Pesticides (Chap 9)

Is the UK “silently eroding” key environmental and human health protections in the Brexit-inspired rush to convert thousands of pages of European Union pesticide policy into British law? DEFRA says it will continue to rely on its expert committee, but critics say the 10,000 pages that have been drawn up with little scrutiny are putting more power into Minsters' hands.
Brexit may mean more exposure to pesticides according to Soil Association & PAN-UK. The Cocktail Effect' argues "for improved monitoring systems for pesticides, government-funded research and reducing pesticide use in the UK."
Prospect union warns of chemical chaos. "The UK chemicals sector is the second largest exporter to the EU with an annual turnover of £32 billion. The Chemicals Regulation Division (CRD) of the HSE of is one of major regulator partners in the EU. One of its main remits is to ensure that any negative effects of chemicals being used in farming are minimised on people and the environment. They are working on system to ensure that companies can continue to register chemicals in the UK. However, the system is an insurance policy at a considerable cost to the UK taxpayer and government as it might never need to be used.
Government needs to spell out how we would 'carry out risk assessment' post Brexit, according to Lords report. When they say 'risk assesment' they are already jumping the Brexit gun, as the EU law is largely based on hazards characterisation (eg the food MRLs), whereas Britain wants 'risk assessments' - which take into account actual use. Big debate to be had. If we wanted to have standards to comply with Single Market, we would have to stay with MRLs.
Worldwide decline in insect numbers blamed mainly on intensive agriculture, particularly pesticide usage. "In terrestrial ecosystems, Lepidoptera (butterflies & moths), Hymenoptera (bees, wasps & ants) and dung beetles (Coleoptera) appear to be the taxa most affected, whereas four major aquatic taxa (Odonata (Dragonflies), Plecoptera, Trichoptera (Caddis) and Ephemeroptera (Mayflies)) have already lost a considerable proportion of species."
Caroline Lucas Green MP speaks about "the malign influence of the pesticide industry"
Charlie's (site author) doctorate was in 'the effects of herbicides on soil mesofauna'.
He was a member of the government's Advisory Committee on Pesticides for around 5 years My last year (2006) hat dealt with issue I bought up re biomonitoring workers for pesticides particularly migrant workers.While I was a member.. 2005 2004 2003 Me starting issue of monitoring workers for exposure particularly migrant workers.

Integrated Pest Management

IPM seeks to understand better about pests and diseases, using more natural methods to control them, and using chemical only as a last resort Possible IPM Course. New App to help Crop Protect

Higher proportions of Highly Hazardous Pesticides used in poorer countries

Proposed UK-US Deal

(Official DTI Official Notes 13-14 Nov 2017 Meeting p 41)

"Key Points to Note

The US repeatedly emphasised their view that the UK should seek regulatory autonomy following EU Exit to allow us to evaluate methods/products independently. The US suggested this would be beneficial for the UK not only in terms of trade, but in relation to productivity, competitiveness and driving innovation from our agricultural and bio-tech markets.

 The US saw their difference in approach from the EU as a `philosophical difference` between a risk based approach (US) and an increasingly hazard-based approach (EU). They expressed concern about the process by which decisions were reached on SPS matters, critiquing the comitology process for perceived politicisation when member states are consulted. The EU aims to reduce chemicals on food; the US aims to reduce pathogens, and these two systems are not easily compatible. The illustrative example cited was the struggle to reapprove glyphosate in the EU.

 There was recognition from the US of the sensitivity of SPS issues in the UK in terms of attention from the media and consumer groups. They are also sensitive to the likely push from the EU for harmonisation during EU Exit.  The US view the introduction of warning labels as harmful rather than as a step to public health."

at WTO about new EU MRLs

"Colombia and India raised concerns on the European Union policy on Maximum Residue Levels (MRLs) of the following pesticides: buprofezin, diflubenzuron, ethoxysulfurom, ioxynil, molinate, picoxystrobin and tepraloxydim. They said the EU has based measures on a 'Hazards approach". The US and 13 others said there was not enough time to comply.
This is part of wider debate that will open up on Brexit. The EU 'Hazards' approach examines the intrinsic properties of the chemical which are then used to guide control mechanisms. The UK will want to adopt a 'Risk-based' approach which tries to take into account the actual conditions of use. While on the government's Advisory Committee on Pesticides, we voted which approach we would like to adopt. I voted for 'Hazards' but lost 1 - 18 preferring 'risk based' approach. The UK has always favoured this - rather than intrinsic dangers - even going back to the days when we were concerned about 'acid rain'. The UK argued in the 1970s that we didn't need to control acid rain - as our winds and rain got rid of the intrinsic hazards of acid (sulphur from power stations polluted the air),. Nevertheless countries in Scandinavia accused UK of the being 'The Dirty Man of Europe' for killing their trees.

