You only have to think about how difficult it is to get officially registered products for broad-acre crops like cereals to begin to realise the challenges being faced by growers of minor or speciality crops. When you grow these crops, it is a real challenge to get registered products for use in weed, pest and disease control.

Last week, the Pesticides Registration and Control Division (PRCD) in the Department of Agriculture held a very useful seminar entitled Plant Protection Developments in the Horticultural & Speciality Crop Sector. Small specialist crops have a much more limited portfolio of approved products and so they can have real challenges for crop protection.

In Europe, plant protection product (PPP) active substances are approved at EU level, which then allows an individual member state to consider authorising a product containing that EU-approved active substance.

Both EU approval for the active substance and subsequently member state authorisation of products is done on foot of a comprehensive data package and on the information provided on the range of crops for which approval is sought.

It is often the case that the smaller the market, the less likely companies will be to incur the cost of generating data to secure registration in individual small or minor crops like those in horticulture.

To help overcome this problem, the EU system allows marketing bodies, farmer groups, etc, to apply for an off-label clearance for an individual product on a specific crop.

Because it is not the chemical company requesting the registration, the onus of crop safety and efficacy falls back on the farmer. However, because the crops are going into the food sector, there is an understandable necessity to produce and present residue data to support such a request.

It is often the case that this lack of data relating to pesticide residues in the crop are an obstacle for authorisation of the product. Therefore, if a grower, grower group or marketing group, etc, could provide this residue data, they would be able to gain authorisation to use the product on the crop concerned.

Alternatively, if growers have already produced such data in another country, the growers in Ireland could purchase access to this data or maybe share data of their own with other countries.

To facilitate such trading and to allow growers identify what data they need and where they can find it, the member states and the EU Commission are funding the Minor Uses Coordination Facility.

This option to generate off-label recommendations is particularly important in Ireland because the sector is so small and many such off-label authorisations have been secured with the help of Bord Bia, Teagasc, the IFA and the Department. Failure to secure them could mean that growers would not be able to make the quality spec the market demands.

Brexit concern for registrations

Opening one of the sessions, Gordon Rennick from PRCD warned of another problem which is pending for the whole registration process. “Around 80% to 90% of our product registrations are achieved via mutual recognition from UK registrations.

“This is a cause of great concern for Irish farmers because no one knows what will happen the registration process in the UK post-Brexit. Not having the UK clearing product registrations to EU standards could significantly reduce the arrival of new products in the future.”

The overall approach within EU circles to pesticide registration at the moment is worrying. The official drive to low-risk active ingredients may theoretically be solving one problem for society, but, by definition, these are also likely to be less useful in controlling the range of pests challenging commercial agriculture.

In the EU, there were about 800 active ingredients registered for use in the early 1990s. This is currently down to 400 actives and falling. This latter number includes all the new products registered in recent years and these include actives such as vinegar, nettle juice, extract of horsetail, salt, whey and even beer. Is it now only a matter of time before beer itself becomes a focus of food safety investigations?

Many of these new registrations are biological rather than chemical agents and it is likely that less than 300 of them are useful for field use. Just because we have products does not mean we have solutions.

Off-label authorisations

Donal Lynch (PRCD) explained that Ireland is a tiny market for PPPs for use in minor or speciality crops and, as the decision to register a product for a use is commercial, most broad-acre products do not carry minor crop recommendations.

This is a major challenge for our growers and one of the few options they have is to avail of the off-label provision in our pesticide legislation.

Once a product is officially registered for use, an off-label authorisation for use in a non-registered crop can be sought, but this requires residue data to be submitted. It is essential that the use of an active does not present a health hazard and that it does not exceed the maximum residue limit (MRL) agreed for the specific active.

The fact that this residue information is essential means that some organisation or group must organise and fund the testing. The cost is beyond what an individual grower could realistically consider. But where the data is generated, it can be submitted to the PRCD for evaluation for authorisation.

In the UK, the Agriculture and Horticulture Development Board (AHDB) collects levies across all sectors of agriculture which are used to help fund research and marketing.

Vivian Powell from the AHDB told the meeting that this funding can be used to fund the residue testing for off-label minor crop authorisations. But, as with any levy, funds are allocated on a competitive and benefit basis.

She said that there are also big gaps in minor crop protection capability in the UK despite the fact that the AHDB is working on a big range of crops and projects on an ongoing basis.

Part of this work is looking at crop associations to show that the residue data generated from one crop is equally applicable to another crop. An example of this is the fact that residue data for celery can be extrapolated for rhubarb for official purposes, Vivian said.

While it is possible to extrapolate residue data in the EU, work on the generation of data on the basis of super-crop groups could help this process greatly. This system is used in the United States and Canada to great effect.

Knowing that specific crops behave in a similar way might further facilitate the official use of data for off-label authorisation.

The AHDB has introduced a range of initiatives to help its members overcome some of the challenges of modern production (Spectre and Spectre PLUS).

