Submission to Environmental Audit Committee on the Pesticides Voluntary Initiative

Friends Of The Earth & Pan-Uk

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Submission to Environmental Audit Committee on the Pesticides Voluntary Initiative from Friends of the Earth and PANUK, December 2003 Friends of the Earth and PANUK, both members of the Voluntary Initiative (VI) Steering Group, submitted joint evidence to the Environmental Audit Committee’s 1 2 inquiry into the VI last year . The Committee’s report of the inquiry set out several challenges to the VI concluding that the following year (ie 2003) would be a crucial one in which the VI should start to deliver on its objectives. The Committee recommended that a thorough assessment be carried out by the end of 2003. Although DEFRA has commissioned work on the best way of assessing the VI this is not due to be completed until the end of January 2004. A thorough review of the effectiveness of the VI seems unlikely before the middle of 2004. Friends of the Earth and PANUK consider that there has been little change in the progress of the VI over the last year and that there are some new areas of concern. In October this year Friends of the Earth and PANUK wrote to the Chairman of the Committee outlining our concerns (listed again below). This submission provides more detail on some of those points. We have also prepared a detailed assessment of the Catchment Management project which is key to delivering on the objectives for reducing water pollution. A separate report on this is available which shows that although the project includes some useful awareness raising work about farmyard practices it will not achieve sufficient improvements in water quality to avoid breaches of the EU Drinking Water Directive because the assumptions on which it is based are flawed. Key concerns: 1. There is still no attempt to reduce overall pesticide use or prioritise reduction of the most risky pesticides. There has not even been an agreement to reduce the use of single priority active ingredients such as the herbicide isoproturon (one of the most common contaminants of sources of drinking water).

1 Friends of the Earth and PANUK, 2002, Why the voluntary initiative will not deliver on government objectives 2 House of Commons Environmental Audit Committee, 2002, Pesticides: The Voluntary Initiative, November 2003

2. The principal of substitution, whereby more hazardous pesticides are avoided if safer chemical or nonchemical alternatives are available, is not being considered. 3. Targets have been weakened to make them easier to meet but projects are still behind schedule for meeting the revised targets. 4. Little progress has been made in terms of voluntary farmer incentivisation and compulsion is being used for some projects. 5. The VI has launched a misleading antitax campaign which exaggerates the benefits of the VI and uses the threat of the tax to try to convince farmers to take three of the VI actions. 6. Where there has been success in reaching farmers this has involved pilot cases with an intense use of resources that would be difficult to replicate on a national scale without substantial additional investment by farmers and industry. 7. Crop Protection Management Plans are effectively being made compulsory for farmers through the assurance schemes but they are no more than a form filling exercise. In its target the VI makes no distinction between farmers scoring a ‘poor’ rating on a CPMP and those achieving ‘good practice’. 8. Although information is now made available about overall costs there is still a lack of transparency about the detailed costs of different projects and we believe that in some cases costs to farmers may been underestimated. 9. We consider that costs are being unfairly passed to farmers for the disposal of obsolete pesticides. 10. Important information is not made available to the steering group as a matter of course, for example the Cherwell study that is crucial to several projects, and survey data on the quantities of obsolete pesticides on farms. 1 & 2 No attempt to reduce pesticide use or target risky pesticides for reduction or substitution with safer alternatives The Government’s policy objective for pesticides is to minimise pesticide use as well 3 as minimising environmental impacts . The Food Standards Agency has a policy of 4 minimising pesticide residues in food . The VI only addresses impacts and not use or residues. Following the EAC’s recommendation that a national pesticides strategy be prepared DEFRA is now drafting a strategy for consultation. Friends of the Earth and PAN UK consider that use reduction must be included in the strategy. Minimising pesticide use can be achieved in several ways: preventative action to minimize pest and disease problems; substitution of pesticides with nonchemical means of control e.g. use of natural predators; reduced application frequency; improved targeting of pesticides e.g. spot weeding; and better practice in filling and maintaining equipment. The Voluntary Initiative has focused heavily on the last two approaches and ignored the first three. This is, in our view, a significant failing. The most effective way of ensuring that use reduction also results in reduction of impacts is to take a hazard based approach to prioritise particular pesticides where 3 PSE, HSE, The Registration Handbook, Pesticides, Biocides, Plant Protection Products, A guide to the policies, procedures and data requirements relating to their control within the United Kingdom. 4 FSA, 2003, Progress on an Agency action plan to minimise pesticide residues in food, paper FS03/06/04, FSA meeting 12 June 2003

