4. Farm saved seed
33. The 1969 Directive requires soil testing for PCN only for fields where classified seed potatoes are to be grown. Current controls therefore exclude farm saved seed. However, in drawing up the 2007 Directive, Member States recognised that it was difficult to justify restricting PCN controls in these terms, on plant health grounds. Farm saved seed may sometimes be replanted in the same field or an adjacent field, but it may equally be moved to another holding planted by the same grower in another part of the country, or passed on to another grower contracted to the same merchant. A particular concern is the planting of farm saved seed in rented land; if this becomes infested then the next tenant may transfer PCN to his own land or to other rented land, creating a chain of contamination.
34. A small survey of PCN in ware potato land, carried out by RPID using a randomly chosen sample of fields used to grow ware crops in 2007, found 16% of the 67 fields surveyed (and 9% of the 190 samples taken) to be infested with live PCN. This is lower than the figure of 23% found by SAC in a study of 397 advisory samples published in 1999. It is clear that many ware growers are well aware of the potential impact of PCN on their production and take measures to minimise the risks. This may include having fields tested, either officially or privately, and reserving areas believed to be free of PCN for producing farm saved seed. At present significantly more land is officially tested than is used for growing classified seed crops: in 2006, 17,461ha was tested, but only 10,822ha was entered for classification. We assume that some of the excess is already used for growing farm saved seed. However, we are also aware that in other cases ware growers may not decide which crops will be used for farm saved seed until they are harvested, in which case it may come from untested land.
35. To ensure that the risks of spreading PCN through farm saved seed are kept to a minimum, the 2007 Directive requires that all seed potatoes must be produced on land which has been found clear of PCN by a pre-planting soil test, unless they are to be used "within the same place of production situated in an officially defined area". This phrase is open to a degree of interpretation by Member States. Plant health authorities must also be satisfied that farm saved seed used in this way poses no risk of spreading PCN.
36. The most restrictive definition of "same place of production" would be to limit it to a single holding. This would provide the maximum protection against the spread of PCN, but fails to recognise the reality that many growers operate across owned and rented land on a number of neighbouring holdings. The opposite extreme would be to permit farm saved seed to be moved to any holding in the same ownership or management, anywhere in Scotland. This has been suggested in areas where PCN is widespread in ware land, but we would not consider it appropriate in Scotland, given the restricted distribution of the pest here.
37. The Scottish Government is minded to define "same place of production" as holdings under the same ownership or operational management within a restricted distance which would, on average, cover all fields planted by a single grower. Issues to consider include:
- Given the additional risk of spread posed by planting farm saved seed in rented land, should its use be restricted to holdings in the same ownership?
- Should the same ownership or management refer to the individual grower or to all crops grown under contract to the same merchant?
- What is an appropriate distance within which farm saved seed could be moved? 10km has been suggested as this is considered an appropriate distance over which the use of the same field machinery may occur.
38. Documentation will also be required to identify farm saved seed and ensure it is not used beyond the specified distance. Ware growers are already required to retain labels to prove that the potatoes they plant are no more than once-grown from classified seed, and to submit PP1 forms with details of the location of all ware crops planted. It may be necessary to add to the PP1 the field in which the farm saved seed was grown, and to label it in store to maintain traceability. Since the Scottish Government must be satisfied that there is no risk of spreading PCN, use of farm saved seed can only be permitted if suitable tracking mechanisms are in place.
Question 5a: Which of the following options do you prefer for the definition of "same place of production"?
a. The same holding
b. Any holdings in the same ownership which are no more than [10km] from one another.
c. Any holdings under the same operational management which are no more than [10km] from one another.
If you prefer another definition please give details and explain your reasons.
Question 5b: Is 10km a reasonable distance which would cover all the fields planted by an average grower?
Question 6: Do you foresee any problems with implementing a system for labelling farm saved seed in store in a way which is secure and can guarantee traceability back to the field in which it was grown? Is there a need for an official numbering system?