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Our Toxic Future? Why post-EU pesticide deregulation is a threat to the health of the people and environment of the UK

Briefing February 2017


Summary of PAN UK Policy Recommendations: 1. Introduce clear quantitative targets for reducing the overall use of pesticides in agriculture. 2.  Ensure authorisations are based on a strict interpretation of the precautionary principle; maintain a hazard-based (rather than revert to risk-based) approach to pesticide authorisations and phase out the most Highly Hazardous Pesticides. 3.  Do not authorise, or grant re-approval for, products which pose risks to human or environmental health where safer non-chemical methods are available. 4.  Fast track authorisation of less hazardous pest management products such as bio-pesticides. 5.  Introduce strong penalties and robust enforcement to ensure that any contamination of the environment by users of pesticides – including farmers and amenity users – is dealt with properly and will act as a deterrent to misuse. 6.  Create a human health monitoring system for those that routinely work with pesticides, including farmers, farmworkers and amenity operatives and establish a reporting system for others exposed to pesticides including the general public, farming families and rural residents. 7.  Provide incentives for reducing the use of pesticides and establish a proper monitoring system for pesticide use based on frequency of application. 8.  Introduce a Pesticide Levy and use the revenue raised to support programmes to help farmers reduce pesticide use. 9.  Establish a new body for monitoring pesticide use and enforcing pesticide regulations which is separate from the body that deals with pesticide authorisations 10. Introduce greater transparency to allow independent scrutiny of toxicological and other data prior to authorisation of any active substance or formulation in order to break the undue influence of agrochemical companies.


Contents Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 The PAN UK policy recomendations in full . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1. UK Pesticide use is not decreasing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 2. Harmful effects of pesticide use on UK biodiversity and environment continue to be an issue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18


Our Toxic Future?

Introduction The decision to leave the EU ushers in an era of uncertainty, doubt, threat and opportunity for the UK as a whole. Nowhere is this more pronounced than in the UK agriculture sector – and specifically what it means for the future of pesticide regulation in the UK. This document sets out Pesticide Action Network UK’s (PAN UK’s) vision for how pesticides should be regulated across the UK once we leave the EU. Translating current EU rules into UK ones will be a major task and the pressure to remove ‘red tape’ for the farm and food industry is strong. But any changes could have far reaching consequences on the health and well-being of the citizens and environment of the UK. The vocal pro-pesticide lobby would like to see the current legislation and the protection it offers significantly reduced. If they succeed, this could result in: 66 Greater exposure to pesticides that are linked to cancer, reproductive problems and endocrine disruption; 66 Higher levels of pesticide residues allowed in the food that we eat; 66 Increased use of pesticides that are highly toxic to bees and other pollinator species Over 100 pesticides are banned in the EU for health or environmental reasons, and more are likely to be removed from use before we leave the EU - including dozens that are thought to be endocrine disrupting Successive UK governments have opposed strengthening EU pesticide legislation. Leaving the EU could see the pesticide industry, and its allies, persuade the current Government to allow harmful substances banned in the rest of Europe to be used in the UK to grow the food we eat and manage our public spaces like parks and playgrounds. But it does not have to be this way. PAN UK believes that, whilst there are very real threats, leaving the EU also presents the greatest opportunity in generations to make pesticide use in the UK more sustainable, environmentally friendly, and to reduce the risks for the citizens of this beautiful isle. PAN UK is calling for the Government to strengthen the current pesticide regime and this document sets out a list of policy measures that the UK should adopt to protect the British people and environment from hazardous pesticides. Brexit need not usher in an era of deregulation and weak environmental standards. Now is the time for the UK to set out a clear vision for a sustainable future for farming, food production and pesticide regulation, so the UK can protect the health of its citizens, and become a world leader in environmentally friendly agriculture. In order to achieve this, we need to see a paradigm shift in our approach to pesticides and we do not have time to wait!

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Why post EU pesticide deregulation is a threat to the health of the people and environment of the UK

The PAN UK policy recommendations in full 1. Introduce clear quantitative targets for reducing the overall use of pesticides in agriculture. This is not a new or novel policy recommendation and a number of EU Member States have already introduced use reduction targets, as a result of either national interest, or in order to meet the requirements of the Sustainable Use of Pesticides Directive (SUD). In 2008, France made a commitment to halve overall pesticide use by 2018. It announced this as part of the Ecophyto 2018 plan and aimed to monitor progress by evaluating three quantitative indicators: number of unit doses; quantity of active ingredient; and treatment frequency index. This is an ambitious plan and it is not clear yet that France has or will meet its target: some early analysis has shown that progress is being made in some areas, most notably soft wheat, but even if the targets have not as yet been met, the fact that there are clear reduction targets allows the policy framework to work towards this goal. In 2011, Denmark adopted a target for an overall pesticide use reduction of 40% and current research suggests this target has been met. The reason for the success appears to be the introduction of a pesticide tax at 34-55% of sale price. The notion of a pesticide tax in the UK has historically been very controversial and has consistently been rejected by the UK Government and the pesticide industry.

