Thought Starter for Working Group 2

Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides – Thought Starter – Working Group II: Integrated Crop Management The role of this Conference is to bring together all of the major stakeholders to discuss the European Commission’s Communication Towards a Thematic Strategy on the Sustainable Use of Pesticides. It is hoped that by the end of the day's discussions, all stakeholders will have had a chance to express their views on the Communication and the future strategy, and that convergences and divergences of opinion, as well as concrete proposals to bridge them, will be identified. The workshop will gather all experience so far gained from the practical application of the current regulatory framework and facilitate exchange of this information. * The main objectives of the Thematic Strategy on the Sustainable Use of Pesticides, as defined by the 6th Environmental Action Programme are:1 1. to minimise the hazards and risks to health and environment from the use of pesticides; 2. to improve controls on the use and distribution of pesticides; 3. to reduce the levels of harmful active substances including through substituting the most dangerous with safer, including non-chemical, alternatives; 4. to encourage the use of low input or pesticide free cultivation among others through raising users' awareness, promoting the use of codes of good practices, and promoting consideration of the possible application of financial instruments; 5. to establish a transparent system for reporting and monitoring progress made in fulfilling the objectives of the strategy including the development of suitable indicators. This working group will address actions needed for an enhanced integration of harmonised Integrated Crop management (ICM) in Europe, it will focus on: • • • • • • • • • • policy issues, potential problems and solutions related to ICM and its development (including harmonisation of definition); ways to avoid any overlaps or contradictions in the system; ways to harmonise, improve, and speed-up implementation of existing instruments; ways to improve accountability of the current regulatory system; ways to address gaps in the existing system; potential needs and ways to develop an extended regulatory framework in order to achieve the identified objectives for the further uptake of ICM; ways to address ICM integration at member state level and local level (regional variability), including in the context of enlarged EU; ways to involve all stakeholders in the control/certification system; ways to build-up stronger public confidence in ICM; The role of the future thematic strategy in addressing these issues. * 1 OJ L 242, 10.9.2002, p. 11 p. 1/9 Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides This Thought Starter is divided into 3 sections: Section I – Background from the Communication – contains an overview of key points identified in the Commission Communication "Towards a Thematic Strategy on the Sustainable Use of Pesticides", which relate to the topic of the working group. Section II – Commission proposals for instruments and initiatives – contains a list of Commission proposals as presented in the Communication. Section III – Stakeholders' input – contains proposals and comments put forward by stakeholders in: (i) position papers; (ii) comments on the Communication sent to the European Commission; (iii) presentations and posters for this conference. There are clear overlaps between issues to be addressed by the 3 working groups and relevant information might also be found in the other working groups' thought starters. Working groups should however focus their work on their specific topic. * Section I: Background from the Communication IPM / ICM / Organic production • In Directive 91/414/EEC – on the placing of Plant Protection Products (PPP) on the market – Member States are required to prescribe a proper use of PPP, including not only the exclusive use of PPP authorised, packaged and labelled in accordance with the Directive, but also compliance with the conditions specified on the labelling and the application of the principles of good plant protection practice as well as, whenever possible, the principle of integrated control. Regulation 1259/1999 – on common rules for direct support schemes under the CAP – establishes a link between environmental protection requirements and direct support to producers from the CAP. Member States must take the environmental measures they consider appropriate such as: support in return for agri-environmental commitments, general mandatory environmental requirements, specific environmental requirements constituting a condition for direct payments. With respect to the latter two options, Member States are authorised to use cuts in direct payments as sanctions to support the enforcement of environmental requirements. • Relevant for pesticide use are the agri-environmental measures, through which farmers are paid for environmental services they provide beyond the level of Good Farming Practice. Regarding pesticide use, this can include reporting on actual use of pesticides, lower use of pesticides to protect soil, water, air and biodiversity, the use of Integrated Pest Management (IPM) techniques, or conversion to organic farming. Agri-environmental measures have already influenced PPP use directly, for instance by promoting IPM, ICM, and organic farming. Despite the fact that less than 3.5 % of the total CAP spending is devoted to agri-environmental p. 2/9 • • Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides measures, such measures affect more than 20% of the total agricultural area in the EU. There have been highly successful results in the reduction of PPP use in individual regions with specific programmes, for instance in Emilia Romagna (Italy), with reductions of up to 55% for certain types of production. • Organic farming, regulated by Council Regulation (EEC) 2092/91 and supported by agri-environmental measures, greatly reduces pesticide use. However, some PPP, regarded as traditional in organic farming, are still authorised for specific purposes (the most controversial are certain copper salts, which are toxic for the aquatic environment). While these are also used in conventional agriculture, successful efforts have been undertaken to limit their use in organic farming. An evaluation of whether the cultivation of GMOs will lead to a reduced risk related to the PPP use is currently ongoing. The Commission has recently set up a Working Group on Herbicide Tolerant Crops in the framework of Directive 90/220/EEC, which among other tasks will consider the use of