The nonsense of a further planth health qualification, required to all of the AgSciences graduates, by the National Action Plan on the sustainable use of pesticides
The directive 2009/128/EC has caused a troublesome change in the profession of agronomist and till now I wonder how it could have taken place, considering that the 2009/128/EC directive only aims at ‘establishing a framework for Community action to achieve the sustainable use of pesticides’. So this directive is aimed at creating a framework legislation in order to solve some leading questions that till now had hampered the success of the Rural Development Plans (RDPs), when they targetted the agrochemical pollution in agriculture.
In such case we could have expected it were necessary to enhance the role of the professional agronomists that, almost everywhere in the world, have huge reponsibilites in providing expertise to the farmers, with the purpose of allowing them to implement best practices, aimed at protecting the environment. Consider, for example, that in Brazil ‘only agronomists can prescribe agrochemicals’ (article: published by hortidaily.com).
Apparently not all expected with the 2009/128/EC directive as gone in the right direction. Infact in January 2018, the Pesticide Action Network sent a complaint letter to the Italian Ministry of Agriculture, lamenting that some important aspects of such directive haven’t been applied.
So what were the true targets in the Italian application of the directive 2009/128/EC?
As a Doctor of Agronomy (more simply: agronomist) I soon realized that the Italian derivative legislation of the National Action Plan has firstly targetted my professional competences (Law n.3 of January 3, 1976 – art.2), because I’m no longer allowed to prescribe agrochemicals (untill I pass the new exam), although the Professional Law tells I’m able to take care of the planth’s health. Furthermore: whenever I need to care my plants I can only buy some light (and useless) chemicals, so that I can’t really care my plants, even if they are attacked by parasites! Any farmer could tell me: why don’t you take care of your plants? And they would be right: according to the Italian law I could be sanctioned because of that. So: I should pay an other consultant to keep my plants healty!
In my opinion all that has been possible because, while the 2009/128/EC stated (art.5-2):
‘1. Member States shall ensure that all professional users, distributors and advisors have access to appropriate training by bodies designated by the competent authorities. This shall consist of both initial and additional training to acquire and update knowledge as appropriate.
The training shall be designed to ensure that such users, distributors and advisors acquire sufficient knowledge regarding the subjects listed in Annex I, taking account of their different roles and responsibilities.
2. By 14 December 2013, Member States shall establish certification systems and designate the competent authorities responsible for their implementation. These certificates shall, as a minimum, provide evidence of sufficient knowledge of the subjects listed in Annex I acquired by professional users, distributors and advisors either by undergoing training or by other means.
Certification systems shall include requirements and procedures for the granting, renewal and withdrawal of certificates.’
The Italian derivative law: Legislative Decree August 14, 2012, n. 150 (Art.7) , about the same aspects, treated by the art. 5 2009/128/EC directive, has stated that:
1. The training is aimed at ensuring that all professional users, distributors and consultants on the use of plant protection products have adequate knowledge, constantly updated, in the subjects listed in Annex I. The education includes the training of basic elements and updating, both mandatory for professional users, distributors and consultants.’ [..]
If you know the Italian education system, you would assume the directive purposes of an improved qualification of the advisers are already satisfied by the academic record of the most of the Agricultural Sciences graduates, that (moreover) although they are enough educated about plant-health, they can’t work till they haven’t passed the Statal Examination, that qualify them as ‘Doctors of Agronomy and Doctors of Forestry’.
Surely not all of them passed same academic exames, so you could maybe think it could be useful checking the academic record of each Doctor of Agronomy / Doctor of Forestry; but the Italian national Action Plan has made something very different and strange, indeed:
It has set a short course with a final exam, to give the authorization to prescribe agrochemicals and has called the authorized professionals ‘plant-health advisers’. Also professionals not registered to any of the professional guilds of agricultural advisers are allowed at achieving such qualification, that is released at regional level; but according to the (national) Law you can’t be a plant-health consultant until you are registered to a professional guild!
Such new qualification enables to both prescribing agrochemicals and providing professional advising in IPM. All that could seem a liberal approach, maybe the right one, if it weren’t that are enabled to take such exam both high school agricultural graduate and the University Agsciences graduates (no matter if they are registered to a professional guild). So, all them have been allowed to do what, till 2014, the Doctors of Agronomy/Forestry could do, in accordance with their professional law (and now they no longer do without such exam).
The Legislative Decree August 14, 2012, n. 150 (Art.7) has apparently tried to ‘balance’ its ‘revolutionary approach’ preventing from attending the needed courses, anybody having (in 2015) a two year experience in agricultural consultancy. So also a two year-experienced high-school graduate, even if not registered to a professional guild (that in Italy is mandatory), could be exempted from attending the same course that a graduated person (even if registered to his guild) must instead attend, in the case he hasn’t the required experience! Consequently the major achievement of such law seems to disow relevance to the university degree in agricultural sciences and consequently (also) to the qualification of Doctor of Agronomy / Forestry. But not the same happens in other professions!
