How does the label information help me get the best from a crop protection product?
What’s the difference between an on-label and an EAMU authorisation?
Read the label. In our business we have to, because it’s a legal obligation to take ‘all reasonable precautions’ when using pesticides – and to do that, says Defra, you must ‘consider the product label as a whole’ before you begin using any plant protection product.
But there’s more to it even than that. Although all the most important information about the product and authorised crops must appear on the label, it’s not just the sticker on the pack: it also usually includes a sheet or leaflet that arrives with it. Understanding what to look for on this label gives you a head-start when it comes to getting the best from a product – after all, its information is a distillation of the research and trials needed for the product’s authorisation. The label, as much as what’s in the pack, also has to be officially approved before a product can be sold.
Search out a copy of the label before you get as far as buying a product you’ve not used before – we and most other manufacturers have them to download freely from our websites. It will tell you if you can use the product on your crop, whether it can be applied outdoors or only under protection, and whether it will control your particular weed, pest or disease problem or give the growth control effect you’re after.
Even if you’re familiar with a product, checking the label conditions relating to rates and the number of permitted applications will help when designing your IPM programme. A look-through the label before making each application will remind you about the protective equipment you need, mixing instructions, rates and volumes for the crop and situation, and the environmental precautions you need to take.
What’s on the label itself is usually the end of the story if, for example, you’re preparing to spray a cereal field.
But it’s a little more complicated in horticulture, and in ornamentals in particular.
On-label and off-label
Syngenta Ornamentals products, such as Switch or Dynamec, include on the label ‘ornamentals’, ‘ornamental crops’ or ‘ornamental plant production’ as authorised uses. That means during registration we have submitted experimental data as evidence for effectiveness and crop safety when used as directed on the label. As well as defining the legality of the application, it gives you important assurance about the product’s performance.
But, as we’ve discussed in earlier blogs, it’s not always possible to include ornamental crops in a product’s label recommendations – the diversity of species and cultivars involved, and the small areas grown, means it’s often uneconomic to generate the necessary supporting data from efficacy and crop safety trials.
Most countries’ registration systems recognise this, so have mechanisms that give growers access to some form of ‘off-label’ use for so-called ‘minor’ or ‘speciality’ crops – both to plug some of the crop protection gaps there might otherwise be and to try to provide enough different modes of action for resistance management.
An individual product may be authorised for a range of on-label crop uses as well as several EAMUs for crops not listed on the label.
For example, a range of arable and field vegetable crops as well as strawberry and lettuce are all listed on the label of Syngenta’s fungicide Amistar. But Amistar has also been granted, following applications made on behalf of growers, more than a dozen individually numbered EAMUs, each allowing its use on a specific type of speciality crop. There is one for ornamentals while others cover, for example, asparagus, celery and cucumber.
The EAMU system relies on the fact there’s already an authorised product, such as Amistar, for which all the environmental, wildlife and human safety data have been assessed. While some residues data will be required for an edible crop, and some additional operator safety data for certain ornamentals applications, EAMUs are granted without assessments for efficacy or crop safety. That takes out a lot of the cost involved in authorisations and is what helps bring you a wider range of potential treatments than you would otherwise have access to.
There are two key things to remember when using a product under an EAMU authorisation.
First, the EAMU notice contains instructions on, for example, crops covered, application rates and timing, that carry the same legal weight as the instructions on the product label. You need to think of it as an extension of – and read it alongside – the label itself.
Second, neither efficacy nor crop safety have been tested in order for the EAMU to be granted. So, while you can legally apply the product under its terms, it’s very much at your own risk commercially, and a condition of using the EAMU. If the application fails to kill a particular pest, or damages your crop, it’s your loss.
In practice that risk is largely mitigated by the fact that most EAMUs have resulted from a request by a grower association or AHDB, usually based on knowledge from their own trials, or from information about uses in other countries and, sometimes, advice from the product manufacturer. Even so, it’s a good idea to do your own tests on your own cultivars and under your own conditions before applying something for the first time under an EAMU to a commercial crop.
Next time we’ll look in more detail at how the label information for an ornamentals-specific product such as Switch relates to that in an EAMU for using a product such as Amistar on ornamentals – and how understanding both can help you choose the right one for the job.