Ragwort and the Cinnabar moth

This strikingly coloured moth is the Cinnabar moth. The plant it is on is common ragwort (Senecio jacobaea – which is looking a bit tatty as it has recently been mowed). Ragwort is the principal food plant for the caterpillars of the Cinnabar moth. The caterpillars are equally striking, but they are striped black and yellow.

Cinnabar moth on ragwort
Cinnabar moth on ragwort

In the UK, there are few plants that excite such heated debate as ragwort does. Sadly, the debate is generally more heated than considered.

Ragwort, like very many plants, does contains naturally occurring “toxins”: specifically, pyrrolizidine alkaloids. These alkaloids are produced by vast numbers of plants. The alkaloids make the plants taste bitter and unpalatable, thus deterring herbivores from eating them.

The risk from ragwort comes when it is dried and mixed in with a hay crop – then animals are less able to detect the bitterness and also unable to sort out the different herbage and forage and consequently more likely to ingest ragwort (or any other undesirable plants).

So, ragwort does have some risks, but it also has lots of benefits, including being a food plant for dozens of insects, including several endangered species. It isn’t a plant that warrants a knee-jerk panic reaction, but a considered assessment of its potential risk and benefits in any given situation.

In 2010, the Welsh Government published new guidance on ragwort control. This Code of Practice presents a surprisingly balanced analysis of the ragwort situation, as well as guidance on control strategies as and when appropriate. It is freely available for download from the Welsh Government website.

 

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Environmental Impact Assessment Regulations in Welsh Horticulture

Did you know, in Wales, if you want to plant an orchard, establish a vineyard, or set up a market garden, you might need permission from the Welsh Government?  Really? Yes, really.  Even if the land is yours; even if it’s been in your family for donkey’s years: you’re not free to just do as you may wish with it.

There are lots of reasons why this is the case, this post focuses on the snappily titled “Environmental Impact Assessment (Agriculture) (Wales) Regulations 2007”.  Environmental Impact Assessments are generally referred to as EIAs.  And in fact, these Regulations (in the context of horticulture in Wales) actually rarely deal with actual Impact Assessments.  They deal more with assessing whether or not an Assessment is required.

Whether you agree with the Regulations or are outraged by them and see them as an infringement on your liberties, they are something you need to know about if you’re planning to start-up in horticulture. 

The Welsh Government provides quite comprehensive advice and guidance on the regulations and their interpretation at http://wales.gov.uk/topics/environmentcountryside/consmanagement/conservationbiodiversity/eiahome/eiadocs/?lang=en.  You can also speak to Welsh Government officers who deal specifically with EIA and are generally very helpful (yes, honestly, they are).

In brief, the rules say that if you are “intensifying” production on an area of “semi-natural” or “uncultivated” land, you need to ask permission first.  However, the definitions of these land types are specifically rather vague.

That may be it: you might ask, the Welsh Government might say, ‘no problem’.  Or, they might want to look a bit harder at your land and your plans, and then say it’s ok for you to go ahead.  Or, they might say that you need to carry out a “scoping” exercise to identify the likely impacts of your activities and produce an Environmental Impact Assessment of them.

Tiresome as complying with these requirements may seem, it is in your best interests to do so.  Failure to comply could be costly in the long run.

You may wonder how the Welsh Government would ever know what you’re up to, especially if you’re halfway up a hill in the middle of nowhere.  But the Welsh Government has extensive and detailed aerial and satellite images and data for the whole of the country.  And an army of interested parties is always ready to report any potential breaches to the officials.  The chances are that at some point in time, your new orchard, vineyard, field of potatoes or whatever, is going to come to the attention of a Government official.  The worst case scenario could mean that you have to rip up all your planting and reinstate the land to the condition it was to previously (insofar as that is possible…).  All at your own expense, and with no compensation.

So, the lesson of this rather dry story is be aware and beware.

Food safety – quality assurance for growers

Hypothetically speaking, if someone fell ill as a result of a food-borne pathogen (perhaps e-coli or clostridium) after eating your produce and the finger of blame was pointed at you, how confident would you be that you were in the clear? And how easily could you convince the authorities of this?

Nobody likes unnecessary paperwork and bureaucracy, but in a situation where your production processes are being called into question, having a robust set of procedures in place with appropriate records and documentation will be your first and strongest line of defence.