Pesticides at Crossroads

Are we overusing pesticides? "The number of pesticides applied to an average hectare of UK cropland rose by a whopping 24% between 2000 and 2016, according to government figures. ".
FRC Report on possible changes to pesticide control in UK post-Brexit recommends us to "
Maintain the EU’s hazard-based approach (rather than revert to a risk-based approach) to pesticide regulation.
Introduce a clear, quantitative target for reducing the overall use of pesticides in agriculture.
Create a new government body to support Integrated Pest Management (IPM) techniques."
The 'hazards' approach is based on the inherent dangers of any substance and works from there. eg the Maximum pesticide residue levels in foods (MRLs) are based on the inherent dangers of the substance. A risk-based approach tries to work out what actually happens on release and determine the likelihood of the danger being expressed. While I was serving on the government's Advisory Committee on Pesticides, there was a vote on whether we should adopt the EU style of 'hazards' based approach or develop their preferred 'risk-based' approach. I voted for 'hazards' and lost 1-18.I cannot see how we would do away with MRLs - as that is key standard on moving food about, and is taken very seriously by food retailers. The risk-based approach reminds me of the old days of British pollution control - 'let the wind and water blow it away' was how we dealt with acid rain for many years. Much more in the book!

Pesticide Approval

Pesticide Approval in the EU due to change The EU system for approving pesticides has to show greater transparency
Glyphosate has been at the centre of a fierce scientific debate – mixing associations, politicians and health agencies – whose transparency has been called into question. More see Glyphosate Following this chaotic process, the European Parliament established a special committee to shed light on the process of approving pesticides. Some of their recomendations include:"All of the studies submitted by industry in the approval documentation will have to be made public and their findings will have to be presented in a usable form. ..the same weight is given to academic studies. The European Commission should choose the member state rapporteur of the active substance.there should better post-approval monitoring in order to assess the doses to which the population and the environment are actually exposed, as well as the toxic effects arising from their use. I too proposed this in Bittersweet Brexit Chapter 9. Now I find it has a very clever name : phytopharmacovigilance. "
Part of the approval process is the requirement for protective clothing. Protective Clothing fails to remove all risk. "Pesticide exposure among horticultural workers has shown that levels of contamination can take place despite the provision of protective equipment. "

Early case-control studies revealed that farmers were overrepresented among the victims of a fairly large number of pathologies, mainly cancers and neurovegetative disorders. Two more recent cohorts, i.e. studies of the health events affecting large populations of farmers still in good health and the monitoring of their use of pesticides, provide more reassurance - that for "about 1/3 of the cancers studied (mainly cancers of the respiratory and digestive tracts and the bladder), the standardized incidence of cancer in farmers using pesticides is significantly lower than the mean; for nearly 2/3 of the other types of cancer, there is no significant difference with the general population. " (Differences between case-control and cohort studies) This provides some reassurance, as the UK has better pesticide controls than either France or USA. But it does not provide much comfort for all those plantation workers in the rest of the world, and the studies do not distinguish the two main sorts of pesticides - herbicides and insecticides, each with v different toxic characteristics.
Symposium (June 2018) on role of Pesticides in Sustainable Agriculture in EU. This will include examining the renewal of Glyphosate.General Pesticides
French studies of nearly a thousand farms "failed to detect any conflict between low pesticide use and both high productivity and high profitability in 77% of the farms". They estimated that total pesticide use could be reduced by over 40% without any negative p&p effects in nearly 60% of farms.
Game & Wildlife APPG debate Precautionary Principle post Brexit. CPA v PAN. CPA said: "“risk assessment can deliver high environmental standards while producing more appropriate decisions than a hazard-based or precautionary approach because it allows the valuator to take into account a fuller picture of available information”. PAN said: " PP is a good principle and a common sense principle. It’s a driver for innovation and particularly in the pesticide industry.” (Much more in Chapter 9)
Pesticide Vigilance Science Magazine shows lack of post approval monitoring, agreeing with what was proposed in Bittersweet Brexit.EU to ban pesticides on EFAs (Ecol Focus Areas - farms over 15 h must have 5% designated as EFA.)
Organic Regulation post-Brexit
Diquat - as potato desiccant, set to be banned by EU. Alternatives to diquat for destroying potato haulm include flailing and sequences of other sprays, but none of these methods is as quick and effective as diquat.


