35 Amendments of Molly SCOTT CATO related to 2017/2128(INI)
Amendment 1 #
Draft opinion
Paragraph 1
Paragraph 1
1. Welcomes the fact that an implementation report for Regulation (EC) No 1107/2009 is being undertaken with the aim of ensuring a high level of protection of both human and animal health as well as the environment, while safeguarding the competitiveness of the EU’s agriculture sector by providing access to a broad range of active substances and Plant Protection Products (PPP) for all farmers and producers, irrespective of the Members States they are operating in; recalls recital (8) of Regulation (EC) No 1107/2009 which clearly highlights that particular attention should be paid to the protection of vulnerable groups of the population, including pregnant women, infants and children, that the precautionary principle should be applied and that this Regulation should ensure that industry demonstrates that substances or products produced or placed on the market do not have any harmful effect on human or animal health or any unacceptable effects on the environment;
Amendment 8 #
Draft opinion
Paragraph 1
Paragraph 1
1. Welcomes the fact that an implementation report for Regulation (EC) No 1107/2009 is being undertaken with the aim of ensuring a high level of protection of both human and animal health as well as the environment, while safeguarding the competitiveness of the EU’s agriculture sector by providing access to a broad range of active substances and Plant Protection Products (PPP) for all farmers and producers, irrespective of the Members States they are operating inaiming as much as possible for a level playing field for farmers from different EU member states in terms of access to genuinely safe active substances and Plant Protection Products (PPP);
Amendment 13 #
Draft opinion
Paragraph 1 a (new)
Paragraph 1 a (new)
1 a. Notes the failure of the regulatory framework to consider inevitable non- target impacts, notably on bees and other pollinators and other insects beneficial to farming like predators of pests; Notes the recent scientific study illustrating the "insect Armageddon"1a , whereby 75% winged insects have become regionally extinct across Germany, even in nature reserves where no pesticides were used for agriculture. _________________ 1aMore than 75 percent decline over 27 years in total flying insect biomass in protected areas, Hallmann et al, 2017. http://journals.plos.org/plosone/article?id =10.1371/journal.pone.0185809
Amendment 21 #
Draft opinion
Paragraph 1 b (new)
Paragraph 1 b (new)
1 b. Calls for the implementation by the MS of the 2013 EFSA guidelines 1c on assessing risk of PPPs to bees, developed collaboratively between the Commission and the MS, which has regrettably not been implemented so far; _________________ 1c https://www.efsa.europa.eu/en/efsajournal /pub/3295
Amendment 24 #
Draft opinion
Paragraph 1 c (new)
Paragraph 1 c (new)
1 c. Notes that the cumulative effects of pesticides on non-target species, and also synergistic effects as pesticides are increasingly applied in cocktails of different products, which can alter the expected impacts on organisms exposed to them;
Amendment 25 #
Draft opinion
Paragraph 1 d (new)
Paragraph 1 d (new)
1 d. Notes the duty of care of the Commission, in balancing the public and environmental health with economic interests of chemical producers to ensure only genuinely safe active substances are approved;
Amendment 26 #
Draft opinion
Paragraph 1 e (new)
Paragraph 1 e (new)
1 e. Notes that the final approval of the product by the MS is often granted conditionally upon certain mitigation criteria being fulfilled, for example in restricting use under certain conditions; Regrets that these are so poorly controlled, if at all, by the MS authorities;
Amendment 27 #
Draft opinion
Paragraph 1 f (new)
Paragraph 1 f (new)
1 f. Notes that because both active substance and product authorisations are often granted conditional upon fulfilment of certain criteria of use which are then not checked, this means that even if mitigation measures intending to limit environmental damage were disregarded, inappropriate and illegal use has been rewarded with CAP payments. This should not continue, and respect of mitigation measures should form part of the baseline of sustainability in the CAP;
Amendment 28 #
Draft opinion
Paragraph 1 g (new)
Paragraph 1 g (new)
1 g. Notes the health costs associated with pesticide use, which are often hidden, and the struggle of farmers and agricultural workers as well as those working in storage and transport of grain who are poisoned by pesticides; Notes further that these hidden costs and personal struggles are too often conveniently forgotten by the representatives of farming communities;
