Q: What do operations have to do to make sure that agricultural chemical residues on their product do not exceed the Maximum Residue Limits (MRLs) for product exported outside of Canada? What proof does the auditor need to see that foreign MRLs are being respected?
A: For an operation involved in production:
The auditee is expected to ask his or her immediate buyer (e.g., packer, shipper, wholesaler, broker, etc.) if the product will be sold outside of Canada. The buyer will know if there are foreign customers, and can provide information to the auditee about agricultural chemical specifications. The auditee needs to know before spraying, if there are agricultural chemicals that shouldn’t be used or if the label directions are appropriate.
Asking the questions may prompt the buyer(s) to make some inquiries of their own, and get back to the operation with more information. If this information is not available, there is nothing more that the auditee can do. He has done his due diligence and tried to get as much information as possible before the application of the agricultural chemicals.
The CanadaGAP auditor will want to know if the auditee has had this conversation with his buyer. The auditor should also ask to see if the auditee’s buyer has provided handouts or other sources of information on MRLs, or about which chemicals can or cannot be used.
For an operation involved in packing:
The auditee will need to be aware of different MRLs for the countries that the product is being exported to. They need to know that the product they are shipping to these countries has met any restrictions on agricultural chemical usage. The only way for them to know this is to communicate with the operations who are actually doing the spraying.
There should be proof that this communication has happened and that the auditee has considered the MRLs. Some forms of proof that would be acceptable may include:
- Having copies of Form H1 from the operations supplying product (H1 will have information on what is sprayed, rate etc.)
- A letter that was sent to all suppliers, clearly setting out expectations for suppliers to meet foreign country MRLs, and information about those MRLs (e.g., list of MRLs for specific destinations, website URLs or other sources of information, etc.)
- A list that was provided to all suppliers clearly outlining which agricultural chemicals can and cannot be used.
- Proof of residue testing that they carried out to ensure operations were following the MRLs.
For further information refer to Appendix Q: Documentation Requirements on Agricultural Chemicals for Exported Product.
Q: If fertilizers are mixed in with the agricultural chemicals in the sprayer, can they then be stored with the agricultural chemicals?
A: Yes, fertilizers that are contained (e.g., bag, jug or tote) can be stored in the same storage as agricultural chemicals except where prohibited by applicable regulations. While the fertilizers can be stored in the same storage (e.g. the chemical storage shed) as agricultural chemicals, they must still be separate to prevent cross contamination.
Q: What is required of agricultural chemical applicators?
A: Agricultural chemical applicators are required (Section 6 Agricultural Chemicals 6.2 Application) to have an applicator’s license or be certified, OR be formally trained (e.g., online course), OR be supervised by a formally trained/licensed/certified person.
Note: the CanadaGAP Manual does not state that the applicator’s license/certificate must be current (i.e., it could have expired).
Q: What if there are federal/provincial regulations in place regarding the requirements for agricultural chemical applicators?
A: According to the “How to use the Manual” section of the CanadaGAP Manuals:
Producers, storage intermediaries and packers are responsible to follow all applicable federal, provincial, territorial and municipal legislation and regulations. The producer/storage intermediary/packer is responsible for finding out whether legislation and regulations exist.
…Federal, provincial, territorial and municipal legislation and regulations SUPERSEDE the requirements in the manual and must be followed (e.g., Ontario regulations ask that all agricultural chemical applicators are licensed/certified, while the manual gives a choice that they are certified, trained or supervised by a licensed person. Therefore, an Ontario producer must follow the regulations and be licensed/certified.) However, if the manual requires something that legislation or the regulations do not, then the manual must be followed (e.g., in Alberta, according to the regulations, a producer does not have to have a license/certificate, training or be supervised by someone who is licensed. In order to follow the manual requirements, an Alberta producer would have to do one of the above.)
Therefore, if there are provincial/territorial/municipal regulations regarding agricultural chemical applicators, these will supersede the requirement in the manual. However, if the manual requires something the regulation does not, the manual must be followed.
Q: What are the provincial requirements in my area?
A: Refer to the table of provincial requirements. The table also refers you to sources for more information.
Q: If my provincial government does not require an applicator’s license, certification or training, what courses are available to CanadaGAP-certified producers in my province?
A: We suggest that producers ask their regional growers’ associations and provincial government contacts which agricultural chemical applicator courses are being made available either to producers or commercial agricultural chemical applicators.
Q: How do I score this question on the Audit Checklist (Agronomic Inputs Section – Question #9)?
A: This question is scored on an all or nothing basis. Either the applicator is in compliance with the standard or he/she is not. There is no incomplete option available for this question. If the applicator is in compliance and has proof of this, he/she receives full marks, otherwise the score is ‘0’.