Chlorpyrifos set to be banned by EU (Aug '19). "Chlorpyrifos does not meet the criteria required by legislation for the renewal of its approval (Jan 2020) in the European Union, EFSA (EU Food Safety Assoc) has said in a statement...EFSA has identified concerns about possible genotoxic effects as well as neurological effects during development
There are calls in 2019 to 'Ban Chlorpyrifos', an insecticide used to control insect pests in agricultural crops and amenity situations. This is because the EU is reviewing its approval, arguing that the EU ignored hundreds of independent studies showing evidence of brain-harming effects from chlorpyrifos in their 2005 review,
Following a European Union review, new human health based safety levels (known as endpoints) were agreed in 2015 for chlorpyrifos. Risk assessments carried out by the Health and Safety Executive (HSE) and endorsed by the Expert Committee on Pesticides (ECP) indicated that most currently authorised uses of chlorpyrifos (in UK) exceed these newly agreed endpoints.
While EU is responsible for overall approval of active substances, any member state can decide on formulations of the chemical. As a results of above findings, all uses of chlorpyrifos, other than brassica seedling drenches using gantry sprayers, were withdrawn in UK from 1st April 2016.


The EU ban (Mar '19) on chlorothalonil (UK's most used pesticide) is based on EFSA’s scientific assessment which concluded that the approval criteria do not seem to be satisfied for a wide range of reasons. Great concerns are raised in relation to contamination of groundwater by metabolites of the substance.”

Chlorothalonil has been used across the world since 1964 on barley and wheat, as well as potatoes, peas and beans. The ban will be passed formally in late April or early May and then enter into force three weeks later, the commission spokeswoman said.


@DefraGovUK announce the emergency derogation for #neonic use in sugar beet. R&D into alternatives remain a priority. It could have happened even if the UK was in the EU. France and a few other EU countries have also granted emergency derogations for neonics in the past 6 months.

ICL Scientists find brain damage in young bees

France ban all 5 neo-nics
Three quarters of public want stronger action on neonics. Three neonicotinoid pesticides were restricted from being used on flowering crops attractive to bees across the EU, due to harm to honey bees and wild bees. However, neonicotinoid treated seeds are still widely used in other crops - such as wheat - and as a result are still entering the soil and water, which can end up in wild flowers or flowering crops, thus posing an additional threat to bees. This is why the European Commission extended the ban to all crops. CEH says we need to 'Rethink our strategies' "like forecasting of pest outbreaks, use of techniques like gene editing to more rapidly produce crop varieties with durable disease resistance, and use of traditional control strategies like crop rotation'"
First study to show direct harm of neonics to songbirds. Birds fed with small quantities of neonics (equivalent of single corn seed) lost weight and more importantly got lost; this isn't helpful for migratory species.
Do bees loose their buzz? IPM for Brassicas
Only 1/2 million acres (down about 100,000) Oilseed Rape being grown in UK due to flea beetle threats, meaning that around 1/2 m tonnes being exported - from places like Ukraine who do not bother with neonic ban. Says United Oilseeds managing director Chris Baldwin: "“We need to come together to halt this trend and we need some kind of working party to fight against this flea beetle in a sustainable, environmentally friendly and economically viable way.”
Flea beetle control New research finds a non-chemical control method resulted in 30-60% larvae reductions.
Matt Ridley argues that Neonics different from other insecticides as they are mainly used for seed dressing - thereby obviating the need to spray later. But this is exactly the point I make in the book - that this use is like routine use of antibiotics - that resistance will build up earlier, and in the insecticidal properties get everywhere rather than targeted on the pest when needed. So I argue for banning use as a seed dressing, but - under careful control - use when pest outbreaks - and the evidence from Royal Society backs this up. Game & Wildlife Conservation Trust back Ridley. Their neonic Guide
Michael Gove says we will keep present EU ban on neonics, when we leave the EU "The European Commission has now proposed the ban is extended to non-flowering crops. I asked the UK’s independent advisory body on pesticides to review the issue again. In their view, there is a growing body of evidence that indicates that the risks posed by neonicotinoids are greater than previously understood. They advise that the evidence now supports the restrictions introduced in 2013"
Heavy neonic pollution of rivers uncovered as part of EU Water Directive's 'Watch List'. Five rivers were chronically polluted and two acutely so, most in the Eastern counties.
EU delays decision for blanket ban till early 2018. April 2018, EU ban three neonicotinoids, with 16 countries (inc UK!, France Germany) in favour, 5 opposed and 13 abstentions. Beet farmers are concerned that banning neonic seed treatment will result in more spraying with more harmful sprays. I would certainly not like to see any increased use of organophosphate insecticides - much more toxic to people. The beet farmers say they will be undercut by sugar grown abroad without these standards.

