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The ‘minor uses’ problem

A frequently expressed concern is that the main potential losers from the proposed changes in pesticide rules might be various fruits and vegatables such as peas, cabbages and carrots. The relatively small volumes of production might not justify the commercial effort to find replacement products. Although customarily referred to as ‘minor uses’ of plant protection products, they are important components of a healthy diet. Less well off consumers might particularly be affected by an increase in their price as a result of reduced availability of supply.

This issue was addressed by consultant Cathy Knott at a NFU pesticides conference. She argued that, ‘You may still be able to grow arable crops, but horticultural crops just wouldn’t be viable.’ The greatest threats were to carrot, strawberry, onion, lettuce and pea crops. Leeks and parsnips would also be severely affected. Weed control, in particular, could be compromised in many of these crops, especially carrots.

Volunteer potato control would be a particular struggle without a prosulfocarb + linuron mix, following the loss of metotoxuron. Failing to control weeds that produced toxic weed parts, such as black nightshade berries or volunteer potato apples in vining pea crops, could be a serious threat to the industry. She warned, ‘If vining peas become uneconomic to produce, then factories could close and frozen and canned peas could be imported from outside the EU.’

The loss of ioxynil on top of linuron and pendimethalin would be serious for onions, and metazachlor is important for brassicas. In strawberries, propachlor and napropamide had been lost already. ‘Losing pendimethalin would finish them off.’ Mechanical weed control in some crops would be an option, but yields would be reduced because of less effective weed control, and growers would need extra hand labour, a resource they struggled to find already. ‘Finding enough land to maintain production would be a problem too.’

Disease conrol in a number of crops would be compromised if triazole fungicides fell foul of an endrocrine disruptor hazard criteria, and the added restrictions proposed by the European Parliament would exacerbate problems by removing alternative fungicides.

The Commission would no doubt emphasise the five year derogation which is available where an active substance is necessary to control a serious danger to plant health which cannot be contained by any other available means, although even that has been challenged in the Parliament.

In a recent written Parliamentary answer, EU Health Commissioner Androulla Vassiliou denied that the criteria are cut-off criteria because ‘highly hazardous substances can be approved if exposure to them is negligible (e.g., closed system).’ However, this would be of little help in relation to field vegetables. She also argued that the one impact assessment carried out by a member state, that by the Pesticides Safety Directorate in the UK, was ‘unrealistic’ because it was based on a worst-case scenario where, for example, all endocrine disruptors would be classified as such after a scientific evaluation.

Opponents of an impact assessment at the EU level by EFSA argue that it is a delaying tactic. Parliament Rappoteur Hiltrud Breyer has pointed to the REACH regulation on chemicals which ended up with 42 impact assessments which all reached different conclusions. Nevertheless, there are so many conflicting views on the proposed new regulations, and their potential impact – especially on minor crops – is so great that there is surely an argument for improving the evidence base on which important decisions are made.

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