2. Ensure authorisations are based on a strict interpretation of the precautionary principle; maintain a hazard-based (rather than revert to risk-based) approach to pesticide authorisations and phase out the most Highly Hazardous Pesticides. The precautionary principle is a key element in ensuring that maximum protection of the environment and human health is delivered. It is a very simple concept but one that is infrequently applied correctly or effectively. The very idea of it seems to frighten many in industry and in regulatory positions. The simple concept is: “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.”1 This should form the basis of all decisions made in regard to pesticides and should be enshrined within any new legislation on authorisations introduced once the UK leaves the EU. There have been far too many cases where serious environmental harm could have been avoided if the precautionary principle had been followed. The most recent illustration of this is the case of neonicotinoids where it was clear from the scientific literature that there was serious cause for concern and that a greater understanding of the effects of neonicotinoids was required. However, this didn’t happen until severe declines in bee populations were being recorded and action was only taken retroactively rather than proactively. Given the toxicity of pesticides and the potential harm that they can cause, even when used ‘correctly’, we do not have the luxury of being able to wait until the full potential for harm is proven. Rather, pesticides must be proven to do no harm before they can be authorised for use. This is in essence the hazard based approach rather than a risk based approach and forms the basis for the current EU legislation but PAN UK wants to see this go farther by adopting and strictly applying the precautionary principle to all decisions on pesticides.

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Our Toxic Future?

A key element of pesticide regulation is the registration for active substances. At present this is done at EU level under Regulation 1107/2009, for the Placing of Plant Protection Products on the Market. Whilst far from perfect, the system does offer better protection than its predecessor did and is partly a hazard-based approach that considers the intrinsic harmful properties of each active substance. It is important that pesticides are regulated to the highest degree possible and the current EU model comes closer to that goal than many other systems. Any move to weaken the current EU regime and revert back to a risk-based approach would be a regressive step that would afford the public and the environment less protection from pesticides. It is also questionable whether it would even be possible to establish an effective independent regulatory system in the UK given the cost of doing so. It is also important to recognise that, in order to maintain the ability of the UK to do business with the EU, we would in many instances need to abide by EU legislation on permitted actives. Two options seem to be most likely: the first is to establish a UK authority for approving active substances and if this were followed, PAN UK would like to see this based on the EU model and follow the EU approval system. The alternative option is to make decisions based on the positions taken by the EU as is currently the case. This would have the benefit of keeping the UK in harmony with the EU regulatory system and thus enhancing our ability to trade agricultural produce with the remaining EU Member States. It would also ease the financial burden on the UK from not having to reassess the hundreds of active substances currently in the system. This would seem to be the most pragmatic option given potential cost involved in reassessing active substances. What is more, any weakening or move away from the current EU system could impact UK farmers’ ability to trade agricultural products with EU Member States. A number of commentators, including the NFU, believe that if the UK wishes to maintain trade in agricultural products with the EU it will need to adhere to EU Regulations.2 Currently the EU accounts for approximately 60% of UK agri-food exports which amounts to around £1 billion per year. If the UK were to weaken its pesticide regulation, and allow the use of pesticides that are currently banned or restricted by the EU this could threaten our export trade. If detectable levels of a banned pesticide are found on or in produce entering the EU, that product will not be allowed to be imported or sold. So in purely financial terms, not requiring an expensive reassessment and ensuring that agricultural exports are not affected, maintaining the current EU system would be the most straightforward option for the UK post-EU. However, PAN UK is also recommending that the UK goes beyond the current EU system and adopts our recommendations for phasing out the use of the most Highly Hazardous Pesticides as identified in the PAN Highly Hazardous Pesticide list.3 At the very least we would like to see the general approach to pesticides changed to one where those pesticides that are having, or have the potential to cause, the most harm to the environment or human health are phased out as a priority. As a first step it would be desirable for a panel of independent experts to draw up a list of the priority pesticides for phase out in the UK.

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Why post EU pesticide deregulation is a threat to the health of the people and environment of the UK

3. Do not authorise, or grant re-approval for, products which pose risks to human or environmental health where safer non-chemical methods are available Under the current EU legislation there are provisions for making pesticides that are considered as high risk candidates for substitution. This is based on how they meet the current ‘cut-off’ criteria under Regulation 1107/2009. There are currently 77 active substances4 that are candidates for substitution identified by the EU Commission. Whenever nationally authorised products with these substances need to be approved or reapproved, national authorities must carry out an assessment to establish whether more favourable alternatives to using the plant protection product exist, including non-chemical methods. PAN UK wants to see the concept of substitution retained by the UK in any post-EU pesticide regulations. This is an important tool for phasing out the most highly hazardous pesticides whilst ensuring that alternative methods, not just alternatives chemicals, are explored and developed. It could help to deliver a reduction on overall pesticide use across the agriculture sector.

4. Fast track authorisation of less hazardous pest management products such as bio-pesticides. Biological, rather than chemical, products are increasingly recognised as the future for sustainable pest management. Products in this biological sector include: biopesticides (based on micro-organisms); natural chemical signalling compounds released by insects (pheromones) or plants; botanical extracts; and other natural substances. Market growth for these products is growing at double the rate for conventional pesticides, driven by retailer and consumer demand for residue-free produce and food sector commitments to environmentally friendly practices. These biological products generally pose very much lower or negligible risks to humans and non-target organisms.  Farmers will benefit from more biologicals in their pest control toolbox, by having more options to deal with problems of pest, disease and weed resistance to existing chemicals, and for replacing hazardous pesticides withdrawn. Yet only 35 biopesticide products are currently available in the UK. To support a rapid increase in the availability of safe and effective biological products for British users, the UK government should invest in, and implement, a flexible but robust fasttracking procedure for approval of biological and other non-chemical products. This could include: an automatic provisional approval for products which meet agreed low-risk criteria; putting biologicals ‘at the front of the queue’ for evaluation and review; greatly reduced or waived fees for applicants; and more appropriate data requirements. Biocontrol experts forecast that Europe is set to overtake the Americas to become the biggest market in the world for non-chemical pesticides.  The government should support UK biocontrol companies, many of which are SMEs, with a more favourable regulatory environment to enable them to grow their markets, including export to the EU. It should ensure British farmers do not lose out in terms of equal access to new biological actives gaining EU approval.