there is strongest evidence of harm to the environment, risk to human health, or high clean up costs due to water pollution. If this approach is not taken then the danger is that certain high use products such as sulphur will be targeted in order to demonstrate an overall reduction in use but adverse impacts may not be reduced for some time. However provided that there is a targeted approach we do consider that aiming for overall reduction will be more likely to result in the substitution of chemical pesticides with nonchemical means of control wherever possible rather than the substitution of one chemical pesticide with another. 3 Moving targets and failure to meet them Moving the goalposts In February 2001 the CPA put forward a series of targets for the VI. “We have set clear targets for each of our proposals. Together they form a substantial set of goals, 5 within the fiveyear period, that we are confident can be achieved” .Yet at the very 6 first meeting of the steering group it was agreed that the original project milestones 7 needed to be reviewed. Then in a paper to the steering group it is suggested that “As the Voluntary Initiative has progressed it is clear that some of the targets proposed in 2001 are unrealistic or are no longer appropriate. The Steering Group needs to agree new realistic and achievable targets”.This shifting of targets was noted in EAC’s report. In fact at least 5 out of 18 key targets have been changed to make them easier to meet. Some targets have changed several times over the last few years and others have still not been agreed Example: National Register of Sprayer Operators (NRoSO) This urges farmers and spray operators to join the National Register of Sprayer Operators to ensure that training is up to date. The targets that the VI is working towards for sprayer operators seem to be constantly changing. The initial target set 8 in February 2001 was for all operators to be on a CPD register by 2003 but by September 2003 this had been reduced to just 15,000 members by March 2004, with 9 several changes in between . Part of the problem is that the VI signatories have no idea how many pesticide sprayers are active, but they have estimated that there are 10 11 between 40,000 and 60,500 spray operators so aiming to get just 15,000 signed up is at best unambitious. The VI is behind on even its latest target. There were only 1,632 members signed up 12 according to the September 2003 minutes. If there are 60,500 sprayers, this is less than 3% of them. The scheme is also in a substantial financial deficit which will only be rectified if the 13 15,000 target is met The VI is now ensuring that this target is met by using 5 CPA, Minimising the environmental impacts of crop protection chemicals, Revised proposals – February 2001 6 st Minutes of the Pesticides Voluntary Package Steering Group, 21 September 2001 7 Paper to Voluntary Initiative Steering Group, 2002, Indicators and Targets for the Voluntary Initiative, Paper 02/0062, 4/9/02 8 CPA, Minimising the environmental impacts of crop protection chemicals, Revised proposals – February 2001 9 Paper to Voluntary Initiative Steering Group, 2003, National Register of Sprayer Operators, Paper 03/110, 2/09/03 10 th Minutes of the Voluntary Initiative Steering Group, 26 November 2001 11 CSL, 2001, A survey of current farm sprayer practices in the United Kingdom 12 nd Minutes of the voluntary Initiative Steering Group, 2 September 2003

