This year, 2014, sees the introduction of new measures that govern a number of aspects of the crop protection and pesticide application industry. The long talked-about SUD or Sustainable Use Directive begins to take effect. This will impact on the ground in many different ways, from the registration of advisers, the implementation of safeguard zones for pesticide application and the implementation of IPM (integrated pest management).
These changes are coming about in accordance with the new pesticide regulations and the obligatory National Action Plan, starting in 2014. Different aspects of the plan have different implementation dates but they impact on everyone in the pesticide use cycle, in particular on all those directly involved in the distribution and use cycle.
Registration
All those involved in the advisory, application and user links are obliged to register with the Department of Agriculture and to carry a sufficient level of qualification pertinent to the place in the cycle.
Advisers have already registered last November and only a registered adviser can now give advice on the use of plant protection products. These advisers must carry a minimum level of qualification and experience or be trained up to a specific level outlined within the regulations. As well as this, all registered advisers must be involved in continuous professional education in order to remain on the register. This means participation in conferences, courses, seminars, update briefings, etc. All new advisers from November 2013, regardless of their level of education, must complete a Level 7 Diploma in IPM and the sustainable use of pesticides or an equivalent course.
Professional users must register by 26 November 2015. A professional user is anyone who uses pesticides in the course of their professional activities, including sprayer operators, technicians, employers and self-employed people, both in the farming and other sectors. As and from the registration date, only a registered professional user or a person operating under the direct supervision of a registered professional user can apply pesticides authorised for professional use.
Professional users can register online on the PCS website (www.pcs.agriculture.gov.ie) from 2014. For those who prefer the paper and pen method, an application form can be downloaded from the same website and returned, completed, to
Sustainable Use Directive Section,
Pesticide Controls Division,
Department of Agriculture, Food and the Marine,
Backweston Campus,
Young’s Cross,
Celbridge,
Co Kildare.
Registration will require a basic level of training for professional users. A number of different Teagasc courses and the City and Guilds pesticide application courses, delivered by Coillte, will provide the necessary training. Courses from other training providers may also be acceptable as long as they cover the appropriate content and are up to the necessary standard.
The only users who are not required to register are grassland farmers who apply less than 20 litres of product per annum of pesticides on less than 10ha of grassland.
This exemption is at the discretion of the Department of Agriculture, Food and the Marine and is subject to on-going review. An individual who is not registered as a professional user can buy pesticides but these must be applied for by a registered professional user or a person operating under the direct supervision of a registered professional user.
There is a requirement to keep appropriate records of the chemical use with details of the registered professional user who applied the pesticides.
Application equipment
Farmers who are professional users must also be aware that all boom sprayers greater than 3m working width and all blast and orchard sprayers must be tested at least once before 26 November 2016. And the inspection certificate only lasts for five years maximum up to 2020 and after that testing must be done every three years.
As of now it is expected that all other types of pesticide application equipment (pellet applicators, weed wipers, sprayers <3m, etc.) will have to be tested at least once before 2020. However, knapsack sprayers will remain exempt.
The necessity for equipment to be inspected also means that inspectors will be needed to do this. These inspectors had to be registered by 26 November 2013. However, a pesticide application equipment inspector can be any person who has acquired adequate knowledge and who can verify that pesticide application equipment satisfies the relevant requirements listed in Directive 2009/128/EC. The purpose of this is to safeguard a high level of protection for human health and the environment.
As with advisers, an equipment inspector must commit to participating in continuous professional education (CPE) to maintain his/her registration.
New inspectors can register with the department following completion of a new FETAC accredited course which is being developed in conjunction with Teagasc. Once this course is up and running, all existing registered inspectors, as well as prospective inspectors, will be required to complete it to be on the register. Equivalent qualifications may also be recognised.
Integrated pest management
This is not a new concept of management but all farmers using chemicals must now comply with a set of general principles based on integrated pest management (IPM). IPM aims to manage pests through a combination of cultural, biological, physical and chemical tools so as to minimise economic, environmental and health risks.
Without knowingly doing it, many growers are already engaged in practices to minimise a number of disease and pest risks. This is IPM.
Common IPM practices include crop rotation (pest and disease control), balancing seed rate and sowing dates, stale seedbeds and min-till, using resistant varieties and certified seed, appropriate and balanced fertilisation, irrigation and drainage, equipment cleaning to help prevent the spread of some diseases and the protection of important beneficial organisms such as earthworms.
It also includes the use of monitoring and thresholds, where available, to guide pesticide application and also the use of registered advisers for guidance.
Where satisfactory cultural, biological, physical or other non-chemical methods are available, they should be used in preference to chemical methods providing they provide satisfactory control.
The choice of pesticide, where necessary, must be as specific as possible for the target organism and should have the least possible side-effects on human health, non-target organisms and the environment.
Use the lowest practical rate of pesticide, in combination with other control methods, to balance successful control against the risk of resistance development.
This can be done through reduced rates or reduced application frequency.
Where resistance development is a known risk, the use of anti-resistance measures using different modes of action is essential.
Good records are essential. This is not just what was done but why it was done and, where appropriate, following what triggers. When IPM is practised it can result in a reduction in the amount of pesticide used over time and this may be verified from the combined records.