Amendment 29 #
Draft opinion
Paragraph 1 h (new)
Paragraph 1 h (new)
1 h. Calls for neonicotinoids and other systemic insecticides that are damaging to non-target species especially bees to be comprehensively banned, in order to ensure pollination and other biodiversity- driven ecosystem services useful for farmers, also including predators keeping pest populations in check;
Amendment 30 #
Draft opinion
Paragraph 1 i (new)
Paragraph 1 i (new)
1 i. Notes a weed is defined simply as a plant in the wrong place, and notes they are also wildflowers that feed bees and pollinators and also support natural predators of pests and other beneficial species useful to farming; Notes further only 20% of weed species are actually capable of damaging crops and then, only when in sufficiently high concentrations to affect the yield; 80% of them are so weak in competition with the crops that they do not affect yield substantially 1d. _________________ 1dAndreasen, C. et al., 1996: Decline of the flora in the Danish Arable field. J. Appl. Ecol. 33, p. 619-626. Studies on wild plant species from 1970 to 1990 on approx. 200 wild plant species
Amendment 31 #
Draft opinion
Paragraph 2
Paragraph 2
2. Points out that this regulation is part of the wider EU Plant Protection Products (PPP) regime, which also includes the Sustainable Use Directive (SUD) and the regulation setting Maximum Residue Levels (MRL), and that all three parts must be considered together in order to identify whether they are fit for purpose, including with a view to reducing the total volume of PPPs used, notably through the MS and the Commission ensuring implementation of Integrated Pest Management (IPM) , which can be as simple as crop rotation, and for IPM to be integrated into the CAP as foreseen already in the SUD and the current CAP regulations since 2013;
Amendment 36 #
Draft opinion
Paragraph 2 a (new)
Paragraph 2 a (new)
2 a. Notes that a farmer's "toolbox" is based on methods, agronomic practices as well as chemical substances and alternatives to those, such as biological control.Notes that this broader definition of toolkit is the basis of IPM, which can cut pesticide use by between 50-30%, and can be as simple as crop rotation or avoiding monocultures; Notes the "many little hammers" approach of these alternative tools, as opposed to blanket metaphylaxis by broad spectrum chemical pesticides that can disable other tools in the toolbox;
Amendment 50 #
Draft opinion
Paragraph 2 b (new)
Paragraph 2 b (new)
2 b. Notes that for some tools of the "toolkit" like biological controls using natural predators of pests or their parasites or parasitoids to work, it is important that untargeted broad spectrum pesticides should be avoided until being used as a last resort:
Amendment 53 #
Draft opinion
Paragraph 2 c (new)
Paragraph 2 c (new)
2 c. Notes the need to for careful use of pesticides and only when all other alternative methods have failed, due to growth of resistance of pests to overused pesticides: Notes resistance is a biological inevitability when dealing with fast- reproducing pests and diseases; Emphasises the use of IPM as a way to prevent resistance and the need to avoid blanket or metaphylactic treatment often when no single pests is even detected, which also knocks out other beneficial species, which would otherwise be regulating pest populations, leaving crops susceptible to future attacks;
Amendment 55 #
Draft opinion
Paragraph 2 d (new)
Paragraph 2 d (new)
2 d. Underlines the need for knowledge sharing and skill acquisition for alternatives to chemical pesticides and IPM, including finding the optimum crop rotation for farmers' market and climatic situations; Notes further that this is already foreseen in the horizontal regulation of the CAP, notably also Farm Advisory Services financed within Rural Development;
Amendment 56 #
Draft opinion
Paragraph 2 e (new)
Paragraph 2 e (new)
2 e. Notes the increasing use of broad spectrum pesticides as desiccants and crop ripeners and underlines the principle of not applying pesticide on the final products as this will inevitably raise residue levels in food and feed sometimes to unacceptable levels, given the proximity of this usage to human food chain; Calls therefore for severely limiting this use, with a view to re-writing the authorisations and phasing out this use of pesticides;
Amendment 57 #
Draft opinion
Paragraph 2 f (new)
Paragraph 2 f (new)