compulsion. The VI is relying on “mandatory membership” through the farm assurance schemes which would enrol all operators treating more than 100ha. The 14 latest report on the project reports a rapid increase in application forms received now that farmers know that membership is compulsory to meet Assurance Scheme requirements. However only 4,062 forms had been received so it is difficult to see 15 how this project has been described as “83% complete” Moving the goalposts; how the target for sprayer operators has been reduced 1. February 2001  All operators to be on a CPD register by 2003 (CPA Revised Proposals Feb 01) 2. May 2002 – 5,000 members registered by December 2003 (update on sprayer certification, paper to steering group, 28/05/02) 3. Sept 2002 – 5,000 members per annum to achieve 20,000 members by 2006 (paper to steering group on indicators and targets 4.09/02) 4. Dec 2002 – all operators on farms with >100ha arable cropping to be members by end of 2004, 15,000 operators to have joined NRoSO by end of 2003 (update on NRoSO, paper to steering group, 9/12/02) 5. Sept 2003  15,000 members by March 04 (update on NRoSO, paper to steering group, 2/09/03) This is a project where reaching the target is very important if any environmental benefits are to be realised. Dr Burn of English Nature has commented that achievement on a national scale of NRoSO enrolment would not necessarily result in a similarly high achievement of environmental benefit because of the ‘dilution factor’ 16 of the behaviour of those not on the register . Example: National Test for spraying equipment This is an MOT style test for pesticide sprayers, but unlike MOTs it is voluntary. The original target set in February 2001 was for all ‘active’ sprayers to be tested by 2006, with an interim milestone of 50% of eligible machines tested within 36 months (CPA Revised Proposals Feb 01). The target has since been changed to “all sprayers with over 50ha cropping to be tested by 2005 (estimated 20,000 sprayers)”. The new target has been criticised by Lord Whitty for being unambitious. Inadequate environmental indicators The VI has agreed targets for water quality and biodiversity. However the emphasis is still on behavioural outcomes and project completion and discussions continue about how to better measure the real outcomes of the VI. At a steering group meeting in September 2003 Dr Burn of English Nature stated that there was“still a pressing need for better measurement of the outputs resulting from VI activity in the medium and longterm”. Little progress on environmental outcomes The EAC were particularly concerned with progress towards environmental outcomes 13 nd Minutes of the Voluntary Initiative Steering Group, 2 September 2003 14 nd Paper to Voluntary Initiative Steering Group, 2 December 2003, National Register of Sprayer Operators. Paper 03/0116 15 nd Paper to Voluntary Initiative Steering Group, 2 December 2003, Milestone Report for All Projects, November 2003, Paper 03/0114 16 nd Presentation by Dr Burn to Voluntary Initiative Steering Group, 2 September 2003

Example: Water The main target for water is very weak in that it only seeks“to maintain and increase downward trend with the objective of achieving a 30% reduction in detection levels 17 above 0.1ppb pesticides by 2006 ” Since 0.1ppb is the limit set by the EU Drinking Water Directive the VI should be aiming to eliminate such exceedences. Even with a weak target it is by no means certain that the VI will meet it, particularly when incidents of pollution with the herbicide IPU are considered. Despite a very intense input of resources into three catchment area projects spikes of water pollution continued, in one case seeing no improvement at all. The most recent Cherwell catchment newsletter (autumn) asks“do you know that there is still a pesticide 18 contamination problem in the River Cherwell, especially IPU?”In the Blythe and the Leam projects farmers were congratulated in 2003 because the levels of IPU 19 “reduced significantly last season” . However in the previous Newsletters for both 20 catchments the VI reported :“The very wet ‘back–end’ to 2002 meant that much isoproturon (IPU) was not used and water monitoring results must be viewed in this light”.These farmers appear to be given a pat on the back for achieving a result that was entirely due to the weather and not any action they took. The VI projects aimed at reducing water pollution are largely based on a single study of one herbicide (IPU) in the Cherwell catchment over two cropping seasons from 19982000. The VI has used this study to claimthat “40% of contamination of water 21 by pesticides is caused by run off from farm yards”The catchment projects, the operator road shows and the VI literature stress the importance of farmyard operations over the actual use of herbicides on the crop. The summary of the Cherwell study was circulated to the VI Steering Group, the full 22 report was not. However if the full study is examined it becomes clear that the importance of farmyard operations has been overstated by the VI. In the second year of the study, heavy rainfall soon after IPU was applied to the crop was the main cause of pollution. In drier years the contribution from point sources such as farm yard operations are likely to be more important, but in wet years runoff from the field will be much more significant. The study also indicated that spray drift can contribute to river pollution even when Good Agricultural Practice is followed. Overspraying of ditches was also a possible source of IPU pollution. The study shows that filling and cleansing operations and spray drift can increase the amounts of herbicides in rivers and it is therefore important that farmers follow good practice. However the other conclusion that can be drawn from the study, but which has been ignored by the VI, is that the only certain way to avoid costly cleaning of water supplies to ensure that legal limits are not exceeded is to ban IPU. It should be noted that bans on two other pesticides that are currently major water pollutants, atrazine and simazine, are coming off the market as a result of the EU review of active ingredients so that progress towards the target will happen without any action on the part of the VI.