For IPM, farmers are legally required to do two things:
1. Farm using the general principles of integrated pest management.
2. Maintain records demonstrating the application of these principles.
Farmers will need to complete a record sheet outlining the various measures taken to implement IPM on the farm and to show the different monitoring and actions used to help minimise the risk to the crop in the field.
The Department of Agriculture, Food and the Marine (DAFM) has produced guidance notes on how to apply the general principles of IPM at farm level and also a simple record template (Figure 2) that should be maintained throughout the year with minimum effort. So make sure your chemical use record always includes a reason as to why each product and active is used.
Ticking the boxes
When you look at the form that needs to be filled, the process is less intimidating.
Section 1 looks at measures that help prevent or suppress harmful organisms. So rotation, use of certified seed, management of crop residues, optimum sowing date, using stale seedbeds, cultivation systems, etc are all actions that support IPM. Stubble cultivation can be successfully used to significantly reduce slug numbers and activity, promote the germination of many problem weeds and thus reduce numbers long term, incorporate chopped straw to help soil organic matter and soil biological activity and also to incorporate organic manures to help conserve nitrogen and reduce odours.
Section 2 looks at monitoring of harmful organisms. So being able to clearly identify the problem pest, using the weather forecast to aid decisions, using traps or early warning systems (e.g. blight) to predict problems, monitoring crops and taking professional advice all help to justify the action taken. But these measures may sometimes also help the grower to not have to take action at a specific time.
Section 3 relays the decisions taken to use plant protection measures. Potential reasons here include decisions made with the crop adviser or made jointly with the adviser, the use of pest/disease thresholds, the use of preventative treatments for some potential problems, etc.
Section 4 looks at the use of sustainable biological, physical or other non-chemical methods to reduce or negate the need for pesticide use. There are many possible boxes to tick but most are not relevant to grain growers. But using netting to keep out rabbits and deterrents to keep away crows, etc are possible methods worth considering. And using stubble cultivation and stale seedbeds help to reduce the long term dependence on pesticides for reasons like weed and slug control.
Section 5 relates to using products that are as specific as possible for the target pest. So it relates to the choice of product and the rationale for the choice made, the impact for rotation of the decision made (e.g. control diseases like sclerotinia so that it will not threaten other crops in the rotation), the minimisation of drift risk through type of sprayer or choice of nozzle, decisions to prevent resistance development or the use of seed dressings rather than sprays to target specific pests.
Section 6 relates to the actual use of pesticides and the total quantity used. Using less than full rate, using adjuvants to help increase efficiency or reduce rates, treating early to reduce the rate required, reducing frequency of application where possible and the use of spot treatment where appropriate are all ways of showing that you are using as little as necessary.
Section 7 relates to helping prevent resistance development. This means using products with multiple modes of action or tank mixes to achieve the same objective. Other boxes relate to keeping yourself informed about the development of resistance, the use of robust rates and being familiar with different products. Here also it is worth noting the use of broad spectrum fungicides like Bravo and Phoenix fungicides and various herbicide pre-mixes.
Section 8 relates to a summary assessment at the end of the year of the various measures taken. So recording the success, or otherwise, of different actions, and discussing them with an adviser or discussion group is seen as preparing for the future and part of IPM.
No-spray zones
The new legislation pays particular attention to water and measures to help prevent access of chemicals into sources of drinking water in particular. It includes measures to prevent application in safeguard zones surrounding water abstraction points, while each individual pesticide product may have a unique requirement for a buffer zone along surface water bodies (rivers, lakes, drains etc.) or hedgerows in some instances.
Safeguard zones
These apply around areas where water is being abstracted for human consumption. Examples include shallow wells, boreholes, river points etc. The respective distances are shown below and are non negotiable. These are the same as the no spread zones required under the nitrates regulations. The size of the safeguard zone relates to the amount of water extracted from that point.
Safeguard zone required for different abstraction requirements
*(karst area, sink hole or collapse feature)
Buffer Zones
Buffer zones are areas where plant protection products cannot be applied. These zones can be either adjacent to water or hedgerows and they cannot receive direct application of plant protection products. Most of the buffer zones prescribed on Irish products relate to aquatic zones (water courses).
Buffer zones are now more frequently associated with the products we use and are typically 5-10m avoidance zones. However, they may extend to 70m. Products such as Bravo, Sumi Alpha, Adexar, Arelon 500 and Aviator Xpro, all have a 5m buffer zone. Because this is a new requirement, it is very important that you read the label specifically for this and record the fact that you have adhered to it.
While the buffer zone requirement is written on the label, the Department hopes to have in place a scheme which will allow the farmer reduce the buffer zone requirement. This will be based on using approved drift-reducing nozzles in conjunction with using reduced application rates. It is envisaged that many buffer zones could be halved, with some being reduced down to 1m.
Enforcement
Adherence to buffer zones, safeguard zones and IPM are now mandatory requirements and will be included in cross-compliance checks, along with all previous pesticide and records requirements. Advice can only be provided by registered and qualified personnel. The requirements for professional users to be registered and trained and for boom sprayers (>3m) to be tested will become obligatory in the years ahead according to the designated timetables.
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