Agricultural Chemical Applicators
The applicator follows prevailing legislation (e.g., provincial regulations) AND has completed formal training (e.g., online course, self-study course with materials and successful completion of exam, etc.).
Formal training is defined in the CanadaGAP manual as:
Formal training: Consists of a course offered by a recognized educational institution, government body or industry association/group for which a record of attendance is issued. Information about the training content is readily available from the course provider (e.g., course outline, online training materials, etc.).
The definition contains the elements that will be used to determine compliance with the CanadaGAP requirement of formal training. Namely:
- The course is offered by a recognized organization (per options listed in the “Formal training” definition).
- There is evidence that the applicator attended the course
- Information is available about the course content (e.g., course outline, training manual, link to on-line material, etc.) so that it can be determined if the content was relevant.
“Relevant” means that the course relates to agricultural chemical application and to food safety concerns (e.g., if the course only covered matters related to worker safety, it would not be relevant training for food safety).
A list of accepted or approved courses is NOT provided by CanadaGAP or Certification Bodies. Neither CanadaGAP nor the Certification Bodies will review specific courses for content or duration nor will they identify which courses are acceptable or best.
If an agricultural chemical label does not specifically identify if the product can be used on a commodity found in the field (including orchard/vineyard) OR in a greenhouse, can the agricultural chemical be used on any applicable (field or greenhouse) crop listed on the label?
No, according to the Health Canada Pest Management Regulatory Agency (PMRA), the label must specify “greenhouse” if it is to be used on a greenhouse commodity. If “greenhouse” use is not specified on the agricultural chemical’s label, the agricultural chemical is intended for outdoor field-grown crops only. If an operation would like to apply an agricultural chemical to a product grown in a greenhouse, the product label must clearly indicate that the agricultural chemical is intended for use in greenhouses (e.g., greenhouse eggplant, greenhouse tomatoes).November 16th, 2021 at 09:39 am
Maximum Residue Limits (MRLs)
What do operations have to do to make sure that agricultural chemical residues on product do not exceed the Maximum Residue Limits (MRLs) for product exported outside of Canada? What must an auditee show to prove that foreign MRLs are being respected?
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 should 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 (verbally) with his/her 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, etc. There should be proof that this communication has taken place.
For an operation involved in packing, storage, repacking, wholesaling or brokerage:
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 that is being shipped to these countries has met any restrictions on agricultural chemical usage. The only way for the auditee to know destination market MRLs are being respected is to communicate with their suppliers who are actually doing the spraying.
There should be proof that this communication has taken place and that the auditee has considered the MRLs. Some acceptable forms of proof may include:
- Having copies of Form H1 from the operations who are 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 was carried out to ensure suppliers were following the MRLs.
For further information refer to Appendix Q: Documentation Requirements on Agricultural Chemicals for Exported Product.