Consultation outcome

Summary of responses

Updated 15 December 2021

Background

In 2020, Defra, the Scottish Government, the Welsh Government and the Department of Agriculture, Environment and Rural Affairs (DAERA) Northern Ireland (‘the four Administrations’) drafted a revised National Action Plan for the Sustainable Use of Pesticides (NAP). The revised NAP is intended to supersede the 2013 UK National Action Plan (2013 NAP), laying out a 5-year strategy to increase the sustainability of pesticide use in the UK.

The four Administrations sought the public’s views on the revised NAP through a public consultation. This document contains a summary of responses to the consultation on the revised NAP.

The high-level aim of the revised NAP is to minimise the risks and impacts of pesticides to human health and the environment, while ensuring pests and pesticide resistance are managed effectively.

In order to meet this aim, the draft revised NAP focuses on five key goals, to:

1. Ensure continued robust regulation to protect our health and environment
2. Support the development and uptake of Integrated Pest Management (IPM)
3. Ensure those that use pesticides do so safely and sustainably
4. Support in the reduction of the risks associated with pesticides by setting clear targets by the end of 2022, and improving metrics and indicators
5. Ensure that we work effectively with others to deliver the NAP goals

The consultation ran for 12 weeks between 4 December 2020 and 26 February 2021. 1,564 responses were received through Citizen Space, and 7 email campaigns organised by NGOs with a combined total of just under 37,000 emails.

This document summarises the main themes received. The next step is to consider the responses further and produce the final National Action Plan. The expectation is that it will be published in Spring 2022, and will be jointly adopted by the four Administrations.

Policy background

Pesticides play an important role in supporting the UK’s plant health, crop production and maintenance of national infrastructure and public spaces. Targeted use of pesticides protects our crops and natural landscapes from native and invasive non-native pests; supporting domestic food production and ecosystems and maintaining our recreational, transport and amenity areas. However, it is essential that the use of pesticides does not pose unacceptable risk to environmental health or adversely affect human health.

The 2013 UK National Action Plan was developed as a requirement of the Sustainable Use Directive and established actions to increase the sustainability of pesticide use in the UK including a framework of indicators for measuring success. The UK has left the EU since then. The NAP is due for revision and needs to reflect our increasing ambition for the UK environment whilst maintaining crop protection and fighting pesticide resistance. We want our regulation to be forward facing, rigorously protective of health and the environment and responsive to the changing pressures faced by farmers, the amenity sector and amateur growers.

Number of responses

There were 1,564 responses received through Citizen Space, distributed as shown in appendix A, and c.37,000 responses received by other means (including email), providing a wealth of detailed information.

A large number of responses received were classed as ‘campaign responses’ as they were identified as using standard wording to form all or part of the response. 205 Citizen Space responses have been identified as campaign responses, as well as just under 37,000 emails. Seven different email campaigns, and four different campaigns on Citizen Space were identified, assumed to be facilitated by a number of different organisations. It should be noted that campaign text is not always copied and pasted but often forms the basis for a more individualised response. For this reason, the count of campaign responses is an approximation.

A large number of emails received focused on neonicotinoids and their potential effects on bees and pollinators, with no explicit reference to the draft revised NAP. This suggests that the Emergency Authorisation, issued on 8 January 2021 for England to use a product containing a neonicotinoid to treat sugar beet seed in 2021 had a role in prompting a significant number of the responses.

All relevant responses, either through Citizen Space or via email, are used to inform the analysis. Qualitative analysis was undertaken to identify key themes which have been summarised below.

Key points raised

Regulation

Some respondents hoped for a more flexible approach to regulation now that the UK has left the European Union, for example, facilitating a quicker approvals process for low-risk actives or extending time periods for using up stocks of products which are being withdrawn. Suggestions for more efficient regulation largely focused on communications, with respondents asking for:

• more timely communication around the regulatory process and decisions
• clearer, more consistent and more accessible guidance to help them navigate the process

Many respondents emphasised the importance of robust regulation and were concerned that moves towards greater flexibility after leaving the European Union could be linked to a weakening of environmental and health protection. Suggestions put forward by this group included:

• reducing or eliminating the use of derogations
• stronger requirements to protect people who might be exposed to pesticides
• regulation of internet sales and ending the complexity of parallel trade

More transparent information-sharing and public accountability was also called for, including by:

• full publication of evidence underpinning decisions, and how this was funded
• more consultation and a dedicated communications channel for regulatory decisions, delivering engaging and accessible briefings

Respondents saw opportunities for the UK to lead on sustainable pest management by embracing innovative science and technology and supporting further development in genetics, biopesticides, nature-based solutions, and precision technology, taking full account of international developments. This would require investment in expertise, training, risk assessment and monitoring. The UK’s departure from the EU was referenced by respondents, with diverse and in some cases opposing views received for divergence, alignment and enhancement of protections.

