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There is often confusion when it comes to reading and interpreting pesticide labels. This guide will hopefully clear up any confusion with regard to the reading and interpreting of labels.
A few important notes:
– A label MUST have a registration number on it (e.g. an L-number).
– All labels must also be GHS compliant (as per SOP example).When trying to determine if a product is applicable for your intended use, you need to read the WHOLE label. The “declaration regarding formulation and use” on the front page of the label is often insufficient.
The TIPWG APL stipulates if a product is suitable for:
1. Compartment
2. Conservation
3. Firebreak prep,
4. Nursery
5. Industrial.Under the “Compartments” column “X” denotes use in all compartments, regardless of species; a “E” denotes use in Eucalyptus species only; a “P” denotes use in Pine compartments only and a “W” denotes use in Wattle compartments only.
For some products, aerial application is mentioned in the TIPWG APL “Comments” column. Where there is no information in the “Comments” column regarding aerial application, you will need to refer to the label to determine if aerial application is permitted. Even if it is mentioned in the “Comments” column still refer to the label for individual specifications. Care must be taken to read and understand the label fully as a product may be registered for aerial application with one crop but not another.
The tables at the end of the label which refers to crop, pest, dosage and remarks will be your guidance as to what application rates and methods are legally registered for the crop / pest combination.
To download the Global Harmonised System Label SOP, click here
- When a new pesticide has been legally approved for use in South Africa, it must go through a TIPWG approval process to be added on the TIPWG Approved Pesticide List. TIPWG members may request for new products to be added to the APL. Members must ensure that:
- New products to be added are needed by the industry;
- All documentation is in order;
- Quick reference check is done of the Forest Stewardship Council (FSC) Highly Hazardous (HH) list to ensure the active ingredients aren’t listed
A TIPWG review is done by an independent expert who carefully reviews the three documents below. These would be submitted by the company applying for pesticide registration.The electronic labelThe electronic label confirms that the pesticide has been legally registered for use in South Africa and complies with Fertiliser, Farm Feeds, Agricultural Remedies & Stock Remedies (Act No. 36 of 1947).
The Safety Data Sheet (SDS)This contains all the relevant environmental, health and safety information along with the key chemical information, including:
1) Information to identify the: substance/mixture; company (including emergency telephone numbers)
2) Hazard identification
3) Information about and composition of the ingredients
4) First aid measures
5) Firefighting measures
6) Accidental release measures
7) Handling and storage
8) Exposure control / personal protection
9) Physical and chemical properties
10) Stability and reactivity
11) Toxicological information
12) Ecological information
13) Disposal considerations
14) Transport information
15) Regulatory information
16) Other information
The Certificate of Analysis (CoA)To acquire a CoA for a new pesticide the manufacturer has to submit the following:
- Full details on the manufacturing process;
- The identity and purity of all Technical Grade Active Ingredients (TGAI);
- The identity and quantities of its impurities. This is specified in the “Guidelines on Equivalence of Agricultural Remedies (pesticide)” issued by the Registrar, Act No. 36 of 1947.
The above information needs to be substantiated by an analytical report on 5 different production batches of the TGAI.
This report needs to be done by either:
- An ISO 17025 accredited laboratory a certified Global Laboratory Practices (GLP) compliant laboratory
The TGAI must conform to internationally recognised specifications or standards.
If the results of the 5-batch analysis are inconclusive, a test for mutagenicity (Ames test) done by a laboratory complying with the Organisation for Economic Cooperation and Development (OECD) principles on GLP will be required. In cases where the active ingredient does not have a known minimum percentage purity, a CoA from an ISO 17025 or GLP accredited laboratory will be accepted in place of the 5-batch analysis.
Choosing a TIPWG expertTIPWG has the authority to determine who qualifies as an expert.
Generally, it is considered to be:
- Someone who is unbiased, and has extensive knowledge and understanding in the field of chemicals and/or pesticides;
- Someone who has an understanding of the forestry industry and the various certification schemes;
- Someone who is recognised as a leader in their field.
The TIPWG expert will then check to ensure the pesticide complies with the following:
Compliance with Fertiliser, Farm Feeds, Agricultural Remedies and & Stock Remedies Act No. 36 of 1947
This involves double checking that the pesticide is registered in South Africa for forestry applications and is done by searching for the pesticide on the following website:
- agri-intel.com has all the information about registered pesticides along with their labels.
When it comes to the label, every section is checked for compliance with Act No. 36 of 1947 and the label is then scrutinised to ensure the correct information (i.e. dosages etc.) is presented. Aside being GHS compliant, all information presented on the SDS must also conform to the regulations of Act No. 36 of 1947 and the technical information needs to be double checked to ensure everything is correct.
