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The UK’s longstanding and rigorous pesticides regulatory regime and other existing statutory and voluntary controls, incentive schemes and research programmes, mean that it is well placed to prepare a comprehensive and effective National Action Plan (NAP).
The Government has communicated the NAP to the European Commission and other member States. Using the expertise of the stakeholder Pesticides Forum, the Government will continue to monitor the health, social, economic and environmental impact of the measures detailed in this Plan and where necessary update it. NAPs must be formally reviewed every 5 years, although it is recognised that Government and non-Government initiatives may change within this period, and periodic major or minor updating of the Plan may be appropriate to ensure that the Plan forms a ‘living’ document.

UK National Action Plan for the sustainable use of pesticides (plant protection products)

Purpose

1.1 This is the UK’s National Action Plan (NAP) to meet the obligation on Member States under Article 4 of EU Directive 2009/128/EC establishing a framework for Community action to achieve the sustainable use of pesticides which has been transposed in the UK by the Plant Protection Products (Sustainable Use) Regulations 2012 (the PPP (SU) Regulations 2012; SI 2012 No’ 1657).

1.2 It has been developed following consultation with stakeholders, including the public, as required by the Directive.

Background

Legislative background


2.1 Regulation (EC) No 1107/2009 regulates the marketing of plant protection products in the EU (and repealed and replaced previous rules in Council Directive 91/414/EEC on 14 June 2011). The Regulation aims to harmonise, as far as possible, the overall arrangements for authorisation of plant protection products within the EU. It sets out rules and criteria which must be met for EU approval of pesticide active substances, and for member State authorisation of pesticide products. The Regulation, which is supported by domestic enforcing regulations, sets out common rules and guidance on data requirements; data evaluation; risk assessment; the protection of commercial information (data protection); and public access to information on pesticides.

2.2 In addition, EC Regulation 396/2005 provides a harmonised system of setting Maximum Residue Levels (MRLs) for all foods treated with pesticides. MRLs are not safety limits but reflect the largest amount of pesticide which the regulatory body setting the MRL would expect to find in that crop when it has been treated in line with good agricultural practice.

2.3 In addition to these controls, the EU Directive on the sustainable use of pesticides, published in 2009, provides a framework to achieve a sustainable use of pesticides, specifically by “reducing the risks and impacts of pesticide use on human health and the environment and promoting the use of integrated pest management and of alternative approaches or techniques such as non-chemical alternatives to pesticides.” To facilitate implementation of the Directive, Member States are required to develop and submit NAPs to the European Commission. 2

2.4 The NAPs are to be developed with public participation, and in addition to any periodic public consultations, Defra and CRD welcome comments on the UK Plan at any time. The Directive requires NAPs to be reviewed at least every five years, although it is recognised that Government and non-Government initiatives may change within this period and periodic major or minor updating of the Plan may be appropriate so that the Plan forms a “living” document.

Scope of the Plan Products

3.1 Pesticide is a general term that includes a variety of chemical and biological products used to kill or control living organisms such as rodents, insects, fungi and plants. The definition of pesticide in Article 3 of the Sustainable Use Directive follows this broad general term. However the Directive currently only applies to plant protection products, defined under Regulation (EC) 1107/2009 as those pesticides used to protect plants and plant products from pests, diseases and weeds (essentially agricultural, amenity and home garden pesticides). This NAP therefore only covers such products. It does not cover ‘biocides’ (such as wood preservatives or disinfectants) or veterinary medicines (such as sheep dip chemicals) which are subject to separate policies and regulatory requirements. Where the term “pesticides” is used in this document it refers only to plant protection products. Geographical coverage

3.2 As this is a UK Plan it covers England, Scotland, Wales and Northern Ireland. Devolved governments have contributed to its development and will be involved in its review. Annex 1 gives information on pesticide use in the UK regions. The terminology for current schemes used in this strategy is accurate at the time of publication. However, the devolved governments (and Defra in England) may develop in the future parallel but different agricultural or environmental schemes to reflect priorities within their territories. Life-cycle

3.3 This NAP covers those stages of the pesticide life-cycle relevant to the requirements contained in the Sustainable Use Directive. It therefore includes legislative and other controls on the marketing of pesticides, on the use of pesticides and on pesticide residues in foods and other areas affected by pesticides degradation and disposal. As required by the Directive, the Plan takes account of the health, social, economic and environmental impacts of pesticides (whether potentially positive or negative) to protect the health of people (operators who apply pesticides, other workers, 3 residents and bystanders and consumers) and the environment (water and aquatic environment and biodiversity).

