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Application for an Emergency Authorisation for the 2022 season

Emergency Authorisation Application 

On behalf of the Bracken Control Group, the application to permit the use of Asulam for bracken control for the 2022 season was submitted to the Chemicals Registration Division of HSE, on 31 October 2021.  

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.  Of particular note is the report from the Drift Trials,  which supports the need for a review proposed in the first key issue below (Annex C). 

In addition to the three key issues submitted for the 2021 application (1-3 below), two additional issues were included for consideration (more detail in Annex D):

  1. Review of the 90m buffer zone introduced in 2020.
  2. Consideration of management options to address the one-month exclusion period for livestock.
  3. Maintenance of ground-based control options.
  4. Longer duration for an Emergency Authorisation approval.
  5. Possible adoption of an Integrated Pest Management (IPM) approach to choosing the best control option.

Emergency Authorisation 2022 Application Documents

The application documents are listed here and the main ones of interest with hyperlinks can be downloaded.

  • Covering Letter, including:
    • Annex A - The Bracken Control Group
    • Annex B - Sector Representatives 
  • Annex C - Research Programme
  • Annex D - Key Issues
  • Annex E - Conservation Perspective
  • Annex F - Five Tests of a Valid Application
  • Annex G - Data Requirements Summary
  • Annex H - Areas Treated with Asulam
    • Appendix 1 - Application Records Charts 
    • Appendix 2 - Application Record Form 
  • Enclosure 1 - Update - Health and Conservation
  • Enclosure 2 - UPL Europe Ltd Registration Position Paper
  • Enclosure 3 - Form CRD9
  • Enclosure 4 - Letter of Access

The other documents are available by request.

Provisional Dates for 2022

16 May 22 Storage, promotion, sales, and transfer authorised.
1 Jul 22 Application of Asulam can commence.
12 Sep 22 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 22 Expiry date: for  storage and disposal of stocks. It will be illegal to store Asulam after this date.

 

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 2021 season details are available from the HSE website.

Asulam Registration

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 authorisation holders for the active ingredient asulam, UPL Europe Ltd (UPL), who are also the owners of the product Asulox, started the EU application process for the re-registration of asulam for bracken control, in 2013.  This is an expensive process and requires an investment of many £100,000s.

The re-registration process takes a long time and for the GB, this must now be considered under national, not EU regulations.  

The latest indications are that we may not hear the outcome of the application for a further 2-5 years.