Application for an Emergency Authorisation for the 2021 season
Emergency Authorisation Approval
The EA approval was issued on 10th June and it is available to download (this links to a version dated 11th June, which was revised to allow Asulam to be sold in 1000 litre containers).
Anyone planning to apply Asulam products for bracken control this year must study this approval document carefully.
- Aerial application is approved subject to a 90m wide no-spray buffer zone against surface water bodies.
- Ground-based application is authorised but restricted to conservation areas only, and the use in these areas must be under the direction of the relevant conservation body. See the full details in the Authorisation document.
Livestock must be removed from areas to be treated and must not be allowed to return until at least 1 month after treatment.
A copy of the revised Product Label will be added when it has been finalised.
Dates for 2021
10 Jun 21
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 Application Records
The EA approval document contains data and information requirements that must be submitted to the regulator, the Chemical Regulations Division of the HSE.
UPL will be distributing some information with the product, and a form which can be completed by hand and returned by post or by e-mail. Two other versions of the form are available:
- Using the online form.
- This is likely to be easiest way to provide the information.
- As this form loads information straight into a spreadsheet, it is preferred way to provide the information.
- A Word version that can be completed on a PC / Mac computer (but not on a tablet) and returned as an e-mail attachment to firstname.lastname@example.org.
The support of everyone who applies Asulam to provide this information is essential; the provision of this information to CRD is a prerequisite to securing the future use of Asulam for bracken control.
Emergency Authorisation Application
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.
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.
Emergency Authorisation 2021 Application Documents
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 and is being updated for the 2021 season. 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.