The consultation period on the United Kingdom’s Department of Environment, Food and Rural Affairs’ (Defra’s) draft National Action Plan (NAP) for the sustainable use of pesticides recently ended. The NAP is resulting in strong comments pro and con about a department plan that establishes an environmental perspective in overseeing pesticide use.  

Colin Ruscoe, Ph.D., British Crop Production Council (BCPC) chairman made an extensive comment that the BCPC issued to those in agriculture within the UK and the world. Some of the comments relate to programs that those outside the UK will not fully understand, but the overall comment content is interesting. Within the brackets below are comments that I’ve provided from my perspective.  

“BCPC welcomes Defra’s balanced and pragmatic approach. This includes the intention to continue the present direction and initiatives for supporting good practice, e.g. the Catchment Sensitive Farming program. Continuing the existing successful policies also has the benefit of not increasing the regulatory burden on business. [Whenever someone involved in agriculture can say a government policy would not increase regulatory burden, then that has to be music to those in agriculture’s ears.]

“BCPC is pleased to see that there is no intention to aim for pesticide use reduction per se—since this does not correlate with reduction of risk—but to continue the monitoring sales and usage data, and of pesticide residues. But although monitoring residues in relation to internationally agreed MRLs (maximum residue levels) is useful, great care must be taken in presenting such results, making clear the purpose and significance of the MRLs. Too often, the presence of any detectable residue above the MRLs is misrepresented as ‘a danger to health’ by the media. [Just as in the U.S., there always is concern about media that does not understand agriculture blowing things out of perspective.] 

“However, some aspects of the National Action Plan are of concern to BCPC. The UK’s approach to operator training, combining mandatory training and continuing professional development (CPD), has been highly successful in raising standards and reducing risks. CPD is not required by the draft National Action Plan, but it is desirable to maintain standards in our rapidly changing technological and regulatory environment. [Per this comment, it is obvious that professional training is an emphasis in the UK just as in the U.S.]

“BCPC supports the focus on protecting water courses, and on improvement of amenity and amateur usage; some amenity applications are potentially high risk and very visible to the public. However, this sector is generally not well dealt with. For example, there is nothing comparable to the crop assurance schemes that could drive an inspection regime for sprayers used in amenity applications. In some high risk situations, sprayers need to be tested more frequently than specified in the Sustainable Use Directive. [As in the U.S., there appears to be different enforcement for custom applicators and farmer application.]

"Reference is made to the suite of UK pesticide indicators, and we are pleased to see that there is no plan to proliferate indicators. However, BCPC stresses that caution needs to be used in applying some of the existing indicators. The Pesticide Forum Indicators Group uses the Farmland Birds Index, in recognition that there may be indirect effects from pesticides, but many other factors can have much greater effects on this index, including changes in land use such as the balance between winter and spring cropping. Other wildlife indices are being developed and these may be more suitable for assessing pesticide impacts.” [Possible pesticide influence on the environment and wildlife is always a concern and an area where the general public gets highly motivated to condemn agricultural business.]

Details of the UK NAP can be found at:

The British Crop Production Council (BCPC) is a 50-year-old non profit-making organization. The ag industry group contends it promotes science and practice of sustainable crop production.