17 Voluntary Initiative report, Voluntary Initiative Indicators and Targets 18 For example in the Upper Cherwell newsletter ‘why worry about water?' October 2002 19 Voluntary Initiative, 2003, Blythe and Leam Catchment newsletter Autumn 2003 20 Voluntary Initiative, 2003, Blythe and Leam Catchment newsletter no 2 March 2003 21 VI leaflet, Every drop counts: keeping water clean 22 ADAS, River Cherwell Catchment Monitoring Study 19982000 Project Report, prepared for Aventis CropScience

Poor reporting on progress The EAC also wanted to see progress towards targets clearly reported in the annual report. Although the Steering Group now receives regular progress reports and the latest Annual Report includes a progress report on projects, the means of measuring progress is unclear, and seems to relate more to project activity than targets. For example progress on the NRoSO projects was reported as 83% complete when membership of NRoSO was only at about a third of the target. In the Annual Report progress on water catchments was also reported as 83% completed, which clearly does not relate to success in reducing pollution incidents. The Obsolete Pesticide Disposal Campaign was recorded as 79% complete although the scheme had just been launched; the project may be nearing completion but the important measurement will be quantities of obsolete pesticides safely disposed of. 4, 5 & 6 Little progress on farmer incentivisation despite antitax campaign The EAC was concerned about the lack of farmer incentivisation. It is clear that little progress has been made in this area with the VI resorting to a blatant antitax campaign to try to persuade farmers to take up the VI actions. It has also made some of the key measures effectively compulsory for farmers by including them in the farm assurance schemes. Even with these in place the VI is way behind on key targets. A farmer commenting on the VI in Farmers Weekly (October 2003) said “When the VI was introduced it was just that, voluntary. Now that it clearly has little support it is being made compulsory”.He went on to say that“A better alternative would be to accept a pesticides tax, allowing all VIregistered farms to reclaim it like 23 VAT” Antitax campaign misleads farmers The anti tax campaign, coordinated by the pesticides industry (the CPA) but under the banner of the VI, urges farmers to take three actions (join sprayer register, get sprayer equipment tested, and fill in a CPMP form). This summer, materials have been distributed to farmers at agricultural shows and the message has been promoted in the farming press and on the VI website. However, to avert the tax the VI has to show government that it is making real progress towards minimising the environmental impact of pesticides. These three actions are unlikely to make any significant difference to pesticide use or impacts, and so are unlikely to convince the government that the VI is more effective than a tax. The CPA is also stating that these actions will “Save Crops, Costs and the Countryside” implying that farmers will save money and make a contribution to reducing environmental impacts. We consider that these materials are misleading. The materials say that the tax would cost farmers £125m a year. This is repeated in the newsletter distributed to farmers in the water catchment projects which states that a tax would“wipe £125 million a year off UK farming’s bottom line”.But the tax could raise £130m a year which could be recycled back into farming. So by averting the tax for the last three years the VI could be said to have deprived farming of £390m. It is the pesticide industry who are really set to lose if a tax is introduced, not farmers, unless the companies start to develop alternative controls (e.g. biological controls) that they have so far shown little commercial interest in. The materials also fail to tell farmers what the costs of the VI are, including the three measures they are urged to take. The three actions being promoted in the campaign are: 23 Farmers Weekly, 2003, VI Voluntary Status comes under review, October 2430

