CIPC Stewardship

 

Background

CIPC stewardship in the UK was established in 2008 and industry compliance ensured continued availability of this critical sprout suppressant to growers and store managers through to the non-renewal of the authorisation in January 2020 and subsequent ‘use up’ in October 2020.  This was achieved through active involvement of key industry stakeholders in the Potato Industry CIPC Stewardship Group (PICSG) that developed and implemented research to resolve key issues to improve CIPC distribution and efficacy. An effective knowledge transfer programme was used to communicate best practice,  including this “Be CIPC Compliant” website and the introduction of standards (including BASIS, NPTC tests and Red Tractor protocols) raised industry competence to maintain availability for as long as possible. A programme of residue monitoring and reporting to demonstrate industry commitment and compliance to the regulatory authorities was also established. This integrated approach was crucial, and the principles have been adopted and developed by the Chemical Residues Division (CRD) of the Health & Safety Executive in their published guidance for new stewardship groups.  

 

Now CIPC has gone but contaminated stores remain, what happens next?

The EU decision for non-renewal of CIPC recognised that its previous use resulted in store contamination and that any crops subsequently held in those stores may be re-contaminated with CIPC which may pose a risk to consumers. Consequently, proposals for a temporary Maximum Residue Level (tMRL) that would address these concerns were developed and submitted to the Commission by European potato industry stakeholder groups (PVC), working in collaboration with the Authorisation Holders.  The authorisation of a tMRL by the EU is exceptional and the level set needed to provide assurance for consumer safety, whilst still enabling crops to be stored and marketed despite the potential for recontamination.  To ensure that the risk to consumers was minimised the Commission has also required the industry to undertake a programme of potato store cleaning.  A set of cleaning protocols have been developed by PVC (in collaboration with AHDB and Arvalis) and were implemented during 2020. 

Access the latest store cleaning best practice information here

There is a requirement to report on the extent and store success of cleaning as part of the EU tMRL review process and a similar process is expected in the UK post-EU.  To help establish the effectiveness of store cleaning, a second set of protocols for sampling and monitoring crops to establish levels of contamination have been developed but are not yet finalised. The first of these stakeholder reports is due at the end of December 2021 and the EU review will consider the potential to reduce the tMRL further, with the expectation that over time it will reduce to the LOQ.  It is likely that, whilst collaborative links with European countries will be maintained, any legal requirement for sampling and monitoring post-EU will be directed by CRD. Further details of how that may be implemented are awaited.

The tMRL for CIPC has now been established following a recommendation by SCoPAFF in September 2020. The level was confirmed at 0.4 mg/kg (8 October 2020) and is likely to come into effect in late summer 2021.  In the meantime, the existing MRL of 10 mg/kg will remain.  Parallel legislation in the UK currently mirrors the European position.

 

Why do we still need CIPC stewardship?

The Be CIPC Compliant programme of stewardship for the application of CIPC came to an end at the final ‘use- up’ date of 8 October 2020, after which the use of CIPC on crops became illegal.  However, there are still issues the industry will need to address, which the CIPC Stewardship Programme will continue to oversee:

  • Demonstrating compliance with the existing MRL of 10mg/kg (until the tMRL is introduced) and then demonstrating compliance with the tMRL at 0.4 mg/kg.
  • Continuation of store cleaning initiatives & development of best practice advice for store managers.
  • Demonstrating the effectiveness of store cleaning by monitoring crops from stores which have been previously treated and subsequently cleaned.
  • Reporting on store cleaning and reside monitoring.
  • Investigation of any exceedances to help identify and resolve issues. 
  • Levels of technical and political engagement with European collaborators (PVC).
  • Understanding and engagement with UK regulators (CRD & Defra) on legislation and their monitoring and reporting requirements (post-EU).