Section 4: Commercial Application of Seed Applied Technology (SAT)

Summary: Commercial Application of SAT can include fungicides, insecticides, nematicides, plant health products, inoculants, micronutrients, herbicide safeners, plant growth regulators and other biologically functional materials to commercial seed. Compositions of SAT may include other materials such as colorants, polymers, drying agents, water and other additives (e.g. coating materials) to provide suitable appearance, physical properties, process performance, and other factors. Quality of treatment is dependent on the composition of the applied material (the “treating mixture”), the application rate to the seed, the process conditions (seed throughput, seed temperature, product temperature, etc.), treatment procedures and the application equipment. These quality factors must be selected, defined and monitored to ensure a safe, effective and high-quality treated seed, with properties that help ensure environmental stewardship. Quality of the seed prior to treatment (e.g., chipped seed, negligible dust) is also very important for ensuring the quality of seed treatment.

NOTE: Not all standards may apply to all processes, and some may apply only in a very limited way such as label verification or visual inspection.

  1. Factors Affecting Product Integrity and Product Control
    1. Use of suitable SAT treating mixtures.
    2. Use of appropriate equipment in good operating condition.
    3. Use of suitable and consistent processes.
    4. Proper mixing of components.
    5. Application at correct rates.
    6. Use of correct materials.
    7. Use high quality seed.
    8. Purity of slurry mixture or components; e.g., avoiding contamination from previously used treating mixture.
    9. Use of unexpired components (if applicable) or treating mixture.
    10. Operation of treating processes within acceptable ranges; e.g., application to seed that is at the correct temperature as indicated by the process and/or treating mixture.
  2. Determine Control Points
    1. Receipt of seed from third party or output from seed cleaning process.
    2. Receipt of slurry components.
    3. Preparation of treating mixture.
    4. Application Process (calibration and monitoring of application rate).
    5. Output from seed treating process.
    6. Packaging.
  3. Establish Application Processes
    1. Read, understand and follow all directions on labels and Material Safety Data Sheets (MSDSs) for all components of the treating mixtures.
    2. Establish and use documented training procedures for seed treater employees, including mixer/loaders, seed treatment equipment operators, packagers, and fork lift operators. Iinclude personal protective equipment and hazardous material handling, as specified on labels or MSDSs, where appropriate.
    3. Establish understanding and/or agreements with third-party providers of seed on standards for material to be used in treating process, including needed data.
    4. Treater: provide appropriate seed tag contents as per the seed treatment product label requirements and the Federal Seed Act.
    5. Test seed material using appropriate methodology to establish or confirm quality of seed used in treating processes.
    6. Establish appropriate protocols for assessment of process inputs (seed, formulated products which include active ingredients, coating materials, etc.).
    7. Establish and use documented slurry preparation procedures (including composition, sequence of addition, operator and preparation date).
    8. Establish and follow changeover procedures when switching from one slurry to another.
    9. Establish and use documented procedures for handling, control, and proper disposal of leftover and unused slurry components, packaging materials, wastes, and treated seed.
    10. Properly calibrate equipment and be sure to adjust equipment settings for lot changes, such as when applying products on a mg ai/seed basis.
    11. Establish and follow treater cleanup procedure.
  4. Establish Monitoring Procedures
    1. Treating Process Verification: Verify equipment is capable of accurately and uniformly applying the chosen product to seed, with acceptable physical properties of the treated seed including, but not limited to, acceptable process performance (e.g. lack of treatment build-up, etc.), treated seed dust levels, handling properties and plantability.
    2. Upon receipt of materials, confirm by documentation or verify using diagnostic methods (where appropriate) that material meets specifications.
    3. Verify application rate (options include calibration verification, mass balance of applied material and seed throughput, and analysis of treated seed).
    4. Periodically monitor physical properties (e.g. tackiness, visible dust off, flow) and appearance (e.g. uniformity, color) of treated seed during the treatment process.
    5. Re-verify treating process if key parameters change and on a periodic basis:
      1. Slurry composition;
      2. Material suppliers;
      3. Treating process parameters such as throughput; and
      4. Treating application equipment.
    6. Verify shelf life of components where applicable and use only within approved use period.
    7. Verify shelf life of slurries where applicable and use only within approved use period.
  5. Establish Verification Procedures
    1. Confirm and establish appropriate sign-off and administrative approval of verification procedures.
    2. Verify procedure for quality of treated seed.
    3. Verify procedures for periodic auditing and assessments through a checklist and inspection.
    4. Verify adequate feed-back to the supplier of the material.
  6. Establish Corrective Measures
    1. If seed or slurry components do not meet specifications, review use and disposition of the material.
    2. If sourced material does not meet established standard, review procurement practices with supplier.
    3. If treated seed does not meet application rate or required physical property specifications, review use and disposition of the treated seed.
    4. Review application equipment maintenance and calibration.
  7. Establish Record Keeping and Documentation Procedures
    1. Establish that information accompanying receipt of the treatment components (e.g., shipping documentation, lot numbers, MSDSs for treatment components) is accessible, secure and retained, internally and/or externally, as provided by third party.
    2. Maintain MSDS documents for hazardous components.
    3. Keep records of training certifications and administrative approval.
    4. Establish documentation requirements and retention policy for equipment calibration, treating records, seed treatment application rate analysis reports, and related documents.
    5. Maintain records of equipment maintenance and calibration.