1. Join NRoSO 2. Use NSTS 3. Do a CPMP The first two of these have direct costs to the farmer, and the development of a CPMP could represent a significant cost if the farmer employed an agronomist and/or farm wildlife advisor. However, the lack of take up on the first two of these measures (as described above) suggests that farmers are not responding to the antitax propaganda. Interestingly, in its report on the water catchment projects the CPA has recently admitted that “positive messages such as practical advice and help are more effective in changing 24 behaviour than negative messages such as the threat of a pesticides tax” . Intense use of resources needed to reach farmers Where there has been success in reaching farmers this has required an intense use of resources, as has been shown by the catchment projects. This could not realistically be scaled up to national level For example, in three of the catchment projects text messages were sent every week to every farmer during the spraying seasons, and three newsletters were distributed to every farmer, agronomist, distributor and spray contractor in the area. Even with this intense outreach work water pollution spikes continued. Although there appeared to be some improvement in two catchments, this may have been due to weather conditions leading to a reduction in the amount of herbicide that could be sprayed. 7 Crop Protection Management Plans ‘compulsory’ but still a paper exercise The EAC report raised concerns about progress on CPMPs, and also suggested that they may be little more than a paper exercise adding little to existing schemes. This fear seems to have been confirmed. As noted above farmers are being urged via the antitax campaign and in the farming press to get on with filling in a ‘Crop Protection Management Plan’. The CPMPs are a self assessment form on which farmers should record the efforts they are making to use pesticides more safely and reduce environmental impacts. This approach has clearly not worked well enough since filling in a CPMP will become compulsory by its inclusion in the farm assurance schemes ,therefore adding to the bureaucratic burden for farmers without bringing any significant environmental benefits. In the farming press farmers are reassured that filling in a CPMP won’t take long, which suggests that it is simply a form filling exercise. This is confirmed by the fact that the VI target will only measure numbers of farmers filling in a CPMP and will not measure changes in practice or the effectiveness of the plans. Farmers who tick all the boxes with a ‘poor’ rating will still count towards meeting VI targets. For example, a farmer who has no safe storage for pesticides, sprays too close to water courses, and is totally dependent on chemical pesticides would count as a success just for filling in the form. 24 Report to Voluntary Initiative Steering Group, 2003, Water Catchment Protection, Paper 03/0115, nd 2 December 2003

How bad practice scores you points with the VI Even if a farmer ticked all the following boxes their CPMP would be counted as progress towards the VI target: “no knowledge of or no codes available on farm” [refers to approved Codes of Practice] “total reliance on plant protection products” “pest and disease control by chemical means only, yield is the only consideration” “products selected by price and effectiveness only” ie no consideration of environmental impact “no records kept” ie no records of pesticide treatments made “no knowledge of what is in stock. No stock records. No annual checking of stock” “no training ever undertaken” ie no training in proper application of pesticides “no assessment made” of farm’s environmental features “no special measures taken” to reduce exposure of nontarget organisms and vulnerable habitats to pesticides 8 & 9 Lack of transparency about costs/costs passed unfairly onto farmers The EAC wanted to see details of costs in the Annual Report. Although information is now made available about overall costs, including a table in the latest Annual Report, there is still a lack of transparency about the detailed costs of different projects and we believe that in some cases costs to farmers may be underestimated. Friends of the Earth looked at one project in more detail (pesticide retrieval costs) because the figures for costs to farmers appeared low, and it appears that costs have been underestimated. Example: pesticide disposal The CPA has estimated that the costs to farmers for the disposal scheme will be £1,300,000. It is not clear how these costs are calculated but a number of assumptions seem to have been made that seem unrealistic. The first assumption is that there is a small percentage of farms that are storing 25 obsolete pesticides. A recent survey of farm waste estimated that there are 28,000 holdings with agrochemical waste. However this survey was carried out in February to April 2003. After the survey in July 2003 45 active ingredients came off the market as a result of the EU review of active ingredients. It will be illegal for farmers to use st these products after 31 December 2003, but many farmers would not have been aware of which products were affected at the time of the survey. The surveyors asked farmers whether they were aware of the review and which products would be affected: only 35% of respondents were aware that any pesticides were being revoked and only 26% thought they had a ‘good level of knowledge’ of the changes that would result. It is therefore likely that there will now be additional waste products for disposal which were still in use at the time of the survey and would not have been recorded by the farmer as waste. The second assumption is that all those farmers that do have products needing disposal will be able to negotiate a significant reduction in the normal price. Although waste companies have said that they will offer a discount to farmers who group together so that products can be picked up on a ‘milk round’ system, it cannot be assumed that the majority of farmers will be able to organise in this way, especially if

