THEMATIC STRATEGY ON THE SUSTAINABLE USE OF PESTICIDES

HISTORICAL BACKGROUND

The 5th Environmental Action Programme called ”to achieve a substantial reduction of pesticide use per unit of land under production”. No action was taken but there were 7 studies made during the 1990’s to prepare a Directive. One stakeholders’ consultation meeting was held in 1998 with PAN Europe participation.

The 6th Environmental Action Programme (2001-2010) called to ”reduce the impact of pesticides on human health and the environment... as well as a significant overall reduction in risks and of the use of pesticides” and decision about measures for a Thematic Strategy on pesticides.

In May 2002, PAN Europe launched a ”Suggested text for a Directive on Pesticides Use Reduction in Europe (PURE)”. The PURE campaign is supported by 92 organisations and European federations of organisations in 30 European countries.

The Thematic Strategy on the sustainable use of pesticides is being prepared by Directorate General (DG) Environment of the European Commission in coordination with the revision of Directive 91/414/EEC by DG Health and Consumer Protection.

THE COMMISSION COMMUNICATION “TOWARDS A THEMATIC STRATEGY FOR THE SUSTAINABLE USE OF PESTICIDES” (2002)

As a first step, the Commission adopted the Communication on the sustainable use of pesticides in 4 July 2002.

PAN E participated at the Commission Stakeholders meeting concerning this Commission Communication in November 2002 and issued a position paper. In general, PAN Europe welcomes the initiative of the Commission, but believe that the Commission’s approach fails short of introducing strong and immediate European action. New European legislation to reduce pesticide use is needed inter alia because of the building evidence that pesticide use poses threats to children’s health and is causing increased contamination of groundwater, Europe’s primary source of drinking water. These problems require immediate and European action. The PAN Europe and European Environmental Bureau specific comments on the Commission Communication can be downloaded here.

The Environment Council Conclusions were adopted in December 2002 and called for a thematic strategy proposal in the beginning of 2004 where national programmes should have clear quantifiable objectives. It also called for the promotion of low-input or pesticide free crop farming, especially organic farming and for an EU framework for the development of Integrated Pest Management/Integrated Crop Management (IPM/ICM).

The European Parliament (EP) Resolution as adopted in March 2003 and was very critical towards the Commission Communication. It regretted the lack of ambition and the fact that very few legally binding measures, no economic instruments are proposed and the lengthy timetable for adoption and implementation. It called for a quantitative target of 50% of pesticide use reduction in 10 years, as measured by indicators such as frequency of application.

Several technical meetings followed in 2003 and 2004 (on compliance, aerial spraying, sprayers, indicators and collection of empty packaging).

EXTENDED IMPACT ASSESSMENT (2004)

The Extended Impact Assessment (EIA) "Assessing economic impacts of the specific measures to be part of the Thematic Strategy on the Sustainable Use of Pesticides" was finalised in October 2004 with PAN E input to BiPro consultants during its elaboration. PAN Europe also prepared a very critical position when published. You can download the full report or the extended summary in the relevant DG Environment web page.

Regarding aerial spraying, the environmental and health impact evaluations are key elements to consider. These evaluations in the EIA suffer from lack of reliable and comparative data and appear to be arbitrary. PAN Europe does not agree with BiPro evaluations and states clearly that the contamination of water, bystanders and non-target plants/wildlife will be much higher by “proper aerial spraying” with helicopters than with ground spraying.

For reduced or PPP-free zones, just like the European Parliament in its Resolution on the Commission Communication “Towards a Thematic Strategy on the sustainable use of pesticides”, PAN Europe asks not only for Member States to designate pesticide vulnerable zones, where use of pesticides is banned or severely restricted due to ecological and human health vulnerability, but also for the Commission to propose objective criteria for determining those zones.

As for quantitative use reduction, PAN Europe states that it is not enough, for health and environment protection reasons, to reduce just “unintended use of pesticides” as a result of the measures recommended in the BiPro report. Indeed, as it is extremely difficult to assess the real risk of pesticide use due to limitations of risk assessment and risk indicators and consequently impossible to determine an acceptable level for consumption of pesticides, it is necessary to reduce as much as possible the total exposure to pesticides by also reducing “intended use of pesticide". Therefore, like the European Parliament, PAN Europe urges Commission and Member States to adopt measures aimed at pesticide dependency reduction with targets (as measured by a dependency reduction indicator) and timetables.

