Description
Pesticide labels in the UK must carry a highlighted section that contains the statutory conditions of use. These statutory conditions would include, inter alia, field of use restrictions, crops/situations that may be treated, maximum individual dose/application rate, maximum number of treatments/total dose, last time of application, environmental protection requirements and any other specific restrictions (PSD, 2004). Specific restrictions to address risk mitigation for specific exposure pathways, like drainflow, have been used to great effect in other countries, like the United States and Germany. At present specific label restrictions that vary spatially, e.g. restricted use on vulnerable or drained soils, are not permitted in the UK. This is largely a function of the ability of the user to interpret these varying restrictions, the uncertainty of their knowledge of their land and potential exposure pathways as well as the ability to police/enforce compliance with them.
However, the establishment of Water Framework Directive (WFD) river basin districts, with their accompanying management plans, offer the potential for clearly defined, managed spatial units that might, in part, address these concerns. In addition, various legislative drivers (Cross Compliance, Entry Level Scheme, Voluntary Initiative) are also forcing/encouraging land managers to consider risk, including spatially variable aspects like soils, when compiling their various management plans e.g. manure, soil or crop protection management plans. The restructuring of the farm payments also offers a financial mechanism to aid compliance, e.g. under statutory management requirement 9 of the cross-compliance guidelines pesticides should be used in accordance with the label.
In order to inform this discussion further a suite of questions centred on land managers knowledge of their land were included in the Defra Farm Practices Survey (FPS) and the ADAS Farmers Voice survey. We propose analysing and summarising these results at both WFD river basin district and Defra region. The output would be a report summarising the results along with interpretation of the headline issues.
|