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Animal & Plant Health Association

APHA

The Animal and Plant Health Association (APHA) is the representative body for manufacturers and sole distributors of animal health (veterinary medicines) and plant health (plant protection/agrochemical) products in Ireland.

Lobbying Activity

Response to Sustainable use of pesticides – revision of the EU rules

16 Sept 2022

Ireland is a food production country. Agriculture is and will remain a core sector for our country. Despite the importance of Agriculture, and the many weather-related challenges faced by Irish Farmers, Ireland's use of pesticides is low and declining over time. Ireland uses 32% of the EU average application of pesticides per Hectare of utilisable agricultural area. Over time 2011 - 2020 usage per hectare has declined by over 20%. These statistics are validated by Eurostat, and demonstrate the responsible approach taken by farmers, advised by the network of professional advisors to minimise the use of pesticides. Against this track record, Government in Ireland have a stated objective to increase crop production so an adequate toolbox must be available for farmers to effectively protect their crops from diseases, weeds, and pests. Rather than imposing arbitrary targets, coupled with overburdening administrative requirements, and an undifferentiated approach to sensitive areas, as proposed in the draft SUR published in June 2022, on member states who are demonstrating a responsible approach to reduce pesticide use, the EU Commission should focus on improving the toolbox available to farmers. Access to new products (both conventional and new bio pesticides), new technologies in plant breeding and precision agriculture need to be prioritised. Integrated Pest Management (IPM) depends on the availability of alternatives to pesticides, and progress has been slow. The EU Commission should speed up all evaluations. Consideration should also be given to the positive contribution pesticides can make to tackling climate change by lowering greenhouse gas emissions through carbon sequestration. Non-inversion tillage and the various associated minimum tillage approaches are enabled through the use of herbicides. Without these tools, conservation tillage will no longer be possible, so arbitrary reduction targets are not appropriate. Recent events have demonstrated EU external energy dependency. Whilst the EU may not yet view food security similarly, it should be very cautious of the warnings contained in the impact assessment of the draft SUR, which state "Professional pesticide users will face additional costs for record keeping and for advisory services. Banning the use of chemical pesticides in sensitive areas may result in lower crop yields from those areas. The pesticide industry may see reduced demand for their products. Higher production costs may also trigger a rise in food prices for EU consumers. EU reliance on imports such as cereals may increase" Suggestions that CAP funds can be used to compensate for the impact seems to imply that there is capacity in CAP to accommodate these costs, but our understanding of the demand on CAP funding suggests otherwise. In Summary, please Recognise the pesticide usage records of member states and do not apply arbitrary reduction targets in the absence of other tools to control weeds and diseases Acknowledge the role of pesticides in managing and reducing greenhouse gas emissions, and don’t reverse the progress achieved to date. Do not force through regulation that will increase Europe’s reliance on imported cereals. We already see the dependence Europe has created in the energy sector on imported sources. Please do not create the same situation for food.
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Response to Criteria to identify endocrine disruptors for plant protection products

27 Jul 2016

APHA considers the proposal for the ED criteria for pesticides to be unacceptable in its current form and fails to take agriculture, food production, sustainable farming and viable farming into account. We are highly concerned that the proposal will have unintended and potentially dangerous consequences for the food chain and will ,further reduce the availability of crop protection solutions for farmers, without providing any demonstrable benefits to health or the environment. Proportionality and specific awareness of potential consequences, especially unintended consequences need to be addressed. If our farmers/growers cannot prevent or cure disease in crops, and these crops are then not giving a financial return, they will not be grown. For Ireland a potential loss of significant numbers of “preventative and disease tools” will make cereal and crop farming unprofitable and therefore not viable in Ireland. See example of Wheat in Ireland. Wheat Growing in Ireland. Currently wheat disease control programmes in Ireland are heavily reliant upon azole fungicides (commonly referred to as triazole fungicides). Most wheat crops now receive between three or four fungicide applications to prevent yield reductions mainly caused by disease. Although the main target of these applications is often Septoria, additional disease are also targeted at 3 different timings (e.g. FHB at the ear application) The broad spectrum of activity of the triazoles, coupled with their ability to provide protection and eradication have meant their inclusion in three applications during the growing period (those timed to provide best protection of the upper canopy and the ear which contribute most to yield) has become relied upon. As Septoria is the principal target, in the absence of triazoles, fungicide programmes will become heavily reliant on the SDHIs, with specific fungicides included to target the other pathogens. Unfortunately due to the development of resistance the availability of alternative fungicides is limited, e.g. control of FHB is almost entirely dependent upon the triazole fungicides, and wet summers such as 2012 can cause significant yield losses of 1.5 t/ha. Due to their mode of action the SDHI (new chemistry) fungicides are very susceptible to resistance development. Resistance prevention is mainly achieved through mixing active ingredients and in the case of STB the most useful combinations are triazoles and SDHIs. The loss of triazoles is therefore likely to hasten resistance to SDHI’s, which may provide useful control for only a couple of years once mixing ceases. When resistance develops to SDHI’s there will be no useful chemical control of Eyespot which will become reliant on long non-cereal breaks between cereal crops and Septoria fungicide programmes would become entirely protectant in nature built upon multisite fungicides (e.g. chlorothalonil). Under normal Irish climatic and cropping practises a drop in productivity would be expected of 20% or more from reliance on multisites for Septoria control. These proposals, if approved in their present form, and with the subsequent loss of actives will in all probability result in a significant development of resistant mutants to the newer chemistry SHDI. There is already growing evidence of this after 3 seasons with this new chemistry in UK and Ireland. A similar situation exists for potatoes growing in Ireland. The potential loss of Maneb and Mancoseb, which have particular modes of action in control of blight in potatoes, will have consequences. EU wide legislation needs also to take account of the pressures that the climatic conditions that farmers/growers are growing their crops. Ireland, has predominantly temperate mild climate and this results in warm damp weather that is conducive to certain wet weather type fungi developments. We need the tools to control these diseases.
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