Why growers must use legal guidelines on pesticide labels

Growers risk losing a considerable chunk of their basic payment if they use a pesticide outside the legal guidelines on a product’s label.

Those guidelines are under constant review and are often changed to accommodate tighter regulation of the way pesticides are applied.

Not being aware of the changes and applying a product in a way that breaks the rules could be picked up by a RPA or crop assurance scheme inspection and cost the grower thousands.

Here is all you need to know to stay within the rules.

See also: Best practice for farming around watercourses

What is a Mapp number and why do they change?

Every pesticide product used on farm is given a ministerially approved pesticide product (Mapp) number when it is registered with the Chemicals Regulation Directorate (CRD) for use in the UK.

Previously, they were called ‘Maff’ numbers.

  • Products authorised before 1 July 1999 are distinguished by a ‘Maff’ number.
  • Products authorised since then have a ‘Mapp’ number to identify them.

When a pesticide product is assessed for re-registration or where significant changes to labels occur, in most cases it is given a new Mapp number upon its re-approval.

Revocation dates for the sale, supply, storage and use of products carrying the “old” Mapp number will be advised by CRD on their website. However, this is not always the case and can be an issue for distributors, agronomists and growers.

What changes can occur on a pesticide product label?

Changes can be made to the:

  • Crops the product can be used in
  • Dose that can be applied (individual and total)
  • Number of applications
  • Intervals between applications
  • Harvest intervals (earliest/latest growth stage)
  • Health and safety requirements for operators
  • Environmental precautions, such as buffer zones
  • Agronomic advice such as resistance management to maintain the product’s efficacy

What happens to a product with an “old” Mapp number?

Where a Mapp number changes, distributors invariably have unsold stock from the previous season, together with new stock with a new Mapp number.

To help with stock control and ensure both products are supplied according to the customer’s requirements and applied according to the label conditions, many Agricultural Industries Confederation (AIC) members treat these as two separate products and allocate a different stock code to each.

This helps highlight to distributor storekeepers, delivery drivers, purchasers and end users there is a difference between the products supplied.

While agronomists also aim to stress this on recommendation sheets, end users must check the product label to ensure they are aware of differences between two products that on the face of it are identical, but need to be used differently.

Is there anything I can do on the farm?

For farmers and growers, pesticide stock rotation is essential to ensure products are used according to the label ahead of any revocation dates – this will also save costs having to dispose of products through waste disposal contractors.

Farmers should note when a Mapp number changes on their stock records so they remember to use the product in accordance with any new conditions. 

How can I keep up with label changes?

It is very difficult to keep abreast of label changes, some which can have serious consequences. For example, changes to the rate of use or changes to the crops on which the product is approved are particularly significant – especially where crops are removed from the label.

Many professionals using pesticides resort to checking labels and CRD databases in combination with any notification from the product manufacturer to keep abreast of label changes.

The HSE has a register on plant protection products with on-label authorisations.

What about aquatic buffer zones?

Changes to aquatic buffer zones have been particularly difficult to keep up with due to the scheme changes over the past few years. These changes are not easy to identify by a cursory look at the label.

Agronomy software is helpful and agronomists will highlight aquatic buffer requirements on recommendation sheets, but again users must check the label to ensure they leave the correct buffer distance and use the correct nozzles.

In particular, attention is needed when tank mixing different actives with different buffer zone requirements – in all cases the widest buffer zone specified must be used.

What if an agrochemical company rebrands itself or a product?

Where a manufacturer has rebranded (such as Makhteshim-Agan to Adama), products marketed under the old business name and the new business name each have their own extension of authorisation for minor use (EAMU) – one for each “branding”.

Growers need to ensure they hold the correct EAMU for the product being used. Fortunately the EAMUs are identical – it’s just the brand name that is different, but the correct one must be held. 

What could happen if I use a product outside the label guidelines?

Using product outside of the statutory requirements on a label could result in a breach of cross compliance if picked up in a RPA inspection. It can also be picked up by farm assurance inspections and lead to suspension from the scheme with consequences for the marketability of the crop.

Use of a product on a crop for which it is not approved, at a higher dose or more frequently than the (amended) label states could also lead to a maximum residue level (MRL) being exceeded, which for fruit and vegetable growers in particular, could lead to rejection by the packer/supermarket, with significant losses for the grower. In addition CRD may take action.  

What are the potential financial penalties?

Under the current system, as a rule of thumb growers face losing 5% of their single farm and/or rural development scheme payments if found to be using a plant protection product an unauthorised manner. If the action was deemed intentional, that could rise to as much as 30%.

For example if you were farming 600ha and receiving a SFP of £120,000, not reading the label or ignoring changes could cost you £6,000-36,000 – a very costly mistake.

Of the 75 RPA cross-compliance inspections for the “restriction on the use of plant protection products ” in 2013, 10.27% failed. Of those failures, 49% were fined 5% of their SFP.

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