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Our Toxic Future?

5. Introduce strong penalties and robust enforcement to ensure that any contamination of the environment by users of pesticides – including farmers and amenity users – is dealt with properly and will act as a deterrent to misuse. There is very little in place at present that will act as a deterrent to bad practice, misuse or illegal use of pesticide. There is very little effective monitoring or enforcement, most of which is reactive and happens only after an incident has occurred, by which time it is often far too late to prevent harmful effects on the environment. Even on the rare occasion that a perpetrator is prosecuted for a pesticide pollution incident the penalties are so small as to not act as any kind of deterrent to others. It seems that in the UK the polluter often doesn’t pay! Leaving the EU is a perfect opportunity for the UK to bring in legislation that will effectively punish those that pollute with pesticides.

6. Create a human health monitoring system for those that routinely work with pesticides, including farmers, farmworkers and amenity operatives, and establish a reporting system for others exposed to pesticides including the general public, farming families and rural residents. There is no doubt that the health of the people that use pesticides can be negatively affected by their exposure to various active substances. In fact, given their greater overall exposure, both directly and indirectly over the course of a working life, the people that work with pesticides are most at risk from their harmful effects. There is an obvious need to protect farmers, farmworkers and their families from the harmful effects of pesticides. But first there is a need to actually acknowledge that the problem exists. An in depth report for the European Parliament on the health impacts of human exposure to pesticides5 concluded that the children of farmers and farmworkers are more prone to childhood cancers than the general population. In France, a growing number of farmers who have been poisoned by pesticides are taking a stand against those that have poisoned them and are demanding tougher controls on pesticides to avoid future poisonings.6 In the UK, there is currently no monitoring system for the long term, chronic health effects of worker pesticide exposure and very little in the way of an effective reporting system for acute poisonings. There appears to be a complete lack of interest from the Department of Health in taking on pesticide related health issues. This is perhaps best illustrated by the case of sheep farmers in the UK who have been poisoned by organophosphate sheep dips.7 It is one of the most clear cut of all worker pesticide poisoning cases but has to date been largely ignored by successive governments and also even more disgracefully by the National Farmers Union (NFU). These two areas need to addressed if we are to ensure that the health of those growing our food is not put at risk by the chemicals that they often have no choice about using. But it is not just farmers and farmworkers that are at risk. Rural residents that live near to sprayed fields and bystanders can experience high levels of exposure to pesticides with devastating effects on their health. Measures – including demanding no-spray zones – should be introduced to protect groups that are currently poorly protected. PAN UK is calling for the establishment of a new body to take responsibility for the human health aspect of pesticide use. This body would be completely independent and made up of health professionals and others with no vested interests or relationship with the pesticide industry. In order to do this the Department of Health would need to collaborate with the

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Why post EU pesticide deregulation is a threat to the health of the people and environment of the UK

Health and Safety Executive and maintain distance from Defra and the other pesticide regulatory bodies. There is also no currently available system that satisfactorily monitors or deals with reports of pesticide poisoning in general. The current Pesticide Incident Appraisal Panel (PIAP) system is not working and needs to be changed. This is an area that could be rolled into the new health monitoring body outlined above. If the overall goal of any new legislation and regulation post EU is to protect workers and the public from the harmful effects of pesticides then effective human health monitoring and incident reporting is vital.

7. Provide incentives for reducing the use of pesticides and establish a proper monitoring system for pesticide use based on frequency of application. At present UK farmers receive £3bn per year from the EU’s Common Agricultural Policy (CAP). This can reasonably be expected to be reduced once the UK leaves the EU, though it is likely that some form of subsidy will continue to be paid to farmers. Currently the CAP pays about £80 per year for each acre “farmed”, whether it produces food or not. PAN UK would like to see agricultural subsidies move away from a flat rate acreage policy to a policy that supports farmers growing a greater variety of food with an emphasis on supporting small scale farmers rather than massive agribusiness. Added to this it is vital that any reformed subsidy system is linked to greening agriculture with incentives for reduced pesticide use, increased attention to biodiversity, more sustainable crop rotations and the development of organic agriculture. Help could also be given to small producers who farm in an environmentally friendly way to find outlets for their products with retailers. What must not happen is for chemically intensive, environmentally harmful agricultural practices or for landowners who are not growing food to be supported with UK tax payer’s money.

8. Introduce a Pesticide Levy and use the revenue raised to support programmes to help farmers reduce pesticide use. Experience from a number of European countries has shown clearly a tax on pesticides is an effective mechanism to reduce pesticide use and their impact on the environment. Sweden, Norway and Denmark were amongst the first to introduce pesticide taxes starting in the 1980’s. In Sweden, at first, the revenue generated from the tax was used to finance agrienvironment schemes, but since 1995, the revenue has gone into the general treasury. In 2015, the sum generated was in the region of 8 million Euros. The stated goals for introducing the tax were to reduce the overall use of pesticides and by doing so reduce the environmental risk of the use of pesticides. Since 1980, the overall sales of pesticides in Sweden have been reduced by 50%. Similar results have been seen in Norway and Denmark. Other European countries are also considering introducing a pesticide tax. In the German region of Schleswig-Holstein, the Ministry of Agriculture has proposed the introduction of a tax that would be paid by the manufacturers and wholesalers and the projected reductions in pesticide use are, in the short-term, 20% and, in the longer term, 35%. Again these would represent significant reductions in overall use.

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Our Toxic Future?