Quality check list for the CoA
The first step is to check the credentials of the laboratory used and the authenticity of the analytical report. This needs to be done as occasionally fraudulent copies are submitted. If the product specifications are in doubt, a container is bought and the quality of the active ingredients is tested, along with the quantities of any impurities. This is very important as these impurities could be banned ‘highly hazardous pesticides’.
The FSC filter
The FSC published their latest FSC Pesticide Policy (FSC-POL-30-001 V3-0 EN) in May 2019. This Policy lays out FSC’s position for managing the use of chemical pesticides in FSC-certified management units in consistency with Criterion 10.7 of FSC-STD-01-001 V5-2 FSC Principles and Criteria, which requires, inter alia, the use of integrated pest
management.FSC identifies HHPs according to the internationally recognized hazard criteria. The criteria, indicators and thresholds are listed in the policy. FSC also classifies HHPs into three categories based on prioritized hazard groups and criteria, as follows:
- FSC prohibited HHPs
- FSC highly restricted HHPs:
- FSC restricted HHPs
The SAFAS filter
All new products have to pass the Sustainable African Forestry Assurance Scheme Filter, the components of which are outlined in SAFAS 4:2018 Issue One (2018-05-22) Forest Management Standard Outlines the Requirement for Pesticide Use. SAFAS identifies four requirements a pesticide must fulfil to be available for use in a SAFAS certified forest:
- Compliance with the Fertiliser, Farm Feeds, Agricultural Remedies and Stock Remedies Act (No36 of 1947)
- NOT be listed by the World Heath Organisation as a Type 1A or Type 1B pesticide
- NOT contain Chlorinated Hydrocarbons whose derivatives remain biologically active and accumulate in the food chain beyond their intended use
- NOT be banned under the Stockholm Convention on Persistent Organic Pollutants 2001 – as amended
NOTE: First and final bullet are already addressed by the APL process as mandatory TIPWG requirements.
Why do it? – The benefit of having the TIPWG approved pesticide listForest protection strategies used in South African plantations include the use of pesticides where appropriate and necessary. The TIPWG approved pesticides list is a single handy reference that indicates those options that are effective when used correctly; are legally registered for the specific use; and are approved for use by FSC and SAFAS.
In addition to the active ingredient, all other constituents of a pesticide formulation as per label and SDS, are screened for compliance by appropriate experts. Forestry South Africa through TIPWG maintains this list with input from researchers, experts in the field, and agricultural pesticide suppliers to ensure compliance.
Furthermore, FSA members can access a version of the TIPWG APL with ESRA mitigations included. This is available from the Members Section of the TIPWG website. The ESRA mitigations can then be adapted and adopted by FSA members into their own management plans.
click here to download SOP APL infographic as a .PDF
click here to download the FSC Filter SOP, click here
- Re-established vs established compartments
Re-established – Zero to one year for Eucalyptus and wattle, or zero to three years for pine.
- Weeds should be controlled before and after felling. This ensures that pre-planting weeding operations are effective and productive.
Established– one year and onwards for Eucalyptus and wattle and four years and onwards for pine
- For the most part, there is little to no need for weed control within pulpwood rotation compartments once you have canopy closure – except in the case of alien invasive species (AIS).
- Compartments on a sawlog rotation will need to be re-assessed for weed control after each thinning operation due to canopy exposure.
Pre-planting vs post-planting herbicide applicationsPre-plant applications
- A total cover spray before planting is essential to ensure that the area is weed-free for as long as possible, giving young trees more time to establish themselves before riskier, and costly weed control/management operations have to be used.
- Timing and quality of the operation is critical to ensure effectiveness.
Post-plant applications
- The focus is to eradicate all competing weeds within ~25cm around the tree for the initial zero to one/zero to three-year period with a focus on the AIS. Inter-row weeding should then not be more than 25%, specifically targeting weeds that have reached a height of 50cm as these compete for nutrients and water.
AgeEucalyptus and wattle compartments under 12 months and pine compartments under three years are more susceptible to weeds and therefore need to be prioritised.
Research shows that the removal of weeds, thus competition for resources, has significant benefits:
- Eucalyptus trees kept free from weed competition have a substantially higher yield.
- Pine trees have an improved survival if kept weed-free for the first three months. Weeding thereafter has no significant growth benefit but does have advantages such as reduced fire fuel loads and airflow in frost-prone areas.
Monitoring - weed spectrumThe weed spectrum present will dictate the control methods used. As a result the following weed characteristics should be identified:
- The presence of broadleaf weeds or grasses and the ratio of each.
- Whether the weed species are annual or perennials and the ratio of each.
- Life cycle – the aim is to eliminate weeds, not wound them. This means knowing their life cycle and targeting the growth stage where they are most susceptible to pesticide control measures. This minimises the amount of herbicide required and improves the productivity of the application method.
- Presence of AIS.
- Presence of invasive indigenous species.
