Emergency Authorisation for the 2020 season
The Chemicals Regulation Division of the Health & Safety Executive has confirmed that an Emergency Authorisation (EA) for the use of Asulam for bracken control will be issued for the 2020 season.
There are two significant difference from previous EAs:
- The approval, applies to application from a helicopter only. Application from hand-held or ground-based equipment will not be authorised.
- For aerial spraying the required buffer zone against surface water bodies will be increased from 50m to 90m.
The implications of these changes, and the information/data that will need to be collected to support a further EA application, will be considered by the Bracken Control Group and further guidance will be provided.
Anyone planning to apply Asulam next season must read the terms and conditions contained in the draft EA Approval. The final version of the Approval will be issued before the start of the EA period. This final version must be checked before any Asulam is applied; the BCG will aim to highlight any changes from the draft on this website.
Key dates for 2020
From the draft EA Approval, the relevant dates for the 2020 season are:
18 May 20
Start of the Emergency Authorisation period of 120 days.
Storage, promotion, sales, and transfer authorised.
1 Jul 20
Application of Asulam can commence.
14 Sep 20
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 20
Expiry date: for storage and disposal of stocks.
It will be illegal to store Asulam after this date.
Asulam Product Label
To reflect the changes outlined in the draft EA approval, a revised Product Label to be issued with the Asulam containers, has been drafted. This may change further, but anyone applying Asulam next season must abide by the terms of the Label.
Emergency Authorisation Application - 2020 season
The application for an Emergency Authorisation for the bracken control season in 2020 was submitted on 26 July 2019.
The full application consists of the following documents:
- Covering Letter
- Annex A - The Bracken Control Group
- Annex B - BCG Sector Representatives
- Annex C - Supporting Information
- Enclosure 1 - Health and Conservation Information
- Enclosure 2 - UPL Europe Ltd Registration Position Paper
- Enclosure 3 - Form CRD9
- Enclosure 4 - Letter of Access
- Enclosure 5 - Draft Bracken Control Review
The documents with hyperlinks can be downloaded. Other documents are available on request.
The draft Bracken Control Review will be considered by the members of the Bracken Control Group before being circulated.
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.
The Permit System - Guidance:
Permit System - Guidance
All aerial spraying must be carried out under a permit issued by the Chemicals Regulation Division (CRD) of HSE.
CRD has issued guidance that is available to download from the CRD website. There is also some BCG guidance that aims to help applicants in the different parts of the UK understand what is required of them.
The Application Plan templates for applying asulam to bracken have been revised for 2019. The latest versions are available below:
The latest versions of the forms should be used for all applications.
Note that the table in Appendix A asks for the amount of product (Asulox) to be applied to be recorded in litres rather than kg. In all cases, the amount to record is the total amount to be applied for that job (rather than the rate of application).
The Permit System - 'Update' template
There is a separate procedure and form to complete to amend a previously approved Application Plan.
In cases where either the application of asulam failed to reduce the canopy cover to any noticeable degree or did not take place as planned in the previous year (and the template does only refer to the previous year), CRD will accept applications to update the associated permit.
This is only for jobs permitted in the previous year. Any permits issued two years ago (or earlier) will not be updated, and completely new applications will be required.