25 Environment Agency, 2003, Agricultural waste survey 2003

the proportion of farms with products for disposal is small as claimed as there may be many farmers whose neighbours do not have products. For the cost to farmers to be as low as £1,300,000, even assuming that only 28,000 holdings had waste products (ie that there are no additional farms with products for disposal as a result of the EU review) this would require the cost per farm to be as 26 low as £46.43. The ‘typical’ cost quoted by Biffa is £95 and a quote from 27 Cleanaway gives the cost at £128 . So this would be a very significant reduction, unlikely even if every farmer managed to organise his or her neighbours into a milkround. In our view this figure is a significant underestimate of the total cost to farmers. It also masks the fact that for some individual farmers, who are in a remote location, the costs could be considerably higher than the ‘typical’ cost. Friends of the Earth and PANUK are concerned that the costs of disposal of pesticides could be a barrier to safe disposal. We believe that the pesticides industry should cover the costs of the disposal of their products, especially because many products which have been removed from the market are the result of the company deciding not to support that product rather than a ban on health or environmental grounds. A MORE EFFECTIVE WAY FORWARD In order to meet the Government’s objectives to reduce pesticide usage, residues in food, and the environmental impacts of pesticides, a package of measures is needed including support for farmers, regulation and fiscal instruments. This approach has worked well in other EU countries such as Sweden and Denmark where reductions in pesticide use have been achieved. Denmark has successfully reduced the treatment frequency of pesticides (average number of times per year agricultural land is treated 28 with the pesticides sold) . In Sweden the quantity of active ingredient sold was 29 reduced by 61% between 1991 and 1995 and by 60% between 1996 and 2000 . In Denmark, the provision of an independent farmer advisory service has been crucial in supporting farmers to reduce the frequency of application of chemical pesticides, 30 and the outcome has been achieved with no economic loss to farmers Regulatory measures should include: • Mandatory sprayer operator registration (likely to be required by the EU Thematic Strategy on the Sustainable Use of Pesticides). •spray equipment testing Mandatory • Bans on the most risky pesticides. • Changes to the regulatory process to enable nonchemical products to be assessed in an appropriate manner rather than under the same process as chemicals. Fiscal measures should include: •banded tax on pesticides products to discourage the use of the most A problematic pesticides (covering a range of problems from high toxicity to soil 26 th Farmers Weekly Interactive, 2003, Clean up with spray away campaign, Arable News, 14 November 2003,www.fwi.co.uk 27 figures given to Friends of the Earth by a farmer who obtained a quote from Cleanaway 28 PANUK, 2002, Danish success with Pesticide Action Plans, Pesticides News 57, September 2002 29 PANUK, 2002, Persistence Pays, lower risks from pesticides in Sweden, Pesticides News 54, December 2001 30 Presentation by Danish Agricultural Advisory Service to PAN Europe conference, November 2003

mobility) and to raise funds for measures to support farmers in finding non chemical alternatives Support for farmers should include: •free independent sustainable farming advisory service for farmers A •R&D into nonchemical means of pest and disease control. Increased Changes to PSD’s remit •should become responsible for pest management, not solely chemical PSD pesticide approvals Friends of the Earth Regional office 74 Kirkgate Leeds West Yorkshire LS2 7DJ Tel [phone] Fax [phone] Email [e-mail] Website www.foe.co.uk Friends of the Earth Limited Registered in London No 1012357 Registered Office 2628 Underwood Street London N1 7JQ Printed on paper made from 100% postconsumer waste