IPM Uptake

Although a definition of IPM was provided in the consultation document, respondents interpreted this in different ways, which will need to be fully considered and accounted for in the final NAP. This included recognising existing uptake and that a ‘one size fits all’ approach would not be suitable or appropriate. Generally, respondents felt that more investment in provision of advice, training and education was needed to increase awareness, understanding and uptake of IPM, by:

• providing standardised and regularly updated IPM guidance for users, possibly via an IPM centre of excellence
• improving access to IPM education and training, across all sectors
• ensuring the credibility of advice through professional certification, support for peer to peer learning, and clear separation of advice from sales
• better communication of ‘what works’ in IPM, accounting for costs and effectiveness alongside environmental benefits

Promoting IPM within voluntary standards was felt by some respondents to be effective. Others argued that ‘sticks’ might be more effective than ‘carrots’ in delivering change among hard to reach groups though the complexity and variability of IPM solutions could make enforcement difficult to achieve.

There was widespread support for using future schemes that reward farmers and land managers for producing public goods to incentivise uptake of more sustainable pest management. There were mixed views on the usefulness and feasibility of implementing safety net schemes to cushion IPM risks.

Safe and responsible use and disposal

Respondents drew attention to areas of high levels of existing regulatory protections and good practice in responsible pesticide use, while highlighting that bringing everyone up to the standards of the best practice is still a challenge. Suggestions for doing so included:

• using licence systems to facilitate recording of pesticide purchaser details and subsequent tracking of usage and disposal practices
• increasing certification requirements and their rigour, including for sprayer testing schemes
• making it easier to report bad practice
• stronger enforcement of existing rules with tougher penalties to deter misuse, balanced with a supportive and collaborative approach where this is more effective
• more effective communication of good practice using the full range of available media

Many respondents felt that use of pesticides by amateurs should be more restricted, and that the potential environmental risks of pesticide products should be made much clearer on labels. They wanted retailers to do more to promote sustainable pest management solutions but also felt that motivating them to do so could be a challenge. There were calls by some respondents for a phase out of certain uses of pesticides, in particular for the amateur sector and in public spaces such as parks and schools. Suggestions for reducing risks of incorrect pesticide disposal focused on reducing costs of safe disposal for users and providing more convenient and well-advertised collection facilities, including take-back schemes and amnesties. Respondents recommended more investment in disposal science, recycler training and enforcement of standards.

Measuring our progress

Responses highlighted the urgent need for progress to increase the sustainability of pesticide use, supporting livelihoods while also reducing risks to our environment, ecosystems and biodiversity. Key suggestions included:

• the need for a systematic and joined-up approach to data collection and analysis, covering crop protection methods and their efficacy; pesticide usage and toxicity; environmental and health risk assessment; exposure and impact monitoring; actions taken and their effects
• maximising access to data to gain added value from scientific expertise
• investment in applied research with involvement of users to ensure it delivers practically applicable results
• adopting a precautionary approach where evidence is incomplete
• being open to innovation and encouraging wider participation in the search for more sustainable solutions, for example, through research challenges and competitions
• creation of a clear roadmap setting out commitments to action, timings, and goals
• making faster progress towards the establishment of targets for reducing the risks associated with pesticides
• ensuring that NAP governance includes representation from a full cross-section of interest groups, including the public, environmental and health organisations, and relevant independent experts as well as pesticide users and their advisors

The next steps

The themes identified from all the consultation responses, as well as key policy ideas and recommendations, will be used to inform the drafting of the final revised NAP. We plan to publish the final revised NAP in Spring 2022. The consultation responses will be securely held by Defra for two years in line with retention policies.

