Plant Protection Products & Sustainable Use Directive: Requirements, Checking, and Breach Inspections

1. 2019 FAS Training SMR 10 Concerning Plant Protection Products & Sustainable Use Directive

2. Pesticides Outline of Presentation • Pesticides • Requirements • SUD Directive • Checks carried out • SUD Directive • Breaches found at inspection • Summary

3. SMR 10 – Pesticides Plant Protection Products (PPPs) • Council Regulation – 1107/2009/EC • SI – 159/2012 Objective: High level of protection for man, animals and the environment & reassurance to general public, that PPPs are applied safely

4. SMR 10 – Pesticides Generic term used to describe 2 Groups of products • Plant Protection Products (PPPs) (used on crops) • Biocides Products (non-crop use)

5. Plant Protection Products (PPPs) Include: • Herbicides • Insecticides • Fungicides • Plant Growth Regulators • Seed Dressings • Molluscides • Fumigants

6. Biocides • Used to control non-agricultural pest e.g. insects, bacteria & fungi “Products designed to kill or control harmful organisms” not covered by PPP, Veterinary or Cosmetic legislation Used in a diverse range of situations including • Dairy detergents/sanitisers & disinfectants • Rodenticides • Wood Preservatives • Masonry Preservatives

7. Pesticide Registration • Pesticidesusedmust be registeredwith the PCD • Approved Plant Production Products (PPP) - Pesticide Control Service Number (PCS No.) • Approved Biocidal products will have a PCS No or a Biocidal Product Authorisation Number (IE/BPA) or EU number • The register of currently approved PPPs & Biocides products can be viewed on DAFM Website (http://www.pcs.agriculture.gov.ie)

8. PCS Number

9. Biocides • Dairy farmer may store limited quantities of specific biocides (dairy hygiene products) within the milking parlour/dairy, as opposed to within a dedicated storage facility They must pose no risk of contaminating the milk

10. SMR 10 Plant Protection Products (PPPs) Can only use plant protection product if it is: Approvedi.e. registered with PCD • Used in accordance with conditions specified on the label • Used in accordance with the principles of good plant protection practice • Used in accordance with the principles of integrated control

11. SMR 10 Principles of Good Plant Protection Practice (GPPP) include: • Optimal practice in the use of PPPs • Correct choice of active substance • Perform handling operations well away from waterways, ditches, drain, boreholes, well/springs • Appropriate dosage rate • Number, timing & frequency of application • Method of application • Strategies to reduce spray drift • Resistance management

12. GPPP & STRIPE STRIPE – Surface water Tool for Reducing the Impact of Pesticides in the Environment • The DAFM have developed the STRIPE initiative whereby individuals using low-drift nozzles can reduce buffer zones by 75 and 90% respectively (depending on choice of nozzle). Cannot eliminate buffer zone completely, min. distance of 1m will still apply.

13. SMR 10 Requirements Principles of Integrated Control The use of the PPP is limited to the minimum necessary to keep harmful organisms below levels at which economically unacceptable damage or loss would occur Consider alternative methods of pest control rather than pesticides

14. SMR 10 Requirements Usage: • Use registered PPPs and biocidal products • PPPs must be used as specified on current approved product labels e.g. crop, rate of application, timing etc. • Comply with buffer zones as specified on the product label • Never fill any sprayer directly from a water body • Application equipment must be suitable for purpose and properly calibrated • Use in accordance with the principals of Good Plant Protection Practice

15. Storage Requirement • Chemical store can be stand-alone building, container, press/cupboard/cabinet/filing cabinet, which is independently lockable, and is capable of containing spills

16. Storage Requirements Dedicated storage facility/area • Warning Sign at entrance • Secure, independently lockable • Bundled store leakages/spillages • Well ventilated • Store Powders separately or above liquids • Store in original containers & labels attached • Facility to clean up small spills e.g. bucket of sand/peat • Keep out of reach of children

17. A Good Store? Liquids beside Powders Bunding???

18. Powder stored on bottom shelf Storage??

19. Products in store Powders above liquids

20. SMR 10 Handling • Clean, suitable & proper protective equipment and protective clothing • Appropriate designated measuring equipment Records • Purchase, application, (by applicant and or contractor) disposal & return are maintained & available for inspection • Product applications records: must include date of application, product name, PCS No, crop, LPIS No., area treated, application rate , water volume of water, method of application, buffer zone applied, whether STRIPE was used, reason for application, Professional user number (PU) of the person who applied the treatment • Farmers must maintain records of application where a contract applicator is used