herbicides on such crops. One of the major problems is the possibility of uncontrolled transfer of the resistance genes to weeds, which has already been observed for rape and beet. In its Communication on Life Sciences and Biotechnology, the Commission has recently announced an action plan including e.g. the reinforcement of the monitoring of potential long term effects of GMOs. In the framework of the Common Organisation of the Market in fruit and vegetables, support is granted to producer organisations for the implementation of operational programmes that must obligatorily comprise environmental measures (going beyond application of good farming practice), including measures aiming to reduce the use of PPP, for example through the development of organic or integrated production. Although all the above-mentioned measures helped to achieve a certain decoupling of yield development from pesticide use, there is no sign of a significant downward trend in the dependency on PPP in agriculture in general. However, the midterm review of the CAP reform under Agenda 2000 creates a new possibility for further integration of environmental concerns, including with regard to the use of PPP. There exist a number of national policy initiatives, which include efforts to increase IPM, pest forecasting techniques, and biological control methods. Some Member States have developed strategies to promote organic farming. Additionally, within the Codes of verifiable Good Farming Practices in the Rural Development Programmes established under Regulation 1257/1999, some Member States have addressed questions related to safe use and good practices with regard to pesticides. In some Member States, producer groups and food retailers are developing accounting systems in relation to PPP use. Monitoring data on the situation in the Member States regarding percentage of agricultural surfaces or farms using IPM and/or pesticidefree agriculture and percentage using pest forecast systems should contribute to a more comprehensive picture of the situation. In numerous rural areas of the candidate countries, the intensity of agricultural production and the use of pesticides are very low and may be expected to have no significant effect on environment. However, the further p. 3/9 • • • • • • • Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides development and establishment of agri-environmental schemes in some rural areas of these countries is an important task in reducing environmental and health impact of pesticides. Research and development efforts to support IPM and organic production will also be of relevance. • Various projects related to pesticides use have been and are financed through Development Programmes. Some concern the promotion and implementation of IPM techniques. Application and storage equipment, aerial spraying • • Technical checks and certification of application equipment implemented in several Member States with encouraging results. are Some Member states have developed national policies that prohibit aerial spraying for targeted protection of sensitive species and habitats, and protection of waters in general. Substitution • There is room for improvement of existing instruments, particularly concerning matters such as potential synergistic or cumulative effects of PPP, long-term risks for the marine environment, incentives for substitution and an effective shift of use from more dangerous active substances to safer alternatives, improvement of provisions on enforcement and controls on distribution or sales of PPP, educational requirements for users and technical requirements for application equipment. Research • The Community supports research efforts aimed at the reduction and sustainable use of pesticides. Over 200 projects related to pesticides have been funded under the five Community framework programmes on research and development. Most of these projects fall under the Quality of Life programme and the Energy, Environment and Sustainable Development programme and relate, in particular, to food, nutrition and health; environment and health; sustainable agriculture, soil and water resources. Section II: Commission proposals for instruments and initiatives IPM / ICM / Organic production • Measures such as: actions concerning Codes of Good Farming Practices, the promotion of IPM, training programmes for users, further promotion of organic farming and low-input agriculture and the application of penalties including the reduction or even cancellation of benefits from the CAP, fall currently within the purview of the Member States. In order to achieve a higher level of harmonisation and better implementation, it might, however, be necessary to define minimum requirements at Community level. The thematic strategy should encourage the use of low-input or pesticidefree crop farming particularly by raising user’s awareness, promoting the use of codes of good practices and consideration of the possible application of financial instruments focusing on the following: a) Promotion and development of alternatives to chemical control via IPM agriculture, organic farming, and biological control for specific p. 4/9 • Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides uses, such as glasshouse crops and examining the potential of the use of Genetical Modification Technology when its application is considered as safe for health and environment. Promoting good practices by further developing Codes of Good Farming Practice integrating IPM concepts. Further encouraging the allocation of funds by Member State and the adoption by farmers of Rural Development measures, in particular agri-environmental schemes designed to promote low-input farming beyond Good Farming Practice with less use of pesticides (organic farming, ICM and specific measures to reduce pesticide use), but also by training and other relevant measures. b) Imposing penalties on users by reducing or cancelling benefits under support schemes. Member States should make more rigorous use of the possibility of applying penalties by cancelling or reducing benefits covered by Council Regulation 1259/1999 – on rules for direct support schemes under the CAP – when environmental requirements which they have identified as appropriate in view of the situation of the agricultural land used or the product concerned have not been respected. Where not yet existing, these requirements should be defined. For points a and b, the Commission proposes to implement the current provisions more rigorously and exploit them fully. The upcoming report on Regulation (EC) 1259/1999 will unveil what Member States have done on environmental protection