efficient strategy, and will not only address the impacts that we are aware of but cannot yet quantify, but will mitigate against unknown impacts. Thus the European Commission’s Sixth Environmental Action Programme for reducing our dependence on chemical pesticides is key to achieving a real reduction in pesticide impacts. The Dependence Reduction Action Plan should have two aims: (a) to reduce the quantity of pesticides used and (b) to reduce the intrinsic hazards of the pesticides used. 

Action plan measures
The draft strategy listed a wide range of measures against each action plan. These ranged from the very weak (‘Consider the scope for reducing the use of particular high risk pesticides on particular crops’) to the much stronger (‘Tightening of approvals requirements, including the introduction of comparative risk assessment/substitution …’). There was no indication of which were likely to be supported, and which were not. For example, ‘economic instruments’ was included, despite indications that the government does not favour a pesticide tax. The PAN UK response listed almost 100 measures in its alternative action plans. Some of the most important relate to:

Some of the proposed measures should be mandatory. Some (such as those that rely on use of best practice) cannot be easily defined nationally and will need tailoring to local conditions. These may best be delivered through voluntary means, for which incentives and free independent advice will be essential. It will not be appropriate to leave the implementation of the strategy in the hands of the agrochemical industry, as currently happens through the Voluntary Initiative, since there are clear conflicts of interest and cannot be expected to achieve a reduction in our dependence on chemical pesticides. 

References
1. Catherine Wattiez, Pesticide News 57, 2002, p9.
2. Towards a Thematic Strategy on the Sustainable Use of Pesticides, European Commission, http://europa.eu.int/comm/environment/ppps/1st_step_com.htm
3. www.pesticides.gov.uk/environment.asp?id=70
4. www.sustainable-development.gov.uk/what/principles.htm
5. Royal Commission on Environmental Pollution: Crop Spraying and the health of residents and bystanders, September 2005.6. Personal Communication