21. Product Rotation • Ensure products no longer approved for use are not retained in store • Once products are past their “use-by date” they cannot be applied & must be correctly disposed of as hazardous waste • Regional collection programmes • Empty, triple-rinsed, containers and foil caps must be disposed of in accordance with the Good Practice Guide

22. Records • Template available on DAFM Web Site

23. Sustainable Use of Pesticides Directive (SUD) - Background The SUD is a European Directive (Directive 2009/128/EC) which seeks to establish a framework to achieve the sustainable use of pesticides by reducing the risks and impacts of pesticide use on human health and the environment, and to promote the use of Integrated Pest Management (IPM) and alternative approaches or techniques to chemical use. It introduces new requirements surrounding advice, sale, supply and the use of Plant Protection Products (PPPs). • SI No. 155 of 2012 NOT ANTI-PESTICIDES – SEEKS TO PRESERVE EXISTING CHEMISTRY FOR THE FUTURE

24. SUD - Background Pesticides = Plant Protection Products (PPPs) + Biocides (disinfectants, preservatives, pest control products, antifoulants etc.) Currently the SUD only impacts on PPPs

25. SUD – Main Impacts • Training & registration (the DAFM) of advisors, distributors & users of PPPs • Testing of sprayers • Controls on storage, supply and use • Integrated Pest Management (IPM) • Protection of water from pesticides

26. SUD Training & Registration Deadlines • Pesticide Advisors - Registration mandatory sinceNovember 2013. Continuous Professional Education (CPE) - IASIS scheme or similar (100 credits/annum). • Inspectors of Pesticide Application Equipment – Registration mandatory since November 2013. Training course available through Teagasc. • Pesticide Distributors – Registration mandatory from November 2015. FETAC Level 5 course available through approved training providers. CPE requirement. • Professional Users - Registration mandatory from November 2015. http://www.pcs.agriculture.gov.ie/sud/

27. Pesticide Advisors (PA) • November 2013, all PAs must be registered with the DAFM • Dip in IPM and Sustainable Use of Pesticides or equivalent • Must maintain CPE – Irish Agricultural Supply Industry Standards (IASIS) scheme or equivalent • DAFM registered PAs are required to achieve either a minimum of 100 IASIS CPE credits (or equivalent) over the previous calendar year, or an average of 100 IASIS credits/annum over the previous two calendar years!

28. Pesticide Advisors (PA) • Change of mind-set • Smarter use of Pesticides • IPM • Raise the bar • Training • Currently ≈ 1000 registered PAs

29. Pesticide Distributor (PD) • Must be registered by 26 Nov 2015 • Handling and Distribution of Pesticides course 5S2466, FETAC Level 5, 2 day duration • Must maintain CPE – IASIS scheme or equivalent • Currently ≈ 900 registered PDs

30. Professional User (PU) Who are Professional Users? • Any person who uses or applies professional use pesticides - farmers, contractors, landscapers, green keepers, CC workers etc. NO EXEMPTIONS • Registration number of person applying pesticides will be required as part of a cross-compliance inspection Register at • www.agfood.ie for DAFM clients • http://www.pcs.agriculture.gov.ie/sud/sudreg/ if not a DAFM client NB Registered Pesticide Advisors are eligible to register as Professional Users

31. Training the Professional User (PU) • Teagasc letter • FETAC 5N0731 (handheld) • FETAC 5N1797 (boom sprayer) • City and Guilds PA1 + PA2/6 • Lantra PA1 + PA2/6 • BAgSc UCD (Hort/forestry) • BAgSc UCD (modules on crop production and protection) • BSc (Hort) ITB (modules on plant protection) • BSc Ag Technology QUB (modules on crop production and protection) Currently ≈ 31,500 registered PUs

32. Professional User (PU) • Protection of operators, bystanders and consumers • Only use approved products • Protection of water, buffer zones respected • Follow label recommendations

33. Inspectors of Equipment • DAFM/Teagasc 2 day course in Kildalton • Registered with DAFM & maintain CPE • Tests must be done by DAFM-registered Equipment Inspector, recorded online to DAFM system • All boom sprayers > 3m and all blast and orchard sprayers must be tested at least once by 26 November 2016 • Testing interval must not exceed 5 years up to 2020 • Testing interval must not exceed 3 years thereafter

34. Application Equipment • Timetable and inspection intervals for other types of application equipment will also be developed in due course • Knapsack sprayers exempt • New sprayers must be tested at least once within 5 years of purchase

35. Integrated Pest Management(IPM) • IPM is a sustainable approach to managing pests by combining biological, cultural, physical and chemical tools in a way that minimises economic, health and environmental risks • Not ‘anti’ chemicals, about prolonging lifespan of existing chemical portfolio, e.g. straight SDHI fungicides had only a 5 year window before reports of resistance emerged • Many farmers already practicing IPM but not aware that this is the case Nothing to be afraid of!