requirements and indicate whether further steps will be necessary to reinforce their implementation. The Commission will include pesticides issues in the discussion on the future evolution of Good Farming Practices as a policy tool. Application and storage equipment, aerial spraying • The Commission proposes the introduction of a system of regular technical inspection of application equipment within two years of the adoption of the thematic strategy. The scheme should include adequate monitoring measures to assess compliance and, where appropriate, a link between support to farmers under the CAP and compliance with the required measures should be established. The Commission proposes a general ban on aerial spraying. Specific derogations may be given by the national authorities of the Member States, if aerial spraying presents clear advantages and environmental benefits compared to other spraying methods. • Substitution • The Commission proposes to reduce the levels of harmful active substances by substituting the most dangerous with safer (including non chemical) alternatives. This goal will be achieved mainly by a quicker implementation of Directive 91/414/EEC and its amendments in the near future. In practice this would entail systematic evaluation of the possible substitution of a particular active substance for which certain concerns persist, either by another substance (on the basis of the inventory of active substances, when an alternative is available for a specific purpose) or a pesticide-free alternative. p. 5/9 Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides Directive 91/414/EEC would be amended in order to include among other modifications the substitution principle. The Commission will study feasibility and possible methodologies for its application in practice. Member State Rapporteurs should then carry out comparative assessments under appropriate conditions (which need to be defined) when evaluating active substances, taking due account of possible resistance problems. Research • The Commission proposes to support or create together with the Member States research and development efforts and calls on industry to contribute to such activities. This should in particular include: further research and development into IPM techniques as part of ICM, such as early pest warning systems, disease forecasting, etc. less hazardous methods of application and handling of PPP such as precision spraying, improved coating and packaging technology (new soluble packaging and packaging which retains less residual product when empty) and better adaptation and use of protective clothing. Section III: Stakeholders' input IPM / ICM / Organic production • • The future Thematic Strategy should in particular focus on the promotion of good practices and integrated farming systems including ICM. ICM is the cornerstone for sustainable farming systems. Systems using ICM techniques can meet the three criteria of sustainable development in agriculture (economic viability, social acceptance and environmental friendliness). They offer long-term solutions in guaranteeing sustainable production to deliver adequate quantities of food at affordable prices to the consumers, while taking care of the environment. The use of chemicals for crop protection should be part of an integrated crop protection system. As a dynamic system, IPM needs flexibility instead of strict rules or regulations. There is a need to promote farming methods where use of pesticides is reduced and where risks are decreased. These methods could be organic farming, integrated production and other methods that reduce risks. The IPM framework needs the EU-wide harmonisation of regulations concerning PPP. IPM and ICM can help reduce the risks associated with PPP use. IPM should combine the sustainable use of PPP with a wide-range of non-chemical methods. IPM should mean a method of pest control in both agricultural and nonagricultural settings in which the use of pesticides is minimised as much as practicable and, wherever possible, eliminated, by giving priority to nonchemical practices and methods for prevention and control of pests. Least-harmful plant protection practices promoted wherever feasible and practicable. should be developed and • • • • • • • Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 p. 6/9 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides • There is a need for setting targets and drivers for the uptake of farming methods which help reduce dependence on chemical pesticides, including those methods using the IPM concept and organic farming. A proposal is: the mandatory application of ICM for all cultivated land not yet in organic farming and IPM for all other pest control operations; a target of 30% of all cultivated land in organic farming within 10 years. This would need to be backed by additional financial support from Member States and the Commission for research, training and advice to farmers, and support for organic conversion. • Mandatory use reduction programmes do not consider qualitative aspects of PPP like their environmental properties and are thus not in accordance with ICM. There is a need to assess the potential risks from all agricultural practice and any material introduced into the environment. Low input or pesticides free cultivation or organic practices may also have negative effects. Under the CAP and the agri-environmental measures, all practices need to be considered, not "pesticides" issues separately – both in Member States and in candidate countries. The suggestion that GM crops should be examined as alternatives to chemical control is challenged on the grounds that GM crops are not likely to reduce pesticide use and that they do not represent a sustainable method of farming. There is a need to further promote alternative methods of reducing pesticide use. Organic farming is an important market but one that should not be unfairly preferred over other agricultural approaches. Yields of organically grown crops are lower when averaged over several years and there is no proof that organic production is safer. The encouragement of integrated crop/farm management is the most sustainable route forward. But the maintenance of the natural self-regulating capacity of the agricultural and ecology system by using the minimum quantity of pesticides and facilities requires a high level of management skill. More attention should be paid to the tracing, and information provision to, farmers, technicians and advisors. Proper knowledge is the correct starting point for any concerted action aimed at reducing the risk of pollution from legitimate pesticide use. Once