Plant Protection Products - A time of change!
With a time of 9.58 seconds, Usain Bolt holds the record for the fastest ever 100 metres. The speed of change in the amenity sector relating to Plant Protection Products (PPPs) hasn't quite been at that record setting pace, but there are a good number of individuals who either apply chemicals, or are involved in the supply chain, who wouldn't contest that the pace of recent change in this sector is somewhat 'Bolt' like. Maxwell Amenity's Dan Hughes reflects on a time of change for PPPs.
An unprecedented wave of product withdrawals and amendments impacting herbicide, fungicide and insecticide control options has forced us to consider and evolve cultural and chemical practices. What is sure is that off the shelf replacements, in the vast majority of cases, are not available.
The bad news for some is that the rate of pace of withdrawals shows no sign of changing and, as an industry, we are rapidly adapting practices with new and innovative approaches to problems.
- the establishment of National Action Plans; compulsory testing of application equipment
- provision of training for, and arrangements for the certification of, operators, advisors and distributors
- a ban (subject to limited exceptions) on aerial spraying
- provisions to protect water, public spaces and conservation areas
- the minimisation of risks from handling, storage and disposal
- promotion of low input regimes, including Integrated Pest Management (IPM)
Operator and public risk exposure to hazardous and toxic substances and maximum residue levels (MRLs) are often talked about as the primary drivers for withdrawal, but a pesticide product can be taken off for a number of reasons. The HSE list the following reasons to why a chemical may get withdrawn:
1. When active substances are included or renewed on the approved list (Regulation (EU) No 540/2011) but are not successfully re-registered
2. The active substance(s) contained in the product are withdrawn from/not renewed on the list of approved active substances included in Regulation (EU) No 540/2011
3. Significant safety or efficacy concerns with the product or a specific use
4. A requirement for the submission of data to continue with the authorisation of the product or a specific use is not met
5. Data submitted in support of an application does not support the continuing authorisation of the product or a specific use
6. A product or a specific use is commercially withdrawn
7. For products not authorised/permitted to uniform principles at the final commission deadline for re-registration of all active substances in the product
8. False or misleading information was submitted to support an authorisation/permit
Manufacturers have detailed knowledge of their products and liaise extensively with CRD regarding re-approvals. To the public, it may be perceived that the chemical company has simply not bothered to resubmit a renewal application, (this is only the case when the product has no commercial case for resubmission).
It is almost always a health risk, excess residue levels in water, or examples of negative impact on sensitive bio-organisms that, with close liaison with the Chemicals Regulation Division (CRD), indicates to the authorisation holder that there is no or a very little chance that going through the financial and time investment of resubmission would result in a product re-approval being granted.
In extreme cases, such as the withdrawal of chlorpyrifos, it is likely the manufacturer acted on known risk, or as a result of an identified problem, took an ethical and/or responsible decision after close liaison with CRD.
Alternatively, use a BASIS qualified amenity advisor to ascertain dates, or ask questions you may have about chemical revocation.
Changes occurring
The amenity market faces significant challenges in the immediate future. A wide number of active ingredients are under scrutiny or have impending withdrawals. This will change the way we have to prepare and strategise for problems going forward.
Perhaps the biggest insight into the future has been provided with recent changes to insecticide PPPs. Just over two years ago, end users had imidacloprid (Merit Turf) and chlopyrifos, two relatively cost effective solutions for the control of leatherjackets and chafer grubs.
Whilst imidacloprid withdrawal was, to many, predictable and appeared to follow standard protocol and lead times, chlorpyrifos was subject to an 'immediate withdrawal notice' giving end users and distributors little over three months to apply product or dispose of stock.
Whilst the above changes apply only to insecticides, similarities exist, at present, with widely used fungicide and herbicide active ingredients.
At the time of going to print, a scheduled EU vote in July will determine the withdrawal period for the go to contact active ingredient of iprodione and it is anticipated that, at the latest, products containing this will only be available to purchase until sometime in spring 2018; however, this could be accelerated. The withdrawal of the widely used fungicidal 'aspirin for the headache of disease' poses turf managers with significant changes to turf management practices and, ultimately, this will have to be effectively combatted by a better understanding of soil and plant health and factors that can increase the likelihood of plant disease.
