Third European Workshop on the inspection of plant protection equipment - SPISE 3-Workshop - from 22 to 24 September 2009 at Brno/CZ
The SPISE 3-Workshop took place from 22 to 24 September 2009 at Brno (CZ) and was attended by 100 participants from 27 European countries. The Workshop was organised by the SPISE Working Group (SWG), to which representatives from Belgium, France, Italy, the Netherlands and Germany belong (Chairman: Dr.-Ing. H. Ganzelmeier)
The aim of the Workshop was to discuss Article 8 of the Framework Directive (the inspection of plant protection equipment already in use) and to reach conclusions for implementing equipment inspections in the Member States. The participants came from testing and research institutes, administration departments and companies and the majority possessed technical expertise so that in particular practical implementation was the focal point of the Workshop.
The Workshop was opened by Mr. Hnizdil from the State Pyhtosanitory Admininstration Department in Prague.
Two representatives from the European Commission were present and both gave a presentation at round table sessions:
Mrs van Tongelen, DG-Environment
-Directive of the European Parliament and the Council establishing a framework for Community action to achieve the sustainable use of pesticides -
Mr. Fräser, DG Enterprise,
- Directive of the European Parliament and the Council on machinery for pesticide application, amending Directive 2006/42/EC of 17 May 2006 on machinery.
Representatives from ECPA, CEMA, COPA und JKI/AT also contributed to the round table session by giving presentations.
The individual sections of Article 8 were presented, explained and discussed in the 6 sessions which followed.
On the evening of the first day, contributions concerning the training of inspection personnel and on software solutions for compiling and analysing data and inspection facilities were presented under the agenda item "Optional Evening Activities" and also several posters.
On the 2nd day there was an excursion to inspection workshops in the Czech Republic and Slovakia. This excursion was welcomed enthusiastically by the participants because the inspection workshops demonstrate equipment inspection procedures in practice and there are always positive examples to see and other cases in need of improvement.
The results of the workshop can be summarised as follows:
- Mrs von Tongelen asked the participants to take part in the 2nd meeting of experts (in accordance with Article 18) which is planned for June 2010.
- Mr Fraser explained why the certification of new equipment is organised by the Machine Directive and the inspection of plant protection equipment already in use by the Framework Directive.
- Mr Hagenvall (ECPA) emphasised that equipment which works well is an important prerequisite for the complete efficacy of plant protection products and for avoiding negative effects.
- Mr Oldenkamp (CEMA) welcomed the harmonisation of equipment inspections because this means that national regulations will be phased out. He supports the inspection of new equipment by the manufacturers at their factory and before delivery to the customers. (This approach is already used successfully for some neighbouring Member States based on bilateral agreements).
- Mr. Rademacher (COPA) would welcome a similar inspection for plant protection equipment already in use in the Member States and called for the harmonisation of the inspection procedure and inspection intervals.
- Mr. Wehmann reported on the results of a survey in the Member States on the present situation of the inspection procedure for plant protection equipment already in use. He established the fact that the compulsory inspection has now been introduced to all participating countries or that this is definitely intended in the next few years.
- It was considered practical and equivalent for the inspection of plant protection equipment to be carried out both by officially certified inspection workshops and offices of the official service (as is the case, for example, in Belgium, Germany and the Netherlands).
- Most Member States which have not yet had as much experience with plant protection equipment inspections will keep to inspection intervals of 5 years; other Member States considered a shorter interval to be more practical.
- Inspections of new equipment after 5 years at the latest following their first use, as provided for in Article 8 § 2, is not seen as being particularly practical. An inspection which takes place immediately at the manufacturer's is considered as being practical and is supported.
- The question also arose as to whether an operator can have his plant protection equipment inspected in a neighbouring Member State where the inspection is easier and cheaper.
- It remained open as to whether Member States have to offer inspections for all plant protection equipment or whether plant protection equipment owners can also be referred to offers from other Member States (e.g. for aircraft).
- It has to be clarified for which types of construction the Member States may use different schedules and inspection intervals and which types of construction may be exempt from inspections.
- It has to be clarified how the assessment of risks for human health and the environment, including an assessment of the scope of use of the equipment, should be carried out in order to be able to examine certain types of construction independently of the regular inspection intervals or to exclude them entirely from the inspection. The question arose as to whether EN/ISO 12100 - Safety of machinery - General principles for design, risk assessment and risk reduction (ISO/DiS 12100:2009) can be used as a basis for the required risk assessment.
- When introducing equipment inspections to the Member States it is considered suitable and practicable to limit these first of all to the type of construction, for which the corresponding EN standards have already been published in the Offical Journal (EU). This is only expected for field sprayers and air-assisted sprayers for bush and tree cultures at short notice at the moment. Other types of construction could then be included in the obligatory examination as soon as the corresponding standards are available.
- In conjunction with the inspection of handheld plant protection equipment and knapsack sprayers, training operating personnel is considered very important. Studies have shown that the 'human' factor is just as important as the factor 'equipment'.
- The Commission has assigned the CEN the task of drawing up standards for the inspection of plant protection equipment. A first meeting of the CEN/TC 144/WG 3 which has been assigned the task took place on 20 and 21 October 2009 in Paris.
- The participants expected that this standardisation work by the WG 3 would be promoted and be high up on the list of priority.
- Alternatives for inspecting plant protection equipment without having mandated standards available were discussed and demonstrated by the JKI/AT using examples.
- In accordance with Article 8 § 5 operators are obliged to carry out regular calibrations and technical checks. To this end interesting case studies were shown and explained.
- The required certification regulations for the mutual recognition of inspections can be limited to the submission of a valid inspection report and a valid inspection sticker on the plant protection equipment. A separate and more detailed certificate is not deemed necessary.
- The inspection report is stipulated by EN 13790. The inspection sticker itself (shape, print design) was not discussed in any greater detail. The question of whether the German method of still issuing an inspection sticker despite minor deficits would meet with general approval could not be clarified for definite.
- These 'minor deficits' still have to be defined for further types of construction. Similarly a decision is to be made on whether this should be at CEN or MS level.
- It was suggested to orientate the colour of the inspection sticker around ISO 10625 (colour coding for nozzles).
- Furthermore, the criteria for not issuing inspection stickers and for recognition and monitoring officially recognised inspection workshops were addressed. In this context, reference was made to exemplary regulations from the Netherlands, Belgium and Germany which can be found on the SPISE website.
- Monitoring recognised inspection workshops was seen as essential, harmonisation was considered necessary. To this end it was suggested to compile an EU database. Accreditation according to ISO 9000/ISO 17020 was seen as too complicated and costly.
- The draft prepared and presented by the SPISE Working Group, 'Proposal for uniform enforcement of inspection in the Member States', can be seen as a contribution on how equipment inspections according to Article 8 of the Framework Directive can be implemented in national legislation. Particularly technical and administrative aspects are taken into consideration.
- A concluding recommendation/comment was compiled on the basis of the previous SPISE Workshops.
- The SPISE Working Group intended to report to the Commission on the SPISE 3-Workshop in the near future.