Should pesticides be toxed? Let us spray - on the vicarage lawn, railways, roadsides, and hedge bottoms? And what about residues and when the pest is a little furry animal? We engage in consultation with DEFRA. VEGA's comments on a DEFRA consultation due 30th June 2005, 'The Sustainable Use of Plant Protection Products - A Draft Nutritional Strategy'.
We are favourably impressed by the research and work entailed in preparation of the despatch and congratulate the Directorate on its assessment of the topics.
Question 1. In many consultation with DEFRA and the Food Standards Agency, we have called for much greater use of IT and a desire for openness in satisfying customers’ needs for full information and means of print-out from retailers’ websites available in-store and off-site. This requirement extends to education in schools in citizenships to arouse an appreciation over all standards in plough-to-plate, farm-to-fork (or Salutary Food from Salubrious Farming) production of food and consequent issues in the environment, international trade, and animal welfare. (We have been keen from its start that the British agency is a comprehensive Standards body, not just a body obsessed with targets of Safety). A better understanding of issues challenging and informing policies, compromises, and limitations in organic, permaculture and veganic regimes should be developed.
Animal welfare arises in challenges connected directly or indirectly with food production, e.g. as consumers of contaminated feeds, or recipients of untoward pesticide applications (as might occur with birds, insects such as bees, and fish, and as commensals or outright pests – and even the “enemy” in our unilaterally declared territorial war deserves some decency sentient beings), as well as victims in the undeniably cruel experimentation on aspects of residues and safety of the agents employed in this form of chemical and biological warfare: developments in genetic engineering must also be anticipated. We look forward to support for representations we have made on these matters to the FAWC. Components of formulation, e.g. tallowates used as adjuvants in sprays, may be derived from slaughterhouse by-products. Shooting is a means of plant protection, e.g. of ducks, pigeons, pheasants, crows, deer, and squirrels; it raises problems of environmental pollution in the form of lead and other harmful heavy metals, some of them avoidable by changes in the weaponry. The grey partridge presents a fine case of human duplicity: rescued from extinction under farming pressure, the species is now rescued by the processes of sustainable agriculture – to survive just for the joy of “sporting” exultation with a gun! (Clay pigeon shooting is a farming enterprise less cruel, but is another cause of environmental pollution with residues of toxic metals).
When gentle “scarecrows” methods of deterrence fail, resort to humane methods of killing (which entail prior capture in well supervised traps, but not snares) must be considered, with licensing in some instances, e.g. for the killing of moles.
Question 3. In previous consultations with DEFRA, FSA, and the Farm Animal Welfare Council, as well as in connection with the European REACH project, we have emphasized the need for training and licensing of all handlers, owners, and custodians of non-human animals. Similar upgrading of competence and care must apply complementarily to practitioners on the plant side of food and feed production, as well as on all toilers on the land for the purposes of commerce, leisure, amenity or pleasure and in the auxiliary trades (“land” in this context would apply to freshwater lakes and rivers and to estuarine and coastal areas). Current topics in EU and non EU, CAP and Fair Trade contexts, e.g. in the sugar regime bear on all these issues, particularly in exportation of comprised standards and importation of products cheapened and debased by such unworthy exchanges.
Question 4. Some items we have singled out for particular attention are:
1. Preservation by careful husbandry of set-aside corridors and hedge-bottoms raises conflicts of pest-control and residues of pesticides such as those raised in our answer to question 3 on grey partridge (further details on this and related matters are given in DEFRA Project CR0281, Provisional Bag Statistics for huntable birds, Parrot, O. and Moore, N., 2003).
2. Allegations of viral pesticides, e.g. to reduce rabbit populations making inroads into commercial cereal and grass crops raise issues of policing and control by the spread of diseases such as myxomatosis, and development of resistance and undesirable spread. We note also that antibiotics, such as the tetracyclines, are being used within the EU to counter blites on some pome trees, without due consideration of controls applying to medical and veterinary usage and multi-resistant cross-infections. These possibilities were raised in the last House of Lords report on this subject. Since then a further complication has arisen from marker genes and residues in crops made pesticide-resistance by GM.
3. The Strategy may have to pay more attention to water crops, such as watercress and the pests and pesticides associated with the crop and husbandry. Algal blooms are pestilences for which lack of care leading to eutrophication and resort to means of eradication are called for.
4. Sterilizing soils, e.g. in greenhouses used for crops of all sorts, may entail use of non-specific toxicants such as methyl bromide, also associated with severe atmospheric effects. Stores for grain may be “fogged” with volatile toxicants such as phosphine and formaldehyde. Special skills are required of operators to protect themselves from danger. Growth regulators and substances to burn off unwanted foliage or stubbles attract treatments with inorganic agents or formic or sulfuric acid. These include generally dangerous compounds. Burning off has been tried by organic farmers as a less hazardous alternative, but its efficacy and practicability are in doubt; it certainly attracts misgivings over usage of fossil fuels and generation of “greenhouse” gases beyond the expenditure in making “chemical” pesticides and the attendant contamination.
Question 5. Control by means of a pesticide tax or P numbers on labels (by analogy with E numbers for ingredients of food) has been mooted. The Strategy should consider the relevance of such measures. Such descriptions should be applied to other products from farming, e.g. textiles.