Application for an Emergency Authorisation for the 2021 season
On behalf of the Bracken Control Group, the application to permit the use of Asulam for bracken control for the 2021 season was submitted to the Chemicals Registration Division of HSE, on 30 October 2020.
It is likely that a response will be provided in late January or early February; this will depend on the timing of the meeting of the Expert Committee on Pesticides.
To provide background to the application, the BCG submitted Supporting information. The references below are to the Annexes to the application (see below).
Three key issues were highlighted (Annex D):
- Review of the 90m buffer zone introduced in 2020
- Review of the one-month exclusion period for livestock
- Maintenance of ground-based control options
The research programme is continuing to develop the evidence base to support the need for bracken control by all means, including chemical control with Asulam and/or other active ingredients (Annex C).
The areas treated with Asulam are reported in Annexes F and H.
Asulam Application Records
The information in Annex H records the reported use of Asulam during 2020. It is based on the information provided by the end-users using the reporting form.
There are some gaps in this, but the BCG is grateful for the effort taken by end-users to provide this information.
Being able to report the amount of Asulam used and where it was applied, is an increasingly important part of the application for further authorisations for use of Asulam.
The reporting arrangements this year will be reviewed with a view to Improving them.
Proposed dates for 2021
These dates are provisional. They will be confirmed if the application is approved:
17 May 21
Start of the Emergency Authorisation period of 120 days.
Storage, promotion, sales, and transfer authorised.
1 Jul 21
Application of Asulam can commence.
13 Sep 21
Expiry date: for sale & distribution and use of stocks.
Storage of stocks can continue, and stocks can be moved for disposal. Asulam cannot be applied after this date.
31 Oct 21
Expiry date: for storage and disposal of stocks.
It will be illegal to store Asulam after this date.
Asulam Product Labels
Two versions of the Product Label have been produced - one for aerial and one for ground-based application. They will be provided with the containers, but they are also available to download using the links.
These labels remain current, but may be revised for the 2021 season.
Emergency Authorisation Application - 2021 season
The application for an Emergency Authorisation for the 2021 bracken control season was submitted on 30 October 2020.
The full application consists of the following documents:
- Covering Letter
- Annex A - Background
- Annex B - The Bracken Control Group
- Annex C - Research Programme
- Annex D - Key Issues
- Annex E - Conservation Perspective
- Annex F - Areas Treated with Asulam
- Annex G - Data Requirements Summary
- Annex H - Asulam Application Records – Summary 2020
- Enclosure 1 - Update - Health and Conservation Information
- Enclosure 2 - UPL Europe Ltd Registration Position Paper
- Enclosure 3 - Form CRD9
- Enclosure 4 - Letter of Access
The documents with hyperlinks can be downloaded.
The Permit System - Guidance:
All aerial spraying must be carried out under a permit issued by the Chemicals Regulation Division (CRD) of HSE.
An Application Plan template must be completed that lists the jobs it is intended to carry out; CRD may need to consult conservation authorities as part of the permitting process.
There are different Application Plan templates for the different parts of the UK and the 2020 season details are available here; this briefing is based on the information provided by CRD. The latest version of the appropriate form should be used for applications.
Following the ending of the approval to use Asulam for bracken control on 31 December 2012, temporary, annual arrangements have been put in place to allow the use of Asulam for bracken control to continue. Approval has been subject to the terms set out in Emergency Authorisations granted by the Chemicals Regulation Division (CRD) of the Health & Safety Executive.
The continued availability of Asulam cannot be guaranteed, but the Bracken Control Group is working with all parts of the bracken control community to promote the value of Asulam for the control of this invasive species.
Asulam offers selective control of bracken and it has approval for aerial application. These characteristics are unique to Asulam, which makes its use for bracken control very important. Additional justification is submitted as part of the applications for an Emergency Authorisation, which can be viewed by following the link in the section above.
The support being provided by CRD, which is the relevant agency for the whole UK, is very gratefully acknowledged.
Medium Term Availability
If application of Asulam is to continue without a break, applications for Emergency Authorisations will need to be submitted by the Bracken Control Group, each year until registration of the product is achieved.
Long Term Availability
The owners of Asulam, UPL Europe Ltd (UPL), have applied for the re-registration of Asulam in the EU for bracken control. This is an expensive process and requires an investment of many £100,000s.
The re-registration process takes a long time and the latest indications are that we may not hear the outcome of the application until 2022.