Strategic background

4.1 As envisaged in article 4 of the Sustainable Use Directive, the Plan builds on the actions and experience on pesticide risk reduction and minimisation gained from the two previous pesticides strategies but reflecting the priorities of the Coalition Government, particularly in reducing the burdens on business and reducing the costs, and, where appropriate, the activities of Government. The Plan follows the direction of travel set out in the 2010 document “Consultation on the implementation of EU pesticides legislation; summary and government response” of 15 December 2010.

4.2 The NAP stands in its own right as the central vehicle for delivering the continuing reduction of risks from pesticides by setting measures for the responsible use of pesticides. However, it also supports wider Government objectives for health protection, the environment and for agriculture. For England, these include: “Improving the productivity and competitiveness of food and farming businesses, with better environmental performance”; “Helping to enhance the environment and biodiversity to improve quality of life”; “Adopting a proportionate approach to regulation and removing unnecessary burdens”.

4.3 The Scottish Government (SG) is also actively trying to reduce the burden of bureaucracy on Scotland’s rural land managers. A review is underway to consider how to reduce the red tape associated with farming and help farmers free up time for farming.

Delivery of the UK plan

5.1 The Plan will be managed by the Chemicals Regulation Directorate (CRD) of the Health and Safety Executive as the UK pesticides regulator. Strategic oversight will be maintained by Defra who have responsibility for pesticides policy, in collaboration with policy units in devolved governments. Other Government Departments may also have an interest in specific elements of the Plan.

5.2 The Plan can only be delivered through Government working in partnership with a wide range of stakeholders including the crop protection industry and the wider agriculture, horticulture and amenity interests and other non-government organisations. The Government is keen to ensure that regulatory burdens on businesses are kept to a minimum and reduced/removed wherever possible. For pesticides, this means that the Plan aims for non-regulatory approaches to be adopted as much as possible, and looks to stakeholder partners to deliver these. Of particular relevance in delivering the non- 4 regulatory measures in the Plan are the two key stakeholder organisations, the Voluntary Initiative for pesticides for agriculture and horticulture, and the Amenity Forum.

5.3. All pesticide users, and especially professional users, have a key role to play in ensuring the success of the Plan in reducing the risks and impacts from pesticides on human health and the environment by: • adopting an integrated approach as described in the Directive, drawing on all available techniques to tackle pests, diseases and weeds; • complying with all relevant regulations and record keeping requirements for pesticides; • complying with any Codes of Practice and following guidance – including that from industry groups such as the VI - for using pesticides appropriate to the local situation; • supporting the measures in this plan relevant to their sector.

Stakeholder oversight

6.1 Development of this Plan has included consultation with UK stakeholders including the public. Ongoing stakeholder input and oversight will be carried out by the UK Pesticides Forum, a stakeholder group, which has provided advice on responsible pesticide use to government and industry for many years (see Annex 2 for more information on the Forum). The Forum will keep the Plan under continual review, and where necessary, in consultation with Government, will set up short-life expert working groups to consider specific issues which arise or are identified. The Forum will produce an Annual Report on developments in the Plan.

6.2 The Forum will be assisted in its work by three standing working groups covering the amenity and amateur uses of pesticides and wider agricultural and horticultural grower issues.

