PAN Europe welcomes Commission proposal to amend Directive 2006/42/EC and to include environmental protection requirements for pesticide application machinery. This European Directive is also useful for setting minimum mandatory levels of performance for this kind of equipment. Fully automatic machinery is advisable and handheld spraying equipment and “knapsack” to be phased out.
We propose to put environment in the text of the Directive at the same level as health and safety of person and not (as in Art. 2,4 and 9) only “where appropriate”. Pesticides are released on purpose in the environment, so environment is always at stake. Additionally to that the articles in the Directive (like 2 and 4) should be based on the precautionary principle and we propose to add this in at least Art. 2.m and art. 4.1. Precautionary principle means that in case any doubt might arise for a given action, the precautionary approach demands the use of the safest alternative (like no spraying) to prevent environmental damage.
PAN Europe aims at banning the most hazardous pesticides and at reducing the use of the other synthetic chemicals. Synthetic chemicals should only be used as a last resort as no other means of crop protection are available. If spraying is necessary, pollution of the environment should be prevented. In case of spraying we see the hardware (machinery) and the software (management by the farmer or other applicant) as two sides of the same coin. For both coinsides we need strict and mandatory provisions to prevent pollution of the environment. For three main areas we see a need to act and include provisions in this Directive or in the Framework Directive on the sustainable use of pesticides.