UK National Action Plan for Pesticides: integrating regulation and non-regulatory approaches

1. UK National Action Plan for Pesticides:integrating regulation andnon-regulatory approaches James Clarke Chairman pesticidesforum@hse.gsi.gov.uk

2. Presentation content • The role of the Pesticides Forum (PF) • Thematic strategy (for pesticides) • The UK National Action Plan (NAP) • EU context • UK approach • Indicators of Sustainable Use • By key heading in NAP • Summary and future plans

3. Pesticides in the UK • Pesticides Forum annual report • Impacts and sustainable use • PPT of data available www.pesticides.gov.uk/pesticides_forum_home.asp

4. About the Pesticides Forum Members, objectives and topics covered

5. Pesticides Forum Membership OrganisationsUsers, Advisors, Manufacturers, Environment, Consumers Fresh Produce Consortium/British Retail Consortium ADAS The Game & Wildlife Conservation Trust (GWCT) The Organic Sector Linking the Environment & Farming (LEAF) Advisory Committee on Pesticides (ACP) National Farmers’ Union (NFU) Agricultural Engineers Association (AEA) National Farmers’ Union Scotland (NFUS) Agricultural Industries Confederation (AIC) Pesticide Action Network (PAN-UK) Agriculture & Horticulture Development Board (AHDB) Scotland’s Rural College (SRUC) The Amenity Forum Scottish Natural Heritage (SNH) BASIS (Registration) Ltd SUSTAIN The Co-operative Farms Unite Country Land & Business Association (CLA) Voluntary Initiative (VI) Crop Protection Association (CPA) Environment Agency (EA) Wildlife & Countryside LINK (WCL) Women’s Food & Farming Union (WFU)

6. Aims and Objectives Aims: To oversee work under the UK National Action Plan To monitor the effects of policies, laws and other initiatives that affect or are affected by the use of pesticides, and To offer advice to Ministers and stakeholders To provide a forum for exchanging views, and where possible to allow our stakeholders to come to a general agreement Specific Objectives: Communications Monitoring impacts Knowledge transfer

7. Available from: https://www.gov.uk/government/publications/pesticides-uk-national-action-plan The UK National Action Plan

8. Statistics regulation 1185/2009/EC Thematic strategy (for PPPs) Authorisation regulation 1107/2009/EC Pre-marketing Sustainable Use Directive 2009/128/EC Use Machinery Directive 2009/127/EC (Amended) Pesticides and Waste law Disposal/degradation

9. National Action Plan (NAP) • NAP setting objectives, targets, measures and timetables • Indicators to monitor products containing substances of concern • Use reduction targets if appropriate for risk reduction • To take account of health, social , economic and environmental impacts, national, regional and local conditions and other legislation (e.g. WFD) • Public participation • To Commission by November 2012 and reviewed 5 yearly

10. UK National Action Plan: Approach • Outlines pesticides legislative regime • Authorisation, MRLs, Sustainable Use Directive • Explains government’s wider strategic priorities • reducing burdens in business, improving productivity and competitiveness of farming, enhancing the environment and biodiversity • adopting a proportionate approach to regulation and removing un-necessary burdens • Clarifies roles • Defra with strategic oversight, government and non-governmental organisations to work together • Stakeholder consultations, role for the Pesticide Forum, supported by short-life and standing working groups

11. National Action Plan (NAP) • Required under implementation of the Sustainable Use Directive for PPPs • Provides framework for: • reducing the risks and impacts of pesticide use on human health and the environment • promoting the use of integrated pest management and of alternative approaches or techniques, such as non-chemical alternatives to pesticides.

12. National Action Plan R&D Assurance schemes Regulation

13. Role of PF and NAP • Ensure appropriate regulation and compliance • Encourage current best practice • Monitor progress (indicators) • Identify and promote even better practice • Regulation • Industry initiatives • Research and Development • Short-life working groups

14. NAP – main headings • Training • Improving standards – Operators - (R), advisers • Sales – storekeeper certification • Information and awareness raising • Consumer and health protection, wildlife protection • Inspection of application equipment • Sprayer testing (R)- every 3 years from 2020; Annual (Assurance Schemes) • Aerial application – very limited, permitted application only • Protection of aquatic environment and drinking water • Risk in specific areas • Protected areas, amenity • Handling & storage, packaging • Sub-group & communication • Integrated Pest Management (IPM) – encourage and support uptake • Baselines, sectoral needs, IPM Plans • Indicators – Usage data (R), needs

