III. Sustento Pedagógico
3.1.10 Enfoque cognitivo, comunicativo y sociocultural
The data basis for organic inputs is very small. Data from the year 2000, presented in the annual report on agriculture by the Federal Ministry of Consumer Protection, Food and Agriculture, show that the input for plant protection is very low. Only 2 DM/ha (=1.3 EUR/ha) were spent on plant protection on organic farms – that is 2 % of what conventional farms spent (93 DM/ha). Compared to this, the input for feed on organic farms is as much as a third (183 DM) of that on conventional farms (488 DM), whereas money spent on fertilizers is only 10 % (15 DM/ha) of the input on conventional farms (149 DM/ha).
Regulatory framework
Definition of terms
First of all, the Act on the Protection of Crop Plants defines the difference between Plant Protection Products and Plant Resistance Improvers.
Current evaluation procedures for plant protection products used in organic agriculture 27 Plant Protection Products are defined as protecting plants and plant products against harmful organisms; against animals, plants or micro-organisms which are not harmful organisms; as influencing the processes of plants (e.g. growth regulators) and as inhibiting the germination of plant products. They do not include water, fertilizers (as defined in the Fertilizer Act) and plant resistance improvers.
Contrary to that, Plant Resistance Improvers are those substances which are intended to enhance the resistance of plants to harmful organisms, to protect plants against non-parasitic impairments and to be used on cut ornamental plants (not for planting material, though).
If a newly developed substance is to be marketed, it has to comply with the following rules: it is not allowed to have harmful effects on human and animal health, groundwater and the natural balance. Furthermore it has to be included on a list of Plant Resistance Improvers issued by the Biologische Bundesanstalt (BBA – Biological Research Centre of Agriculture and Forestry) and the designation “Plant Resistance Improver” plus the list number has to be stated on the containers and outer packaging or packaging inserts.
As EC 2092/91 does not regulate the use of plant resistance improvers, all products recognized as plant resistance improvers may be used in organic agriculture in Germany.
Inclusion on the list of plant resistance improvers
In order for a product to be included on the list, the manufacturer, distributor or importer has to apply for inclusion. The application has to contain the name and address of the applicant, the trade name of the product and its composition (specifying the nature and quantity of the substances using scientific nomenclature). Information on its mode of action and instructions for use as well as the labelling intended for the container and outer packaging or package inserts have to be given.
In addition to this information, several optional points can be submitted with the application in order to avoid separate requests and to accelerate the handling of the application. Topical Safety Data sheets for both the product and its components (if present) and CAS numbers (or similar registration numbers) for clear scientific identification of the (chemical) components of the product should be supplied. If the applicant is not the manufacturer of the product, he or she should be named, as should the manufacturer of the product components. For products which cannot be clearly identified in substance, raw materials and manufacturing procedures can be given. Statements can also be included to the effect that the product – especially products based on organic materials – does not contain pathogenic germs or – for microbial products – it is free from toxic metabolites and that no toxic metabolites are formed. Reference literature should show that the product is harmless with regard to human and animal health, groundwater and the natural balance.
Listing procedure for plant resistance improvers
If the necessary information is given in the application, the listing procedure according to the Crop Protection Act follows three different steps.
First, the Federal Office of Consumer Protection and Food Safety tests whether the application is complete and whether the product is to be classified as a Plant Resistance Improver (plausibility test). If all the information that is necessary for this is not handed in with the application, it requests more documents and samples. When documentation is complete, the processing period of four months starts. Now the Federal Institute of Risk Assessment (BfR), the Federal Environmental Office (UBA) and the Federal Biological Research Centre of Agriculture and Forestry (BBA) check whether the criteria for marketing the product as a Plant Resistance Improver are fulfilled.
28 Current evaluation procedures for plant protection products used in organic agriculture As the last step, the Federal Office of Consumer Protection and Food Safety (BVL) decides in agreement with the other three institutions (BfR, UBA, BBA) whether the product is included in the list of Plant Resistance Improvers.
Numbers and fees
In May 2003 there was a total of 324 applications, of which 222 were already included in the list. 43 applications had been withdrawn or were rejected and 59 were still in progress.
According to the BBA (2002), the fee for the general test, the decision and the inclusion on the list is EUR 290. In case of objections or additional demands, further tests cost between EUR 800 and 5 200.
Categories of plant resistance improvers
There are different categories of Plant Resistance Improvers depending on their ingredients. In 2002, 18 % of the products listed were based on inorganic compounds (stone meal, sodium silicate, etc.), 58 % were based on organic compounds (algae and plant extracts, plant oils etc.), 16 % were homeopathic preparations and 8 % mainly consisted of microbial agents (Trichoderma spp., Bacillus subtilis etc.).
Applying distinctions similar to those made in the definition of terms, there are three categories of intended purpose. As of May 2003, there were 222 products included in the list, of which 186 were intended to enhance the resistance of plants to harmful organisms. 144 are supposed to protect against non-parasitic impairments and 46 are intended for use on cut ornamental plants.
Some of the Plant Resistance Improvers on the list have multiple purposes: 107 products can be used for the first two categories (harmful organisms and non-parasitic impairment); 3 substances act against harmful organisms and can be used cut ornamental plants; 20 products help against non-parasitic impairment and on cut ornamental plants. Only one of the 222 products can be used for all three purposes.
Hot issues
Several risks and problems may arise as more applications are made for listing of Plant Resistance Improvers. An important point to be considered is that problems might occur when the listing requirements are reduced so that an increasing number of ‘low risk pesticides’ is included on the list. This may lead to a modification of the basic principles of plant protection in organic farming – away from preventive measures towards direct control of pests and diseases.
Although bureaucracy and costs might increase, there is no quality control of the listed Plant Resistance Improvers.
Neither producer organizations nor consumers and environmentalists are involved in the evaluation of Plant Resistance Improvers.
Advisory services are sceptical about Plant Resistance Improvers and there is only a small market for these products so far.
Current evaluation procedures for plant protection products used in organic agriculture 29
References
BBA (2002): Liste der Pflanzenschutzmittel zur Herstellung im eigenen Betrieb entsprechend dem deutschen Pflanzenschutzgesetz. http://www.bba.de/oekoland/oeko2/liste6a.htm.
BBA (2002): Beschreibende Liste der eingetragenen Pflanzenstärkungsmittel http://www.bba.de/oekoland/staerk/b_staerk.pdf.
Bioland standards (2002): http://www.bioland.de/bioland/richtlinien/bioland-standards.pdf. BMVEL Ökolandbaugesetz (2002): http://217.160.60.235/BGBL/bgbl1f/BGBl102047s2558.pdf. Demeter standards (2003): http://www.demeter.net.
Konferenz der Kontrollstellen (2002): Betriebsmittelkatalog für den Ökologischen Landbau. http://nrw.oekolandbau.de/service/bm_katalog.pdf.
Naturland standards (2002): http://www.naturland.de/englisch/n2/Naturland_standards_July2002.pdf. SÖL (2002): Die Richtlinien der Verbände. http://www.soel.de/oekolandbau/richtlinien.html#riliverb. SÖL (2003): Ökologischer Landbau in Deutschland. http://www.soel.de/oekolandbau/deutschland.html. Wick, M. (2003): Anwendungsliste der zugelassenen Wirkstoffe im Ökologischen Landbau.
30 Current evaluation procedures for plant protection products used in organic agriculture