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Roundup, statutory use and cross compliance
Failure to follow Cross Compliance rules can lead to the Rural Payments Agency,(RPA) deducting penalties and reducing payment of Single Farm Payment, (SFP) monies from the EU to growers.

Two Statutory Management Requirements, (SMR) rules apply to the use of Plant Protection Products, (PPP). SMR9 encompasses legal obligations which were already in place under pesticide legislation whereby all PPPs must be approved by Chemicals regualtion Directorate,(CRD) and used in accordance with any requirements or conditions on the approval or labels or Extensions of use.

In 2010 26 farms had deductions of 3-15% of their SFP after RPA inspections found failures in compliance with SMR9. Records of PPP use must also be kept to comply with SMR11 where there were 22 failures reported in 2010.

Further obligations for where & when Roundup products can be sprayed also fall under Good Agricultural and Environmental Conditions, (GAEC) cross compliance measures. Care should be taken to follow the rules in GAEC2, GAEC11, GAEC12 & GAEC14. In 2010 the RPA reported a further 82 failures from these GAECs.

With nearly 200 approved glyphosate products for use in agriculture and increasing scrutiny of statutory conditions on pesticide labels under SMR9, this technical note highlights some of the differences between Roundup and other glyphosate formulations with regard to legal use.

 

Glyphosate differences under SMR9

1) Perennial weed rates in stubbles

Monsanto formulations have a maximum use for perennials of 1800 g ai/ha whereas most other glyphosates have only 1440g/ha. Historically this lower rate was sufficient for the control of the main problems of Common Couch and volunteer potatoes in the stubbles, but with increasing populations of perennial broad-leaved weeds- especially ahead of sugar beet and potatoes, Monsanto recognised the need to increase the maximum rate. The rate was increased at re-registration in 2006 for most Roundup products. This allows legal use of the higer rate needed to control weeds like Creeping Thistle, Sow Thistle, Mugwort, Rosebay Willowherb etc which originally developed from set-aside. It avoids the consequences of Crop Assurance Schemes, RPA inspectors or British Sugar finding rates in excess of the statutory maximum have been used in stubbles prior to the spring crops and applying penalties.

2) Multiple applications to stubble- autumn or autumn followed by spring

With increasing problems of resistant annual grasses and fewer in-crop chemical choices, the emphasis on out-of-crop reduction in weed populations is greater than ever. For Black-grass, Wild oats, volunteer cereals, Barren Brome and Meadow grasses the practice of cultivation and consolidation immediately after combining gives optimum germination of weeds, allowing removal with low rates of glyphosate. Two or even three flushes can be sprayed this way in the autumn, providing there is enough moisture in the soil. Monsanto brands have the advantage of allowing this under the Statutory Use Conditions, but many others are limited to just one application to stubbles.

The move to a Maximum Total Dose rather than Maximum Number of Applications, allows for a splitting of the perennial rate. Two applications of 0.75kg/ha R.Max, 2.6 applications with R.Ace/Klik/Energy are covered for annuals, but other Monsanto labels have a Maximum total dose of just the annual rate. However, by splitting the perennial rate for example 3 applications at the annual weed rate are possible with Roundup Biactive because 5l/ha is allowed in total.

I.e. Monsanto glyphosate products can always be used legally more than once on the same stubble situation, either in the autumn or in the autumn and then again in the spring prior to spring cultivations and planting. Other glyphosate products, where only one application is allowed per situation are precluded from splitting the perennial rate to achieve this.

3) Cultivation intervals

With pressures on to start drilling asap, the cultivation interval allowed is also under scrutiny and it pays to choose formulations where cultivations are allowed after just 6 hours like Roundup Max or 24 hours with other Monsanto brands. In contrast some glyphosate products have a 5, 7 or even 14 day drilling interval.

4) Post-plant, pre-emergence

 

Not all glyphosate formulations have approval for use post-planting, pre-emergence of listed crops. Listed crops include asparagus, cereals, oilseed rape, beans, peas, potatoes, mustard, linseed, sugar beet, swedes, turnips, bulb onions and leeks. No other brands can be used PPPE of potatoes.

5) Specific Off-Label Approvals

Many Specific Off-Label approvals, (SOLA) are available for Monsanto Roundup products such as inter-row use in some root vegetables, bush & tree fruit & nuts and pre-harvest of bird seed, poppies, lupins, Rye as well as Energy crops, game cover and farm forestry. SOLAs are specific to one product and cannot be used by farmers to apply to other crops or with other products.

6) Tank mixing

Monsanto brands can be used in many tank mixes with residual herbicides in rape, beans potatoes and cereals to save a vital pass. These have been fully tested with up to date lists held on the Monsanto website and referenced from the labels. Some glyphosate product labels actually prohibit tank mixing-meaning any tank mixes even at the growers risk constitute an immediate failure under SMR9.

7) Adjuvants

Additional adjuvants are label requirements for most ETA products at low annual weed rates (720g/ha or less). Adjuvants used must be on the CRD Adjuvant list and must be used only on crops at rates as listed on the Adjuvant list. Many cannot be used with full rate partner pesticides for pre-harvest use, so should be chosen with care.