15. Key issues: NAP • Protection of water • Best practice in Amenity and Amateur • Integrated approaches • Availability and viable techniques • Adoption

16. Indicators of Sustainable Use 3

17. Part 1: Training 4

18. Training and Certification Training – initial and on-going – by November 2012 Access for users, distributors and advisors, to recognise different roles Training bodies designated by the competent authorities. Certification - by November 2013 Establish certification systems. Designate competent authorities responsible for implementation Establish requirements and procedures to grant, renew and withdraw certificates.

19. Training Context Importance of training, market is able to meet demand and deliver to an appropriate quality. Retailer assurance schemes promote continuing professional development Regulation Law requires that all users must be trained initially. CRD has established system for designation of training bodies. Content of existing training courses has been updated Non-regulatory Industry has developed continuing professional development training programmes for users and initial and ongoing training for advisors and distributors

20. Figure 1: Indicator - User practice: National Register of Sprayer Operators (NRoSO) (number of members & % sprayed area) Source: VI Annual Report 2011-2012

21. Figure 2: Indicator - User Practice: BASIS professional register (number of members) Source: BASIS *2012 figure as at 31 Jan 2013

22. Part 2: Sales .

23. Sales distributors of non-professional products to provide general information on risks/mitigation/low-risk alternatives. by November 2015 distributers of professional products have sufficient staff with training certificate in employment. Staff with certificate to be available at time of sale. Micro-distributors may be exempt if not selling certain types of products. Member states to take measures to restrict sales of professional products to persons holding the certificate.

24. Sales Context Pesticides purchased ‘on account’. Responsible distributors make enquiries before selling to persons ‘unknown’ Regulation Law requires: distributors to have sufficient staff with certificate available at point of sale; any person who purchases a pesticide to ensure end user holds a certificate; distributors of non-professional products to provide general information; and that storekeepers take ‘reasonable precautions’ to protect human health and the environment Other measures High standards promoted by BASIS nominated storekeeper certificate Information for non-professional products on simple/clear labels and Amateur Liaison Group

25. Figure 3: BASIS Nominated Storekeeper (NSK) / Amenity Storekeeper (Amenity NSK) training courses: Total number of successful candidates Source: BASIS

26. Figure 4: BASIS Garden Centre qualification (Guardian Certificate in Garden Care): number of candidates and passes Source: BASIS

27. Part 3: Information and awareness raising 4

28. Information and awareness raising Member states to take measures to inform the public and facilitate information and awareness raising programmes Information should be balanced and accurate and cover risks to human health and the environment and use of non-chemical alternatives Member states to put in place systems for gathering information on pesticide poisoning incidents

29. Information and awareness raising Context Active sharing of information by government and stakeholders. EU Commission developing guidance document on monitoring systems Regulation Revised labelling to products (e.g. hard surfaces) Other measures Reviews on human health monitoring arrangements

30. Figure 5: Indicator - Consumer protection: Maximum Residues Levels compliance% of fruit and vegetable samples tested and found with one or more residues above the MRL Source: Defra Expert Committee on Pesticide Residues in Food

31. Figure 6: Indicator - Human health protection: PIAP investigations Number of incidents Source: HSE Pesticide Incident Appraisal Panel Report 2011-12

32. Figure 7: Indicator - Pesticide poisoning incidents investigated by the Wildlife Incident Investigation Scheme (WIIS) Source: CRD

33. Part 4: Inspection of application equipment 5

34. Inspection of application equipmentMany different deadlines Certified equipment used from 2016. 5 yearly tests until 2020, 3 yearly thereafter Possible exemptions or differing arrangements for certain types of application equipment Users to conduct regular calibrations and technical checks Designation of bodies to conduct tests/certification systems Mutual recognition of certificates

35. Inspection of application equipment • Context Market supplies demand for annual testing of application equipment • Regulation New law requires all equipment to be tested in line with requirements of the directive. Also requires CRD to designate bodies to conduct inspections, keep a register of inspectors and grant certificates. Low-scale of use equipment to be inspected every 6 years. Derogation for knapsacks and handhelds. Professional users must carry out regular calibration checks • Non-regulatory measures Retailer protocols specify annual testing of equipment

