Protecting the operator from contamination when spraying pesticides:

The Role & Function of Tractor & Self-propelled Sprayer Cabins

European Agricultural Machinery

Frequently asked questions (FAQs)

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1. Is it mandatory to use a protective tractor or self-propelled sprayer cabin when spraying? p.4

2. When spraying, what do farm operators have to do to make sure they meet all legal requirements and achieve an adequate level of protection? p.5

3. What is the applicable legislation regarding the protection of operators against contamination when using Plant Protection Products? p.7

4. What does the label on a Plant Protection Product indicate? p.8

5. What is the link between the mandatory protective measures and the risk of contamination from a specific substance? p.9

6. What are the applicable legal rules regarding the protection of operators from contamination by Plant Protection Products? p.10

7. What are protective cabins on vehicles? p.11

8. In the future, will protective cabins on vehicles become a mandatory feature when spraying? p.12

9. What is CEMA’s position on the issue? p.13

THE PURPOSE OF THIS DOCUMENT is to explain the legal requirements regarding the protection of operators from contamination when spraying pesticides (Plant Protection Products - or PPPs), and to explain the role and function of protective cabins on vehicles in this process.

What do operators have to do right now to make sure they meet all legal requirements and achieve an adequate level of protection when spraying?They need to follow the mandatory protective measures required by law. These include the following:

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There is a general consensus that the cabin of a tractor or self-propelled sprayer should be an alternative to PERSONAL

PROTECTIVE EQUIPMENT in the future. The current legal provisions on this issue are somewhat unclear and inconsistent, and have therefore caused concern and confusion among farm owners and operators across Europe. To address these concerns, efforts should be undertaken by the EU to modify and clarify the respective legal provisions.

Is it mandatory to use a protective tractor or self-propelled sprayer cabin when spraying?

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Carefully read the label on the Plant Protection Product and follow the instructions regarding the mandatory use of Personal Protective Equipment. If, for instance, the product label indicates that a specific protective mask must be worn during the spraying process, this mask MUST under all circumstances also be worn inside the tractor cabin so as to eliminate any potential risk - irrespective of the category of the tractor cabin used.

Carefully read the manual of the Plant Protection Product and follow all prescriptions concerning the measures to be taken before, during and after the application of the substance.

Carefully read the manual of the tractor and/or sprayer and follow all prescriptions concerning the measures to be taken during and after the application of the substance. If you follow the instructions on the Plant Protection Product label and the handling prescriptions of the manual you will meet all legal requirements and any potential risks are adequately controlled.

The rules to protect operators against contamination from Plant Protection Products are defined in the respective European and national safety and health regulations as well as regulations for the authorisation of Plant Protection Products. They specify:

What is the applicable legislation regarding the protection of operators against contamination when using pesticides?

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Measures to minimise risks from handling, storage and disposal of Plant Protection ProductsEducation and training requirementsMeasures to be applied in specific situations (like on buffer strips, cleaning procedures)

In addition to these measures, the operator may want to choose optional protective measures:

You may want to use a protective tractor or self-propelled sprayer cabin so as to enhance the comfort when spraying.

In legal terms, the use of such a cabin - at the moment - CANNOT be seen as a replacement for wearing the mandatory Personal Protective Equipment required by law.

Also bear in mind the following points as they can have a significant impact on the protective function of the cabin:

Store Personal Protective Equipment in a SAFE and CLEAN place to avoid contamination of the cabin!Do not bring any contaminated clothing inside the cabin!Do not open the cabin while spraying or immediately after spraying!

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It is mandatory to read the Plant Protection Product label and follow the safety instructions carefully.

To be allowed on the market, a certain level of protection for the operator is mandatory. This protection can be achieved by Personal Protective Equipment the exact need for which will be indicated on the product label. The correct use is indicated in the respective documents (application, packaging, cleaning of equipment, precautionary measures, transport, storage, in case of fire…).

What does the label on a Plant Protection Product indicate?

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A Plant Protection Product contains one or several active substances. These substances are assessed and authorised before the product is placed on the market. This means that all risks are adequately identified and reduced to an acceptable level.

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The protective measures depend on the risk(s) identified for a specific substance.

What is the link between the mandatory protective measures and the risk of contamination from a specific substance?

