Chlorination of irrigation water impacts on chlorate and perchlorate residue in edible produce at harvest: Questions & Answers

A:  Details on why some personal data is being collected is given in the tender. The successful contractor will process this data on behalf of the AHDB and they will be expected to comply with General Data Protection Regulations (GDPR) rules including having in place suitable systems and processes to ensure that the collected data is not misused, lost, stolen nor corrupted during data processing.

The successful contractor will be asked to sign a legal agreement with the AHDB and in turn the contractor will be expected to work with their chosen laboratories and to sign legal agreements to comply with GDPR.  AHDB will hold contractors to account should a breach in GDPR rules arise.

The successful contractor will be required to work with AHDB to complete relevant sections of a Data Protection Impact Assessment (DPIA), to detail how they will collect and process personal data on behalf of the AHDB and the risks involved. 

A: All data (raw and processed) will need to be securely transferred to the AHDB.  Only anonymised data will be submitted to the Chemicals Regulation Directorate and the Food Standards Agency by the AHDB. AHDB will keep all data (grower contact information and chemical residue results) indefinitely under the GDPR provision of data required for scientific and historical research purposes to enable it to monitor residue trends over time and undertake further research. The successful contractor and participating laboratories will be expected to delete all data that they hold, following its secure transfer to AHDB, by 31 March 2019.  

A: No, the aim is to gather on farm data.  Contractors will need to design sampling protocol(s) and data collection template(s) which will be used by growers to gather information on how they are chlorinating their irrigation water and the impact that this has on residue in their specific edible produce. 

Contractors will need to take into account the different chlorination systems and different crop types e.g. outdoor vegetables; protected soft fruit; protected edibles when producing the protocols and templates.

A: AHDB has a database of UK growers of horticultural produce who pay the statutory horticultural levy as well as other horticultural growers who may not pay it (where business turnover is below the threshold).

The protocol for data collection and the data collection template will go out to all growers of edible horticultural crops with a request for those disinfecting irrigation water with chlorine compounds to participate, at their own cost.  It is difficult to gauge how much data will be collected as some growers may choose not to participate.

As regards spinach, the contractor is expected to work closely with five commercial spinach growers.

A: Part of it is a desk study involving data gathering and analysis but the work on spinach is practical.

For spinach, contractors will need to design a spinach chlorate and perchlorate data collection project that will generate sufficient robust data to inform MRL setting. They will need to follow a crop of spinach through from drilling to harvest. The budget was set high to allow for soil, water and spinach samples testing for chlorate/perchlorate from the five participating businesses.  Chlorate and perchlorate testing at laboratories such as Concept Life Sciences costs £85 in total for both, per sample. 

A: The contractor should list all laboratories offering chlorate and perchlorate testing that they are aware of in their submission.  All identified labs must be UKAS accredited. In addition, their methodologies for chlorate and perchlorate testing must be UKAS accredited.  This listing will go out to targeted growers for growers to make their own decision as to where to send their own samples. 

If the successful contractor is a laboratory, then for spinach, at least half of the samples from each business should be analysed elsewhere, for results comparison.