2454 final report.pdf - Agra CEAS Consulting

Evaluation of the Community Plant Health Regime: Final Report
DG SANCO Evaluation Framework Contract Lot 3 (Food Chain)
The reduction of active substances available for control measures may also lead to a situation
where for a certain pest or even group of pests, only one family of products is likely to be
available creating a risk of the development of pesticide resistance, as it becomes almost
impossible to rotate the PPP used.
For example, as illustrated in the National Audit Office (NAO, 2003) report on protecting
England and Wales from plant pests and diseases, the main pesticides used to combat Thrips
palmi, are no longer available because they are prohibited from use in the EU. The study
concludes that any outbreak might therefore be more difficult to contain and eradicate in
future. The report concludes that the relevant competent authorities need to work more closely
together to co-ordinate the phasing out of key pesticides alongside the development and use of
other means of control, such as pest-resistant crops. Similar recommendations were indicated
by several respondents to the general survey and during the interviews.
Another potential issue to consider is that the framework Directive on the sustainable use of
PPP in principle prohibits aerial treatment 252 , and defines buffer zones around aquatic areas
(rivers, lake, etc...) in which the use of PPPs may be forbidden. These two elements may
create refuge zones for some HOs, and this could put at risk eradication measures in certain
cases. In particular, aerial treatments are in some cases the only solution if particular action is
required in forestry.
An adverse effect of the increasing prohibitions on usage of PPPs in Europe, as mentioned by
one interviewee representing farmers, is that the cultivation of some crops is moving to third
countries, where less strict rules apply to the use of pesticides. The problem in this case is that
some substances are detectable only for a limited period only after harvest (i.e. 15 days, but
not one month); therefore when products on which such substances have been used are
imported, the controls may fail to detect these substances.
Biological control measures may be an alternative to the reduction and/or ban on use of PPPs,
However such measures are by definition never fully and immediately effective, particularly
to address quarantine pests. Also, the availability of these alternative methods at large
commercial scale is rather limited at the moment.
Due to the recent entry into force of the new PPP legislation, FCEC considers that it is
premature to judge on the inconsistencies between PPP legislation and CPHR. The extent to
which the possibility for derogation in case of minor crops and in case of serious danger for
plant health will be used and granted in practice as well as the extent to which the PPPs for
which derogation are requested are likely to be available to farmers (there is the risk that PPP
manufacturers will not be producing products that would not be authorised just in case there
may be a need for them) are not known at this stage.
252 Aerial treatment is forbidden by the new Framework Directive 2009/128 (art.9 (1)) but case by case
derogations can be granted by MS (art. 9 (2 and following)). For example in FR, aerial treatment is authorized in
some cases, e.g. Bacillus thuringiensis against Thaumetopoea pityocampa in forests.
Food Chain Evaluation Consortium 261