While voluntary and stewardship approaches may work in other areas, they have repeatedly proven to be ineffective at reducing pesticide-related harms to either human health or the environment for a number of key reasons, including:
Hazard vs. risk-based approaches – Arguably the most fundamental problem with voluntary and/or stewardship approaches to reducing pesticide harms is that nothing is as effective as removing the hazard itself. The UK (along with the EU) currently follows what is commonly called the ‘hazard-based’ approach to pesticide regulation. This means that if an active substance is judged to be intrinsically dangerous – for instance by being able to cause cancer or persistent pollution – then it is too hazardous to be used safely and should be banned. Controlling exposure to hazards is a basic approach to protecting workers and the environment which is applied far beyond pesticides. The fundamental principle underpinning risk management in hazardous industries such as construction and nuclear power is that the first step is to “eliminate the hazard”. Only if this is impossible, should other means of controlling the risk be considered.
The ‘risk-based’ approach sits in direct contrast. It emphasises assessing and managing risks and involves the deployment of specific measures to keep risks below acceptable levels.
To apply these two approaches to veterinary medicines, a hazard-based approach might see the most environmentally harmful active substances banned from appearing in medicines, while a risk-based approach would recommend that owners do not let their pets swim in rivers for a certain length of time after applying a spot treatment. It should be noted that, if the UK implemented the hazard-based approach to its full extent, then active substances deemed to be too harmful to be used on crops would also be banned in veterinary medicines.
Use reduction vs. risk reduction – Another key reason that voluntary approaches don’t work is that they almost always focus on reducing the risks associated to pesticides, rather than reducing the amount of pesticides being used. While ‘use’ is easy to quantify and measure, ‘risk’ is not. By focussing on risk, voluntary approaches manage to block any meaningful action which would reduce the amount of pesticides applied. It sounds obvious, but evidence from around the world shows time and time again that the best way to meet the ultimate goal of reducing harms is to reduce the amount we are using. Or in the case of Highly Hazardous Pesticides, introduce bans to eliminate the hazard all together.
There are many examples of voluntary schemes on pesticides failing. Meanwhile, the body of evidence on the environmental harms caused by pesticide active substances found in medicines for cats and dogs has been growing for more than five years now. Despite many statements of concern from both veterinary and environmental groups over the years, concrete improvements or reductions in use have not occurred. PAN UK and its allies, therefore, believe that it is time to adopt a precautionary, hazard-based approach and ban the pesticide active substances from being included in pet medicines.