 Integrated Pest Management (IPM) is the careful consideration of all available pest control techniques and subsequent integration of appropriate measures that discourage the development of pest populations and keep pesticides and other interventions to levels that are economically justified and reduce or minimize risks to human health and the environment. IPM emphasizes the growth of a healthy crop with the least possible disruption to agro-ecosystems and encourages natural pest control mechanisms.

 By imposing requirements aimed simply at reducing residues (quantity and concentration) farm managers are not able to pursue IPM in its true form. This also undermines environmental sustainability.
Given the long process of PPP registration, of equal concern is that producers may have to adopt older, less desirable and more hazardous PPPs, possibly making it more difficult to comply with new IPM practices. With the introduction in the European Union of the comparative assessment and substitution of PPPs, the horticulture industry faces further challenges to control pests, weeds and diseases with potentially fewer alternative products being available. All PPPs undergo a rigorous and independent authorisation process. Any active substances put forward as a potential candidate for substitution remains approved for use and must not be regarded as ‘unsafe’.

 Managing resistance is an important component of reducing overall dependence on PPPs. Reducing concentrations of active ingredients in order to meet reduced MRLs, as requested by numerous commercial organisations, selects for resistant pests that soon dominate the population. This leads to the loss of effectiveness of the active ingredient. Resistance management very much depends on the availability of alternate active ingredients used at effective rates, especially those with different modes of action.

 There are many microbiological control points on farm environment, water, soil, animals, personal hygiene, equipment, storage areas and transportation, all to prevent a microbiological hazard.

 MRLs are set at levels low enough to ensure that safety limits are not reached but such that the Plant Protection Products (PPPs) are effective against the target pest in the country of production.

 Only PPPs with approved uses in the country of production can be used.

 Provided PPP use results in residues that do not exceed the importing countries MRLs, there should be no restriction on their use.

 Restricting PPPs conflicts with other generally accepted GAP principles and Integrated Pest Management.

 Food safety is neither a competitive nor a marketing tool by which retailers differentiate themselves; food safety is pre-competitive and the responsibility of all members of the value chain.

 We rely on the independence of governments and the best science available to set legitimate standards, critical limits and tolerances that best ensure the health, safety and welfare of producers, consumers and the environment. Food Safety critical limits and tolerances are established on the basis of detailed technical dossiers and are therefore assured by scientific evidence.

 Consumers entering any fresh produce outlet should be assured that fruit and vegetables offered is safe if it complies with the local and destination-country Food Safety legislation.

 International harmonisation should be encouraged at every opportunity to facilitate trade, protect consumers and to ensure sustainability at all levels.

 Wherever possible international standards (such as CODEX Alimentarius) should be adopted. Again, science-based justification must be provided to deviate from these standards.

 Food supplier and buyer organizations are encouraged to adopt a Food Safety culture, where all parties take more responsibility to ensure safer food.

 Stricter Food Safety requirements themselves do not necessarily result in safer food, as Food Safety limits and tolerances are already securing the safety of the product.

 The Sanitary and Phytosanitary (SPS) Agreement is the basis for continued access to markets.

 Failure to adhere to the SPS agreement, specifically the failure to control phytosanitary pests and diseases, compels the importing country to take stricter trade measures.

 In the absence of suitable alternative technologies, compliance to phytosanitary requirements is largely achieved through chemical control. Restrictions placed on plant protection product use compromises the biosecurity of the importing country and may lead to stricter trade measures.

 Setting MRLs at a lower percentage of the official MRL could jeopardize the efficacy and resistance management of a particular active, putting the plant health security and quality of the product at risk. For some markets, it may be illegal to use an active ingredient below the label rate and hence below a particular MRL for control of a pest of biosecurity significance.