In the UK, the idea of a pesticide tax was first put forward in the late 1990’s, but in the face of strong opposition by the pesticide industry and other agricultural stakeholders, it was rejected in favour of a raft of voluntary measures and the introduction of the Voluntary Initiative. However, those measures have not delivered a reduction in pesticide use or halted the harm that pesticide use is having on the UK environment. The introduction of a pesticide tax would be an effective and straightforward measure to tackle the problems of pesticide use. It need not be overly complicated or burdensome, in Sweden it is a simple flat rate tax. The money generated from a tax should be put toward practical support and research to help farmers to shift away from dependence on chemicals as the primary means of pest control.

9. Establish a new body for monitoring pesticide use and enforcing pesticide regulations which is separate from the body that deals with pesticide authorisations At present the responsibility for authorising pesticide products, and for enforcing legislation, lies with the Chemicals Regulation Directorate (CRD), a body that is answerable to both the Environment Department (Defra) and the Health and Safety Executive. This structure creates an in-built conflict of interest and there is a need to separate the two roles and for there to be greater clarity over which part of government is responsible for overseeing matters relating to pesticides in the UK. The approval authority should not be involved in the day-to-day enforcement and oversight of pesticide use. At present, the CRD receives 60% of its funding from approving pesticide products. This in itself presents problems as it develops a very close link between the manufacturers of pesticides and the regulatory authority. It is essential that the pesticide regulator should remain entirely independent and impartial. If the UK opts to completely withdraw from EU pesticide regulatory control and not choose the option of abiding by approval decisions taken jointly by EU countries, the UK will need its own authorisation system for active substances. Creating an effective body to undertake this work will have significant cost implications and manpower requirements. But it presents an opportunity to invest in a new, fair and impartial authorisation process that protects the people and environment of the UK. A vital pre-requisite is that this body be seen to be free from any kind of influence by pesticide manufacturers and that regulatory and authorisation issues are dealt with by separate bodies.

10. Introduce greater transparency to allow independent scrutiny of toxicological and other data prior to authorisation of any active substance or formulation, in order to break the undue influence of agrochemical companies. At present, the toxicity testing undertaken by pesticide manufacturers and submitted to the regulatory authorities remains unavailable to independent scrutiny due to confidentiality clauses and data protection issues. Given that the manufacturers and regulators are the only bodies able to scrutinise the toxicity data, the influence of the manufacturer is heightened ,making it impossible for the regulator to make a balanced assessment based on all interpretations of the data. Allowing independent third party assessment to play a part in evaluating the safety of an active would fill a vital precautionary gap in the current system.

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Why post EU pesticide deregulation is a threat to the health of the people and environment of the UK

All data relating to the toxicity of an active substance or to the adjuvants in a product should be made accessible to independent scientists and researchers to assist in identifying potential issues with pesticides before they become problems, either for the environment or human health. In fact, a recent ruling by the European Court of Justice has concluded that because pesticides are in effect emissions to the environment they are subject to the Aarhus Convention on public right to access of information. This could mean that there will be a legal requirement for such data to be made available as the EU as a whole is a signatory to the Convention. With the UK also being a signatory to the Convention the requirements of the Convention will still be applicable post-EU. It is vital that the UK establishes legislation or guidance on open access to toxicological data on pesticides that is prepared by the manufacturers.

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Our Toxic Future?

The Issues The use, overuse and misuse of pesticides in UK agriculture continues to cause a wide range of negative impacts on the biodiversity and environment of the UK. Pesticide use is not going down and the effects of that use are not being ameliorated by the measures that are currently in place to control pesticides. Numerous measures have been introduced to try and reduce the harmful impact of pesticides in the UK: some have been developed in the UK, while others have come as a result of EU legislation. But in spite of all of these controls, and initiatives, the UK continues to ride on the pesticide treadmill: pesticide use is still on the rise, and people and the environment are still exposed to too many dangerous chemicals. New policies, and new ways of implementing, overseeing and enforcing those policies, need to be introduced for the UK to move towards a more sustainable farming future that brings positive benefits for wildlife, biodiversity and the people of the UK.

1. UK Pesticide use is not decreasing The UK has never had an overall strategy for reducing the use of pesticides in agriculture; rather policy-makers have adopted the ideology of “acceptable risk� which aims to reduce the harm from pesticides by controlling the way they are used. An opportunity to introduce quantitative reduction targets was missed in 2012 when the Department for the Environment, Food and Rural Affairs (Defra) failed to include them in the UK National Action Plan on Pesticides (UK NAP), in spite of it being one of the key recommendations contained in the EU Directive on the Sustainable Use of Pesticides (SUD). The pesticide industry and UK regulators often claim that pesticide use is decreasing by using data on the volume or weight of pesticides applied to UK agricultural land. However, this is not a meaningful measure of reduction in any sense, because some newer chemicals possess higher, per-unit toxicity, than the older pesticides they replaced. This means that even though smaller physical amounts are used, they can have a much more significant impact on the environment or human health. In fact, the overall use of pesticides, and the area of land treated with pesticides, has increased over the last fifteen years and this includes some active substances that are associated with serious environmental and / or human health impacts. The UK pesticide usage survey data shows that total area of crops treated with pesticides increased from 59.1 million ha in 2000, to 78.2 million in 2013, an increase of 32%:66 the total area treated with fungicides increased from 27.3 million ha in 2000 to 39.2 million ha in 2013, an increase of 11.9 million ha treated, or 43% 66 the total area of crop treated with insecticides increased from 5.08 million ha to 6.92 million ha, an increase of 1.84 million ha, or 36% 66 the total area treated with herbicides increased from 20.3 million ha to 24.3 million ha, an increase of 4 million ha, or 20% These rises stem from the fact that the number of applications per crop has increased, rather than from a spatial increase in the overall treated area. The total cropped area (including fallow but excluding permanent grassland and woodland) in the UK8 has remained broadly constant between 2000 and 2013 at around 4.6 million ha9.

