Understanding AWSA Requirements for Shipping Seedcare May 2019 Shipping requirements are accurately described in the AWSA “Accredited Seed Treatment Operation – Bulletins” found on the Seed Treatment Resources web page at https://awsa.ca/. AWSA has also published a “Shipping Tip Sheet” that interprets the Bulletins. Please consult these AWSA Bulletins and the Shipping Tip Sheet for an understanding of the shipping requirements. Important: Please note that many AWSA regulations will be changing on December 31 st , 2020. The guidance contained in this bulletin is therefore only valid until December 31 st , 2020. The Seedcare Institute has found the following decision tree is also a helpful way to navigate the AWSA shipping requirements; The decision tree makes reference to terms and documents that have specific meaning within the AWSA Seed Treatment Accreditation Standard. Many of these terms are described in detail below, along with links to the AWSA website for supporting documents. The Designated Seed Treatment Product List, Shipping Tip Sheet, and applicable AWSA Bulletins are also appended. This information is provided by Syngenta as a guide and is not a complete statement of all AWSA requirements. Always consult the AWSA Accredited Seed Treatment Operation Standards for compliance or certification information (AWSA.ca, 1-877-236- AWSA (2972)). No representations, warranties or legal advice is provided by Syngenta in this document, nor will Syngenta be liable for any damages, losses or claims, including those of an incidental or consequential nature, arising out of the use of or inability to use the information contained herein.
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Understanding AWSA Requirements for Shipping Seedcare May 2019
Shipping requirements are accurately described in the AWSA “Accredited Seed Treatment Operation –
Bulletins” found on the Seed Treatment Resources web page at https://awsa.ca/. AWSA has also
published a “Shipping Tip Sheet” that interprets the Bulletins. Please consult these AWSA Bulletins and
the Shipping Tip Sheet for an understanding of the shipping requirements.
Important: Please note that many AWSA regulations will be changing on December 31st, 2020. The
guidance contained in this bulletin is therefore only valid until December 31st, 2020.
The Seedcare Institute has found the following decision tree is also a helpful way to navigate the AWSA
shipping requirements;
The decision tree makes reference to terms and documents that have specific meaning within the AWSA
Seed Treatment Accreditation Standard. Many of these terms are described in detail below, along with
links to the AWSA website for supporting documents. The Designated Seed Treatment Product List,
Shipping Tip Sheet, and applicable AWSA Bulletins are also appended.
This information is provided by Syngenta as a guide and is not a complete statement of all AWSA requirements. Always consult
the AWSA Accredited Seed Treatment Operation Standards for compliance or certification information (AWSA.ca, 1-877-236-
AWSA (2972)). No representations, warranties or legal advice is provided by Syngenta in this document, nor will Syngenta be
liable for any damages, losses or claims, including those of an incidental or consequential nature, arising out of the use of or
inability to use the information contained herein.
Designated Seed Treatment Products Shipping Tip Sheet
The Accredited Seed Treatment Operation Standards restricts the shipment of designated seed treatment products for application on specific crops (commodities) to seed treatment operations that have successfully passed a seed treatment audit.
Step 1: Familiarize yourself with the Designated Seed Treatment Product List
• The Designated Seed Treatment Product List itemizes designated seed treatment products including Trade Name, PCPA#, Registrant, etc.
• The list also identifies specific commodities (i.e. corn, canola, soybean) that only Accredited Seed Treatment Operations are eligible to receive shipments of to apply as a commercial seed treater.
Step 2: Become familiar with seed treatment product labels
• Seed treatment product labels contain a lot of information including a list of crops and con-ditions for which the seed treatment product is registered for application on.
• Seed treatment labels are available in hard copy or electronic format from registrant sales/technical staff or are available for download on each of the product registrant’s websites.
• A free seed treatment label training program is available at: awsa.ca
• Accredited Seed Treatment Operators are eligible to receive shipments of designated seed treatment products for application on designated commodities.
• A list of Accredited Seed Treatment Operations is available at awsa.ca
Non-accredited commercial seed treatment operator
• Non-accredited commercial seed treatment operators are not eligible to receive shipments of designated seed treatment products for application on the specific commodities listed on the Designated Seed Treatment Product List (i.e. corn, canola, soybean).