36. IPM – how do farmers prevent/suppress harmful organisms? • Choose resistant/tolerant cultivars(Hybrids, GMO’s??) • Use optimum crop rotation strategies • Consider alternative cultivation techniques e.g. topping • Protect important natural enemies • Monitor harmful organisms (only apply PPP when pest or disease thresholds breached) • Use of target-specific pesticides • Use of pesticides at necessary levels – avoid build up of resistance by using too low a rate • Check and record success of plant protection measures

37. IPM

38. IPM • General principles applied from January 2014 • Record of IPM practices at whole enterprise level • In due course IPM will be a component of cross compliance http://www.pcs.agriculture.gov.ie/sud/ professionaluserssprayeroperators/

39. SUD & Water Quality Article 11 of the SUD deals with the protection of water from pesticides. Legal limits for pesticides are specified under EU legislation: • Water Framework Directive - covers all water bodies • Drinking Water Directive - covers drinking water and supply

40. Buffer zones (untreated area adjacent to water body) SUD & water quality Two main SUD water protection measures Safeguard zones (areas around drinking water abstraction points in which pesticide use is prohibited)

41. SUD & Water Quality Buffer zones No-spray strip of a specified minimum width between the edge of a water body and the edge of the treated area Legal requirement to comply with buffer zone specified on product label Applies to all types of surface water bodies, e.g. ditches, streams, ponds, rivers and lakes

42. SUD & water quality Safeguard Zones • 5 m – 200 m depending on supply capacity of water source • Abstraction point supplying 500 or more persons or 100 m3 or more of water per day :SZ = 200 m • Abstraction point supplying 50-500 persons or 10 m3 or more of water per day :SZ = 100 m • Abstraction point supplying 10-50 persons or 1-10 m3 of water per day :SZ = 25 m • Abstraction point supplying 10 or less persons or 1 m3 or less of water per day :SZ = 5 m Note 1. The DAFM are not aware of location of abstraction points Note 2. No use within 15 metres of a landscape feature that is known to be a ground water vulnerable area including karst areas, sinkholes and collapse features

43. SMR 10 – Pesticides Inspections Part 1 inspection of SMR 10 assesses the storage & handling of PPPs on farm Check for: • Dedicated storage facility/area • Secure, bunded store & warning sign • Facility for containing spills e.g. sand/peat • Protective equipment/clothing for handling PPPs • Powders are stored above liquids (avoid contamination) and products are in their original containers

44. SMR 10 – Pesticides Inspections Check for: • Where possible buffer zones for each individual PPP product have been adhered to • Sprayer tank was not filled or washed from a watercourse • Records of PPP usage & IPM are being maintained & available on the day of inspection Currently no CC implications for IPM, sprayer testing & PU training

45. SMR 10 – Pesticides Inspections Record • Details of spraying equipment, plus when last calibrated, date of testing & test certificate serial number or date of purchase if <5 years old • How and where sprayer is filled & washed • PU no of applicator • Full inventory of chemical store

46. Pesticides Worksheet - Sprayer & Calibration Details Sprayer Cert No.

47. Pesticides worksheet • How and where does the applicant fill & wash the sprayer? • Is the applicant a registered Professional User (PU)? • Record PU Number & obtain training cert. • Is the application of plant protection or biocidal products undertaken by a contractor/third party • Must provide contractor’s name and address; • Contractors PU no. • Who provides the chemicals (applicant or contractor)

48. Pesticides worksheet • Are records indicating the practice of Integrated Pest Management available? If No- indicate which IPM practices are carried out, e.g. Topping, ploughing, use of disease resistant varieties etc • Does the herd owner carryout the application of plant protection or biocidal products as a contractor / third party? • Is the applicant the sole owner/user of the designated PPP store? If NO– must give Name & Herd No of other owner

49. Pesticides Worksheet – Year Purchase & Disposal Records

50. SMR 10 – Pesticides Inspections • Application records for the previous 12 months obtained to assess compliance with max rates of application and status of products used • PCD are mainly concerned with products purchased and used in the previous 12 months • “No records” a sanction will be applied