36. Figure 8: Indicator - User practice: National Sprayer Testing Scheme (NSTS) (number of sprayer tests and % sprayed area) % sprayed area number of tests Source: VI Annual Report 2010-11 and NSTS /AEA (2011/2012)

37. Figure 9: Membership of crop assurance schemes on holdings sampled in the United Kingdom Pesticide Usage Survey n = number of farms surveyed 1 = Surveys of GB only 2 = Excluding holdings only growing cider apples Source: Pesticide Usage Survey

38. Part 5: Aerial application Indicators 408 permits issued in 2012

39. Aerial spraying • Prohibited but derogation possible if conditions met • Designate authorities to set out conditions/ circumstances under which aerial spraying can be carried out • Designated authority to consider application plans and issue permits to spray • Monitoring to check compliance • Records to be kept and made available to the public

40. Aerial spraying • Regulation Law allows CRD to issue permit to spray only when relevant conditions exist. Aviation legislation also regulates low-flying activities. Nature conservation legislation also relevant where CRD permits applications in or close to protected areas • Non-regulatory Aerial Application Association developing Operating Standards (best practice guide)

41. Part 6: Measures to protect the aquatic environment and drinking water 6

42. Protection of the aquatic environment and drinking water • ‘Appropriate measures’ support Water Framework Directive • Give preference to particular products and application techniques • Use mitigation measures that minimise risk of off-site pollution – including buffer zones and safeguard zones • Minimise or eliminate applications on man-made surfaces with risk of run-off to water

43. Protection of the aquatic environment and drinking water • Context Pesticide pollution of water means that UK may fail to meet requirements of Water Framework Directive. Good understanding of pesticides which most frequently pollute surface waters and groundwaters • Regulation Use of risk assessment and mitigation measures. Users to take ‘reasonable precautions’ to protect the environment, confine spray to target areas, minimise use in identified higher risk areas and give preference to particular product types. Also use of water legislation • Incentives Use of subsidies to encourage adoption of best practice measures • Non-regulatory Government and industry published guidance (Codes of Practice, Voluntary Initiative, Campaign for the Farmed Environment, Get Pelletwise, Amenity Forum), Catchment Sensitive Farming programme • Research and Development programme to improve • understanding of behaviour of pesticides once released into the environment; precision of spraying; and safe disposal practice

44. Figure 10: Indicator - Surface water Drinking Water Protected Areas (DrWPAs) in England and Wales where assessments indicate pesticides are putting WFD Article 7 compliance at risk • 15% at risk of non-compliance • metaldehyde • MCPA • chlorotoluron • mecoprop-P • carbetamide • 2,4-D • propyzamide Source: Environment Agency

45. Figure 14: Indicator – Groundwater bodies in England and Wales failing WFD objectives due to pesticides • 5% at risk of non-compliance • bentazone • mecoprop-P • and 5 pesticides no longer available Source: Environment Agency

46. Figure 16: Indicator - Number of substantiated category 1 and 2 pollution incidents for land, air or water, involving agricultural and non-agricultural pesticides Source: Environment Agency

47. Part 7: Reduction of risk in specific areas 7

48. Reduction of use or risk in specific areas • Member states shall, taking account of hygiene, public health and biodiversity requirements, ensure use in minimised or prohibited in: • areas used by the general public or vulnerable groups (parks, gardens, sports and recreation grounds, school grounds and children’s playgrounds and in the close vicinity of healthcare facilities) • WFD protected areas or Natura 2000 sites • recently treated areas accessible to agricultural workers • The use of low-risk products and biological control measures shall be considered in the first instance

49. Reduction of use or risk in specific areas • Context 10% of all pesticide use in public spaces. Use in conservation areas also subject to conditions of nature protection legislation • Regulation Risk assessment process considers risk to public and workers in recently treated areas and imposes relevant mitigation measures (worker and human health protection legislation also relevant). Nature protection legislation imposes enhanced controls for sensitive sites • Non-regulatory Amenity Forum developing best practice guidance. Training providers launching NASOR and Amenity Assured • Research and Development into effectiveness and cost of integrated approaches

50. Part 8: Handling and storage of pesticides & treatment of their packaging and remnants 7