Appendix A: Citizen Space consultation responses by group

Option	Total	Percent (rounded to nearest whole number)
A member of the public	1061	68
Other - please specify in no more than 25 words	235	15
A farmer	59	4
Representative of a non-government organisation (NGO)	46	3
A scientist, researcher or academic	42	3
A horticultural grower or professional gardener	39	2
Representative of a farmers’ or growers’ organisation	20	1
Government or local authority representative	15	<1
Pesticides manufacturing or distribution industry representative	14	<1
An agronomist or pest management advisor	14	<1
Retail or food industry representative	10	<1
A land or amenity manager or developer	9	<1
Total	1564	100

Appendix B: List of responding organisations

• Abergavenny and Crickhowell Friends of the Earth
• Aberystwyth University
• Acton Court
• Adama Agricultural Solutions UK Ltd
• Affinity Water
• Agricultural Engineers Association
• Agriculture and Horticulture Development Board (AHDB)
• Agrii
• Airedale Beekeepers Association
• Ambleside Action for a Future
• Anglian Water
• Association of Independent Crop Consultants (AICC)
• B4 Project
• Badminton Garden Farm
• BASF plc, Agricultural Solutions division.
• BASIS Registration Ltd.
• BCP Council
• Beckenham & District Allotment Society
• Bee Farmers Association
• Bee Improvement and Bee Breeders’ Association (BIBBA)
• Bingham Parish Church
• Bracken Control Group (BCG)
• Bradford Bee Keeping Association
• Breast Cancer UK
• British Association of Landscape Industries (BALI)
• British Beekeepers Association (BBKA)
• British Crop Production Council (BCPC)
• British Honey Producers LTD
• British Hop Association
• British Pest Control Association (BPCA)
• British Pharmacological Society
• British Potato Trade Association
• Bumblebee Conservation Trust
• Cambridgeshire Beekeepers’ Association
• Canalside Community Food
• Canterbury and District Branch of Parkinson’s UK
• Chappells Estate Agents
• Chartered Institution of Wastes Management (CIWM)
• Cheltenham & Gloucestershire Beekeeping Association (CGBKA)
• Chichester Beekeepers
• Chichester Organic Gardening Society
• City of London Corporation, Open Spaces Department
• Civil Society Pesticide Collaboration
• Client Earth
• Climate and Biodiversity Committee representing the Land Sub-Committee.
• Clydesdale Parkinson’s Group
• CM Consulting (UK)Ltd
• Commonwork
• Confor
• Conservation Farming Trust (CFT)
• Co-operative Group
• Copford Estate
• Cornwall Wildlife Trust
• Corteva Agriscience UK Ltd
• Courtfield Estate
• Crop Protection Association (CPA)
• CSA Network UK
• Cure Parkinson’s
• Dan Ward Consulting
• David Hearle Landscaping
• Delfland Nurseries Ltd
• Doddington Farms LLP
• Doff Portland Limited
• Dragon Garden Services.
• Dudley Branch of Parkinson’s UK
• Dŵr Cymru Cyfyngedig (trading as Dŵr Cymru Welsh Water)
• East of Scotland Farmers Ltd.
• Edaphos
• Edinburgh Branch of Parkinson’s UK
• Emerson College Trust
• Essex Beekeeping Association (EBKA)
• Evergreen Garden Care UK Ltd
• Expert Committee on Pesticides (ECP)
• Extinction Rebellion Ely
• Fareham and District Branch of Parkinson’s UK
• Fera Science Ltd
• Fine Agrochemicals Limited
• Fleurie Nursery Ltd
• Forest Research
• Fresh Potato Suppliers Association
• Freshwater Fruit Farm
• Friends of the Earth
• Game & Wildlife Conservation Trust
• Garden Organic
• GM-Free Cymru
• Gowan Crop Protection Ltd
• Green Lancaster based at Lancaster university
• Greening Steyning
• Grow 73
• Guildford Environmental Forum, Rosamund Community Garden
• Harrogate and Ripon Beekeepers Association
• Health and Safety Executive - Chemicals Regulation Division
• Holme Valley Parish Council
• Hope Valley Climate Action
• Houghton & Wyton community shop
• ICM Sustainable Solutions Ltd
• Incredible Edible Bristol
• Incredible Edible Lambeth
• Institute of Food Science and Technology (IFST)
• International Biological Manufacturers Association UK
• International Union of Basic and Clinical Pharmacology (IUPHAR)
