39 www.seed.ab.ca | fall.2018 designated seed treatment products from an ag-retailer usually weren’t fully aware of the requirements — it was more misinformation or misunderstanding rather than deliberate non- compliance. We also learned the audit protocols must be meaningful to mobile seed treaters. When we first started auditing facilities we had a handful of mobile treaters complete the audit — they were the exception. That segment of the seed treatment business has expanded significantly over the last few years. Within the audit protocols, roughly two-thirds are applicable to mobile treaters. This fall, the working group will be going through those audit protocols to ensure they’re meaningful to mobile treaters because of the unique way their businesses operate. We also see continuous improvement to a facility’s ability to do paperwork, training, education and documentation. That’s been the biggest gap throughout the entire process. All operators, and these are incredibly smart people, know their businesses very well. The biggest gap has been showing us that from an audit standpoint, through documentation. This is a work in progress. It’s something we’ll look to improve upon through templates, or by helping people help themselves by providing examples of what we are looking for, so that they can tailor their documentation accordingly. Moving forward, we’ll likely see associations and registrants in the seed treatment business get more involved because they see it as an opportunity to help their members or customers. One observation that took us by surprise is this process helps governments increase their levels of compliance with regulations, such as provincial licences for example. Within the standards we have a requirement ensuring a site is compliant with all provincial/ federal licenses. Our auditors can let an operator know they need a license for X, Y or Z, if they happen to have either a lapsed license or no license at all. It wasn’t the intent of the standards to monitor license compliance, but has been a nice additional benefit of having an industry standard to ultimately aid our government colleagues and to ensure adherence to various regulatory requirements. ASG: What is the path forward from now until the end of 2020? RH: We’ll continue to use the designated seed treatment products list, which will get updated and reissued annually at a minimum. Typically, the list will be updated toward the end of October, as this is the time of year most new registrations coming online for the next crop year are completed. We’ll do this for the seed treatment years 2019 and 2020. ASG: What happens beyond 2020? RH: The program is going to change for 2021. The direction from our May CropLife board meeting was to implement phase II of the Accredited Seed Treatment Operation Standards program. We’re going to do away with the designated seed treatment products list. All commercial seed treatment operators — if you’re treating seed for sale or gain we deem you a commercial treater — will be required to go through and pass an audit by Dec. 31, 2020, to access seed treatment products. A no-ship policy will be implemented Jan. 1, 2021. If you’re a farmer treating seed on-farm, continue to do what you’ve been doing. If you’re a commercial treater and you’re treating corn, canola and soybeans, continue doing your audits, you’ve already gone through that checkpoint. If you’re treating cereals or pulses commercially, by 2021 you must complete an audit. For those seed treatment facilities in the cereals and pulse space, it’s going to be the same journey the corn, canola and soybean operators went through from 2014 to 2018. They’re just going to do it a couple years later. In terms of preparing the industry for that, some of these sites have already completed a pre-audit as part of phase I. We will go through that same process for phase II of the program. ASG: How does implementation of phase II affect industry stakeholders? RH: It gives farmers purchasing commercially treated seed an assurance that as of 2021 all facilities across the country, and currently the ones treating the noted commodities, adhere to an industry level of best practice. Farmers benefit from consistent, high-performing products, which in turn protects their investments. Regulators benefit because their needs are being heard. Specifically, uniform adherence to environmental, health and safety compliance within seed treatment operations. And if when we act on those needs we’re doing it in a manner that is implementable and reasonable, they’re happy. From the standpoint of commercial seed treatment operators, after they’ve gone through the process, I believe everyone will feel their operations were improved. Registrants will have an assurance their products are being used correctly from an environmental, health and safety aspect. Also, that their products are going to perform in the field — and for them that’s the holy grail. Kari Belanger READMOREONLINE@ SEED.AB.CA ToreadmoreaboutthephaseIIofCroplife’sAccredited SeedTreatmentOperationStandardsimplementation for2020andbeyondfindthestoryonlineforweb exclusivecontent.