Pesticide enforcement and HSE
HSE is on the move when it comes to safe use of pesticides, and their team is already carrying out spot checks on those using pesticides within the land based sector. Breaches of pesticides regulations carry an unlimited fine. How can you ensure that you’re meeting regulations?
In Autumn 2021, we had an enquiry to provide training to a team from the HSE for PA1 safe application and handling of pesticides and PA6a handheld applicator (knapsack field-based situation). Their intention is for them to carry out pesticide enforcement audits to ensure compliance, along with random spot checks.
We have heard that a pesticides user was stopped only recently. Therefore, it’s even more pressing that you make sure that:
1) you are qualified in the correct units of application
2) products you are using are still authorised and legal to use
3) equipment is in good, safe working order
4) transportation and storage of products are as per the HSE guidelines
5) you use PPE at all times:
- type 5 and 6 coveralls (or as per product details)
- wellies, full length
- gloves, 300mm long, 0.5mm thick, nitrile rubber, no flocking
- full face shield for when measuring out the concentrate
6) your records are up to date, including:
- stock records
- environmental risk assessments
- application or treatment records to hand
- COSHH assessments
- risk assessments
- copies of waste transfer notes
- control measure records (where applicable)
- training records and certifications for distributors and users
More information about visits from pesticide enforcement officers can be found on the HSE website.
Pesticides and the environment
Of course, in a time where everyone is so much more concerned with protecting the local and global environment, we really must think carefully about our use of pesticides.
Within the land based sector and the work we do, there is still the need to use pesticides. However, this must be done safely, correctly and legally. We have a responsibility to ensure the use of pesticides is ideally a last resort, not the first port of call we jump to because it may be the quickest and easiest.
Therefore, we should consider the hierarchy of control before any application:
- Is it possible to eliminate the use of pesticides? Could we have controlled our weeds or pests through other methods, which may be more time intensive?
- Can we substitute the product we are considering using for something that is safer for the environment and us as the users?
- What engineering controls could we put in place? For example, using a nozzle shroud to control any potential drift.
- Administration controls – think carefully about the time of day when you carry out the application and who else has access to or near the site.
- Finally, are you wearing the correct PPE? Remember, you should have the correct type of coveralls (type 5 and 6 or type 3 and 4, dependent on the product you are using). Gloves should be nitrile rubber with no flocking, 300mm long and 0.5mm thick. Wellies must be full length as they are easy to decontaminate if necessary, and a full clear face shield for when measuring out the concentrates, due to being at the highest risk of contamination when handling the concentrate. The product label will have further guidance as to the requirement of face protection during application, if needed.
At the end of the day, we have to remember that a pesticide is there to kill pests, weeds or fungi. As you are also a biological entity, any misuse has the potential to make you feel unwell too. We are, after all, unique and react differently to external influences, from hay fever to skin complaints, and this is no different when it comes to using these products.
Pesticides and your legal responsibility
In addition, as a professional user of pesticides, we have a legal responsibility to ensure we:
- protect the health of human beings, creatures, and plants
- safeguard the environment
- secure safe, efficient and humane methods of controlling pests
Unfortunately, there has been, and continues to be, quite a lot of misuse of pesticides, not only with professionals but also domestic users. Therefore, it is so important that professional users should be setting an example for best practice and why pesticide enforcement is now in place.
Avoiding contamination from pesticide use
Especially in and around water, the potential consequences of watercourse contamination are huge. This is because the contamination could reach the sea if not contained quickly. The smallest droplet can travel miles in a short space of time and cause terrible damage to ecosystems and possibly kill non-target species. Therefore, it is so important to:
- put in place buffer zones
- check that products have aquatic approval
- use equipment that is in good working order
- make the correct nozzle choice
If you’re not adhering to the Pesticides Code of Practice, one piece of legislation you would be prosecuted under is likely to be the Plant Protection Products (Sustainable Use) Regulations 2012. Therefore it is important to take this possible pesticide enforcement seriously.
Despite misuse occurring, there are many safe and competent users that do a great job of using pesticides only where necessary and actively putting measures in place to protect the environment, such as:
- calibrating applicators on a regular basis
- using the correct nozzles
- replacing nozzles regularly
- carrying out environmental risk assessments
- taking into consideration the area in and around the treatment site
- applying buffer zones or no-spray zones to protect specific areas
- correctly identifying the species they wish to treat
- considering the timing of the application
- reading all of the pages of product labels carefully
- controlling drift, through consideration of:
- nozzle choice (size and type)
- nozzle height
- weather conditions
- defective equipment
- direction of spraying
Pesticide use course structure
We appreciate time is in short supply and to take out a few days to complete these courses is difficult. With this in mind, we have developed our courses to run differently from the traditional method. Usually the courses are face-to-face over two-three days and a huge investment of your time. We have developed a unique way for you to access the courses, in a more time friendly and accessible manner.
PA1 is all online, from either work or home. You have access to the candidate portal, where you will find videos broken down into short topics which run in conjunction with a workbook sent to you in the post. That way, you can dip in and out of the training, completing a little each day around your timetable and not become overwhelmed with the amount to learn.
As long as you have watched all the videos, read the workbook and completed the set tasks, you will be ready for the multiple choice exam held in Settle.
The PA6a, PA6aw, PA2a and PA2f are run in a similar manner. All the theory is to be completed by yourself via the videos and workbook. You then attend half a day in Settle where the theory and practical are brought together in preparation for your assessment. Whenever possible, we hold the assessment on the same day for you, to reduce travelling back and forth.