• Non-accredited commercial seed treatment operators are eligible to receive shipments of designated seed treatment products for application on commodities (in accordance with the product label) other than those listed on the designated seed treatment product list. A waiver must be signed outlining the specific industry stewardship obligations associated with Designated Seed Treatment Products. The waiver is to be signed at minimum, at the beginning of each application season.
• See Bulletin #10 for more details and for a copy of a sample waiver.
Grower/ Producer
• Growers are eligible to receive shipments of designated seed treatment products for their own farm use.
• In all cases a waiver must be signed outlining the specific industry stew-ardship obligations associated with Designated Seed Treatment Products at a minimum of the beginning of each application season.
• See Bulletin #9 for more details and for a copy of a sample waiver.
This document is designed to assist industry stakeholders in interpreting the shipping requirements for designated seed treatment products. This document should be reviewed in conjunction with available program materials which are available at awsa.ca.
AWSA and the CropLife Canada, their employees, members or agents have neither made, nor do not hereby make, any representation, warranty or covenant with respect to the specifications, information and recommendations in this bulletin, or the results generated by their use, nor will they be liable for any damage, losses or claims, including those of an incidental or consequential nature, arising out of the use or inability to use this bulletin. Use of trade name implies neither endorsement of products, nor criticism of similar ones not mentioned.
Accredited Seed Treatment Operation Standards Designated Seed Treatment Product List
Version: 2.0, Date: January 7, 2019
1201-350 rue Sparks Street, Ottawa, Ontario K1R 7S8 613.230.9881 Representing Canada’s plant science industry | Représentant de l’industrie de la phytologie du Canada
Designated Seed Treatment Product List (January 2019)
CropLife Canada and its members request that all commercial seed treatment operations (as
defined by treating seed for sale or gain) successfully complete a 3rd party audit of their
operation. This audit will help ensure strong environmental, health and safety practices are in
place for the storage, handing and application of seed treatment products in Canada.
Effective January 01, 2018 only commercial seed treatment operations that have
successfully completed an Accredited Seed Treatment Operation Standards audit will be
eligible to receive shipments of designated seed treatment products for commercial
application from Canadian distributors and ag-retailers.
The following seed treatment product registrations have been identified by CropLife Canada
members as products that are to be used exclusively in commercial seed treatment operations
that have successfully completed an audit (*).
Trade Name Manufacturer PCP# For use in (Crops)*
Acceleron Bayer CropScience
(distributed by Monsanto) 31067,
31068,
32441,
32462
corn, soybean
soybean
corn
corn
Acceleron Monsanto Canada 30988,
30989
soybean
soybean
Acceleron NemaStrike ST Monsanto Canada 32775 corn, soybean
* Farmer access to designated seed treatment products for on-farm application. There are no restrictions on the shipment of designated seed treatment products to farmers for their own on-farm seed treatment on labelled crops (i.e. see product label statement) unless otherwise stipulated by the registrant. See Accredited Seed Treatment Standards Bulletin #9 for more information.
The Designated Seed Treatment Product Listing is at the discretion of the Canadian product
registrant. The listing will be updated periodically and re-issued as CropLife Canada members
choose to include registered seed treatment product(s) on the designated seed treatment
product list.
Additional Accredited Seed Treatment Operation Standards information including a copy of the
standards, list of auditors and program supporting materials can be found at www.awsa.ca
The Accredited Seed Treatment Operation Standards are intended to be used by the Agrichemical Warehousing Standards Association (AWSA) for the purpose of issuance of a Compliance Certificate. Neither CropLife Canada, AWSA, their employees, members, allied associations or agents have made or hereby purport to make any representation, warranties or covenants with respect to the specifications or information contained within the standards or results generated by their use, no will they be liable for damage or loss of claims, including those of an incidental or consequential nature, arising out of these compliance standards. These standards are not in any way intended to supersede or detract from any requirements contained in municipal, provincial or federal by-laws, regulations or legislation.
