Tobacco GAP Certification
Training 2014
Dr. Bob Pearce
Extension Tobacco Specialist
US
Tobacco
GAP
Manual
Guidelines
remain the
same from
2013
US
Tobacco
Gap
Manual
2014 GAP
Record
Book
Update
Brief History of Tobacco GAP
2009-2011
– Each tobacco company administered their own version of GAP
– Multiple sets of expectations
– Multiple assessments
Jan 2012: General agreement that an industry-wide GAP was
needed
NCDA took the lead role all developmental meetings held in
Raleigh, NC
April 2012: Draft GAP document prepared
October 2012: GAP Document agreed to by tobacco
companies
January 2013: “US Tobacco GAP” implemented
October 2013: Gap Connections formed
– December 2013 Grower ID system launched
US Tobacco GAP
GAP Connections
– Non-profit entity formed and supported by
tobacco buying companies
– Formed to administer the GAP program
Provide a framework to decide on GAP changes
– What GAPs should be followed
– Recordkeeping requirements
– Training requirements
Run by a Board of Directors
– Each company has a seat (12-14)
– Growers representatives (2)
http://www.gapconnections.com
US Tobacco GAP
GAP Connections
– Developed a grower ID system
Secure database
Tracks training history
Only companies with which you have a contract
will know your training history
– Developing an audit process
Contractor agreed on
Pilot program for 2014
Random Selection of Growers
GAP Continuing Education
Annual requirement for training?
– Currently, Yes.
Training in each of the three main areas
– Crop Management
– Environmental Management
– Labor Management
Record Book Changes from 2013
By type
– Air-cured
– Fire-cured
– Flue-cured
By field instead of topic
–
–
–
–
–
Transplanting
Fertilization
Pesticide
Topping
Harvesting
Increase emphasis on traceability
Records Checklist
If you currently use an
alternative record keeping
system that can supply
the same information you
do not have to use the
provided templates.
Checklist is a tool for
assuring that required
records are kept, whether
using GAP templates or
another system
Required Records are Detailed
Transplants
– Source of transplants
– Seed lot number should be recorded
– Variety name
– Date seeded
– Pesticides applied
– Date transplanted
Required Records are Detailed
Fields
– Each field individually identified
– Soil test results
– When and how much fertilizer
– Which pesticide, when, and who applied
– Rainfall amounts per event
– Irrigation
– Planting, topping, harvest dates
Required Records are Detailed
Curing Structures
– Each barn individually identified
– When housed
– Spacing of sticks
– How tobacco ordered/cased
– When taken down
Efficient Record Keeping
Do as much as possible before start of season
– Much of the General Records Packet can be
completed preseason
Develop system of documenting practices
daily
– Carry notebook and fill out as completed
– Pocket notebook, calendar, tablet computer, etc.
– Call into central place as operations completed
Update records frequently
– Ideally daily
Don’t try to remember anything !!! Document !!!!
GAP Principles for Variety Selection
Selection should be based on
– Disease resistance
– Curing characteristics and cured leaf quality
– Yield
– Holding ability
Review variety performance on your farm
Identify and test new varieties
Use LC seed
Black Shank % Survival
Variety
2009
2010
2012
Mean
HB 04PLC
22
3
18
14
HP 3307PLC
97
49
44
63
Hybrid 404LC
40
3
14
19
KT 204LC
100
66
79
82
KT 206LC
97
68
70
78
KT 209LC
98
85
91
91
KT 210LC
93
66
83
81
KTH 212LC
97
56
31
61
KY 14 X L8LC
3
0
2
2
N 7371LC
93
30
39
54
NC 2002LC
12
0
-
-
NC 7LC
83
16
38
46
TN 90LC
90
57
46
64
Seasonal Avg.