Somebody could think that the Italian Agricultural Science graduates be all Professional Agronomists, but NO, it’s not so: they must also be qualified, by means of a statal exam, to be a professional agronomist and furthermore they need to be registered to the Order of Doctors of Agronomy & Doctors of Forestry, a mandatory guild, that is controlled by the Ministry of Justice. Only in such cases you can consider you are a Professional Dr. Agronomist/ Forester. So we could think that could be enough. It’s not still so: they must also follow a certain number of conventions/conference every years and have an insurance in order to be permitted to work. All that was set by the Reform of the Professional Orders (D.P.R. 7 agosto 2012, n. 137), that was aimed at enhancing the free market (!). It was published only one week before the Legislative Decree August 14, 2012, n. 150 that set the Italian action plan. Can we think all such a regulation has increased the free-competition among the agricultural advisers? I don’t think so.
What happened is not only strange, but it also denies what is stated by the art.2 of the professional law (Law n.3 of January 3, 1976) of the Doctors of Agronomy/Doctors of Forestry:
‘1. Sono di competenza dei dottori agronomi e dei dottori forestali le attività volte a valorizzare e gestire i processi produttivi agricoli, zootecnici e forestali, a tutelare l’ambiente e, in generale, le attività riguardanti il mondo rurale. In particolare, sono di competenza dei dottori agronomi e dei dottori forestali: (=Particularly are among the Doctors of Agronomy’s and the Doctors of Forestry’s competences:) [..]
i) i lavori e gli incarichi riguardanti la coltivazione delle piante, la difesa fitoiatrica (=jobs and assignments dealing with the plant cultivation, the plant-health defense)‘ [..]
Usually nobody could dare think about checking the capability of a medical doctor in prescribing the right human drugs: they are professionals, they must fulfill ethic commitments and moreover they are used to practice the self-apprenticeship: this is what the university truly teach all us! So how could you think to check the agronomist’ knowledge, about the ‘subjects listed in Annex I’ (2009/128/EC): the most of such arguments are studied during the academic studies; during such period the most of the students pass examinations about plant-healt and care.
It seems evident that the 2009/128/EC directive wanted all professional prescribing agrochemicals have the same expertise; so I doubt that it wanted everybody started from point 0, no matter what he knows!
The Italian national Action Plan come into force by the Ministerial Decree 22/01/2014 that has consequently created the new ‘Plant-Health Consultant’ degree, that is attributed to those people, passing a regional examination mostly based on the agrochemical regulation. Such regional regulation can be different in each Italian region creating possible inequalities.
Against these comprehensive circumstances is apreciable that the National Council of the Order of Agronomists (CONAF), in 2016, has appealed to the Italian Administrative Justice. Their petition was against the Ministerial Decree 22/01/2014 (Italian National Action Plan), but unfortunately they endly lost their legal battle (TAR Lazio:n.12730/2016 del 21/12/2016 and State Council, sentence n. 1577 del 12 marzo 2018).
As follow you can also read the final Press-release published (‘.pdf’) by the National Council of the Doctors of Agronomy and Forestry .
Anyway also inside a same professional register you could find some unfair differences, infact, navigating the lists of ‘plant-health consultants’, you could find people who has highlighted (in their online profile) a qualification/experience in not so related matters; but such circumstance doesn’t prevent them from passing the exam and get the ‘plant-health consultant’ qualification too. Infact any guild’s member is allowed to get jobs related to all the competences listed in the art.2 of the professional law, no matter if they are rural appraisers, cattle experts, landscape architechts, or plant-patologists. At a same time, you could find people who (according to their profile) are qualified as plant-pathologist/entomologist, but they are wating to attend the mandatory agrochemical course.
The lack of qualification at prescribing agrochemicals is very important because can prevent from providing IPM expertise to the farmers (e.g.), in the context of the EU Rural Development Plans (RDPs), a true opportunity to get jobs for many agronomists. Do you think that could be right?
I haven’t till now taken part to any of such courses (and following exam), because the plant-health competence of the Doctors of Agronomy and Doctors of Forestry is anyway established by the Italian Professional Law (Law n.3, of January 7, 1976; art. 2), but I’m no longer able to prescribe agrochemicals, while (e.g.) in Brazil, on the contrary, agronomists are the only professionals allowed to to that!
In Lombardy (my region), if I wanted register to a ‘plant-health consultant’ course, that is mandatory for the most of the Doctors of Agronomy/Forestry, I should anyway wait till the course is available. So any professional who want achieve the new ‘Plant-healt consultant’ qualification must, firstly, periodically check the regional portal ‘DOTE ON-LINE’ . In that case he (we) could assume the best search is ‘plant-health consultant’ (consulente fitosanitario): unfortunately at present this search doesn’t provide any result.
Endly I have understood there could be some pitfall in the keywrods of the course search-engine: in fact, when I fill the form-fields with the adjective ‘fitosanitario’, the search releases a series of strings such as ‘FITOSANITARIO – UTILIZZATORE PROFESSIONALE CORSO DI AGGIORNAMENTO’, ‘FITOSANITARIO – DISTRIBUTORE CORSO DI AGGIORNAMENTO’, ‘UTILIZZATORE FITOSANITARIO’ and ‘CORSO BASE DISTRIBUTORE FITOSANITARIO’, where ‘utilizzatore fitosanitario’ seemingly stands for ‘utilizzatore di prodotti fitosanitari’ and ‘distributore fitosanitario’ stands possibly for ‘utilizzatore di prodotti fitosanitari’.
Anyway, till now (August 15, 2019), no string displays courses for ‘consulente fitosanitario’, or maybe ‘consulente per l’utilizzo di prodotti fitosanitari’.
That’s all from Italy.
Last Update August 19, 2019 – 02:02 a.m.