You can download the full PAN Europe position here, covering the measures: aerial spraying, reduced or PPP-free zones, systematic data collection on use, training and certification of users, technical check of spraying equipment, common framework for IPM, enhanced protection of water and quantitative use reduction.

INTERACTIVE POLICY MAKING CONSULTATION (2005)

An Interactive Policy Making (IPM) internet consultation was held by the Commission from March-12 May 2005, although the design of the questions and the limited choice of proposed answers do not allow in various instances to reflect different and nuanced opinions.

PAN Europe called upon participation to this consultation exercise in order to avoid an even more diluted Thematic Strategy proposal and to counterbalance pesticides industry inputs via individuals and industry funded NGOs.

More than 17 PAN Europe partners, from 11 different countries, responded to the online consultation questionnaire and sent a complementary letter to DG Environment.

The results of the IPM consultation have been published by the European Commission. You can view the statistics and charts in the DG Environment relevant webpage.

Some of the answers proposed by PAN Europe were reflected in the results of the questionnaire. For example:

- the high importance of the proposed elements in the National Action Plans including the introduction of special requirements for application of pesticides by aerial spraying and the restriction on the use in public areas;
- the high importance of the proposed minimum requirements for training and awareness raising including the compulsory participation with certification of participants;
- the compulsory control and standardisation of sprayers;
- the introduction of specific measures for aerial spraying;
- the creation of areas of strongly reduced use or zero PPP use;
- the collection of packaging and obsolete products by the industry or a specific body for the purpose;

In other issues PAN Europe suggested answers were not the most voted but received a high number of answers, for example:

- the further definition of Integrated Pest Management;
- the taxation of PPP in order to influence the choice of least harmful products;
- the taxation of PPP in order to finance the measures of the Thematic Strategy.

EXPECTED CONTENTS OF THE FRAMEWORK DIRECTIVE ON THE SUSTAINABLE USE OF PESTICIDES

A) Mandatory national action plans to reduce hazards, risks and dependence on pesticides with the following minimal requirements:
1) Public participation in a Steering group to develop, implement, monitor and review action plan;
2) Reduction targets measured by risk indicators, possibly at crop and active substance levels;
3) Awareness raising campaigns for non professional users;
4) Measures for safe handling of preparations including ready-to-use products for amateurs;
5) Training requirements for distributors, advisors, users + certification
6) System for certification and monitoring of spraying equipment;
7) Set up of a structure for independent advice for professionals and amateurs + pest forecasting systems;
8) Specific requirements for aerial spraying;
9) Possible measures for protection of the aquatic environment
10) Designation of areas where use of pesticides has to be reduced
11) System for collection of packaging and obsolete pesticides
12) Monitoring and reporting of poisoning incidents
13) Promotion of organic farming, ICM (mainly based on Regulation on support to Rural Development, EU action plan on organic farming)
14) Promotion of research to reduce pesticide use
15) Taxes to finance measures might be considered
16) Report on the action plan and its publication

B) Commission steering group on the Thematic Strategy
Composed of various stakeholders including NGOs, academics and experts. To be created to assist Commission to:
- facilitate exchange of information between MS
- to prepare guidelines towards more harmonisation to be eventually considered for future revision of the Directive

KEY MISSING POINT: Pesticide use data and indicators calculation
Eurostat will propose a separate Regulation on the collection and reporting of data on the sales and use of pesticides:
- MS will have to report use data to Eurostat (spraying record keeping for farmers mandatory from 1st January 2006 according to food traceability Regulation)
- Eurostat to publish a report within 5 years on the indicators calculated and sales/use data but:
- worries concerning the degree of aggregation of use data for publication and on how these data could be used to refine ICM definitions to be included in the authorisation Regulation
- we are far from access to geographical mapping for (each) pesticide use

KEY MISSING POINT: sound IPM/ICM definition
Tendency of the Commission:
- to limit cross compliance requirements under Common Agricultural Policy (CAP) and therefore to keep a weak definition of general IPM in the new authorisation Regulation and consequently to leave to door open for voluntary approach by Member State to go beyond these general IPM requirements (agri-environmental measures)
- to leave for future revisions of pesticide authorisation Regulation, crop specific minimum ICM requirements , pending on comparison of crop specific use data from various Member States with comparable crop cultivation conditions and scientific progress.

As a consequence, no concrete steps towards precautionary pesticide dependency reduction: rather use reduction of unwanted pesticides (pesticide optimisation according to industry ICM definition) than pesticide dependency reduction as requested by environmental NGOs and other allied stakeholders.