PSD clarifies chemical use for cross-compliance

The Pesticides Safety Directorate has published guidance on its website to clarify issues that have emerged during cross-compliance inspections of pesticide spray records.
While PSD said the checklist for Statutory Management Requirement 9, which it assisted the Rural Payments Agency in preparing, had been kept as simple as possible, it acknowledged there had been concern within the industry about the interpretation of labels.
It said the safe use of pesticides remained a combination of a product’s Conditions of Approval for use and the general guidance in the Code of Practice for Using Plant Protection Products (Green Code).
It also clarified the whole product label – other than company advisory information – had a statutory basis since it all formed part of the approval. “Some parts cannot be varied in any circumstances, for example, maximum dose rates and the use of protective clothing (PPE).”
Others could be varied in the light of advice given in the Green Code, particularly water volumes and tank mixtures, it noted. “The essential point is that by following product labels and relevant parts of the code when using a pesticide no offence will be committed.”
A further nine commonly raised issues are dealt with in a Q&A document on the website. These deal with topics such as when products can be used at lower water volumes, whether growers can use reduced doses, split the maximum total dose, and tank mixing.
Keith Dawson, SAC’s principal crop consultant, welcomed the clarification notes issued by PSD, but suggested it still left areas open for further discussion. “The confusion in this area has also highlighted the need for clear communication earlier.”
Questions and answers Farmers Weekly also asked PSD and the RPA the following questions not covered in the PSD guidance: Q How is the issue of growers buying product from buying groups, and getting the same active but with a different product name from the one intended (which might have a different label) being addressed? RPA will be checking that farmers are using approved products. So provided all products used by a farmer (irrespective of his original intentions with respect to products) have been approved and the farmer follows the instructions on the pesticide product’s label (supplemented by guidance in the statutory code of practice on using plant protection products) they should encounter no problems. (PSD) Q Has anyone had SFP deducted for non-compliance on SMR 9? Details from the results of inspections in 2006 are being drawn together and will be published on the RPA website shortly. However, emerging findings indicate that issues with appropriate certificates of competence to spray are an area of concern (RPA). Q Can inspections be of historical records? How far back can inspections go? RPA inspectors have the scope to check records dating back to the introduction of SMR 9 on 1 January 2006 (RPA). Q Are RPA inspectors BASIS qualified? RPA inspectors have been trained specifically to undertake SMR 9 inspections and the training course has been accredited by BASIS and NRoSO (RPA). Q What general advice would you give agronomists/growers? The regulations require the sprayer operator applies the approved product in accordance with the conditions and requirements of approval, and those on the label, and within the principles of good plant protection practice and, whenever possible, integrated control. The operator is also expected to know whether or not the product approval has been revoked – by reference to PSD or its website of necessary (RPA). |