regulation of distribution and farm level uses
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Regulation of distribution and farm level uses. Paul Adamson & Helena Cooke. Post approval activity should inform the approval process & vice versa Rules/guidance must be clear and helpful Action must be proportionate and based in law Need for good communication between all agencies concerned. - PowerPoint PPT PresentationTRANSCRIPT
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Health and Safety Executive
Health and Safety Executive
Regulation of distribution and farm level uses
Paul Adamson & Helena Cooke
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Why is there control and monitoring?
• Post approval activity should inform the approval process & vice versa
• Rules/guidance must be clear and helpful• Action must be proportionate and based in
law• Need for good communication between all
agencies concerned
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What does CRD do?
•Cross Compliance Checks
•Formulation analysis
•Label checks
•Wildlife Incident Investigation Scheme (WIIS)
•Human Health Incident & Enquiry Survey
•Marketing, Storage and Use Cases
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Cross Compliance
• Undertaken by Rural Payments Agency (RPA)
• On farm inspections of pesticide use, rates & timings, application records and Good Practice including equipment checks
• 1% of Single Farm Payment (SFP) claimants checked annually (about 1,200 farms)
• Breaches identified in 24 – 30 (2 – 2.5%) of inspections
• Breaches usually minor certification and record keeping – penalties 3 – 5% of SFP
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Cross Compliance
• Where MRL breaches are detected in UK grown products as part of residue analysis– CRD undertakes preliminary investigation
to• identify grower; and• check no other explanations for residue
– Information on grower passed to RPA for future field investigation as part of Cross Compliance.
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Formulations Analysis
• Samples obtained by CRD from Distributors and analysis undertaken by FERA
• Rolling Programme looks at:– active substances– specified impurities– co-formulants; and– physchem properties
• Follow-up of results outside FAO tolerances by CRD – not routinely published
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Label Checks
• Rolling programme of label checking by specialists in CRD
• Products selected on scheduled basis so all labels are checked every 3 to 5 years
• Includes all authorised products and parallel permit products
• Minor errors marked for correction next time authorisation holder amends application
• More serious breaches followed up by Compliance team
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Human Health Incident and Enquiry Survey (HHEIS)
• Conducted annually by CRD
• All authorisation and permit holders required to provide information on all incidents and enquiries in relation to their products
• Typically: – 250 authorisation/permit holders surveyed– about 180 usually minor incidents/enquiries
reported
• Results reported with other human health monitoring to Advisory Committee on Pesticides
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Human Health Incident and Enquiry Survey (HHEIS)
• Incidents set into context by comparison with sales figures
• Many more amateur products than professional involved in incidents
• Incidents affecting children specifically monitored
• Incidents are usually minor in nature and usually do not involve a need for GP or Hospital treatment
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Wildlife Incident Investigation Scheme (WIIS)
• Operated in England by Natural England who follow up cases reported with field investigation
• Sample analysis undertaken by FERA and post mortems by Veterinary Laboratories Agency
• Where evidence from field investigation supports prosecution is taken lead by National Pesticides Enforcement Team (NPET)
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Wildlife Incident Investigation Scheme (WIIS)
• 300 - 400 reports per year to WIIS
• 180 of these accepted on to the scheme
• 60 cases require field investigation
• may lead to 5 or 6 prosecutions per year
• Scheme costs about £500 to operate with funds coming from industry and government
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Who does what?
• Food Standards Agency• EC Rapid Alert system
• Environment Agency, SEPA, NIEA• incidents of environmental pollution caused by
pesticides (e.g. major spills affecting rivers)
• CRD/Devolved Administrations• adverse data, labelling, parallel imports, residues,
WIIS
• BASIS (Registration) Ltd – • check sales stores
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Marketing and Use Cases
• Reactive cases from:– industry complaints, e.g. about the
formulation of parallel traded products– residues monitoring where residue
indicates illegal use– on-line retailers
• 60 – 100 cases per year
• Initial investigation by CRD, where prosecution indicated this is via the NPET
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Marketing and Use Cases
• Reactive cases from:– industry complaints, e.g. about the
formulation of parallel traded products– residues monitoring where residue
indicates illegal use– on-line retailers
• 60 – 100 cases per year
• Initial investigation by CRD, where prosecution indicated this is via the NPET
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Enforcement options
• Advisory letters
• “Naming and shaming”
• Enforcement Notices
• Seize and dispose
• Cross Compliance Penalty
• Prosecution
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Who does what?
• HSE– on farm inspections, use of pesticides as a work activity
• Local Authorities – Environmental Health Officers - domestic use– Trading Standards Officers - sale/supply, storage for sale,
residues
• Rural Payments Agency– Cross Compliance inspections under the Single Payment
Scheme
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What advice is available?
• Code of practice • Department for Environment Food and
Rural Affairs• Chemicals Regulation Directorate• Sales personnel• Agronomists, consultants, advisors• Trade and industry organisations
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Codes of Practice• Two codes of practice
– For use– For sale and supply
• Statutory but not mandatory• Explains the law and best practice• Can be used in evidence in a
Court of law• Focussed on user• Electronic media – easy to search
text
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Training and certification
• What’s it like at the moment?– Sales– Storage for supply or
sale– User
• NOT advisors• How do we monitor and
control it?
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What is a ‘certificate of competence’?
• Mandatory requirement• Endorsed by Government
Ministers• Awarded only by:
– Use – City & Guilds NPTC– Sales and storage – BASIS
(Registration) Ltd– Not advisors
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