Document 6yzrLKRYNnYzeLk8kQJrRjx1

oe % Fsernotm To ce Subject Attachments: I undi 15 aot 2022 11:37 - -cor> SCHREIBERKristin (GROW) (GROW) Follow-up exchange on C5 Bayer OG GROW26 Juy 34905-CLE input on PMT criteria in responstoe CARACAL Meeting 34905].pa; 35004- rope Europe PMTImpactAssessment pdf; SUD training obligations farmers.pdf Dear Ms.Schreiberand colleagues, thankyou onceagain forthe exchanage few wesks ago regarding the EU Chemical Strategy for Sustainability. As agreed in the meeting, we would lie to follow-up on some of the points discussed 1. IntroodfnuewcPMtITihaozanrdclassunder CLP 2. Extension of generic approach to risk managementto professional users During the meeting we had also discussed the need to differentiate highly trained professional users such as farmersor healthcareprofessionals from others and we would liketoshare some information regarding the EU-wide obligations farmers have tofulfil in the handinogf plantprotection products. or example aims to achasiusetaivnabeleuse ofpesticindethse EU by reducing the isksand impoafpecstticisdeuse on human healthand the environment, EUcountrieshavedrawn 4p National Action Plans to implementtherange of actions set out n the Directive. The under the Sustainable Use Directive (SUD) relateto training of users, advisors and distributors of opfespteicsitdiecsi,dIenusspeecitnisoennsoiftpievseatirceiadse,aanppdliicnaftoiornmaetqiuoinpamnednta,wtahreepnreoshsirbaiistinigoafnboaeurtialpessptriacyiidneg,rislkismitation According to Chapter Il, Article 5 of the SUD, Member States shall ensure that all professional users, distributors and advisors have access to appropriate initial and additional trainings by bodies designated by the competent authorities. The trainings shall be designed to ensure that participants acquire sufficient knowledge on the 13 subjects liisntAnenedx | of SUD, including: hazards and risks associated with pesticides for human healt&h environment (non-target plants, beneficial insects, wildlife & biodiversity); risk minimization measures such as safe working practices for storing, handling, mixing pesticides, disposing of empty packaging; emergency actions in case of accidents and first aid measures; use ofpesticideapplication equipment and its maintenance;risk associated with illegal (counterfeit) products and methods to identify them, etc In Germany for example every professional user of pesticides has to acquire a so called "Pllanzenschutzsachkundenachweis" and has to do refreshing trainings at least every three years at an accredited organization. In the context of the current revision of the SUD, these requirements will ikely be further reinforced, including a broader seto training topics and a fixed validity of training certificates (10 years for professional users or distributors of plant protection products and for5 years for advisors). Furthermore, professionalusersare protected under the legal framework on the safety and health of workers at work, the chemical agents at workDirectives and in addition certainsectorsare subject to specific legislation which highly controls the exact manner in which the regulated products are used (e.g. biocides, plant protection products, etc). These regulations ensure that the exposure scenarios for such uses have inherently less uncertainty compared to other uses, are legallybinding and subject to enforcement Pleasealso find further informationregarding the additional commitments regarding the training of farmers in the sector: ProPteopele c-CrotpliifeEnurogpe Lastly, we would like to inform you that we are currently developing an overview of the potential impact of all CSS measures taken together on a specific groupof chemical substances. As soon as this is ready we would be happy to share it with you for your confidential information. We also work in `cooperation with Crop Life Europe to translate the impacts from CSS into the understanding what this means for the agricultural sectoras a whole. Thank you once again and we are available for anyquestions you might have. Sn A Sn mn i 3Sro0e2o2SrpEma, croSp Sacore Dor e R I R raat