2 f. Stresses the importance of using IPM as the basis for approving less damaging active substances, when candidates for substitution of the most dangerous pesticides are being considered; this means when MS are considering to authorise an alternative chemical (to substitute a more dangerous one), if the same effect to protect against past damage can be ensured by agronomic practices or alternatives, neither pesticide should be approved;
Amendment 64 #
Draft opinion
Paragraph 3
Paragraph 3
3. Stresses the importance of a science-basedobjective, peer-reviewed evidence derived from an open and independent, holistic and multidisciplinary scientific approach in authorising any active substance, in line with the EU’s risk analysis principleof hazards and the precautionary principle as established in the General Food Law (Regulation (EC) No 178/2002);
Amendment 69 #
Draft opinion
Paragraph 3 a (new)
Paragraph 3 a (new)
3 a. Notes that Ecology is also a scientific discipline that deals with the interaction between all living organisms including the impacts of chemicals on non-target species. Notes that Toxicology is also a scientific discipline, with the sub- discipline of Ecotoxicology. Welcomes therefore a holistic, science-based approach based on publically funded and published, peer-reviewed science, and especially welcomes moving on from outdated 1950's arguments that undermine scientific approaches that are not chemistry;
Amendment 74 #
Draft opinion
Paragraph 3 b (new)
Paragraph 3 b (new)
3 b. Notes that in science it is harder to find a causal relationship than for this relationship to remain hidden, and that determining those causal relationships and impacts requires objective investigation in the right places, in replicable datasets and for long enough time periods - this is rarely the case, which limits the useful of the weight of evidence approach, especially when those conducting experiments and field trials, e.g. via private science, have a vested interest not to find anything;
Amendment 76 #
Draft opinion
Paragraph 3 c (new)
Paragraph 3 c (new)
3 c. Notes that the weight of evidence approach is not used in the same way for the approval of pharmaceuticals, where risk managers avoid using any studies that are repeated, are not peer reviewed, are not published, are duplicated, have conflicts of interest or are otherwise compromised;
Amendment 78 #
Draft opinion
Paragraph 4
Paragraph 4
4. Expresses its concern about systematic delays in the authorisation processes and the increasing use of derogations as laid down in Article 53 of Regulation (EC) No 1107/2009, while underlining the necessity for Member States to comply with the legal deadlines to ensure predictability for applicants and facilitate the market introduction of innovative PPPs that are in line with more stringent requirements; recalls recital (10) of Regulation (EC) No 1107/2009 which clearly highlights that substances should only be included in plant protection products where it has been demonstrated that they present a clear benefit for plant production and they are not expected to have any harmful effect on human or animal health or any unacceptable effects on the environment;
Amendment 81 #
Draft opinion
Paragraph 4
Paragraph 4
4. Expresses its concern about systematic delays in the authorisation processes and the increasing use of unjustified and inappropriate derogations as laid down in Article 53 of Regulation (EC) No 1107/2009, and the associated working document 1b , while underlining the necessity for Member States to comply with the legal deadlines to ensure predictability for applicants and facilitate the market introduction of innovative PPPs that are in line with more stringent requirements; _________________ 1bsee annex 1 of the Working Document on Emergency Situations According to Art.53 of Reg.1107/2009 of DG SANTE of the Commission
Amendment 84 #
Draft opinion
Paragraph 4 a (new)
Paragraph 4 a (new)
4 a. Expresses dissatisfaction regarding derogations to prohibitions of use, and notes the rules are being abused; notes the current regulation and comitology arrangement allows a member state to simply announce its will to derogate and it is deemed to pass; Notes that often there is no justification for derogations, e.g. those that have been systematically granted to the partial neonicotinoid bans. Underlines that the Commission has a duty as Guardian of the Treaties to check the derogations are really justified and there are no alternatives, such as crop rotation or combinations of alternatives, that negate the need to use those substances or limit the extent of an expected pest outbreak. If no alternative preventive measures are taken, the derogations should not be granted;
