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Application of the HardSPEC Assumptions from the Regulatory Risk Assessment on Non-Porous Hard Surfaces

Regulatory Update: 42 /2011

Issued: 17 November 2011

Introduction

This Regulatory Update introduces new labelling requirements on the method of application of herbicides authorised for use on non-porous hard surfaces to ensure that best practice is followed.

Background

There is evidence that some users apply herbicides to non-porous surfaces in a ‘blanket’ rather than targeted fashion, i.e. treating the whole road or paved area rather than a 30 cm swath and/or spot treatments outside the swath and the current label ‘directions for use’ do not provide appropriate instructions for application.

Implications

Applying pesticides in a ‘blanket’ fashion to non-porous hard surfaces gives rise to a number of issues:

  • Unnecessary and wasteful use of herbicide where it will have no impact. This is inconsistent with both long-standing government policy of minimising pesticide use and with the requirements in Directive 2009/128/EC (on the sustainable use of pesticides) that use in such areas be minimised.
  • There is a greater risk of run-off of product to urban drainage systems. This has the potential to increase predicted environmental concentration of active substance in water bodies and is inconsistent with the requirements in Directive 2009/128/EC that measures be taken to support the aims and objectives of, and compliance with the Water Framework Directive (WFD).

Action

Following consultation with the Crop Protection Association (CPA) and interested authorisation holders we are issuing a Notice of Authorisation amending the labels of herbicides authorised for use on ‘hard surfaces’*. Such products must include one of the following additional phrases in the directions for use’ (depending on the type of active substance) to better reflect the assumptions in our fate & behaviour assessment:

a) Products which act only by contact or systemic action via foliar application:

“Apply this product carefully. Ensure spraying takes place only when weeds are actively growing (normally March to October) and is confined only to visible weeds including those in the 30cm swath covering the kerb edge and road gulley – do not overspray drains”.

b) Products which act only in a residual fashion:

“Apply this product carefully. Ensure spraying takes place only to areas of potential weed growth (e.g. gaps between paving stones, kerb edges and road gulleys) and/or a 30cm swath covering the kerb edge and road gulley – do not overspray drains”.

c) Products which contain more than one active substance, at least one of which acts by foliar application and at least one of which acts in a residual fashion:

“Apply this product carefully. Ensure spraying takes place only when weeds are actively growing (normally March to October) and is confined only to visible weeds, areas of potential weed growth (e.g. gaps between paving stones, kerb edges and road gulleys) and/or a 30cm swath covering the kerb edge and road gulley – do not overspray drains”.

* These phrases are not applicable to products that are specifically authorised only for use on ‘hard surfaces (railway ballast)’.They are however applicable to all products authorised on ‘hard surfaces’ which may include ‘railway ballast’ in addition to non-porous surfaces such as roads and pavements. Such product labels may clarify that the statement is not applicable to the ‘railway ballast’ use.

The changes to relevant product labels will also apply to all future applications for authorisations. If any applicant or authorisation holder is unsure whether these conditions should apply to their products please contact CRD.

Timetable

Labels must be updated at their next reprint and at the latest by May 2012 although the use of temporary labels (“stickers”) may be used up to November 2012. To support this label information we will work with industry to develop an explanatory diagram on the method of application for inclusion with product information sheets.

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