Resistance Action Committee Position paper on Proposed EU Cut-off Criteria (Version 6. 26 February 2008)

A document prepared by Insecticide, Herbicide, Fungicide Resistance Action Committees- IRAC, HRAC and FRAC has been sent to EPPO as a technical position paper arguing against the use of cut-off criteria to remove active substances from Europe. The paper recommends.  

1. Sustainable resistance management is based on effective disease/pest/weed management. To permit the implementation of an effective, sustainable resistance management strategy for any crop and pathogen/weed/pest situation, no less than three pesticidal modes of action should be considered for a particular crop and target pest in individual geographies, of which one should ideally be from an accepted low risk category. Four or more modes of action are desirable. Current knowledge does not predict future needs.

2. Especially in crops where season long control requires a higher number of crop protection applications, the use of less than four modes of action to control a crop and pathogen and pest situation is considered extremely risky and therefore unsustainable from an effective disease and pest management perspective and as well as from a resistance management perspective. Five or more modes of action are desirable.

3. The value to the crop protection industry of diversity in available modes of action including genuinely multisite active substances is very high and must not be underestimated. This importance should also be factored into the decision making process and means sought to maintain this valuable resource.

4. Hazard-based cut-off criteria and substitution should not be indiscriminately applied in such a way that the minimum level of chemical diversity, as defined above is not available to achieve effective disease/pest/weed management and resistance management and thus jeopardise future food production in Europe.