Designated Seed Treatment Products – Shipping Guidance This Bulletin provides clarification to ag-retailers and distributors to ensure compliance with the designated seed treatment product no-ship policy. Effective January 01, 2018 only commercial seed treatment operations that have successfully completed an audit will be eligible to receive shipments of designated seed treatment products for the commercial application (i.e. for sale or gain) on designated commodities from distributors or ag-retailers.
Note: a complete listing of all Accredited Seed Treatment Operation sites and corresponding site specific certification number is available to access on the AWSA website (www.awsa.ca).
Scenario Analysis – a number of common industry scenarios have been identified with requirements for each situation:
1. Ag-retail location staff applying designated seed treatment products on designated commodities as part of service offering
• Required to complete Accredited Seed Treatment Operation Standards audit.
2. Ag-retail location offering seed treatment service of designated seed treatment products on designated commodities with 3rd party equipment and staff
• 3rd party required to complete Accredited Seed Treatment Operation Standards audit. • Ag-retail operation MAY be responsible for seed treatment product storage. Evidence must
be provided to AWSA auditor as part of audit outlining defined roles and responsibilities of both parties.
3. Ag-retail ships designated seed treatment products to commercial seed treatment operation applying product on designated commodities
• Ag-retail facility must ensure that the commercial seed treatment operation is an Accredited Seed Treatment Operation (as evidenced by a current site specific certification number)
• The Accredited Seed Treatment Operation Standards site specific certification number must be included on all shipping documents (i.e. invoice(s) and bill(s) of lading).
4. Ag-retail ships designated seed treatment products to farmer for on-farm treatment • There are no restrictions on shipments of designated seed treatment products to farmers for
on-farm treatment. • Ag-retail operations are required to inform farmers who receive a shipment(s) of designated
seed treatment product(s) for on-farm application to acknowledge that the seed treatment is to be applied on designated commodities that will only be used (i.e. planted) exclusively with their farming operation.
• Farmer acknowledgement waivers must be updated annually.
5. Ag-retail ships seed treatment products (non-designated) to farmer for on-farm treatment
• There are no restrictions on shipments of non-designated seed treatment products to farmers of on-farm application for their own use.
6. Ag-retail facility sells previously packaged seed that has been treated with a designated seed treatment product (i.e. product was previously treated prior to ag-retail site receiving product)
• There are no Accredited Seed Treatment Operation Standards requirements for the selling previously packaged seed that has been treated with a designated seed treatment product.
Note: for additional mobile seed treatment clarification refer to Bulletin # 7 Code Applicability for Mobile Seed Treater Scenarios
Shipping Documentation Requirements
Ensure:
• Shipments of designated seed treatment product(s) to an Accredited Seed Treatment Operation should include the site specific certification number on applicable shipping documents (i.e. invoice(s) and bill(s) of lading).
Note: As part of the AWSA Agrichemical Warehousing Standards audit process (Reference AWSA Agrichemical Warehouse Standards Protocol E16) an AWSA auditor will inspect a sample of shipping documents to verify that designated seed treatment product was shipped in compliance with the no-ship policy.
If a facility is identified as wrongfully shipping designated seed treatment products the AWSA Compliance and Enforcement Process will be invoked.
Updated: January 31, 2018 NUMBER: 9 Farmer Access to Designated Seed Treatment Products for On-farm Application –
Shipping Guidance This Bulletin provides clarification to ag-retailers and distributors to ensure compliance with the designated seed treatment product no-ship policy. Effective January 01, 2018 only commercial seed treatment operations that have successfully completed an audit will be eligible to receive shipments of designated seed treatment products for commercial application (i.e. for sale or gain) on designated commodities from distributors or ag-retailers.
Farmer access to designated seed treatment products for on-farm application:
• There are no restrictions on shipments of designated seed treatment products to farmers for on-farm seed treatment on labelled crops (i.e. see product label statement) unless otherwise stipulated by the registrant.
Shipping Documentation Requirements
Ensure:
• Shipments of designated seed treatment product(s) to a farm operation should include a current waiver form signed annually (see example) or equivalent verification of farmer acknowledgement is on file. The information may be included on the bill of lading, product invoice or other means of shipping documentation (as per company policy) indicating the end user acknowledges (via signature) is aware of the application restrictions for all shipments of designated seed treatment products they receive for on-farm treatment.
