Hopefully your chemical store is now empty and your pesticide records showing all purchases, PCS numbers and applications for 2011 are ready for inspection.
If you still have chemicals in stock, you will have to either use or dispose of them as it is unlikely that your supplier will accept returns at this stage.
In general, returns of unopened, full outer containers of product are only accepted in the year of supply. You should check the PCS website (www.pcs.agriculture.gov.ie) with your adviser or supplier to see if you are still permitted to use the chemicals in store.
Products whose registration has expired must be used before their use-by date or sent for disposal to an approved management company. A list of products for which registrations have expired in the past two years is on the site.
You will find that the registration for the dock control product Asulox expired on 31/12/2011 but that you may use it up to 31/12/2012. Product which will not be used within that period should be disposed of before the end of the period. The same deadlines apply to Fusilade Max and Panoctine.
With the exception of products withdrawn due to hazard, products may be sold for a period not exceeding six months from the date of expiry of registration and be used on farm for a further 12 months. Therefore, if you purchase a product whose registration has expired or is due to expire, you should manage it carefully so as to ensure that you use it properly and that you do not have to opt for disposal. Your supplier will not be in a position to take it back.
Designation of an area within your chemical store for expired products that are still within their use period may help to ensure that you do not forget to use product on time. Mark such products clearly with their use-by dates. You should also ask your supplier, when buying chemicals, to advise if use-by dates have been specified.
For the coming season and into the future, care should be taken when ordering chemicals to ensure that you only buy what you need. If you do buy surplus to your requirements, you should seek to make returns early so that products may be sold on to other customers. Try to avoid opening a large container and leaving some chemical in it if there is an option to buy a smaller container.
A system of stock rotation should be used to minimise storage time and avoid deterioration of products and their containers. A 'first in, first out' policy should be adopted. Recording the date of entry to the store and, if applicable, it's use-by date on the outward facing side of the containers is a useful technique to ensure good stock management.
Full details of the regulation on the registration, marketing and use of plant protection products within the EU may be found by typing 1107/2009 into the Google search bar.
Assuming that your chemical store is in order, the other item which may require attention is management of empty chemical containers. Disposal of used chemical containers must be managed in accordance with Good Plant Protection Practice (GPPP). It is GPPP to clean plant protection product containers using a triple rinse technique, unless otherwise specified on the label. Triple rinsing involves three sequential separate rinsings involving the following elements:
Fill the empty container 10-20pc full of water, replace the cap securely and shake the container vigorously.
Remove the cap, add the washings to the sprayer and let the container drain for 30 seconds or more.
Triple-rinsed containers should be punctured to prevent re-use. Triple rinsing of empty containers facilitates their safe disposal by an authorised contractor or municipal waste recycling system.
Patrick J Phelan is a member of the ITCA and may be contacted at firstname.lastname@example.org