71
38
46
55
Cured Leaf Yield (lbs./A)
3 Year Yield Average (No-Stress)
3000
2500
2000
1500
1000
500
0
Suggested “New” Varieties
Disease-free
H 404
HBO4P
N 126
Moderate
black shank
KT 212
HB4488P
KT 204
Strong black
shank
Fusarium
KT 209
KT 210
KT 210
NC 7
May want to use Ridomil or similar fungicide
where moderate to heavy black shank is expected
Gap Principles for Pest Control
Crop Management
– Accurate Identification of the pest
Extension Agents/Specialists can help
– Selection of effective and economical control
methods
Tobacco Production Guide ID-160
http://www2.ca.uky.edu/agc/pubs/id/id160/id160.pdf
– Assessing results of control method
– Residue Reduction
– NTRM reduction
Reduce weeds and suckers in cured leaf
GAP Principles for Pest Control
Environmental Management
– Proper storage of pesticides
Secure (locked)
Away from tobacco storage
– Reduce reliance on pesticides when possible
– Selection of safest alternatives
– Proper application methods
Correct rate
Calibration of spraying equipment
Field Disease Management
Use resistant varieties when available
Practice good sanitation to prevent spread
– Wash off equipment
– Sanitize equipment with 10% bleach
– Don’t spread stalks in “clean” fields
Use appropriate pesticides when needed
– Would Ridomil cure this ?
Field Disease Management
Use appropriate pesticides when needed
– Black Shank
Ridomil
– Transplant water application
Ultra-Flourish
Meta-Star
– Leaf Spot Disease (target spot and frogeye)
Quadris
– 1 time use on transplants at second clipping
– 1 well timed application in the field when tobacco is knee
to waist high
Satori
– 1 well timed application in the field when tobacco is knee
to waist high
Must have supplemental label at
time of application
Must have supplemental label at
time of application
Generic Quadris
Insect Management
Scout and Treat Approach
– Walk field at least 2 times per week
– Thresholds
3 or more Flea beetles per plant
10% of plants with aphid colony
10% of plants with a worm
Insect Management
Preventative Approach
– Use a neoncitinoid product in transplant water
for aphid and flea beetle.
Low cost
Effective
Relatively safe
– Use Coragen for worm control in transplant
water
Effective
Relatively safe
– Still need to scout in case of control failure
Weed
Management
Competition
–
–
–
–
Space
Light
Nutrient
Water
Harbor Disease
Physical Damage
– Morningglories
– Honeyvine Milkweed
NTRM
Herbicide Options for Tobacco in
Kentucky
Brand
name
Chemical
name
Grasses
Nutsedge
(Cyperus)
Pigweed
Ragweed
(Amaranthus) (Ambrosia)
Command
Clomazone
++++
+
+
++++
Devrinol
Napropamide
++++
+
++
++
Prowl*
Pendimethalin
++++
N
++++
+
Spartan
Sulfentrazone
++
++++
++++
+
Poast
Sethoxydim
++++
N
N
N
* Other Brand names: Acumen, Pendant 3.3 EC, and Stealth
Herbicide Trial
Washington County
4000
3500
3000
2500
2000
1500
1000
500
0
CHK
Mech
Prowl
Command
Spartan +
Command
New Formulations/Rates
Spartan 4F
8 oz/A
10 oz/A
12 oz/A
Spartan Charge
10.2 oz/A
12.8 oz/A
15.2 oz/A
• Use higher rate on fine textured soils or when pressure
from morningglory or yellow nutsedge is high.
