The government unceremoniously released its National Action Plan on Pesticides (NAP) late last month. Pushed to develop such a plan under European law, Defra claimed its approach to pesticide management is already stringent enough, and the new plan therefore features very few new measures.  

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The NAP, which will be managed by the Chemicals Regulation Directorate of the Health and Safety Executive, focuses on industry and voluntary self-regulation. Defra justified this, stating, "The Government is keen to ensure that regulatory burdens on businesses are kept to a minimum and reduced/removed wherever possible." However, Paul de Zylva of Friends of the Earth dismissed the NAP as an "inaction plan."    

The plan sets no targets for reductions of pesticide use, instead, "the Plan aims for non-regulatory approaches to be adopted as much as possible, and looks to stakeholder partners to deliver these… non-regulatory measures."

However, the EU directive (EU Directive 2009/128/EC) under which the Action Plan was created, demands "quantitative objectives, targets, measures, timetables and indicators to reduce risks [and encourage] the development and introduction of integrated pest management and of alternative approaches or techniques in order to reduce dependency on the use of pesticides." The same section of the directive adds that "Member States should... establish timetables and targets for the reduction of their use."

The only new measures set out in the documents relate to training – operators will need to hold certificates by November 2015 – and water safety, given problems associated with metaldehyde pollution in water courses. There will also be a new inspection scheme to ensure application equipment is adequate.

The government maintains that many measures already in place in the UK go beyond the requirements made in the EU directive, which aims to harmonise regulations across the bloc, and thus believes extra regulation is unnecessary.

This week it was announced that fines incurred by the UK for inadequate fulfilment of obligations under the Common Agricultural Policy amounted to a quarter of all recovery charges being demanded by the European commission. Amongst these UK received penalties relating to weak requirements on fertiliser and pesticide use, as well as "deficiencies in Agri-environment measures."

Consultation on NAP

In a Defra consultation on the NAP, respondents were critical of the lack of quantitative objectives outlined in the plan, the lack of commitment to reduce pesticide use, define 'integrated pest management', or use extension services to facilitate moves away from reliance on damaging chemicals. Defra responded that it does not "consider that persuasive evidence has been submitted to demonstrate that it is proportional to set more ambitious measures."   

Respondents praised the government's commitment to compulsory training for pesticide users, which Defra described "as an appropriate and necessary measure, even if this [goes] beyond the requirements of the Directive."

Concerns were raised over the lack of reference to neonicotinoid pesticides. Mounting evidence of the effects these chemicals have on bees and other insect pollinators has led the European Commission to press for a legal commitment to suspend use of the pesticides on crops attractive to bees for two years.

In response, Defra said it "takes this issue very seriously and is actively examining the evidence… However, the concerns raised… do not relate to the way products are used, stored or disposed of, and so it is not, therefore appropriate for the NAP to address this issue."

Nevertheless, The Guardian's environmental correspondent Damian Carrington lamented the plan's "belated publication" and accused the government of "denial" and "complacency over the impact of neonicotinoids on the bees and other pollinators on which a third of our food relies."

Speaking to Farming Online on Friday (1 March), Friends of the Earth spokesperson Paul De Zylva was critical of the plan's lack of ambition and the delays to its publication. He questioned "What has the government been doing for three months? There has been three months' extra work for very few changes since the draft plan was produced and meanwhile pesticide use has been rising steadily in the UK. How does the plan propose to tackle this? It doesn't."

Speaking before the Environmental Audit Committee inquiry into insect pollinators and pesticide use on Wednesday (27 February), Health and Safety Executive Director Dave Bench admitted that "The Action Plan contains broadly the same content as the draft." It was also revealed that government trials into neonicotinoid exposure have stalled, due to contamination of control hives used in field experiments, which were demanded by industry and government.  

Mr De Zylva added, "They must think we're fools to believe this constitutes active engagement to protect public health and the environment. The real aim seems to be to go as slowly as you can and be as arcane as you can."

The plan will be subject to review every five years, though the government said it may be subject to change within the period, as it is desirous the plan forms a "living" document.