Strength in collaboration

Vivian said that collaboration can be very useful in finding solutions to these challenges. “Minor crop authorisations are essential to enable such crops to be produced,” Vivian stated. Such off-label authorisations become essential where the market size does not justify full official registration for that crop.

Sometimes the chemical producers help out with the necessary funding or data. It is also quite common to get sharing of data between such interests, providing the different parties can bring something to the table. It is common for one vested interest to share such data with another which has equivalent information for a different product.

For this reason, it would be very useful if all such organisations in different member states shared their problems and their solutions for minor crops. If all such problems across the EU were coordinated, it would make the task of finding solutions much more streamlined. Knowing the problem always makes it easier to find a solution.

An organisational perspective

Copa-Cogeca is the main body representing farmers and their co-operatives at EU level and Luc Peeters told us that it helps prepare up to 125 dossiers per year for minor crop uses across the EU. Luc said the speciality crops are worth about €70bn in the EU or about 20% of total agricultural output value, but they only account for about 5% of the EU’s UAA.

These crops are important for healthy human diets and so they are important to society. More and more, they are grown as speciality crops and often in businesses that specialise in just one crop. The market is ultimately driving this trend and such speciality producers have the exact same problems encountered by broad-acre crops.

However, “emergency authorisations are not long term solutions,” Luc emphasised. One might well conclude that the system is failing where large numbers of such authorisations are deemed necessary.

The fact that we have from 20 to 140 emergency registrations per year really means that our toolbox is not adequate. The European industry needs proper long-term solutions to its needs.

It remains very difficult to get official clearance for new actives. The system is slow and cumbersome, he said. The figures shown in Example 1 show the fate of the 39 actives submitted for registration between 2011 and January 2016.

The current registration system allows for zonal registration and mutual recognition of products. Luc acknowledged that this is important for Ireland, as Gordon had stated, and said that mutual recognition can work for common regions. Re-evaluating the same product does not add to its value but it does increase its net cost to agriculture.

Growers face many issues

Paul Brophy is chair of IFA’s horticulture committee and he is a specialist producer growing up on 300ha of broccoli. He reinforced the fact that the sector depends heavily on the extension of authorisation for minor uses (EAMU) as it has the fourth-highest farmgate value here at €71m.

With resistance becoming an ever increasing issue for producers in a shrinking pool of PPPs, Paul said that the issue of lower MRLs being imposed by retailers may be having a devastating effect on the sector. This is driving lower application rates, which may be promoting resistance development, as well as allowing problems to occur and potentially increasing food waste. And the few new actives coming to the market are increasingly expensive.

The markets increasingly demand higher quality standards for produce, but this is not possible without a full range of PPPs, Paul stated. Retail trends are now heavily driven by cosmetic standards. Appearance matters more than eating quality and that is impacting on standards and specifications.

While growers fully acknowledge that the Department is very helpful in accommodating efforts to support minor uses, the system places the onus on the grower to find out the necessary information.

This should not be the case, Paul said, as there is no surplus resource or labour on farms to dig out this information. He asked if management software packages being used by growers could carry this information to help guide decisions on farm.

Given the importance of these off-label uses on minor crops, Paul suggested that there should be a full-time person employed by either Teagasc or Bord Bia to help secure the necessary products and information needed by growers.

As in the UK, an obligatory levy would be a very useful method to help ensure that the finances are available to fund the research needed to produce the information needed to secure such authorisations.

Third-party standards

It is not uncommon for large EU retailers to either demand that certain registered products not be used or to set lower MRL levels for specific actives. Such practices should be outlawed, Luc Peeters argued. Any alterations to official levels by secondary or private organisations for marketing reasons should be banned, he stated.

Insistence on lower MRLs could have the effect of increasing food waste through increased food rejection, but they could also lead to increased resistance risks following reduced application rates. Luc commented that such actions by retailers for marketing reasons challenges the confidence of consumers in the registration system that licences the use of these products. Distrust percolates outwards from such actions, so their ultimate consequences are far greater than the actual hassle for the grower.

It was stated in discussion that MRLs are not a product safety measure. MRLs were put in place as a way to control the use of a product for trading purposes and they only become a safety issue if levels are massively exceeded. The official levels set are already many times lower than a level that would impact on food safety.

However, with lower MRLs being imposed, growers asked if retailers will be prepared to accept a little pest damage as a consequence of their enforced higher specification? Indeed, the presence of a little damage might be taken as proof of reduced rates having been used, but will the retailers or the consumers agree.

What’s the real beef

On the glyphosate issue, Luc Peeters asked if the politicisation of its registration renewal is to do with an anti-pesticides sentiment or is it really an anti-GM issue?

That said, if glyphosate were to cease in the EU it would be highly frustrating to see agricultural products being imported which had been treated with glyphosate, or indeed any of the very many other actives that have been removed from use in the EU.

There was strong sentiment expressed at the meeting that since the EU evaluation process has moved to a potential hazard approach, the same principle should apply at import level.