Most farmers have eventually been made aware of the necessity that anyone who applies pesticides by spraying be registered with the Department of Agriculture as a professional user (PU). As and from 26 November last, you cannot legally apply professional products unless you have a specific PU number allocated to you following registration.
Getting a PU number requires specific registration as a professional user through the Department’s sustainable use directive (SUD) web page at here. Here you will find the different ways in which to register, plus information on what is required.
Most of what is required is quite basic, such as name, address, phone number and why you might need to apply professional-use pesticides. One of the questions asks for your highest relevant qualification.
This relates to the qualification or training you received in spray application and this is the reason that so many people needed to complete a sprayer operator course in order to apply to become a PU.
It is not enough to have completed the sprayer course
Remember, it is not enough to have completed the sprayer course – the obligation is to be registered, not to complete a sprayer operator course. Many farmers had already done training with Teagasc which would suffice for registration, but this must be checked and confirmed by Teagasc prior to your registration.
The online application process contains a drop-down menu with a range of course types and you just select the one that is relevant to you.
When all of the boxes are filled in, just hit “submit”. But you do not become an official registered PU until you receive your PU number from the Department. Any spray application applied by you before your PU number has been allocated is a breach of the SUD regulations.
So, just because you have successfully completed a sprayer course does not entitle you to apply pesticides – you must have a PU registration number first.
This is also the reason why sprayer users were encouraged to apply in advance of the November deadline, so as to have the necessary process completed before further spraying might be needed.
As of 20 May there were almost 19,500 PUs approved by the Department with registration numbers allocated. And there were a further 1,500 application submitted but awaiting processing for PU numbers to be allocated.
PU obligations
What does being a professional user really mean? Yes, you need a registration number to apply pesticides, but the general objective is much wider than that. Increasingly stringent regulations are being imposed on a whole range of environmental concerns, with pesticides in water being one major worry.
In recent years, there have been very serious issues with regard to the contamination of surface water with specific pesticides.
In some instances, the concentration of products found have been quite high and will force legislators to act in some way to prevent the problems recurring.
It seems inevitable that these contamination findings relate directly to users, with MCPA being a significant problem and grassland spraying thought to be the major cause of the contamination identified.
Put simply, if pesticides continue to be present in water (different limits are set for surface water and ground water), then one or two official actions seem likely.
Either the product will be withdrawn from the market or products containing the offending actives will be considerably restricted in their use and use rates.
Either way, these actions could significantly limit the ability of farmers to control the target weeds and such action could limit control potential in the future.
While grassland sprays have been at the centre of pesticide findings in surface water, a number of actives used exclusively in tillage have also been found. Continued appearance of any offending product in water testing will inevitably bring changes in the way a product can be used.
We see this currently in the changes that are being forced on straight MCPA products and the rate reductions that have been imposed. Similar reactions will occur in the case of tillage products. This is really a case of “toe the line or lose the product”.
Professional users of professional-use pesticides must exercise considerable responsibility in this regard. Products must always be used within label guidelines and these can be quite revealing at times. Product maximum rates should not be exceeded and products should only be used to control targeted pests when present or expected. Many products need contact to work and so cannot be used successfully in advance of the problem weed or pest being present.
Conditions at spraying
Users often expect chemicals to work irrespective of the conditions in which they are applied. For most chemicals to work, the target plants need to be growing actively so that they can take up the chemicals which can then disrupt plant growth in the case of herbicides or fungal growth in the case of diseases.
While some products can benefit from cold conditions, either prior to application or after application, most require that the active be applied to healthy growing vegetation.
Rushes are one example of a weed where the removal, through topping, of old weathered vegetative growth is advised prior to spraying because the weathered vegetation cannot take up the herbicide. Creeping thistle is often better topped first to weaken root reserves and ensure that all plants are emerged at the time of spraying.
In other instances, it is important to have adequate vegetation present to take up the spray. In these instances, the target plants must be allowed to grow to have enough leaf present. Examples of this would be docks or scutch control in grassland. There is also the increasing concern about resistance. This is now quite real on every front.
Add to this the fact that so many actives are being lost from the system through the regulatory process and this makes for a double reason for farmers to consider all possible ways to either replace the need for herbicide or pesticide or to help the products to work.
Users should use all possible cultural or management tools available to help control every problem. Total and continued dependence on chemicals has only one possible outcome – nature will win.
Alternative control techniques
It is the responsibility of PUs to consider many or all of these aspects of a problem when applying pesticides.
Where possible and appropriate, a farmer must use, in as far as is possible, a range of integrated pest management (IPM) techniques to reduce dependence on pesticides. Such actions can help reduce the size or scale of the problem or provide an alternative control technique.
Alternative control techniques will mean cultural methods such as stale seedbeds for tillage crops or things like topping for grassland weeds.
But it also means avoiding excess potash in the case of docks and in having optimum pH to help control annual meadowgrass and possibly other weeds. Adequate fertility in grassland is also important to help the grass to compete with the weeds.
The need to have an overview on farming and its problems must also be considered by PUs.
Pesticides cost money, so we must always strive to get the most from every application. The responsible application of pesticides must be more than getting the product out across the target area. There is more to consider than just the sprayer and the nozzle.
PUs must consider the size and location of the target, the weather band in which a product is being applied, the specifics of the product used, the help that can be given from other actions and doing what you can by other means to reduce the size of any problem to begin with.
In general, the risk of resistance development is largely proportionate to the scale of the problem. Containing the problem reduces the risk.
Environmental protection
Earlier in this article, I stated the absolute need for care when spraying and for keeping pesticides away from water. This remains a huge concern for the sector.
We have already had a number of consecutive years of high levels of grassland herbicides in surface water – this will not be allowed to continue.
Much of this may relate to the spraying of rushes to make land parcels eligible for aid, but if the problem in water continues, then we can expect even more restrictions on the use of products like MCPA.
The extreme would be the loss of the actives and if the obligation to control rushes remains, alternative control products are likely to be more expensive. Keeping pesticides out of water is critical. There are three main ways that pesticides can enter water, regardless of the crop being sprayed or the products being used.
The simplest one is to allow the working spray boom to stray in over water, thus depositing spray directly. The second is to allow spray drift to be generated, which can carry chemical from the field area into water. The third major risk is to have any direct spill or contamination of watercourses by raw chemical.
All of these issues are in the control of the PU. Filling water directly from watercourses is a definite no-no because of the huge risks associated with raw chemical.
Careless handling of container foils, which allows them to go directly to a watercourse or into a waste or surface water gully, could result in significant contamination. Preventing this contamination is the direct responsibility of the PU.
Sprayer washout
The increasing number of crops being grown on farms increases the obligation of the PU to ensure thorough sprayer wash-out.
This was not a serious concern for years on most farms where only cereals were cultivated. But now the return of crops like oilseed rape and beans means that the rinsing and cleaning of sprayers is very important once again.
There have been numerous examples in recent years of serious crop damage caused by traces of products that survived a number of intervening tank fills.
Certain products used in broad-leaved crops tend to be particularly good at scouring minute traces of things like sulfonylurea herbicides from sprayer systems, resulting in crop damage.
PUs need to be aware of this responsibility to have sprayers thoroughly cleaned, especially contractors spraying a range of crops for different individuals.
To read the full Sprays Focus Supplement, click here