Amendment 92 #
Draft opinion
Paragraph 5
Paragraph 5
5. Points out that the zonal evaluation of PPP applications, which allows applicants to propose one zonal Rapporteur Member State (zRMS) to carry out the assessment, should lead to the concerned Member States (cMS) taking a decision within the maximum time limit of 120 days after the zRMS has issued the registration report; recalls recital (16) of Regulation (EC) No 1107/2009 which clearly highlights the possibility of amending or withdrawing the approval of an active substance in cases where the criteria for approval are no longer satisfied, or where compliance with Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy is compromised, should be provided for under certain conditions;
Amendment 96 #
Draft opinion
Paragraph 5 a (new)
Paragraph 5 a (new)
5 a. Notes that Reg.1107/2009 gives the possibility of amending or withdrawing the approval of an active substance in cases where the criteria for approval are no longer satisfied, or where its use breaches or compromises compliance with the Water Framework Directive 2000/60/EC 1e ; Notes in this regard that the first systematic testing of rivers was mandated the WFD - as an example in the UK these were conducted in 2016, and results showed that half of the 16 rivers tested in England had either chronic or acute levels of neonicotinoid contamination, and they were found in 17 of the 23 rivers tested across Britain; _________________ 1eDirective 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy
Amendment 112 #
Draft opinion
Paragraph 6 a (new)
Paragraph 6 a (new)
6 a. Notes the excellent quality and sufficient provisioning of organic products, the vast majority of which are produced with out resorting to any chemical pesticides, but use a wide range of effective agronomic and physical methods and biological controls;
Amendment 114 #
Draft opinion
Paragraph 6 b (new)
Paragraph 6 b (new)
6 b. Notes the unintentional effects of pesticides on soil and non-target species and also organic farmers who suffer economic losses from their neighbours' pesticide use, whereby drift from pesticide spraying and movement of persistent active substances in the environment contaminate organic produce and soils; notes that organic farmers are often forced to sell that produce as conventional, losing out on their price premium, or worse become decertified, due to actions that are not their own;
Amendment 133 #
Draft opinion
Paragraph 8
Paragraph 8
8. Stresses the contribution that the authorisation of low-risk PPPsnatural PPPs based on natural products can makes to a sustainable EU farming sector, and despecially efficient when introduced/used in combination with good agronomic practices; Draws attention to the importance of contributing to a better functioning agricultural ecosystem and a sustainable farming sector, while p; Pointings out that the lack of availabilityoveruse of PPPs could jeopardise the diversification of agriculture and cause harmful organismpests and diseases to become resistant to PPPs.
Amendment 151 #
Draft opinion
Paragraph 8 a (new)
Paragraph 8 a (new)
8 a. Points out that this low risk PPP category is useful for natural products that carry less risk and therefore should not have to jump through the same legislative hoops to ensure public and environmental safety;
Amendment 158 #
Draft opinion
Paragraph 8 b (new)
Paragraph 8 b (new)
8 b. Underlines that the low risk PPP category should not be used as a loophole for avoiding other justifiably more complex authorisation processes for GMOs and mainstream chemical pesticides.
Amendment 161 #
Draft opinion
Paragraph 8 c (new)
Paragraph 8 c (new)
8 c. Notes that some member states have a tax on pesticide production and usage to cover costs currently eternalised to public health and environmental budgets and so carried by the ordinary citizens and the public purse ; Invites therefore MS and the Commission to look seriously to mainstreaming this tax approach to enforce the Polluter Pays Principle.
Amendment 167 #
Draft opinion
Paragraph 8 d (new)
Paragraph 8 d (new)
8 d. Notes that although Precision agriculture can be used to better target pesticide use where it is genuinely needed and cut overall usage, it can in some cases simply shift the type of input dependencies, while many farmers want to become more autonomous and cut input costs.
Amendment 169 #
Draft opinion
Paragraph 8 e (new)
Paragraph 8 e (new)
8 e. Calls for the same approach we currently have for antimicrobial resistance to be applied also to pesticide resistance.