In the UK, if your produce is going to one of the major retailers, they will insist on you having appropriate production, harvesting and storage protocols in place before they will buy from you.  This may seem like an unnecessary burden and cost, but it protects you as well as the retailer and ultimately the consumer.

Those who sell via other routes (e.g. to wholesale, direct to the consumer or via independent retailers) will seldom be asked to produce evidence that “due diligence” has been used at all stages of producing their crops.  While this is a “nice” and “friendly” approach that often relies on trust, it will be of no use at all if something goes wrong.

Putting food safety quality control processes into place doesn’t need to be overly complex, nor does it have to be costly.  There is no particular reason why you should use a paid for accreditation system if you don’t need or want to.  The advantage of using one of the recognised accredited systems is that they are “fit for purpose”.  That provides an enhanced level of confidence to both you and your buyers.  But if you want to set up your own system there is nothing to stop you, and any kind of system is better than none.

Even with the best systems in place, things sometimes go wrong.  Having a food safety quality control system in operation is not a cast-iron guarantee for your produce.  What it does do is demonstrate that you have considered the risks and put into place measures to address them. Doing that is a legal requirement as a primary producer: but without documentation how can you ever demonstrate that you were acting with due diligence?

Don’t take risks with your business or your customers’ health: put a food safety quality control plan into place and into practice now!

For further information visit:
redtractor.org.uk
http://www.food.gov.uk/foodindustry/farmingfood/
www.salsafood.co.uk

Selling culinary herbs – things you need to know first

Herbs are one of the most pleasurable crops to grow.  They’re also great for selling, but, there are some tricky legislative considerations you ought to bear in mind if you are selling herbs.  The legislation may be infuriating, but it’s also bizarrely interesting.  For example do you know which herbs are “allowed” to be sold by the bunch, rather than by weight?  Read on to find out…

Primary product or food
Since 2006, the EU Food Hygiene Regulations have applied to primary producers (i.e. growers and farmers) as well as food producers and processors.  Culinary herbs fall under these regulations.  In their raw, unprocessed state, culinary herbs are primary products (not food).

The regulations mean that as a primary producer you have a duty of care to ensure your produce is fit for purpose.  Particularly you must avoid it being contaminated by things like soil, chemicals, non-potable water, etc.  You must keep records that demonstrate how you have ensured the produce is as safe as possible.  This will include detailed records of any plant protection products used, when they were applied, why, at what rate, etc. – this type of record should always be kept anyway if you are using sprays and chemicals. 

If your holding doesn’t already have a Customer Reference Number (CRN) or County Parish Holding Number (also known as a CPH number, or Holding Number) you will have to register with your Local Authority as a Primary Producer.

When is a herb a food?
Primary products become food once they have been processed.  In general, fresh herbs sold with little or no processing will remain as primary products.  However, dried herbs are considered to have been processed and are therefore classed as food.  Food products have far more onerous regulatory requirements than horticultural primary products.  Washing (with potable water) and trimming will not usually be considered to turn a primary product into food, but do check with your Local Authority to find out how they interpret the Regulations

By the bunch?
Most foods must be sold by weight, but chives, mint, watercress and parsley can be sold by the bunch, without a weight.  For other herbs, if sold in weights of more than 5g (about 1/6th of an ounce – almost nothing), you get into the realms of selling by weight.  For this, you need to make sure that you have suitable scales with calibration records to prove their accuracy.

Labelling
There are many sad stories of producers printing off sheets of labels only to be told they were non-compliant and therefore unusable.  Labelling regulations are complex.  Essential information for pre-packed herbs is: the name of the herb (plus any additives if appropriate); the business name and address; and the net weight of the product.  For packs of up to 50g the writing must be at least 2mm in height.

Do the regulations always apply (is there wriggle room)?
Direct supply by the producer to the final consumer or to local retailers may fall outside the scope of the Regulations.  However it’s always better safe than sorry, so you should use best practice and comply as far as you possibly can anyway.  Ignorance is no defence in the eyes of the law.

Because the regulations are so complex, you should seek more advice from your local Trading Standards Office (about weights & measures, packaging, etc) and Environmental Health Office (for food hygiene information).  They are almost always helpful and friendly.  They would rather work with you and avoid problems arising than have to take enforcement action.
This information is provided as general guidance only and is no way comprehensive or a replacement for professional advice.