Accredited Seed Treatment Operation Standards Update. CSTA 93 rd Annual Meeting Vancouver, BC July 12, 2016
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1 Accredited Seed Treatment Operation Standards Update CSTA 93 rd Annual Meeting Vancouver, BC July 12, 2016
2 Overview Background Standards development Pre-audit process Standards update/refinement Path forward to implementation 2
3 Background Registrants receiving restrictions/limited registrations on seed treatment products due to EHS complexities associated with treatment activities PMRA seeking consistency when registering/evaluating seed treatment products (or default to lowest documentable activity) Seed treatment products are under significant pressure in respect to user stewardship practices Seed treatment stewardship is key item in other jurisdictions in North America and globally Seed treatment is currently a perceived gap in CLC members stewardship initiatives 3
4 Establishing Standards 4 In 2009 the CropLife Canada Board approved the formation of a committee to develop a set of commercial seed treatment standards. A multi-stakeholder committee was established to develop standards that are : practical, doable, implementable, meet the needs of regulators AND overall industry Committee members include: Developers (Syngenta, Bayer CS, BASF, Chemtura, DuPont) Retailers (Viterra, Richardsons, Agrium/CPS) Seed Industry (Cdn Seed Growers, Cdn Seed Inst, AB Coop Seed Treating Plants, Cdn Seed Trade Assoc) Government (PMRA, AB Envt) Statement of Purpose: To develop and implement improved stewardship practices in the storage and use of the pesticide industry s seed treatment products
5 Establishing Standards 5 Consistency with other CropLife Canada/industry led stewardship programs (including the chemical warehouse, NH3, Ammonia Nitrate and Bt corn programs). Seed treatment was a GAP Consistent with the plant science industry s commitment to support life-cycle product stewardship and risk mitigation activities Address and reduce (in some instances) EHS concerns by stakeholders Create a more predictable new product registration process for manufacturers > access to new technology Development and maintenance of a level playing field for all commercial seed treaters in Canada moving forward Work in collaboration with regulators versus being dictated as to what will be required.
6 Overview of the Standards Standards consisting of 80 audit protocols (68+ are related to existing regulations such as fire codes, building codes, labour codes, etc). The standards encompassed several existing best management practices and guidelines from PMRA, CSTA, CSGA and several CropLife Canada member company label use guidelines and best management practices Significant modification due to stakeholder feedback The standards encompass the storage of seed treatment product(s) and the seed treatment application process, but not the storage and transport of seed post treatment (see CFIA regulations that encompass seed post treatment) Standards will encompass indoor, exterior and mobile seed treatment operations 6
7 Overview of the Standards 7 A - Siting and Exterior Requirements 8 protocols (3 mandatory, 5 scored) B - Building Structure and Equipment 20 protocols (11 mandatory, 6 scored) C Operations 12 protocols (7 mandatory, 5 scored) D Training 10 protocols (9 mandatory, 1 scored) E Documentation 16 protocols (9 mandatory, 7 scored) F - Employee Knowledge 7 protocols (7 scored items) G - Emergency Response 7 protocols (1 mandatory, 6 scored)
8 Overview of the Standards Protocols are a combination of Mandatory and Scored items. Scored items must achieve 80% of available points for each section allowing the site flexibility in achieving accreditation. Existing provincial regulations will be taken into account and protocols where there are overlaps facilities will be granted equivalency Several documents will be circulated to the industry in support of the auditing process including standards manual, audit forms and implementation guide and supporting documents to aid in the documentation process All supporting and program related documentation will be posted on the AWSA website ( 8
9 Seed Code (2014/15 Pre-Audit) - Summary Pre-Audits: To encourage operations to gain a better understanding of the audit requirements sites were encouraged to complete a preaudit in 2014/2015. There are no penalties for sites that do not comply with the standards. There is no obligation to complete an audit prior to Each operation received an audit checklist indicating protocols/areas where they are currently in compliance/noncompliance with the standards. Operations that completed the pre-audit received grandfathering status on several structural protocols. 9
10 Seed Code (2014/15 Pre-Audit) - Summary Pre-Audit Summary: 483 sites completed a pre-audit nationally Regional breakdown: Market Segment: BC: 0 AWSA Certified: 197 (41%) AB: 113 (23%) Seed Grower: 234 (48%) SK: 85 (18%) Seed Cleaning Coop: 34 (7%) MB: 156 (32%) Seed Company: 18 (4%) ON: 85 (18%) PQ: 26 (5%) ATL: 18 (4%) 10 Note: Market segment: several sites may have fit into multiple segments. The primary business function took precedent when allocating industry segments.
11 Standards Update 11 Based on the pre-audit experience there were several protocols that needed to be re-evaluated: Additional clarity of protocol statements, audit notes. Feasibility/practicality of protocol requirement Ventilation Wall opening for augers/belts Seed cleaning processes Treaters with internal air removal Standards were updated and re-released in May 2016 No significant changes to the essence of the protocols. Mainly more audit clarity. Hard copies sent to all sites that completed a pre-audit. Additional copies available upon request. Summary of changes and updated Code online at
12 Path Forward 12 Auditor training/re-fresh completed in May/June. 28 auditors available to audit facilities nationally. Available to site to schedule full audits now. Aim to have the program implemented by Jan Working with CropLife Canada members and stakeholders to ensure consistency and a level playing field in the commercial seed treatment sector in a precompetitive environment Clear articulation and delineation of seed treatment technologies that fit into the scope of the standards (i.e. commercial seed treatment operations) Ensure facilities are adequately supported Ability for all stakeholder to participate in the oversight of the program
13 Path Forward This process has been somewhat challenging (we are asking for change) Aimed to ensure that all stakeholder opinions and positions were heard and taken into consideration throughout the process Wide range of commercial seed treatment operations in Canada Ensure there is flexibility, but with the aim of meeting benchmarks The standards allow the entire industry to take a common approach to environmental, health and safety practices for commercial seed treatment operations Work in collaboration as stakeholders for the betterment of the industry 13
14 Questions Russel Hurst CropLife Canada x
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