Continuing our farm office series with Farmplan, Robert Harris uncovers common livestock cross-compliance pitfalls and how to avoid them

At first glance, the list of cross-compliance conditions which livestock farmers claiming CAP payments must meet looks impossibly long.

There are 18 Statutory Management Requirements for public, animal and plant health, environment and animal welfare, while a further 16 standards known as GAECs aim to maintain land in good agricultural and environmental condition. These cover areas like soil erosion, organic matter and structure, habitat protection and water management.

Failure to meet any of these can result in significant, sometimes severe, deductions from single farm payments and certain Rural Development Programme payments such as ELS and HLS, says Charles Mayson, managing director of Herefordshire-based Cross Compliance Solutions. The firm advises farmers across the West Midlands and Wales to ensure their documentation and procedures will pass RPA inspection.

However, not all conditions will affect every farmer and many are not as onerous as people imagine them to be, says Mr Mayson. “Focusing on those most commonly breached will stand any business in good stead next time the inspector calls.”

Identification, registration and welfare

In 2011, as in previous years, cattle identification and registration (SMR 7) was the biggest cause of inspection failures by a sizeable margin (see table). Sheep and goats identification (SMR 8) and animal welfare (SMR 18) came second and third.

Two identification conditions are designed to ease traceability, particularly in a disease outbreak. They include tagging within certain timescales after birth and registering cattle by applying for a passport through BCMS. On-farm records of movements and deaths are also stipulated.

With cattle, common areas of failure include not replacing lost or illegible tags within 28 days of notifying the loss, not notifying BCMS of movements within three days of their occurrence or deaths within seven days. Poor record-keeping by cattle and sheep farmers is also a problem.

“It’s simply a case of keeping records in order,” says Mr Mayson. “It’s good practice; get into the habit of keeping the books up to date. It’s a way of life for farmers these days, something they have to accept.”

Animal welfare rules set minimum standards of care and husbandry. The usual problems in this area include lack of records for medicinal treatments and deaths.

“The vet and med book is checked by all inspectors; withdrawal periods and expiry dates must be listed.”

Soil Protection Review (GAEC 1)

All businesses claiming single payment should have read and filled in a Soil Protection Review (SPR) book by the end of 2010, says Mr Mayson. These must be reviewed by the end of each year.

Not conducting, adequately completing or updating annually the farm’s SPR were the most common causes of inspection failure. In addition, failure to highlight management issues and rectifying measures also caught farmers out.

“Judging by our experience 90% of books are not filled in correctly. We find many famers don’t have one, can’t locate it or have misunderstood the questions and wrongly completed it. At inspection, it’s the first item the RPA scrutinise.”

Failure to complete, underestimation of risks to soil, failure to account for how waterlogged soils are treated, or to declare non-agricultural uses are common examples of wrongly completed books, says Mr Mayson.

A soil risk map or table of all the land within the farming business should have been completed by the end of 2011. Producing a well-prepared soil management plan is the best insurance, says Mr Mayson (see box). “You can either draw up your own plan or obtain professional advice.”

Protection of hedgerows and watercourses (GAEC 14)

Carrying out operations too close to hedgerows and ditches accounted for most failures under GAEC 14, which each year features high in the inspection failure list. “Remember, cultivations are not allowed within 2m of the centre of the hedgerow,” says Mr Mayson. “The same applies to fertiliser and pesticide application. This rule also applies to land within 2m of the top of the bank of a watercourse or field ditch.”

Nitrate Vulnerable Zones (SMR 4) and no spread zones (GAEC 19)

The Nitrate Vulnerable Zones condition is NVZ is about good farming, which mostly happens – and about good record-keeping, which mostly does not, says Mr Mayson.

“Livestock farmers bear the brunt of NVZ rules. Fertiliser applications are relatively straightforward but when you add manures into the mix life becomes more complex.”

The regulations govern quantities and timing of nitrogen fertiliser and manures to crops. “These can be difficult to measure, which is why plans and records matter a lot.

“It’s easy enough to declare that 25t/ha of fym went on to the Bottom Meadow in April, but how much nitrogen did it supply? Do you allow for grazing deposit by cows? What is the meaning of the 250kg/ha limit? These are potent questions and inspectors ask for these items routinely.”

Storage is also regulated, with a five-month minimum requirement for cattle slurry and spreading restrictions on all manures in fields with watercourses.

Calculations must be made on quantities, spreading dates and rates must be considered in advance and recorded at the time (see box). Lack of manure storage calculations, nutrient management plans and/or a risk map also claim victims every year.

From January this year, all English farmers outside NVZs will be affected by an extension of certain NVZ rules through the introduction of no spread zones (GAEC 19). Here, inorganic fertilisers must not be applied within 2m of surface waters, and organic manure generally not within 10m. In addition, manure cannot be applied within 50m of a spring, well or borehole.

Growers applying organic manure must have a map showing all surface waters and land within 10m of them, as well as all springs, wells and boreholes and land within 50m of these.

“Keeping on top of all the new rules and regulations and managing the farm is a tall order,” says Mr Mayson.

Pesticides and footpaths

Two further problem areas are restrictions on the use of plant protection products (SMR 9) and public rights of way (GAEC 8).

“With SMR 9, inspectors are focusing on appropriate and safe storage including work wear and an inventory in the office and shed.”

The most common infringement of GAEC 8 is footpaths blocked by standing crops. “Spray within 14 days of establishing a crop then you can forget about them for the rest of the season.”


Manure management

A manure management plan promotes effective use of manures and minimises nutrient loss to water and air.

It should contain a risk map showing:

  • No-spreading zones, eg close to water sources
  • High risk – spread only in ideal conditions
  • Moderate risk – avoid adverse conditions
  • Low-risk zones – spreading might be possible all year

Consider soil type, slope, watercourses and set-aside rules.

The minimum area of land needed to spread manure should also be calculated using 250kg/ha maximum field application.

  • Check enough land, otherwise consider exporting muck or obtaining more land
  • Record calculations

Storage capacity of manure and slurry should be regularly assessed.

  • Keep application records
  • Update plans as circumstances change

Closed periods for spreading slurries and poultry manure – 15 October-15 January on grassland (except sandy or shallow soils – 1 September to 31 December).


What is likely to will feature on an inspection visit:

  • SPR10 book
  • Invoices and receipts for inputs and outputs (to prove a traceable system exists)
  • Spray records for selected land parcels
  • Spray store
  • Vet and med record book
  • Cattle movement records (ref TB restrictions)
  • A check of purchased bulk feeds
  • Felling licences
  • Written permissions for works carried out on SSSIs, scheduled ancient monuments, and semi-natural land
  • Full NVZ calculations if in one (70% of the country is). These include Nmax, loading, nutrient management and manure management plan


Soil management plan tips

  • Prepare a whole-farm assessment of risks and run-off. Examining soil after rain helps pinpoint areas. Prepare map of risk class for each field or part field
  • Match intended field use with land capability
  • Use a spade to assess soil structure. Decide steps to improve its condition
  • Record field-by-field steps to minimise run-off, erosion and to ensure good structure to maintain infiltration of rainfall
  • Record problems to help with annual review


Further information from:

Guide to Cross Compliance in England 2012 (sent to farmers and at http://rpa.defra.gov.uk)

Farming Advice Service: 0845 345 1302 or advice@farmingadviceservice.org.uk

Cross compliance solutions: 01981 590 514 www.cxcs.co.uk