In line with the principles of EPPO Standard PP 1/226
Number of efficacy trials,
minor uses and secondary targets
can
be
addressed
by
reduced
datasets,
but
again
trials
should
be
located
to
cover
the
diversity
of
conditions
encountered, and especially the more challenging.
In published case studies (Sunley & Zlof, 2011), guid-
ance on numbers of trials, and the justification for them is
presented for a series of realistic scenarios.
Situations of more limited diversity
For certain uses of plant protection products, the diversity
of conditions encountered is likely to be more limited. For
example, use of plant protection products in stored grain
or
other
storage
situations,
and
in
protected
conditions
where crops may be grown in controlled conditions per-
haps
using
artificial
growing
media.
Article
33
of
EC
Regulation
1107/2009
considers
that
in
the
case
of
an
application for use in greenhouses, as post-harvest treat-
ment, for treatment of empty storage rooms and for seed
treatment, the whole of the EU area is considered as one
authorization zone.
In situations where the diversity of conditions is likely to
be more limited compared to conventional outdoor plant
protection, the applicant should still consider and identify
the different conditions likely to be encountered in the
authorization zone. Testing of the product should occur in
extremes of the conditions encountered to ensure perfor-
mance across the range of conditions. As previously men-
tioned in some situations precautionary label warnings may
be required (e.g. to advise users of possible reduced effi-
cacy where fumigants are used for treatment of leaky rather
than gas tight storage premises) or for example different
doses against the main target species may be required if
there are substantive differences in sensitivity. In the case
of seed treatments, these are subject to the wide range of
soil types and climatic conditions present across the autho-
rization zone, as well as to variation in pest pressure and
sensitivity. As such, it is considered that these treatments
are more similar to conventional foliar plant protection
products and a trials series should encompass the diverse
conditions encountered in the authorization zone.
Some crops may be grown both indoors and outdoors in
the same zone. In such situations and because of the differ-
ence in conditions that protection can bring, efficacy testing
should be conducted in both situations although data from
one condition may
be relevant to the
other (especially
where those conditions result in a more severe challenge to
performance).
Minimum effective dose
EPPO Standard PP 1/225
Minimum effective dose
describes
the criteria, as well as the experimental procedure for deter-
mining the minimum effective dose of a plant protection
product.
Across an authorization zone where there may be sub-
stantial variation not only in climatic and environmental
conditions, but also in agronomy and crop structures, and
in pest pressure and its sensitivity to a plant protection
product,
there
may
be
variation
in
the
minimum
dose
required for effective control of a given target on a crop for
those different conditions.
The applicant may already be aware of differences that
might result in the requirement for different doses against
a target (for example if a reference product is authorized
at different doses in different countries for the same tar-
get), and these should be taken into account in the design
of the trials series across the authorization zone. Alterna-
tively
the
effectiveness
trials
may
show
differences
in
performance
for
certain
conditions,
and
may
warrant
different doses.
EPPO
Standard
PP
1/225
Minimum
effective
dose
requires that in order to establish the minimum effective
dose, at least 1 lower dose than that which is to be recom-
mended should be included in some trials. Where perfor-
mance
may
be
affected
by
the
variation
across
the
authorization zone, it is recommended that more than 1
additional dose than that proposed be included in some of
the trials. In this way the applicant may be able to provide
both
sufficient
data
to
demonstrate
effectiveness
of
the
appropriate dose for a given set of conditions as well as
justify the dose proposed.
Therefore, where appropriate, and supported by data or
reasoned argument, a different dose may be proposed on
an individual National label for the same target. Further,
the main target may differ on the same crop in different
areas within the zone, so it is important to ensure that
data supporting minimum effective dose are generated on
an appropriate range of target pests or pest pressure within
the crop. The applicant should explain/give an overview
on what the proposed strategy is in terms of rates e.g. 1
dose for the same target across the zone, or proposals
(and justification) for varying doses regionally within a
zone.
Use of reference products in a zonal data set
To facilitate comparison of data produced in different con-
ditions across a zone, it is preferable that the same refer-
ence product should be used in the trials. However, it is
acknowledged that in a large zone spanning several coun-
tries, this may not be possible if the reference product is
not authorized for the same uses and rates in all those
countries. In such situations an alternative reference product
may need to be used. It may be beneficial to include both
reference products in some trials for comparative purposes
if this is permitted by available authorizations. It is impor-
tant to note that one of the purposes of a reference product
is to indicate the validity of the trial.
In designing a trial series and considering conditions
across an authorization zone, the applicant may observe that
364
Efficacy evaluation of plant protection products
ª
2012 OEPP/EPPO,
Bulletin OEPP/EPPO Bulletin
42
, 358–366