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Why post EU pesticide deregulation is a threat to the health of the people and environment of the UK

If we focus on just three key types of pesticide, neonicotinoids, pyrethroids and glyphosate, all of which are linked with environmental and / or human health problems, we can see that significant increases in use have occurred, and, in the case of neonicotinoids, those increases in use have led to serious environmental impacts. The weight of scientific evidence showing harm from these particular pesticides is overwhelming.10 But instead of being the focus of concerted efforts to reduce and eliminate their use – as would be expected if the UK had a robust regulatory system as claimed by regulators and industry – we have the situation outlined below where their use continues to grow. Neonicotinoids The harmful impact of neonicotinoid use on honey bees, wild bees and other pollinator species has been well documented in the scientific literature over the past 10 years. Concerns about some neonicotinoid use led to a ban in the EU for some applications. But they are still used on a range of crops, and UK government has been opposed to the EU ban since it was first discussed. There is a real danger that, following a withdrawal from the EU, the UK could seek to reintroduce, and even extend, the use of neonicotinoids. A recent study published by the Centre for Environment and Hydrology showed that the use of neonicotinoids on oil seed rape crops in the UK is having a seriously deleterious effect on species of wild bee.11 Other studies have shown convincingly that neonicotinoids are harmful to a far wider range of species than previously thought and could be having harmful impacts on birds, invertebrates and other aquatic species as well as pollinators and honey bees.12 Graphs

Total area treated with all neonicotinoids 2000 - 2013 2001 2003 2005 2007

Area treated ha

2009 2011

2013 0

500,000

1,000,000

1,500,000

Pyrethroids

Pyrethroid Insecticide Usage forwidely Great used Britain Pyrethroids are the class of insecticide that was most to treat crops to control the 2000pest problems that are now tackled by neonicotinoids. They are an older chemistry 2001 and are applied by foliar spraying, not as seed treatments. Their method of application 2002 means that as well as negatively affecting non-target insect species – including 2003 2004 pollinators – there can be problems of spray drift onto non-target crops and people near 2005 to2006 the treated area. Overuse of pyrethroids has led to serious pest resistance problems Total area treated ha in2007 some areas. 2008 2009

The introduction of neonicotinoids was in part designed as a remedy for the problems 2010 2011 pyrethroid use and was expected to lead to a decrease in their application. However, with 2012 2013

0

1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

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2001

Our Toxic Future?

2003 2005 2007

Area treated ha

between 2000 and 2013, the total area treated with pyrethroid insecticides grew by 2009 1.38 million ha, including pesticides containing Cypermethrin and lambda-cyhalothrin, 2011of which are highly toxic to bees although less persistent in the environment than both neonicotinoids. 2013 Rather the pesticide load by reducing the use of pyrethroids the 0 than decreasing 500,000 1,000,000 1,500,000 introduction of neonicotinoids has instead increased it, and the two combined have increased the overall use of pesticides.

Pyrethroid Insecticide Usage for Great Britain 2000 2001 2002 2003 2004 2005 2006

Total area treated ha

2007 2008 2009 2010 2011 2012 2013

0

1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

Glyphosate The overuse of herbicides in the UK has contributed to a dramatic drop in the numbers of wild flower species and general loss of plant biodiversity. The loss of habitat and food sources provided by these plants is a major factor driving the decline of bees and other pollinators that are crucial for food production. Glyphosate is the most widely used herbicide in the UK. Its use in agriculture has risen from a total treated area of 1.59 million ha in 2000 to 1.76 million ha in 2013, more than a 10% increase. This has not been a steady increase but has risen and then fallen back again, with a spike in 2009 coinciding with the re-establishment of arable crops on former set-aside fallow land. Glyphosate is also the most widely used pesticide in the amenity and home and garden sector, but data comparing the use of glyphosate across sectors are not available.

Glyphosate usage for Great Britain 2000 - 2013 2001 2003 2005 2007 2009 2011 2013 1,400,000 1,500,000 1,600,000 1,700,000 1,800,000 1,900,000 2,000,000

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Total area treated ha


Why post EU pesticide deregulation is a threat to the health of the people and environment of the UK

Glyphosate has also been classified by the World Health Organization (WHO) as a probable human carcinogen. This caused a lot of debate in the EU when the approval for use was up for renewal in 2016. This classification should automatically have resulted in its removal from sale, but intensive lobbying from agribusiness resulted in a stay of execution. The Commission allowed a temporary 18 month extension to glyphosate’s licence to allow further studies to be undertaken. A final decision will be taken in 2018 and glyphosate could be banned in the EU thereafter. Once again the UK government was opposed to limiting its use, and it is possible that once the UK leaves the EU, the UK government will continue to approve glyphosate for use, regardless of the decision by our European neighbours. The increasing use of pesticides on UK cereal crops Cereals, and mainly winter wheat, account for the major part of the pesticide treated area and volume used in the UK because of their dominance in the UK crop mix13. Fungicide use on cereals currently accounts for 69% of the total crop pesticide-treated area in Great Britain (29.44 million ha). Over 60% of wheat crops are now treated three or more times with fungicides. This is a major rise on the early 2000s, when most farmers only applied fungicides once or twice in a season. The area treated more than four times has risen from less than 2% in 2000 to almost 7% in 2013, with a peak in 2012 when disease pressure was particularly high. Over 28 different fungicide active substances were applied to wheat in 2012, with most widespread use being made of the azole group and chlorothalonil14. Many of the azole group of fungicides have been classified as endocrine disrupting chemicals (EDCs) or at least have the potential to be classified as such. As EDCs it is likely that under the present EU regulatory system they could be taken out of use due to their intrinsic hazardous nature. However, it is possible that the UK would continue to use them if it is no longer subject to EU pesticide legislation. The increasing trend in fungicide use frequency has arisen through a combination of disease susceptible varieties occupying much of the wheat area and an exclusive reliance on fungicides to control pathogens. Several fungal pathogens have developed resistance to fungicides, resulting in increasing applications and higher doses, and increasing use of fungicide mixtures15.There is also increasing evidence of the negative impacts of certain fungicides on freshwater biodiversity and recent research has shown that bees exposed to certain fungicides also suffer harmful effects.16

