Biopesticides: Environmental and Regulatory …...specific role to play in crop protection as part...

David Chandler and Wyn Grant, Warwick HRI and PAIS

Biopesticides: Environmental and Regulatory Sustainability

• Pesticide product withdrawals.

• Pesticide resistance.

• Zero detectable residues.

• Sustainable food chain: economic, environmental, social.

• integrated pest management (IPM).

Crop Production & Pest Management: problems & opportunities

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.

• Genes (not EU).• Plant incorporated products.

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

In the EU, microbes & biochemicals are registered as plant protection products

• National authorisations (PSD).– Biopesticides Scheme

• EU arrangements: – Harmonisation.

– Mutual recognition.

– Tailored requirements for biopesticides.

Biopesticides & IPM

• Often v. 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.

Warwick research on biopesticides: insightsfrom natural & political science (1)

• Ecology of insect pathogenic fungi.– Genetic structure of natural populations.

– Ecological factors determining the occurrence of natural populations.

– Theoretical basis for understanding fate, behaviour & environmental impact of biopesticide strains.

Warwick research on biopesticides: insights from natural & political science (2)

• Analysis of biopesticide regulation usingpolitical science (multi level theories).– Underlying principles for regulation.

– Interactions between stakeholders.

– Role of retailers.

– Cost benefit analysis.

• Inform data requirements & regulatory process.

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.

Improved knowledge base & 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.

Stakeholder involvement• A weak policy network• REBECA has helped, but how can it

be continued?• Relative isolation of environmental

groups• Further development of IBMA• Where is constituency of support?

A quasi-governmental champion

• Provided in USA by Biopesticides and Pollution Prevention Division of EPA.

• PSD not really equipped for an advocacy role.

• Possible role for Natural England?

• Risk of case being sidelined.

Organisation of PSD

• Future structure under review, presents some challenges.

• Continue to develop work of Biopesticides Champion and team.

• They have been trained, now they need more customers.

Strengthening ACP

• Development of EU system will require some changes.

• Needs an impartial expert on biopesticides and access to external advice.

Efficacy testing• Submission of data not required in US.

• Needed for marketing purposes and to protect product reputation.

• Work of Biopesticides Steering Group at OECD.

• Support REBECA proposal to allow applicants to defer efficacy testing.

Biopesticides Scheme• A welcome development.• Still outreach challenges.• Importance of early pre-submission

meetings.• Distinctive approval number for

Biopesticides?

Role of retailers• Reflect consumer concerns.• Ask for requirements that go

beyond approvals system.• Legitimately commercially driven.• Variations between retailers.• 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?

Cost-benefit analysis workshop

• Natural and social science experts.

• Brainstorming produced list of perceived costs and benefits.

• Sorted across six stakeholder groups.

CBA results• Negative balance for developers (-14) and

growers (-9)• Moderately negative for retailers (-6) and

evenly balanced for regulators (-1)• Positive for consumers (+2) and opinion

formers (+7)• Is there a balance between private costs

and public goods?

• Dept of Politics & International Studies.Wyn Grant, Justin Greaves.

• Warwick HRI.Dave Chandler, Gill Prince.

• Dept of Biological Sciences.Mark Tatchell.

RELU project team at Warwick

Visit our website

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