Action on co-formulants within products is also having implications. This year, scrutiny on THFA (tetrahydrofurfuryl alcohol) has forced changes to growth regulator, including the widely used Primo Maxx, which had to be reformulated and recently launched as Primo Maxx II. The action taken on this ingredient will likely impact a number of other herbicide and fungicide products, causing manufacturers and authorisation holders significant dilemmas on the viability of investment for product re-authorisation.
Herbicides have also been subject to legislative changes with attention on the 'phenoxy group' of active ingredients. This has forced products and brands from this group of herbicides to be removed or relaunched with less active ingredients and reduced approved application rates on the label.
Revised application rates on products containing the phenoxy group has led to some questioning the efficacy of products against difficult to tackle and resistant weeds. There has been wider use of newer generation active ingredients; the impact to turf managers here being primarily cost, where the £ per ha is more expensive.
Determining solutions and best practice
With greenkeeping and grounds management practices and products rapidly evolving, perhaps this year, through articles, social media and education, we are seeing much more attention paid to organisms, eco-systems and habitat management.
This ultimately links to a concept that has been widely talked about for years, but now, with the forced change, is being more widely adopted by turf managers; Integrated Pest Management (IPM).
Defined by the University of California as "an ecosystem-based strategy that focuses on long-term prevention of pests or their damage through a combination of techniques such as biological control, habitat manipulation, modification of cultural practices, and use of resistant varieties. Pesticides are used only after monitoring indicates they are needed according to established guidelines, and treatments are made with the goal of removing only the target organism. Pest control materials are selected and applied in a manner that minimises risks to human health, beneficial and non-target organisms, and the environment."
Knowledge is fundamental to the success of an IPM approach; for many, this is a better understanding of the problems they face. Using chafer grubs as an example, first determining what species of chafer is causing you the problem, followed by researching the life cycle of that particular species, is extremely valuable knowledge.
Applying a scientific approach to assessing and determining areas most subject to damage, or the risk of damage, is vital. If tees are particularly subject to damage, will changing grass species, from an all fescue to a rye mix, thicken the sward and create a turf environment where it is more challenging for the beetle to access the soil to lay eggs and help prevent infestation?
In this case bats, which consume flying beetles, and starlings, with their thin long beaks to minimise surface disruption, would likely be the two primary species of choice for a turf manager to encourage.
Recent articles by Edward Ainsworth, Course Manager at Avro Golf Club, have highlighted how understanding the habitat requirements for bats and birds can improve the successful installation of boxes and encourage positive populations of bats and starlings.
When control is needed, understanding the pest's life cycle is paramount to success and can help determine solutions. Pheremone traps for chafer grubs are evident throughout a number of courses, with course managers in some cases trapping 'thousands of flying beetles' over the last few months.
Planning and budgeting for biological solutions is essential - in this case nematodes. For our business, adopting biological controls to our product range and contracts operations has given us over five years of knowledge and understanding on application best practice and optimum conditions.
Surely, soon, we will see economies of scale benefit with pack sizes and prices more suited to large scale application requirements.
Where plant disease is concerned, plant and soil health is the turf manager's primary focus. Knowing what nutrients are available in the soil and to the plant is key, and then ensuring that you fully understand any product's inputs (by checking the product label) is vital. Tackling nutritional deficiency and providing a balanced approach is helping to combat the risk of disease, and this is becoming more evident with a 'bio-rationale' approach to plant and soil health being adopted by many.
Herbicides still constitute an essential part of the turf manager's armoury and perhaps are the least under threat of the three pesticide bands (insecticide, fungicide, herbicide). As scrutiny from legislative bodies increases, and we see more frequent amendments to application rates and more withdrawals of products which have not completed their expected life cycle from when approval was issued, the challenge is to attain efficacy and meet financial budget aspirations for control.
As chemical companies feel the impact of legislation, it is likely their strategy will be to try to limit the risk of withdrawal, i.e. if a product has three active ingredients and a number of co-formulants, it is far more likely to get withdrawn for one of the reasons outlined above, than a product containing just a single one of the three active ingredients and less co-formulants. The challenge for industry and end users will be to maximise efficacy and control through responsible and safe tank mixing procedures and applications.
The changes will require more research, wider end user knowledge - and the industry, as a whole, has a challenge and obligation to provide this. Effectively sharing best IPM practice, networking and providing quality education on all matters will be integral to the speed of successful adaptation and evolution of the amenity sector.
Dan Hughes is Sales & Marketing Director at Maxwell Amenity Ltd.
You can read James Grundy's article on chafer grub and leatherjacket control HERE