2. Harmful effects of pesticide use on UK biodiversity and environment continue to be an issue Pesticides have negative impacts on wildlife through both direct toxic effects and indirect effects through impacts on the food chain and habitats, for example by decreasing the abundance and diversity of wild plants and insects. Pesticide use has also facilitated structural changes in agriculture that have indirect negative impacts on wildlife, notably reduced crop diversity within and across fields, simplified crop rotations, denser stands of cereals and less grassland and legumes. Pesticides and farmland birds Populations of many bird species in the UK have been on a decreasing trend since 1970. In particular, species of farmland bird have seen the steepest decline between 1970 and

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data. Species trends within this index vary widely from species increasing severalfold (e.g. Cetti's warbler, blackcap, great spotted woodpecker, red kite and collared dove) to those having declined to less than a tenth of 1970 levels (turtle dove, corn bunting, willow tit and grey partridge). The main patterns and drivers of change are best considered by looking at the indices of species grouped by habitat (Figure 1a 2014.17 This alarming decline has seen a reduction of some key species including the and below).

Yellowhammer, corn bunting and turtle doves.

Figure 1a: Populations of wild birds in the UK, by habitat, 1970-2014

Populations of wild birds in the UK, by habitat, 1970-2014

120 All species (130)

Seabirds (13)

Water and wetland birds (26)

Index (1970 = 100) Water and wetland birds (1975 = 100) Seabirds (1986 = 100)

100

80 Woodland birds (37)

60 Farmland birds (19) 40

20

0 1970

1974

1978

1982

1986

1990

1994

1998

2002

2006

2010

2014

Source: British Trust for Trust Ornithology, Defra, Nature Conservation Committee, Societyoffor Source: British for Ornithology, Defra,Joint Joint Nature Conservation Committee, Royal SocietyRoyal for the Protection Birdsthe Protection of Birds. Note: In 2001

it was judged that there was not sufficient evidence to prove links between have been recorded in the UK, because graph shows unsmoothed trends (dashed lines) smoothed (solid lines). No smoothed trend18,19 is . anyii) effects could not be separated from theand many othertrends changes involving agriculture available for seabirds as individual species population trends are based on full counts at colonies or wetland However, since and coastal sites.2001 a considerable amount of research has been carried out and there is now strong evidence of indirect effects of pesticide use on farmland birds through impacts on food and habitat availability, this evidence was summarised in a key report in 200820. It is more difficult to attribute direct effects of pesticides to bird mortality in the field21, other than poisonings by rodenticides or slug pellets and deliberate poisonings of birds of prey. i) figures use in brackets showspecies the number species.declines pesticide and bird forofwhich

Recent research by Professor Dave Goulson of Sussex University has pointed to the possibility that birds such as the partridge could be poisoned by ingesting seeds treated with neonicotinoids.22 Other research by Dr. Henk Tennekes has drawn the conclusion that insectivorous bird species are declining significantly due to the use of neonicotinoids and the subsequent loss of food sources.23 Examples of some recent findings: 66 Insect sampling in arable crop fields and margins over two years in three different locations in England found that the Grey Partridge chick-food index in all crops was only a half or less of the level required to ensure that chick survival is sufficient to maintain population abundance24. 66 A survey of wildlife in winter cereal fields across Europe found consistent negative effects of insecticide and fungicide use on the species diversity of plants, carabid beetles and ground-nesting farmland birds25. 66 Herbicide drift may be significantly reducing flower, seed and berry food resources for birds, insects and other animals in hedgerows and field margins by delaying flowering times and reducing flower production and seed set in wild plant species26,27.

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Why post EU pesticide deregulation is a threat to the health of the people and environment of the UK

Pesticides and amphibians A study for EFSA in 2012, pointed out the substantial data gaps in assessing pesticide risks to amphibians, particularly on land and in arable fields28. A number of studies have shown that some pesticides, including strobilurin fungicides, are more toxic to amphibians in the agricultural environment at current recommended label rates than is accounted for by current environmental risk assessments29,30,31,32. The authors conclude that large-scale negative effects of terrestrial pesticide exposure on amphibian populations seem likely. What is more, the added surfactants in many glyphosate-based herbicide formulations have been shown to stress amphibians, and acute toxic, chronic and delayed effects at environmentally relevant and sub-lethal concentrations have been shown33. Pesticides and freshwater biodiversity Water monitoring across Europe shows that pesticides and other organic chemicals are likely to chronically affect fish, aquatic invertebrates, and/or algae in at least 42% of river and lake monitoring sites, and to acutely affect at least one group in at least 14% of sites34. This is likely to be a significant underestimate of impacts on freshwater biodiversity across Europe, given the poor sampling density and the small number of chemicals monitored in Southern Europe during the period 2006 to 2010. Field evidence shows that current EU thresholds for aquatic ecotoxicity are not protective for aquatic communities subject to multiple stressors, pesticide mixtures, and repeated exposures 201235. Pesticides at concentrations that current legislation considers environmentally protective have been shown to cause statistically significant effects on both the species and family richness of stream invertebrates in Germany and France, with losses of up to 42% of the recorded taxa36. Several studies have shown how fungicides have wide ranging impacts on freshwater biodiversity and leaf litter breakdown at currently recommended application rates37,38,39. A wide range of pesticides accumulate in soft sediments of edge-of-field ponds, ditches and streams, where they are often more concentrated than in the water40, and where the combination of ongoing exposure with accumulated pesticides (including many banned substances) may be significantly more toxic than in the body of the water41. Current regulatory risk assessment models are failing to predict realistic concentrations of pesticides in surface water42, and ignore accumulated pesticides in sediment, and therefore may be severely underestimating the risk of ecological effects on freshwater biodiversity.

