Wyn Grant with Justin Greaves

Biopesticides: Environmental and Regulatory Sustainability

Crop production and pest management: the challenges• Pesticide product withdrawals

• Pesticide resistance

• Zero detectable residues

• Sustainable food chain: economic, environmental, social

• Integrated Pest Management (IPM)

Biopesticides: mass produced biologically based agents used for the control of plant pests

• Living organisms (natural enemies)• Micro-organisms

• (Arthropods & nematodes)*

• Naturally occurring substances (‘biochemicals’)• Plant extracts.

• Semiochemicals (pheromones & allelochemicals).

• Commodity substances.

*Not regulated by Plant Protection Products (PPP) legislation. Pests = arthropods, plant pathogens & weeds.

Plant protection product registration system• Two-tier system of registration

(legislation under revision in co-decision process)

• Active ingredients at EU level, products at member state level

• National authorisations PSD

• Mutual recognition not working

Biopesticide products registered in UK (5 in pipeline)

Insecticide Fungicide

Microorganism Bt

1

Microorganism non-BT

1 4

Baculovirus 1

Total 3 4

Biopesticide PPP active substances listed on Annex 1• 40 insecticides (27 pheromones, 8

microorganisms, 5 baculovirus)• 20 fungicides (all microorganism non-

Bt)• 1 Nematicide, 6 Repellants (all

botanical), 2 others (both botanical)• Includes substances voted with entry

into force date of 1 May 2009

Biopesticides and IPM

• Often very specific

• Compatible with other control agents

• Little or no residue

• Inexpensive to develop

• Natural enemies used in ecologically-based IPM

• Lower potency than synthetic pesticides

But uptake has been low & potential benefits are not yet being realised

• Economics (market size, external costs).

• Efficacy (potency, application, formulation).

• IPM (integration, best use of biological characteristics).

• Regulation (system principles, design & operation).

• How can research help? Theory & application.

Work of natural scientists

• Ecology of insect pathogenic fungi

• Genetic structure of natural populations

• Ecological factors determining the occurrence of natural populations

• Theoretical basis for understanding fate, behaviour and environmental impact of biopesticides strains

Focus of political scientists

• Regulatory state perspective (Moran)

• Underlying design principles

• Stakeholder relationships (policy networks)

• Role of retailers

• Inform regulatory process, including training of regulators

Regulatory innovation

• Forthcoming paper by Justin Greaves in Public Policy and Administration

• Regulatory innovation a contradiction in terms as regulators are cautious and risk averse

• Combination of exogenous and endogenous pressures induces change

Improved knowledge base and chain• Better understanding of ecology of

microbial control agents

• Availability of expertise for PSD and ACP

• A more effective knowledge chain linking, e.g., growers and researchers

Underlying principles (1)

• Biopesticides have a key and specific role to play in crop protection as part of IPM – problems of resistance and reduced availability

• Biopesticides should be regulated – because something is ‘natural’ does not mean that it is safe

Underlying principles (2)

• The regulatory system must support sustainability objectives

• This includes economic sustainability

• The ability of SMEs to succeed and growers to have the right plant protection tools

Underlying principles (3)

• Pest management should be ecologically based

• Biopesticides offer benefits to conventional and organic farmers

• Credibility with all stakeholder groups and especially consumers is key – problem of name

Stakeholder involvement

• Weak, immature and poorly integrated policy network

• REBECA (EC policy action) helped, but follow on?

• Further organisational development of IBMA

• Where is constituency of support?

A quasi-governmental champion• Provided in USA by Biopesticides and

Pollution Prevention Division of EPA

• PSD as regulatory agency not really equipped for an advocacy role

• Possible role for Natural England?

• Risk of case being sidelined

Organisation of PSD

• Now part of HSE, a work in progress

• Continue to develop work of Biopesticides Champion and team

• Still uncertainties about organisational culture

• They have been trained, now they need more customers

Efficacy testing

• Submission of data not required in US

• Needed for marketing purposes and to protect product reputation

• Work of Biopesticides Steering Group of OECD

• Support REBECA proposal to allow applicants to defer efficacy testing

Biopesticides scheme• A welcome development, but still

outreach challenges• Importance of early pre-submission

meetings• Distinctive approval number for

Biopesticides?• ‘Grey market’ of leaf enhancers, plant

strengtheners etc.

Role of retailers

• Reflect consumer concerns

• Ask for requirements that go beyond approvals system

• Variations between retailers increase complexity for growers

• Prohibit rather than promote specific products – which is difficult for them

European dimension

• Revision of 91/414 not complete

• Concerns about way in which EFSA operates

• Development of informal networks between regulators

• Eco zone proposal has attracted some criticism

Assistance with costs

• Still a gap between product ideas and an approved product on the market

• Some products may not be viable

• Market failure in terms of positive externalities not being realised

• Constraints of EU state aid rules

Visit our web site

• http://http://www2.warwick.ac.uk/fac/soc/pais/biopesticides/

• Thanks to project team – Dave Chandler, Justin Greaves, Gillian Prince, Mark Tatchell