The Groundsman

October 2012

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the Groundsman October 2012 FEATURE 35 Challenges for the future use of pesticides Jon Allbutt outlines the challenges presented by the new EU Directive on the use of pesticides The new pesticides regulations have been in force since June 2012 with key dates set for implementation. The published document, Plant Protection Products (Sustainable Use) Regulations, is not an easy read and as yet there is no detailed plain language guidance for users or employers. Many aspects of the old regulations will remain; the challenge is to understand how the EU Directive is changing not only the legal structure but also our attitude and approach to using pesticides in the future. National Action Plan (Integrated Pest Management) A completely new aspect of these regulations is a duty on every EU Member State to introduce by January 2014 a National Action Plan for the sustainable use of pesticides. These will be a series of legal requirements aimed at reducing the use, and impact, of pesticides on the environment. The Directive has focused attention on the use of pesticides in amenity situations and it seems we will come under considerable pressure to reduce, or eliminate, our use of pesticides; this despite there being very little scientific evidence to support this. UK Government is currently consulting on a draft National Action Plan ( 07/30/uknap-pesticides/) with responses to be received by 22 October 2012. In effect, this means that you will need to carry out a complete review of all aspects of pesticides use, identify where this use can be eliminated, or reduced, and prepare plans for an integrated approach to pest management. This plan will need to include how you will identify environmentally vulnerable areas (water, people, plants and animals, and more), and the methods for implementation, monitoring and review so that the actual reduction in pesticides use, and the risks, can be measured. It is very unlikely that you will have a competent person in-house to do this and it is very unlikely that any financial assistance will be forthcoming to assist you! Certification and Maintaining Competence Anyone who uses pesticides and holds a Certificate of Competence need do nothing – yet. However, it is clear that there will not be any compulsory requirement to maintain an up-to-date Certificate. This is a disappointing aspect of the new regulations as the voluntary National Register of Spray Operators (NRoSO) scheme failed in the amenity sector and any new voluntary approaches are also likely to fail. This is a serious matter as we must have highly skilled and competent operators to take on the challenges for responsible use of pesticides in the future. There is also considerable confusion over 'grandfather rights'; this is what is proposed for those currently applying pesticides without a Certificate of Competence: "The Regulations provide for the continuation of that exemption until 26 November 2015, when everyone who purchases a professional product must ensure that the intended end user holds a certificate. After 26 November 2015, everyone who uses a professional product, including those who previously relied on 'grandfather rights', must hold a specified certificate." Jon Allbutt is Technical Director of Britrisk Safety –

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