Conclusions It is clear from the data available that the use of pesticides is not falling and that their impact on the environment is not being managed effectively by the current regulatory approach. There is a need to reduce the use of pesticides and strengthen – not weaken – measures to address their impact, if we wish to see UK agriculture deliver comprehensive benefits to the environment after the UK leaves the EU.

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Our Toxic Future?

References 1

“Wingspread Conference on the Precautionary Principle” 26/01/1998 http://www.sehn.org/wing.html

2 “Future of oilseed rape at risk amid pesticide threat” Farmers Weekly 11/11/2016 http://www.fwi.co.uk/arable/future-oilseed-rape-risk-amid-pesticide-threat.htm 3 Pesticide Action Network Germany Highly Hazardous Pesticide List http://www.pan-germany.org/download/PAN_HHP_List_150602_F.pdf 4 http://ec.europa.eu/food/plant/pesticides/approval_active_substances/docs/draft_list_cfs_en.pdf 5 http://www.europarl.europa.eu/RegData/etudes/etudes/join/2008/408559/IPOL-JOIN_ ET(2008)408559_EN.pdf 6 http://www.phyto-victimes.fr/ 7 http://www.pan-uk.org/archive/Publications/Briefing/sheepdip.htm 8 Figures according to agriculture statistics reported by DEFRA available at https://www.gov.uk/government/statistical-data-sets/agriculture-in-the-united-kingdom 9 The area fluctuates from year to year, in relation to the proportion of area under temporary grassland or fallow. 10 https://www.theguardian.com/environment/damian-carrington-blog/2012/oct/22/bees-pesticides 11 http://www.ceh.ac.uk/news-and-media/news/new-study-neonicotinoid-insecticides-linked-wildbee-decline-across-england 12 An overview of the environmental risks posed by neonicotinoid insecticides http://onlinelibrary.wiley.com/doi/10.1111/1365-2664.12111/abstract 13 During the period since 2000 the overall proportion of cereals in the UK cropped area has declined by 7%, but cereals remain the dominant UK crop on nearly two thirds of the cropped area, with a notable spike in wheat area in 2008, due to the ending of the set-aside requirement. 14 Garthwaite et al (2012) Pesticide usage survey report 250. Arable crops in the United Kingdom 2012. Food & Environment Research Agency, York, UK. 15 http://cereals.ahdb.org.uk/publications/2013/september/10/consequences-of-intensive-fungicideuse-or-integrated-disease-management-for-fungicide-resistance-and-sustainable-control.aspx 16 “Bees feeding on fungicide-dosed flowers develop health issues, studies say” The Guardian 18/06/2015 https://www.theguardian.com/environment/2015/jun/18/bees-fungicide-flowersfarm-insecticide 17 https://www.bto.org/science/monitoring/developing-bird-indicators 18 Fuller, R. J. (2000). Relationships between recent changes in lowland British agriculture and farmland bird populations: an overview. In Ecology and Conservation of Lowland Farmland Birds. N. J. Aebischer, A. D. Evans, P. V. Grice & J. A. Vickery (Eds). 5-16, BOU Tring. 19 Plumb, R.T. & Bromilow,R.H. (2001) Pesticides and Birds: A report on the evidence for changes in farmland bird populations and the proposals for a pesticide tax. HGCA Research Review No 46. http://cereals.ahdb.org.uk/media/288205/rr46-final-project-report.pdf 20 Bright, J A, Morris, A J and Winspear, R (2008) A review of indirect effects of pesticides on birds and mitigating land-management practices. RSPB Research Report No 28. RSPB, UK. https:// www.rspb.org.uk/Images/bright_morris_winspear_tcm9-192457.pdf 21 Millot,F., Berny,P., Decors,A., Bro,E. (2015) Little field evidence of direct acute and short-term effects of current pesticides on the grey partridge. Ecotoxicology and Environmental Safety 117: 41-61 22 Pesticides spark broad biodiversity loss Nature 17/06/2013 http://www.nature.com/news/ pesticides-spark-broad-biodiversity-loss-1.13214 23 Declines in insectivorous birds are associated with high neonicotinoid concentrations Nature 17/07/2014 http://www.nature.com/nature/journal/v511/n7509/abs/nature13531.html 24 Holland, J M, Smith, B M, Birkett, T C and Southway, S (2012) Farmland bird invertebrate food provision in arable crops. Annals of Applied Biology No 160 (1), pp66-75. 25 Geiger, F, Bengtsson, J, Berendse, F, Weisser, W W, Emmerson, M, Morales, M B, Ceryngier, P, Liira, J, Tscharntke, T, Winqvist, C, Eggers, S, Bommarco, R, Pärt, T, Bretagnolle, V, Plantegenest, M, Clement, L W, Dennis, C, Palmer, C, Oñate, J J, Guerrero, I, Hawro, V, Aavik, T, Thies, C, Flohre, A, Hänke, S, Fischer, C, Goedhart, P W and Inchausti, P (2010) Persistent negative effects of pesticides on biodiversity and biological control potential on European farmland. Basic and Applied Ecology No 11 (2), pp97-105.