Note: As part of the AWSA Agrichemical Warehousing Standards audit process (Reference AWSA Agrichemical Warehousing Standards Protocol E16) an AWSA auditor will inspect a sample of shipping documents to verify that designated seed treatment product are shipping in compliance with the no-ship policy.
If a facility is identified as wrongfully shipping designated seed treatment products the AWSA Compliance and Enforcement Process will be invoked.
Declaration of On-farm Application of Designated Seed Treatment Product
By signing this document you confirm the following statements are true:
1. I confirm that I understand that effective January 01, 2018 that the designated seed treatment products I receive for application are to be used exclusively for my own farming activities.
2. I understand that the conditions of the On-farm Application of Designated Seed Treatment Product Declaration does not permit the application of designated seed treatment products on seed that as part of a service offering (for sale or gain) beyond my own farming activities.
3. I agree to notify the ag-retailer/distributor in advance of any changes in use, scope or operation associated with my on-farm seed treatment that may result in a change in the applicability of the On-farm Application of Designated Seed Treatment Product Declaration (i.e. treating seed for sale or gain). Failure to provide such notice may result in non-compliance penalties under the Accredited Seed Treatment Operation Standards.
Designated Seed Treatment Product(s)
Designated Seed Treatment Product For use on Identify trade name/PCP# Identify commodity
I understand and agree to the terms of this Declaration.
This Bulletin provides clarification to ag-retailers and distributors to ensure compliance with the designated seed treatment product no-ship policy.
Effective January 01, 2018 only commercial seed treatment operations that have successfully completed an audit will be eligible to receive shipments of designated seed treatment products for commercial application (i.e. for sale or gain) on designated commodities from distributors or ag-retailers.
Commercial seed treater access to designated seed treatment products for commercial application on non-designated commodities:
• There are no restrictions on shipments of designated seed treatment products to commercial seed treatment operations for application on non-designated commodities as long as the seed treatment product is labelled on the noted commodity (i.e. see product label statement).
Shipping Documentation Requirements
Ensure:
• Shipments of designated seed treatment product(s) to a commercial seed treatment operation for application on a non-designated commodity should include a current waiver form signed annually (see example) or equivalent verification of acknowledgement is on file. The information may be affixed on the bill of lading, product invoice or other means of shipping documentation (as per company policy) indicating the commercial seed treatment operator acknowledges (via signature) the application restrictions for all shipments of designated seed treatment products on designated commodities they receive for treatment.
Note: As part of the AWSA Agrichemical Warehousing Standards audit process (Reference AWSA Agrichemical Warehousing Standards Protocol E16) an AWSA auditor will inspect a sample of shipping documents to verify that designated seed treatment product are shipping in compliance with the no-ship policy.
If a facility is identified as wrongfully shipping designated seed treatment products the AWSA Compliance and Enforcement Process will be invoked.
ACCREDITED SEED TREAMENT STANDARDS BULLETIN
Commercial Seed Treater Access to Designated Seed Treatment Products for Commercial Application on non-Designated Commodities – Shipping Guidance
Declaration of Commercial Application of Designated Seed Treatment Products on non-Designated Commodity
By signing this document you confirm the following statements are true:
1. I confirm that I understand that effective January 01, 2018 that the designated seed treatment products I receive for application are to be used exclusively for application on non-designated commodities.
2. I understand that the conditions of the Commercial Application of Designated Seed Treatment Product Declaration on Designated Commodities does not permit the application of designated seed treatment products on Designated Commodities.
3. I agree to notify the ag-retailer/distributor in advance of any changes in use, scope or operation associated with my commercial seed treatment application that may result in a change in the applicability of the Application of Designated Seed Treatment Product Declaration (i.e. treating seed for sale or gain). Failure to provide such notice may result in non- compliance penalties under the Accredited Seed Treatment Operation Standards.
Designated Seed Treatment Product(s)
Designated Seed Treatment Product For use on Identify trade name/PCP# Identify commodity
I understand and agree to the terms of this Declaration.