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Biopesticides: Environmental and Regulatory Sustainability. Wyn Grant with Justin Greaves. Crop production and pest management: the challenges. Pesticide product withdrawals Pesticide resistance Zero detectable residues Sustainable food chain: economic, environmental, social

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crop production and pest management the challenges
Crop production and pest management: the challenges
  • Pesticide product withdrawals
  • Pesticide resistance
  • Zero detectable residues
  • Sustainable food chain: economic, environmental, social
  • Integrated Pest Management (IPM)
biopesticides mass produced biologically based agents used for the control of plant pests
Biopesticides: mass produced biologically based agents used for the control of plant pests
  • Living organisms (natural enemies)
      • Micro-organisms
      • (Arthropods & nematodes)*
  • Naturally occurring substances (‘biochemicals’)
      • Plant extracts.
      • Semiochemicals (pheromones & allelochemicals).
      • Commodity substances.

*Not regulated by Plant Protection Products (PPP) legislation.

Pests = arthropods, plant pathogens & weeds.

plant protection product registration system
Plant protection product registration system
  • Two-tier system of registration (legislation under revision in co-decision process)
  • Active ingredients at EU level, products at member state level
  • National authorisations PSD
  • Mutual recognition not working
biopesticide ppp active substances listed on annex 1
Biopesticide PPP active substances listed on Annex 1
  • 40 insecticides (27 pheromones, 8 microorganisms, 5 baculovirus)
  • 20 fungicides (all microorganism non-Bt)
  • 1 Nematicide, 6 Repellants (all botanical), 2 others (both botanical)
  • Includes substances voted with entry into force date of 1 May 2009
biopesticides and ipm
Biopesticides and IPM
  • Often very specific
  • Compatible with other control agents
  • Little or no residue
  • Inexpensive to develop
  • Natural enemies used in ecologically-based IPM
  • Lower potency than synthetic pesticides
but uptake has been low potential benefits are not yet being realised
But uptake has been low & potential benefits are not yet being realised
  • Economics (market size, external costs).
  • Efficacy (potency, application, formulation).
  • IPM (integration, best use of biological characteristics).
  • Regulation (system principles, design & operation).
  • How can research help? Theory & application.
work of natural scientists
Work of natural scientists
  • Ecology of insect pathogenic fungi
  • Genetic structure of natural populations
  • Ecological factors determining the occurrence of natural populations
  • Theoretical basis for understanding fate, behaviour and environmental impact of biopesticides strains
focus of political scientists
Focus of political scientists
  • Regulatory state perspective (Moran)
  • Underlying design principles
  • Stakeholder relationships (policy networks)
  • Role of retailers
  • Inform regulatory process, including training of regulators
regulatory innovation
Regulatory innovation
  • Forthcoming paper by Justin Greaves in Public Policy and Administration
  • Regulatory innovation a contradiction in terms as regulators are cautious and risk averse
  • Combination of exogenous and endogenous pressures induces change
improved knowledge base and chain
Improved knowledge base and chain
  • Better understanding of ecology of microbial control agents
  • Availability of expertise for PSD and ACP
  • A more effective knowledge chain linking, e.g., growers and researchers
underlying principles 1
Underlying principles (1)
  • Biopesticides have a key and specific role to play in crop protection as part of IPM – problems of resistance and reduced availability
  • Biopesticides should be regulated – because something is ‘natural’ does not mean that it is safe
underlying principles 2
Underlying principles (2)
  • The regulatory system must support sustainability objectives
  • This includes economic sustainability
  • The ability of SMEs to succeed and growers to have the right plant protection tools
underlying principles 3
Underlying principles (3)
  • Pest management should be ecologically based
  • Biopesticides offer benefits to conventional and organic farmers
  • Credibility with all stakeholder groups and especially consumers is key – problem of name
stakeholder involvement
Stakeholder involvement
  • Weak, immature and poorly integrated policy network
  • REBECA (EC policy action) helped, but follow on?
  • Further organisational development of IBMA
  • Where is constituency of support?
a quasi governmental champion
A quasi-governmental champion
  • Provided in USA by Biopesticides and Pollution Prevention Division of EPA
  • PSD as regulatory agency not really equipped for an advocacy role
  • Possible role for Natural England?
  • Risk of case being sidelined
organisation of psd
Organisation of PSD
  • Now part of HSE, a work in progress
  • Continue to develop work of Biopesticides Champion and team
  • Still uncertainties about organisational culture
  • They have been trained, now they need more customers
efficacy testing
Efficacy testing
  • Submission of data not required in US
  • Needed for marketing purposes and to protect product reputation
  • Work of Biopesticides Steering Group of OECD
  • Support REBECA proposal to allow applicants to defer efficacy testing
biopesticides scheme
Biopesticides scheme
  • A welcome development, but still outreach challenges
  • Importance of early pre-submission meetings
  • Distinctive approval number for Biopesticides?
  • ‘Grey market’ of leaf enhancers, plant strengtheners etc.
role of retailers
Role of retailers
  • Reflect consumer concerns
  • Ask for requirements that go beyond approvals system
  • Variations between retailers increase complexity for growers
  • Prohibit rather than promote specific products – which is difficult for them
european dimension
European dimension
  • Revision of 91/414 not complete
  • Concerns about way in which EFSA operates
  • Development of informal networks between regulators
  • Eco zone proposal has attracted some criticism
assistance with costs
Assistance with costs
  • Still a gap between product ideas and an approved product on the market
  • Some products may not be viable
  • Market failure in terms of positive externalities not being realised
  • Constraints of EU state aid rules
visit our web site
Visit our web site
  • http://
  • Thanks to project team – Dave Chandler, Justin Greaves, Gillian Prince, Mark Tatchell