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26 Boutin, C, Strandberg, B, Carpenter, D, Mathiassen, S and Thomas, P (2014) Herbicide impact on non-target plant reproduction: What are the toxicological and ecological implications? Environmental Pollution No 185, 295-306. 27 Schmitz, J, Schäfer, K and Brühl, C A (2013) Agrochemicals in field margins - assessing the impacts of herbicides, insecticides, and fertilizer on the common buttercup (Ranunculus acris). Environmental Toxicology and Chemistry No 32, (5) 1124-1131. 28 Fryday, S and Thompson, H (2012) Toxicity of pesticides to aquatic and terrestrial life stages of amphibians and occurrence, habitat use and exposure of amphibian species in agricultural environments. EFSA Supporting Publications: EN-343. Study by FERA for European Food Safety Authority, York, UK. http://www.efsa.europa.eu/en/supporting/pub/343e.htm 29 Belden,J., McMurry,S., Smith,L., Reilley,P. (2010) Acute toxicity of fungicide formulations to amphibians at environmentally relevant concentrations. Environmental Toxicology and Chemistry 29(11): 2477-2480. 30 Brühl, C A, Schmidt, T, Pieper, S and Alscher, A (2013) Terrestrial pesticide exposure of amphibians: An underestimated cause of global decline? Scientific Reports (Nature) No 3 (1135), doi:10.1038/srep01135. 31 Hooser,E.A., Belden,J.B., Smith,L.M., McMurry,S.T. (2012) Acute toxicity of three strobilurin fungicide formulations and their active ingredients to tadpoles. Ecotoxicology 21: 1458-1464 32 Wagner,N., Reichenbecher,W., Teichmann,H., Tappeser,B., Lötters,S. (2013) Questions concerning the potential impact of glyphosate-based herbicides on amphibians. Environmental Toxicology & Chemistry 32(8): 1688-1700 33 Wagner, N, Reichenbecher, W, Teichmann, H and Lötters, S (2013) Questions concerning the potential impact of glyphosate-based herbicides on amphibians. Environmental Toxicology and Chemistry No 32 (8), pp1688-1700. 34 Malaj, E, von der Ohe, P C, Grote, M, Kühne, R, Mondy, C P, Usseglio-Polatera, P, Brack, W and Schäfer, R B (2014) Organic chemicals jeopardize the health of freshwater ecosystems on the continental scale. Proceedings of the National Academy of Sciences of the USA No 111 (26), pp9549-9554. 35 Schäfer,R.B., Von Der Ohe,P.C., Rasmussen,J., Kefford,B.J., Beketov,M.A., Schulz,R., Liess,M. (2012) Thresholds for the effects of pesticides on invertebrate communities and leaf breakdown in stream ecosystems. Environmental Science & Technology 46(9): 5134-5142 36 Beketov, M A, Kefford, B J, Schäfer, R B and Liess, M (2013) Pesticides reduce regional biodiversity of stream invertebrates. Proceedings of the National Academy of Sciences of the USA No 110 (27), pp11039-11043. 37 McMahon, T.A., Halstead,N.T., Johnson,S., Raffel,T.R., Romansic,J.M., Crumrine,P.W., Rohr,J.R. (2012) Fungicide-induced declines of freshwater biodiversity modify ecosystem functions and services. Ecology Letters 15(7): 714-722. doi:10.1111/j.1461-0248.2012.01790.x 38 Zubrod,J.P., Englert,D., Feckler,A., Koksharova,N., Konschak,M., Bundschuh,R., Schnetzer,N., Englert,K., Schulz,R., Bundschuh,M. (2015) Does the current fungicide risk assessment provide sufficient protection for key drivers in aquatic ecosystem functioning? Environmental Science & Technology 49, 1173-1181 39 Dijksterhuis,J., van Doorn,T., Samson,R., Postma,J. (2011) Effects of seven fungicides on nontarget aquatic fungi. Water Soil Air Pollution 222: 421-425. 40 EFSA (2015) Scientific Opinion on the effect assessment for pesticides on sediment organisms in edge-of-field surface water. EFSA Journal 2015 13(7): 4176 41 Rasmussen,J.J., Wilberg-Larsen,P., Baattrup-Pedersen,A., Cedergreen,N., McKnight,U.S., Kreuger,J., Jacobsen,D., Kristensen,E.A., Friberg,N. (2015) The legacy of pesticide pollution: An overlooked factor in current risk assessments of freshwater systems. Water Research In Press, doi: 10.1016/j.watres.2015.07.021 42 Knäbel,A., Meyer,K., Rapp,J., Schulz,R. (2014) Fungicide field concentrations exceed FOCUS surface water predictions: urgent need of model improvement. Environmental Science & Technology 48(1): 455-463

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Pesticide Action Network UK PAN UK is based in Brighton. We are the only UK charity focused solely on addressing the harm caused by chemical pesticides. We work tirelessly to apply pressure to governments, regulators, policy makers, industry and retailers to reduce the impact of harmful pesticides. Find out more about our work at: www.pan-uk.org

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Our Toxic Future?  

Why post-EU pesticide deregulation is a threat to the health of the people and environment of the UK

Our Toxic Future?  

Why post-EU pesticide deregulation is a threat to the health of the people and environment of the UK

Profile for pan-uk