Consequences of including inspection of sprayers in use in the new Regulation on official controls

Abstract

• Inspection of sprayers in use in its current form cannot be carried out under the control regulation because:
  
  • Neither size of sprayer inspections nor the use of pesticides is large enough to support the administrative structure of the regulation of official controls. Too high costs need to be transferred to the customer.
  • It is unclear if the control regulation allows free pricing.
  • The fee for an inspection of sprayers in use regulated by the control regulation would affect the number of sprayers and thereby diminish the market.
  • The possibilities to implement inspection of sprayers in use outside a workshop decreases. The demand that inspections should be free from any conflicts of interest may make repairs and advisory services impossible.
  • The control regulation does not provide any guidance as to how inspection of sprayers in use should be done in practice. The administrative control adds no positive value to the business. Planned improvements in quality assurance will be impossible.
• This official proposal creates difficulties to give straight answers to companies that want to expand their business. Since an expansion is necessary to provide access to inspections for all plant protection users, straight answers is crucial to implement mandatory inspections.
• If inspection of sprayers, despite our arguments, should be included in the regulation on official controls, the decision should be based on an impact assessment including a cost-benefit analysis, and whether there are alternative ways to achieve the benefits. Our assessment is that the cost of the regulation for corporate profitability, the environment and working conditions for all personal and, above all, increased administration at all stages is not offset by improvements.