UK and EU policy for approval of pesticides suitable for organic systems: Implications for Wales

Summary

This study was commissioned by the Welsh Assembly Government (WAG) to review the pesticide approval system in the UK and Europe as far as it affects the use of substances and techniques for crop protection by organic producers in Wales. WAG considers it important that the UK pesticide approval system does not present unnecessary barriers to the development of organic production in Wales.
Key Recommendations and scope for further work
· WAG should work with the Pesticides Safety Directorate to ensure that the development of pesticide regulatory policy at both National and European level takes full account of the needs of both conventional and organic agriculture and horticulture in the UK.
· There is scope for WAG to support the development of a National Pesticide Policy so that regulatory and commercial barriers impeding the development of organic pesticides are minimised. Not only could greater availability of ‘organic pesticides’ have a significant impact on organic production in Wales but there could be important implications for conventional horticulture systems and the use of alternatives to conventional pesticides.
· One important regulatory barrier to the registration of ‘organic pesticides’ is the MRL requirement(s) for their approval and this needs to be resolved. Suitable analytical techniques are required to determine firstly whether these substances result in residues, and secondly to identify the breakdown and residue pathways. So far, this issue has not received the attention of any EU Member State.
· According to the proposed framework for the 4th Stage Review of EU Pesticides Directive 91/414, notifiers are required to produce a dossier, at their own expense, covering characterisation, human toxicity, ecotoxicity efficacy and other relevant data. The Review includes specific provision for companies notifying the same substance to submit a shared dossier. This will help those businesses (many of which are relatively small companies) to save on the high cost of producing the dossiers. It will also aid the Commission since it will reduce the number of dossiers that have to be considered, and ensure that all the available data is included. WAG should encourage and support the production of collective dossiers; although as yet there is no indication of how this will be done in practice, and further details from the Commission are awaited.
· This study has concluded that access to a wider range of ‘organically acceptable pesticides’ would not have a dramatic impact on organic production in Wales. However, in developing an integrated organic policy, WAG should continue to address the pesticides issue. Some of the methods of pest & disease control in organic systems are either physical or multi-cellular e.g. micro-organisms used as biocontrol agents. WAG agri environment policy may provide a vehicle to promote these techniques much more actively. Further, it is important to recognise that while Wales alone is too small to have a major impact on commercial and regulatory pressures, WAG can have an impact by working pro-actively with others to make progress.
· There are no published EU or national Member State criteria that can be used to evaluate the acceptability of pesticide substances for organic production. Identifying such criteria and promoting their acceptance at EU level and nationally would allow more active substances to be made available. WAG should work with PSD and others to identify appropriate criteria.
· The specific provisions of Article 7 in Annex 2(b) of the Organic Regulation (2092/91) place potential barriers to the adoption of organically acceptable substances for crop protection. There are a number of potentially useful substances currently not included in the Organic Regulation e.g. potassium bicarbonate. WAG should work with PSD and others to identify such substances and support the production of appropriate dossiers. WAG could also encourage further dialogue between the organic sector and Defra to identify amendments in the Organic Regulations to facilitate the inclusion of new pesticides.
· Organic pest and disease management is not just a question of inputs but it also relies crucially on advice and extension through initiatives such as Farming Connect and the work of Organic Centre Wales. Long-term commitment to supporting on going advice and extension activities is vital to promote and disseminate best practice in Welsh agriculture and horticulture.
· Organic horticulture, vegetable and fruit production systems are particularly sensitive to pest and disease management. Successful control of pests, diseases (and weeds) in these sectors can be critical to the business, and is not assured even when all husbandry and management methods have been effectively applied. Consequently, the use of organically acceptable crop protection methods resulting from future developments (e.g. biopesticides, biological control agents) could have an important role in pest and disease management in these sectors. Both organic and conventional producers in Wales could benefit from having these options available to them and WAG could encourage the adoption of these approaches through appropriate Technology Transfer activities.
· The way in which such substances will be regulated at a European level in future is evolving as the review of the Pesticide Directive 91/414 EEC enters the 4th Stage. This stage of the review includes (amongst others) those substances permitted for use in organic production. The guidance documents for the evaluation of applications on plant protection products made from plants or plant extracts and from chemical substances are currently at the draft stage. The response of the Pesticide Safety Directorate and Defra to these developments is not yet clear but this provides an excellent opportunity for WAG to have an input at an early stage in the review process.