Objectives, targets, measures and timetables

7.1 The overall objective of this Plan is to ensure that pesticides are used sustainably by reducing the risks and impacts of use on human health and the environment and encouraging the development and introduction of integrated pest management and of alternative approaches or techniques. This Plan and the controls listed and developed under it are designed to promote risk reduction. The regulatory risk assessment and risk management process is very effective at identifying and mitigating risk. This risk-based approach will also ensure that use of the most hazardous pesticides is reduced to a minimum. However the regulatory process relies upon the fact that all pesticides are used responsibly. If products are not used responsibly, this has the potential to undermine assumptions made in the risk assessment process. 5

7.2 The Pesticides Forum has developed an extensive suite of quantitative and qualitative indicators to monitor how pesticides are being used and the impact they are having. The indicators, supported by the Government cover: surveys of pesticide use in the agricultural and non-agricultural sectors; results of farm inspections; cropping statistics and the availability of methods of control; rates of adoption and impact of industry initiatives; and monitoring the impacts of pesticide use on human health, water quality and the environment. A full list of the indicators used by the Forum in its 2011 report and the framework which explains these is in Annex 3. For its 2012 report (to be published in the spring of 2013), it will review the indicators grouped under the headings of the sustainable use directive. These indicators are used to determine trends in pesticide use and practice and to identify any particular areas of concern. The Forum’s most recent annual report concludes that, broadly, pesticides are being used in a sustainable fashion in accordance with the authorised conditions of use, by a skilled workforce using well-maintained equipment. However, the following priority areas have been identified where there is a need for particular emphasis: - Protection of water. Residues of some pesticides particularly those in slug pellets applied to autumn sown cereals and oilseed rape crops are detected in water in certain parts of the UK with a frequency and concentration that may compromise the UKs ability to meet its obligations under the Water Framework Directive (WFD); - Whilst there are many examples of best practice amongst amenity and amateur users, overall these sectors are not operating to the same high standards as is generally found in agriculture; - Whilst virtually all users aspire to and adopt some elements of an integrated approach to managing pests, weeds and diseases there is scope, and a need in view of the declining number of pesticide products and pesticide resistance, to develop a greater range of viable techniques and ensure these are adopted by users.

7.3 The targets and timetables necessary to deliver the objective of this Plan are to: - maintain the current high levels of training (both initial and continuing) amongst pesticide users for the duration of the life of this Plan with 100% of professional users meeting new certification requirements (see training section for more detail); - maintain the current high levels of regular testing of key types of pesticide application equipment until compulsory testing/certification is introduced in 2016; with 100% of equipment used on farms having test certificates from 2016 (see equipment inspection section for more detail); and - ensure that pesticide pollution of water does not result in the UK failing to meet its objectives under the Water Framework Directive (WFD). This includes the development of a management plan for each river basin every 6 years. The plans are based on a detailed analysis of the impacts of human activity on the water environment against a number of parameters including the ecological and chemical quality and incorporate a programme of measures to improve water bodies where required. Individual river basin plans and catchment management plans have objectives, measures and targets appropriate to the issues identified. For example, 6 the catchment plan for the River Leam has an objective to maintain the pesticide reductions to protect drinking water quality and the environment so that by 2027, pesticides will thereby no longer be considered to a failed element with regards to the WFD and assisting the Leam in meeting its target of Good Ecological Status.

7.4 The objective will be delivered through the mechanisms and measures described in this Plan. This will involve: - use of the pesticide regulatory risk assessment and management process, which is very effective at identifying risk and appropriate risk mitigation; - controlling/influencing storage, use and disposal of products, their remnants and packaging (by legislation and inspections; statutory and non-statutory training; incentives; and administrative and voluntary measures); and - careful monitoring of impacts and utilising the results of research and development through effective Knowledge Transfer.

7.5 Progress in the priority areas identified above will be assessed over the five years of the Plan and in the light of any relevant information resulting from the calculation of harmonised risk indicators which will be developed by the Commission. Indicators for these and other areas will be examined annually in the Pesticides Forum report to provide the quantitative measure of progress. This will also be considered alongside achievement of targets set in other related areas such as in implementation of water protection legislation and uptake of measures in agri-environment schemes which also contribute to minimisation of the use of pesticides.

7.6 The following diagram shows how the cycle of use controls, evidence, reviews and compliance fit together to underpin the National Action Plan. 7

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