• Mix with Prowl or Command to improve grass control
• Prowl H2O: 2 pts/A when mixed with Spartan
• Command: 1.5 pts/A when mixed with Spartan
GAP Principles for Sucker
Control
Apply appropriate sucker control materials
to achieve good sucker control
– Increase leaf yield and quality
– Reduce NTRM
Minimize undesirable residues
– MH residue a concern
Less than 80 ppm
Less than 50 ppm for some
Tips For Good Sucker Control
Use a combination of MH and DNA (Butralin,
Prime+, Flupro)
– 1.0 to 1.5 gallons MH
– 0.5 gallons of DNA
Properly maintain spray equipment
– Use nozzles that deliver a coarse spray
– Pressure 20 to 30 psi
– 3 nozzles per row maximizes coverage
Use adequate water (at least 50 G/A)
Do not spray in the heat of the day when
plants are under stress
Spray fewer rows at a time
GAP Principles for Nutrient Management
Fertilization Should be based on:
– Soil type
– Crop Rotation
– Soil test (no more than 2 years old)
Confirm fertilizers are appropriate for use on
tobacco
Follow recommendations for manure use
Implement required nutrient management
plans
– If applying either fertilizer or manure a plan is
required in KY!
Problem for 2014
Fertilizer dealers report a shortage
of 0-0-50
– Less 0-0-50 imported this year
– More 0-0-50 being used on other high
value crops
– Maybe localized (some areas have may
have adequate supply)
Why can’t we just switch to 0-0-60
High chloride in tobacco
Poor cured leaf color
– dingy, muddy, variegated
Imparts unpleasant flavor and aroma to
smoke
Reduces burn rate
Cause cured leaf to hold moisture
– moldy stems / fat stems
– high case can lead to rot during storage
Impact of Chloride on
Cured Leaf Moisture
% Cl in cured % Moisture at % Moisture at
70% RH
80% RH
leaf
0.9
17.0
21.7
1.4
18.0
23.1
1.7
18.2
23.6
1.9
18.5
23.9
2.1
19.0
24.6
2.3
18.9
24.9
Effect of K source on leaf yield and
Cl content
4 year avg.
240 lbs. K20/A
Muriate Cl
Lbs. SO4
Yield
0
0
282
2774
Cl content
%
0.36
100
50
211
2854
0.87
200
100
141
2903
1.28
300
150
71
2951
1.60
400
200
0
2935
1.94
Problem for 2014
How do we respond?
Use soil test to determine potash need and
apply no more than recommended
Apply up to 100 pounds of 0-0-60 per acre
to provide the first 60 pounds of potash
needed
– If you did not apply 0-0-60 in fall
– If you did not apply animal manures in the
spring
Use 0-0-50 for remaining potash need if
available
Use alternate sources of low Cl potash
Alternate Sources of Low Cl Potash
Check with dealer for local availability
0-0-22
– K-Mag
– Sul-Po-Mag
– Trio
Use “tobacco” blends but check labeling
for max chloride
– 5-10-15
– 6-12-18
GAP Principles for
Labor Management
GAPs for Labor Management
Determine your labor requirements and
source of labor
– PLAN AHEAD!!
– Be realistic about your labor needs (every
operation is different)
– For burley tobacco production
159 to 197 person-hours per acre total
48 to 60 person-hours per acre cut and house
51 to 73 person-hours per acre strip and market
prep
– Determine your peak demand
Peak Labor Demand (Example)
Assumptions:
– 50 Ac of burley to harvest (mid August –
September)
– 50 person-hours per acre cut and house
– 1 day off per week
– 1/3 of remaining days not suitable for harvest
(rain)
– 10 hours working per day
Approximately 24 harvest days or about 2.1
Ac per day
105 person hours per day
10 to 11 workers everyday for 6 weeks
GAPs for Labor Management
Determine your labor requirements and
source of labor
– Family
Reliability ??
– Seasonal/Migrant Workers
Reliability ?
Authorized to work in US?
– Farm Labor Contractor (FLC)
Reliability ?
Registered?
– H2A Worker Program
Reliable
Higher out of pocket cost?
GAPs for Labor Management
Determine and comply with all applicable state
and federal laws and regulations.
– Seasonal Workers
– Migrant Workers
Have on file an I-9 form for all “paid” employees
Fair Labor Standards Act
Post FLSA Poster specific to “Agricultural Employees”
Overtime pay provisions do not apply for “agricultural” work
Minimum age requirements
– Generally do not apply to minors working for parent owned farm
– Must be over 16 to work in “hazardous” jobs on farm
Record keeping requirements
– Payroll records should be kept for 3 years
– Time record should be kept for 2 years
GAPs for Labor Management
Fair Labor Standards Act
– Minimum wage provisions may apply
If you used more than 500 man-days of farm labor
in any calendar quarter of the preceding calendar
year.
