MUCH DELAYED NATIONAL ACTION PLAN FINALLY PUBLISHED

Professor John Moverley of JMM Solutions Consultancy, writes . . .

The much-delayed National Action Plan or NAP has finally been published by the UK government and supported by national governments in the UK. Work on this began some four years ago and publication initially promised early 2023. The NAP is framed against statutory obligations in pesticides regulation. 

So, what is the first reaction, well to be honest, from my side, somewhat disappointing. The amenity and sports sector were expecting to get a clear steer on requirements. However, the document , whilst stating intentions, lacks detail. So, what does it say?

Integrated Approaches

Well, it has three main sections. The first is entitled ‘encouraging the development and uptake of integrated pest management (IPM) and alternative approaches or techniques to reduce dependency on the use of pesticides’ The move to integrated approaches is part of the drive to further encourage sustainable practices and there has already been much progress in our amenity sector although clearly more to do. Again, on a personal basis, I do not like the wording alternative approaches - it tends to imply use pesticides or not as binary decisions, whilst in truth an integrated approach in any given situation is about choosing the right combination of methods and approaches and may often be one with pesticides and other methods in combination.

Within this section there is a separate sub section relating to amenity which contains the following ‘Those who work with professional pesticides must ensure that they have undertaken the relevant pesticide training or that they are supervised by someone who has, and that equipment is regularly tested and calibrated. To maintain good practice, it is important that organisations and individuals involved in the sector refresh their training. We want to encourage operators to regularly update their training and certification to include IPM elements. Membership of an assurance scheme can be a way of ensuring best practice is followed and industry standards are met’

It is good to see mention of the importance of refresher training and CPD and assurance schemes. The disappointment is that it is still about encouraging not requiring. I have long been an advocate of a UK Amenity Standard which would require all organisations to be members of an approved assurance scheme. It makes sense and would help further drive-up best practice. However, it is good to see the mention and is a clear message to all involved in the sector to commit to CPD and assurance schemes, if nothing else, to provide customers and the public of the high professional standard of any amenity service provided.

What is absolutely clear is the need to demonstrate sustainable practice as the UK drives forward with its sustainability targets. A great deal of what we do is already best sustainable practice but we need to understand this and continually improve. The section concludes with some specific actions which offer opportunity to potentially access funds for research and development. I would urge those in our sector to ensure we get our fair share of any potential resource.

Targets for pesticide reduction

The second section relates to ‘establishing timetables and targets for the reduction of the risks and impacts of pesticide use, including monitoring and setting targets for the reduction of use of pesticides containing active substances of particular concern’. The messaging is clear; the UK plan wishes to see further reductions in pesticide use by ensuring increases in the effectiveness of treatments, greater targeting etc.  The Pesticide Load Indicator (PLI) has been in operation for some time in the arable sub sector of agriculture. This gives indication of pesticide use not just in quantity terms nut amount of the various active ingredients. The PLI considers the acute (short-term) and chronic (long-term) toxicity of individual active substances to a range of organisms that are not the pesticide’s intended targets. The plan indicates an ambition to make use of PLI in horticulture and amenity. 

In the listed actions at the end of this section is reference to creating a UK framework for targeting and monitoring - again all linked to environmental and sustainable targets and the further reduction in pesticide use. 

Compliance

The final section is about ‘Strengthening compliance to ensure safety and better environmental outcomes’ Quite an amount of this is re-stating current regulations around OCR inspections, requirements for storage and handling plant protection products, equipment testing and training. Again, in the latter it is good to see emphasis on systems of Continuing Professional Development (CPD) for ongoing training, development and assurance and the BASIS run Professional Register is referred to in this context. Undoubtedly there will be more emphasis placed on CPD in our sector.

The actions listed at the end of this section includes one stating ‘Review how membership of industry/assurance schemes might be taken into account as part of assessing users’ risk profiles, so inspections are better targeted’ This is a further re-statement that assurance schemes are being promoted and will form part of any inspections by HSE and other bodies.

This is just a very brief summary of the NAP and based on just a first reading but hopefully it is helpful. No doubt in the coming weeks, more detail will emerge and I will endeavour to keep colleagues updated as this happens.