Summary of Response to Consultation by Defra, Welsh Government, Scottish Government, Northern Ireland Government by William Wilson, Barrister, Wyeside Consulting Ltd, 26th February 2021.
Summary
The Draft Revised National Action Plan for the Sustainable Use of Pesticides fails to answer fundamental questions about the impacts and overuse of pesticides in the United Kingdom. It advocates Integrated Pest Management and ‘sustainable crop protection’ but stops short of setting any actual targets to reduce pesticide use, or antimicrobial use, in strong contrast to the EU’s ‘Farm to Fork Strategy’ announced as part of the EU Green Deal. It reflects a lack of urgency about the impacts of pesticides in food, in drinking water, surface waters and groundwater, and their effects on wildlife.
Pesticide average inputs per crop are going up, not down (NAP Annex 1, Table 1), as are cumulative numbers of active substances and products approved as biopesticides, and estimated pesticide usage in arable crops in Great Britain (3.4 Pesticide Usage, pp. 58-59).
Over half of foods sampled in the UK contain pesticide residues – (Expert Committee on Pesticides Residues in Food, Annual Report 2019). In combination or ‘cocktail effect’ exposure to pesticide residues in food does not appear to be addressed by the draft NAP at all.
The draft NAP makes no commitment to reduce actual overall pesticide use: it only promises by 2022 targets “to support the reduction of risk associated with pesticide use”. This is in contrast to the EU, which has announced in its ‘Farm to Fork Strategy’ as part of the EU Green Deal, aims to reduce the overall use and risk of chemical pesticides by 50% and the use of more hazardous pesticides by 50% by 2030; and to reduce sales of antimicrobials in farmed animals and aquaculture by 50% by 2030 – https://ec.europe.eu/food/farm2fork.en
If pesticides are contributing to continued non compliance of UK water bodies with existing law, and to the decline in numbers and variety of farmland birds and pollinators, (the draft NAP appears to confirm this) it would be a further argument for reduction in pesticide use.
The draft NAP does not appear to address clearly earlier criticisms that the regulatory system does not deliver adequate monitoring of pesticide residues when applied at the landscape scale. It does not appear to address such concerns with respect to glyphosate, residues of which appear in many foods.
The information on pesticides and their use provided to the public is almost unintelligible, difficult of access and hard to interpret clearly. The public needs unbiased, clear information that it can trust in order to have confidence in the system of controls on pesticide use, and big improvements should be made in this area.
For further information, contact William Wilson at <info@wyesideconsulting.com>