National Action Plan for the Sustainable Use of Pesticides

1 Mar 2021

FPC responded to the consultation on the Revised National Action Plan for the Sustainable Use of Pesticides.

FPC believes that the availability of safe food of good quality at affordable prices can be achieved within a profitable and competitive horticultural industry by the application of scientifically-proven good horticultural practices.

In many cases, these focus on the reduction, whenever possible, of the use of chemical pesticides through the adoption of viable integrated crop management (ICM) systems. FPC provides to its members a’ Code of Practice for the Control of Pesticides’ which sets out guidance on due diligence, as well as systems and procedures which can minimise the risk of pesticide residues exceeding maximum residue levels.

We welcomed the aim to reduce the risks and impacts of pesticide use on human health and the environment and to promote the use of integrated pest management and of alternative approaches or techniques such as non-chemical alternatives to pesticides.

The UK Action Plan takes into account existing non-regulatory approaches and their delivery by stakeholders, for improving education, knowledge exchange and advice. We believe that the UK Government should recognise and support such activities and the value of professional tailored advice from agronomists.

Constraints on the availability of pesticides in the horticultural sector is a key concern. Growers already have a limited range of products to protect horticultural crops, and in some instances there will be no viable alternatives for treating common pests which reduce yields and damage fresh produce. It may become uneconomic to grow some crops such as sprouts and carrots, and lower yields will mean hard-pressed consumers will have to pay higher prices for their fruit and vegetables, including apples, pears, raspberries, leeks, peas and beans.

With the potential for increased pest/weed/disease resistance and a limited number of chemicals available in the horticultural sector, it is vital that we look at developing all tools available to meet future challenges for crop production. We would like to see more details about technology transfer from Defra R&D projects to the industry. Our members have raised concerns that the UK is lagging behind other countries in the following areas:

• Increasing organic fresh produce market growth.
• Development and implementation of integrated crop management.
• Registration of bio pesticides.
• Management of introduced predators, predominantly in UK protected crops.
• Management of natural predators, through habitat architecture and understanding the dynamics of pest/predator numbers. The ability of growers to ‘fine tune’ natural systems by using beneficial-friendly pesticides has been reduced considerably in recent years by the loss of several pesticides.

The revised NAP has changed the emphasis on different aspects of IPM from the definition in Annex III of the Sustainable Use Directive. For example, it assumes a much greater availability of information on thresholds than actually exists.

Thresholds used are already ‘dynamic’ and agronomists will use their experience to assess how the crop will be affected over the next week or so based on the evidence in front of them.

Concerns have been raised that any ‘metrics’ required by the NAP, for example to track how much IPM is being undertaken, will add a significant level of bureaucracy and additional work to the process, and could detract potentially from the resource available to growers to implement IPM.

More work needs to be done to bring opportunities identified in previous research to fruition as commercial products available to UK growers. We would like to see AHDB and others build on outcomes from valuable initiatives such as SCEPTREplus to identify new and extended uses of existing and emerging crop protection products, including non-chemical treatments and products.

Without this urgent focus, the industry faces the position of potentially being unable to grow certain crops commercially in the future. The need to future proof our UK industry with the development of Integrated Crop Management Systems is crucial to ensure a sustainable and competitive industry.

Research and development bodies need to take a more collaborative approach. Greater use of data sharing across the supply chain is essential to avoid duplication of efforts where there are limited resources for the horticultural sector. This should include the need to work with other bodies in the field of automation and robotics which will require working with partners outside our industry.

It is essential that any revised Plan continues to support the UK horticultural and potato sectors by identifying technology, skills and knowledge needed for the industry to become more competitive, increase productivity and future resilience in a post-Brexit environment.