Michael Gove said he would resist any ban on glyphosate Following inability to reach qualified majority on Standing Committee on Plants, Animals, Food and Feed (SCoPAFF) about re-approval Gove says "The scientific picture on glyphosate is very different (from neonics). UK and EU scientists have clearly advised that it does not pose a risk to human health or the environment and that’s why the UK government supports its continuing approval."
Ask for Evidence Lesson PlanHow glyphosate ban would affect no-till farmers
EU countries vote 2:1 to allow Glyphosate for another 5 years UK, Germany & Poland (both previously abstained) voted to allow, France and Belgium against, Portugal abstained. Macron in France goes alone and promises ban in 3 years. This opens up a curious EU conundrum. If the EU votes to allow a substance, but France goes and bans it, is the reverse allowed? Where the EU bans a substance (or e.g GM crop), can a member state ignore the decision and allow it?
I cant help but think there needs to be a whole new set of clear criteria and tests agreed by all..see Chap 9 and 'Hazards Approach' for suggested way forward. And there needs to be a massive prospective epidemiological study measuring exposures and agreed health endpoints - funded by Monsanto but run in the public sector. But that depends on politics, not science.Conspiracy to misrepresent risks?
Monsanto in Court in California See Analysis of the judgement

Copper Sulphate

Approval was renewed in Jan 2018 one of the 'data gaps' they addressed is mammalian toxicology area, "or toxicological information on the stabilisers used in the technical concentrates of some manufacturers.
Estimated exposure of workers re-entering vineyards treated with copper-based formulations exceed the acceptable operator exposure level (AOEL); considering the results of a repeated-dose toxicity study by inhalation, special care should be given for the protection of operators applying insoluble copper-based formulations." Further "an indicative consumer exposure calculated on the basis of available data ...resulted in a chronic exposure of 72.3% acceptable daily intake (ADI)." And Para 5 Ecotoxicology "data gaps were identified for further information to address the risk to birds and mammals, aquatic organisms, bees and other non-target arthropods and earthworms and other soil macro-organisms. A high risk was concluded for all the representative uses for birds and mammals, aquatic organisms and soil macro-organisms (critical area of concern)." Whether earthworms are more sensitive than soil macro organisms was not established.
Despite over 30 'data gaps', that consumer risks could not be finalised, and that there are three critical areas of concern, including 'high risk' to soil macro organisms (Para 9.2), copper sulphate got re-approval. It recommends Personal Protection for workers. Despite all this, copper sulphate is one of the chemicals that are allowed in organic farming.


Worldwide emergence of human resistance to anti-fungal drugs may be due to their other widespread use - on crops. Resistance to anti-biotics has received a lot of attention, but nowhere near as much for anti-fungals, yet the the rate of increased resistance is 'unprecedented'. "The azoles remain the dominant chemicals in the treatment of fungal infections in crops, humans, and livestock, with five licensed clinical azole antifungals and 31 available for crop protection.". This is a long way from being 'proved', but a big signal to look into causal connections.