• Jim’s Mowing Gloucester
• KTN
• Laddingford Beekeepers Association
• Landward Consultancy
• Languard Ltd
• Lantra
• Lincolnshire Cancer Project
• Linking Environment And Farming (LEAF)
• Lluest Growers
• Locks
• Lydbury English Centre Ltd & The Global Approach Ltd.
• Mulbarton Allotment and Leisure Gardners’ Association
• National Allotment Association
• McCreath Simpson & Prentice merchanting department of Simpsons Malt Ltd
• Middlewood Charitable Trust
• National Association of Agricultural Contractors (NAAC)
• National Farmers’ Union (NFU)
• National Parks Wales
• Natural England
• Nature Friendly Farmers Network (NFFN)
• NatureScot
• Newark and Sherwood District Council
• Newbury Beekeepers
• Newbury Branch of Parkinson’s UK
• Newcastle City Council
• Newcastle Green Spaces Initiative
• NFU Cymru
• NFU Scotland
• NFU Sugar
• NIAB
• North Herts Beekeeping Association
• North Staffs. Bee-keeper’s Association
• Northern Ireland Water Ltd.
• Organic Way
• Oxford Branch of Parkinson’s UK
• Oxfordshire Natural Beekeepers
• Parkinson’s UK
• Parkinson’s Birmingham South Support Group
• PD Avengers
• Pearsons Honey Farm
• Pembrokeshire Beekeeper’s Association
• Pesticide Action Network UK (PAN UK)
• Pesticide-Free Edinburgh
• Petersfield Climate Action network (PeCAN)
• Portsmouth and District Beekeepers Association
• Positive Nature
• Processors and Growers Research Organisation (PGRO)
• Proper Job
• Property Care Association
• Queen Mary University of London and Barts Health NHS Trust
• Rayolt Ltd
• Red Tractor (UK’s biggest farm assurance scheme)
• Richmond & District Beekeepers’ Association
• Rooftop Bees
• RootWave (Ubiqutek Ltd.)
• Rothamsted Research
• Royal Horticultural Society
• RSPB
• Rugby Beekeeping Association
• Sainsbury’s
• Salmon & Trout Conservation
• Sandwich Environmental Conservation Group
• SAVE food hub
• Save Newcastle Wildlife
• SBKA as part of BBKA
• SBM life Science
• Scottish Hazards
• SERA climate change group
• Sherborne Beekeepers Association
• Sidmouth Biodiversity Group
• Snowdonia National Park Authority
• Solutions 4 Gardens Ltd
• South East Water
• South Oxfordshire District Council and Vale of White Horse District Council
• South Somerset district council
• Springham Grove LLP
• St Ninian’s Episcopal Church
• Staffordshire Moorlands District Council
• Stephen Moss Consulting
• Strathmiglo and Falkland Allotments
• Sum of US
• Surrey County Council
• Sussex Wildlife Trust
• Sustainable Food Knighton
• Syngenta
• Tees Valley branch of Parkinson’s UK
• The AIC (Agricultural Industries Confederation)
• The Amenity Forum
• The Auckland Project
• The Bee’s Knees Honey as part of BBKA
• The Black Grass Resistance Initiative
• The British Christmas Tree Growers Association (BCTGA)
• The Common Sense Gardening Group of the Crop Protection Association
• The Country Land and Business Association (CLA)
• The Environment Agency
• The Expert Committee on Pesticide Residues in Food (PRiF)
• The Fleming Policy Centre
• The Fresh Produce Consortium (FPC)
• The Highland Council
• The Montessori Place
• The National Association of Cider Makers
• The Open University School of Environment Earth and Ecosystem Science (SEEES)
• The Soil Association
• The UK Centre for Ecology & Hydrology
• The University of Sheffield
• The Voluntary Initiative CIC
• The Wildlife Trusts
• Trenow Fields
• TWR Training LTD
• UK Flour Millers (previously nabim)
• UK Pesticides Campaign
• Ulster Farmers’ Union
• Ulster Wildlife (UW)
• Unite the Union
• United Utilities
• University of Edinburgh and Edinburgh Branch Parkinson’s UK
• Veganpicks
• Verging on Wild
• Warwickshire Wildlife Trust
• Welsh Pollinator Action Plan Taskforce
• West Cornwall Beekeepers
• West Cumbria branch of Parkinson’s
• West Herts Beekeepers Association
• Wicked Leeks magazine, published by Riverford Organic Farmers
• Wildlife & Countryside Link
• Woodland Trust
• Wyeside Consulting Ltd
• Wynnstay (AS) Ltd
• York and District Beekeepers Association