the outcome of the mid-term Review of the CAP is known, the feasibility of using the withholding of support payments as a means of incentivisation will become apparent. The legal bases for different crosscompliance interpretations needs to be transparent if untoward distortions are to be avoided. The possibilities of encouraging further uptake of ICM practices through CAP related measures should be exploited. Cross compliance with ICM should become a minimum condition for CAP subsidies. The agri-environmental schemes under the Common Agriculture Policy (CAP) should be used as incentives to go beyond ICM, e.g., to promote organic farming. One should not use arbitrary measures which prevent farmers from making their own management decisions, but ensure that PPP are used in a responsible way. p. 7/9 • • • • • • • • Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides • There is a need to improve communication about integrated farming, ICM and IPM and also other systems of production such as organic methods. The Commission has an important role to play in supporting such information initiatives. National programmes should include measures for ensuring mandatory implementation of IPM in all significant non-agricultural pest control measures. • Application and storage equipment, aerial spraying • • The future Thematic Strategy should in particular focus on regular technical inspections of application equipment and standards for storage of PPP. There is a need for mandatory technical requirements for, and regular inspection of, pesticide application equipment, storage facilities, use practices, and dealers. Regular technical inspections of application equipment need to be implemented through a system of universally acceptable, independently validated, low-cost testing schemes which need to be discussed and agreed with the stakeholders involved (including equipment providers) at national level. Compulsory sprayer inspection can be an effective tool for optimising PPP treatments in view of guaranteeing protection of users, the environment and especially water. To prevent potential environmental and health risks, a concept of minimum standards for the storage of crop protection products needs to be put in place at wholesale level, retail level and on a farm. Member States should take the necessary measures to ensure that all aerial applications of pesticides are prohibited. Derogations from a general ban on aerial spraying are necessary – e.g. in those areas where aerial spraying cannot be replaced by other techniques of crop protection – and economic considerations, as well as environmental considerations, need to be taken into account when defining these. • • • • • Substitution • The integration of the substitution principle only for the most dangerous pesticides in the review of Directive 91/414/EEC is insufficient to secure the necessary reductions of overall pesticides use. The application of the review programme of existing active substances under Directive 91/414/EEC will probably reduce the number of active substances authorised for use within the EU from over 800 to around 300 by the end of 2003. Impacts of this de facto substitution should be assessed before further regulatory substitutions are considered. Maintaining product diversity is essential for resistance management, IPM, ICM and sustainable use of crop protection products. Regulatory substitution may reduce the chemical diversity of pest and disease control options required for sustainable agriculture, where overdependence on one type or class of chemical can result in resistance development. • • • Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 p. 8/9 Stakeholders Conference on the Development of a Thematic Strategy on the Sustainable Use of Pesticides • PPP uses are much more varied than biocides, and the application of substitution at a regulatory level for PPP could remove the most suitable chemical solution for certain pest/crop situations. It is suggested to set up a EU-wide on-line database on alternatives to pesticides. Germany is currently starting to build up such a database. • Research • Principles for Good Agricultural Practices (GAP) should be developed which specifically aim at reducing the dependency of agriculture on plant protection chemicals. This may be facilitated by establishing an EU-supported 'GAP research facility'. The Commission should be responsible for promoting research on ICM and IPM at Community level. It shall in particular designate a Community agency to co-ordinate national and Community-level research on IPM and on ICM for crops of Community importance, facilitate sharing of information on national ICM and IPM standards with a view towards ensuring coherence and consistency in the implementation of this Directive, and promote reduction of use of pesticides. In co-operation with the Member States, this agency should carry out research programmes to develop less hazardous techniques for pesticide handling and application. • The focus of further research and development should be on scientific efforts that can contribute directly to the sustainable use of PPP and thus on research linked to improving crop protection practices such as research in IPM/ICM techniques, best methods of application and solutions for potential point source contaminations. • General Comments • To change the direction of the CAP for reducing pesticides, we need to leave the objective to produce as cheap as possible for downstream industry and trade, as the present CAP and WTO are forcing farmers to do. To produce at lowest price does not mean to produce with less pesticides, the contrary is true as illustrated by fruits, vegetables and grain. Monitoring of pesticides must be linked to a flow of information and knowledge. To increase efficiency of environmental indicators in the sector, partnerships must be reinforced between EU-Institutions and their organisms (Eurostat, EEA, IES, …) and between EU, national and local authorities. The development of research initiatives include top-down approaches of know-how transfer and bottom-up approaches of evaluation and benchmarking using a track system and a sum-up of data that could allow an analytical feed-back. PPP dose reductions can be obtained for herbicides through the application of mixtures of existing products on young weeds, to exploit the synergetic properties of products and for insecticides through new techniques such as seed pellet application. Warning services based on networks of assessment fields can also contribute to dose reductions. • • Thought Starter – Working Group II – Integrated Crop Management – November 4, 2002 p. 9/9