- When conducting spraying operations, weeds should be targeted as young as possible, whilst at the same time, ensuring that there is an adequate weed flush, and in some cases, sufficient leaf material to absorb the herbicide.
Monitoring - thresholdsThreshold levels identify when weed control becomes cost effective and necessary. Threshold levels are dependent on numerous factors, and can therefore differ for the same species of weed between compartments as well as land-use types. It is important to know the threshold level for each species and compartment.
Factors impacting threshold level:
Age of tree species planted threshold levels will be lower for younger trees as they are more susceptible to weed competition.
Species of tree and end use – Pines are susceptible to competition from weeds for a longer period than Eucalyptus and wattle, so will have longer and lower threshold levels. It should be noted that weed susceptibility also varies between different genera and hybrids. Knowledge of the trees’ response to weed competition is crucial.
Species of weed(s) – Physical and behavioural characteristics of individual weed species will dictate the threat level they pose, thus where the threshold levels are set.- The presence of certain species identified as posing specific threats to trees, or biodiversity in general, should alone be enough to initiate control measures.
- Other species will be tolerated at low levels, but once they reach a certain point, control measures must be initiated. Continual monitoring will be required if their presence is noted.
Damage incurred – The type of damage incurred to the tree, or natural ecosystem, will dictate where threshold levels are set and the extent of control necessary.
Cost of control product can also be an inhibiting factor and should always be considered and weighed against the potential cost of damage incurred without weed control.
Cost of application method – There are significant differences in the financial and time costs of different application methods. These need to be considered when determining threshold levels, as well as the costs of additional monitoring, if weeds are left untreated.Control methods availableThere are several different weed control methods available. These include cultural controls, biological controls and herbicide controls. In accordance with good agricultural practices and the sustainable Integrated Pest Management (IPM) philosophies applied by the South African forestry industry, cultural and biological methods should first be considered. If these methods found to be non-viable, then herbicide control can be implemented as a last resort. Selection of appropriate methods of control shall be based on the following criteria:
- Species to be controlled
- Size of target plants
- Density of stand
- Accessibility of terrain
- Environmental safety
- Presence of desirable vegetation
- Presence of obstructive vegetation. (conservation areas)
- Cost of application
Some considerations when selecting the type of herbicide control measures include:
- Ensure it is on the TIPWG approved pesticide list. These are SA government registered and approved (sometimes with conditions for use) by the Forest Stewardship Council® (FSC®). Refer to TIPWG APL.
- Correct handling and use. Refer to SOP: Handling and Application.
- Correct storage and transport. Refer to SOP: Storage and Transport.
- When using selective herbicides, this often requires planning and budgeting for potential and additional operations.
Application methods available to control weedsIn forestry, there are two primary weed control application methods: knapsack sprayer (refer to SOP knapsack) and tractor with spray cart (refer to SOP mechanical sprayer). Each has benefits and limitations. It is important to know these before selecting the method.
RestrictionsThere are numerous abiotic and biotic factors that will place restrictions on when, how and what you use to control weeds. These include:
Weather conditions – temperature, rain and wind are the big three weather factors when scheduling herbicide applications. These can, to an extent, be managed – doing early and late sprays during hot seasons to avoid spraying during high heat, or using long-term weather forecasts. However, weather can change, so scheduling (and schedulers) should be adaptable.
Compartment size – size, terrain and accessibility are all going to dictate the controls available.
Areas along the boundary of the farm and/or on the outskirts of the compartment are where any pesticide application has the greatest potential for impacting neighbouring land-uses. This needs to be considered when scheduling and applying weed control measures.
Compartment location, in particular if it is adjacent to:- Conservation areas
- Water bodies
- Neighbouring communities
- Neighbouring agriculture
Time to harvest – each herbicide has a withholding period clearly marked on the label – ensure these are followed when scheduling.
Certification restrictions – ensure only TIPWG APL herbicides are used, and conform to any condition/pre-requisites stated is essential.
Tracer-belt preparation – refer to company policies and procedures.
Fire break preparation – this will depend on the fire season (summer time in the Cape, winter for all other areas) Refer to the National Veld and Forest Fire Act No.101 of 1998
Conservation area ecosystem restrictions – for example, the removal of weeds from waterbodies will carry specific stringent restrictions Refer to FSA Environmental Guidelines.- Grassland
- Fynbos
- Indigenous forests and woodlands
- Wetlands and riverine areas
Special management zones (SMZs) – refer to individual company policies.
Other areas – where weeds could become established and act as a source population for contamination.- Nurseries
- Staff accommodation
- Offices
- Workshops
- Road verges
- Quarries
click here to download SOP Scheduling infographic as a .PDF
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click here to download SOP Introducing the APL infographic
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click here to download SOP Safety Signs infographic
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click here to download SANS Handling Storage and Disposal of Pesticides infographic
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click here to download SANS Farmer Version – Handling, storage and disposal of pesticides infographic