Man-day = any day in which an employee does
farm work for at least one hour
Does not apply to immediate family members
If you pay by piece-rate, specify expected
minimum rate of output to insure hourly minimum
wage rate is met.
Current minimum wage is $7.25 per hour
GAPs for Labor Management
Determine and comply with all applicable
state and federal laws and regulations.
– Seasonal Workers
– Migrant Workers
Migrant and Seasonal Worker Protection Act
applies
– Post MSPA poster
Disclosure
Wages
Housing
Transportation
GAPs for Labor Management
Migrant and Seasonal Agricultural Worker Protection
Act
– Disclosure
Each migrant worker must be provided with a written disclosure
at the time of recruitment (also posted at worksite)
– In the worker’s native language
Each seasonal worker must be provided with a verbal disclosure
at time of recruitment and written disclosure upon request
– Items to be disclosed
1.
2.
3.
4.
5.
6.
7.
8.
Place of employment
Wages rates to be paid
The crops and kinds of activities involved
The period of employment
Any benefits (transportation/housing) provides and charges
The existence of any strike or other work stoppage at jobsite
Any relationship between employer and suppliers to workers
Whether worker compensation insurance is provided
GAPs for Labor Management
Migrant and Seasonal Agricultural Worker
Protection Act
– Wages
Pay all wages when due
–
–
–
–
At the rate disclosed
Not less than minimum wage
At least semi-monthly
Deposit and report any taxes withheld
Provide worker with itemized statement of wage calculations
– Employer name address and EIN or SS number
Include any deductions for housing etc. that were disclosed
initially
– Housing (if provided to migrant workers)
Must be inspected prior to occupancy
Certificate of occupancy posted on-site
Contact information for housing provider posted on-site
GAPs for Labor Management
Migrant and Seasonal Agricultural Worker
Protection Act
– Transportation (if provided)
Any vehicles used must be properly insured.
Operated by properly licensed driver.
Vehicle must meet all federal and state safety
standards
– Additional Requirements for Farm labor
Contractor
Certifications to provide transportation required
Certification to drive required
GAPs for Labor Management
Determine and comply with all applicable
state and federal laws and regulations.
– Farm Labor Contractor (FLC)
You negotiate a price and pay the agreed upon price to
a crew leader. Crew leader schedules the work,
recruits and pays the individual workers.
Fair Labor Standards Act applies
Migrant and Seasonal Worker Protection Act
applies
– While workers are putting in your crop they are
likely considered to be in “joint employment”
Both you and the FLC are responsible for compliance
Check that FLC is registered with the Dept. of Labor
http://www.dol.gov/whd/regs/statutes/FLCList.htm
GAPs for Labor Management
Determine and comply with all applicable state and
federal laws and regulations.
– H2A Guest Worker Program
Fair Labor Standards Act applies
Migrant and Seasonal Worker Protection Act applies
Additional Requirements of the H2A Program
–
–
–
–
–
–
Post H2A Worker Rights Poster
Pay worker’s visa fees
Provide transportation to and from worker’s home
Provide transportation to and from work site
Provide housing while in employment
Guarantee at least ¾ of work hours specified in work
contract
GAPs for Labor Management
H2A Guest Worker Program
– Start Early with Process
– Choose a Reputable Agent
Assist with contract terms and guarantees
File applications with appropriate agencies
Assist with advertising requirements
Assist with worker recruitment
Assist with visa processing
GAPs for Labor Management
Implement a worker training program
– Crop Integrity
Grade separation
Moisture and bale weight requirements
NTRM reduction
– Safety
General farm safety
Tobacco barn safety
Green tobacco sickness
Questions?