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This risk is a combination of the hazard and the exposure to a product. The hazard is related to the properties of the pesticide product. The exposure relates to the potential contact with the pesticide product - whether direct or indirect - and the question how such contact can occur (skin, inhalation, intake in digestion system).

The risk for contamination (based on the exposure) is typically as follows :1

RISK = XHAZARD EXPOSURE

Risk of damaging effect(s)

Product properties

Contact with the product

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DURING FILLING

>90% of the exposure1% respiratory<5% body>85% hands

<10% of the exposure1% respiratory <5% body<5% hands

(for crop boom spraying using modern equipment)

DURING TREATMENT (SPRAYING)

This means that exposure is an order of magnitude higher when filling than during spraying.

7Ir. E. Jadin, CRP (Comité régional PHYTO, Ir. J. Marot, UCL (Développement d’outils de sensibilisation pour l’utilisation durable des pesticides), Dr. C. Maillet (SPF Santé publique))

What are the applicable legal rules regarding the protection of operators from pesticide contamination?

What are protective cabins?6. 7.

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Cabins of tractors and self-propelled sprayers play a role in providing the operator with protection from Plant Protection Product contamination when spraying.

A standard has been developed to indicate the level of protection that can be offered.

Standard EN 15695 indicates four levels of protective cabins:

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CATEGORY 1

no defined protection

CATEGORY 2

protection against dust

CATEGORY 3

protection against dust and aerosols

CATEGORY 4

protection against dust, aerosols and vapours

The protective measures regarding the use of Personal Protective Equipment (such as masks and gloves) when using the product, are listed on the product label.

In the future, will the use of protective cabins become a mandatory feature when spraying?

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This remains to be seen. The binding rules for operators are product-specific and, as such, only specified on the label and in the documents of a specific Plant Protection Product.

There is a need for further investigation:

It will be important to put in place a recognised evaluation system that specifies under which category a specific cabin falls.

Open questions remain regarding the proper handling and maintenance of protective cabins, particularly concerning the service and maintenance of the pressurisation systems and filters, and the replacement of filters.

Due to the higher risk for contamination, more focus for improvement should be on safety measures during mixing and filling.

Should, in the future, the role of protective cabins be considered as part of the authorisation process for a specific Plant Protection Product, the appropriate category of cabin could be indicated on the label of the product. In this respect, a suitable version of the cabin standard EN15695-1 could be used during the authorisation process.

CEMA believes that it is important to give the operator the choice of using either the Personal Protective Equipment or the protective cabin when spraying.

Small and medium-sized farms in particular should continue to benefit from the possibility to make use of Personal Protective Equipment only when spraying.

From a practitioner’s point of view, the use of protective cabins would be most beneficial for:

Bigger farms and/or contractors where the application of plant protection products represents a high share of their work

Farms with the need for specialised application techniques such as for bush and tree crops

Employers and employees having received the necessary education and training to ensure the correct use of a protective cabin during the spraying process, following a proper risk assessment.

What is CEMA’s position on the issue?9.

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CEMA IS COMMITTED to operator safety by providing the operator with the highest possible protection.

13Images © All rights reserved by Crop Protection/ ECPA, Deere & Company, Kverneland, Hardi, CLAAS, Amazone, New Holland Agriculture, Delvano

European Agricultural Machinery

THE EUROPEAN AGRICULTURAL MACHINERY INDUSTRY

CEMA

Helping farmers worldwide to grow food affordably and sustainably

The development and production of agricultural machinery is among the most dynamic and innovative industry sectors in Europe. The industry helps to grow food affordably and sustainably by providing farmers worldwide with cutting-edge innovations and services. The European Agricultural Machinery:

For more than 50 years CEMA has been providing an interactive platform to manufacturers of agricultural machinery to formulate common industry positions and work towards a higher degree of European harmonisation in the sector. CEMA is made up of 10 national trade associations which bring together manufacturers located throughout the entire EU.

The voice of the European Agricultural Machinery Industry

Includes 4,500 manufacturers of agricultural equipment consisting of large multinational companies as well as numerous small and medium-sized enterprises (SMEs);

Produces more than 450 different types of machines – ranging from tractors and combine harvesters to plant protection equipment and precision seed drills;

Has a total turnover of €26 billion and provides employment for 135,000 persons directly and another 125,000 persons indirectly in the distribution and service network.

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