COPING WITH THE ENFORCEMENT OFFICER’S CALL
Published 25 November 2023
This month has seen the start of a programme of farm visits by Health and Safety Executive Pesticide Enforcement Officers, with the aim of enforcing rules about the management of Plant Protection Products (PPPs), writes James Hill.
Not only are such visits time-consuming and potentially disruptive – each visit will take between two and three hours – but they also can reveal where farm businesses are not complying with the strict regulations surrounding PPPs.
However, there is one way to reduce the likelihood of such a visit. The HSE is concentrating on those farms which are not currently registered under the Official Controls (Plant Protection Products) Regulations 2000, so the easiest way of avoiding their appearance at the farm gate is to register, which is a relatively easy process (to do so, follow the link at the bottom of this article).
For those who are not registered, a visit is most likely to occur for farms of over 150 acres which have not been visited by HSE in the last five years.
So what does such a visit entail? First, you should be aware that HSE can arrive unannounced, and although this is not always the case, it does happen. Once on the farm, the enforcement officers will focus their attention on the management of PPPs, looking at both storage and usage.
They will want to satisfy themselves about suitable training for those involved in both storage and application of PPPs. They will look at storage techniques, including bunding and inventory; they will examine how PPPs are mixed and disposed of, and they will want to know how the farm deals with PPP spillages.
Record-keeping is important. The officers will want to see application machinery calibration and maintenance records, as well as spray records. They will also want to inspect the oversight of contractors, including record-keeping of their activities.
Finally, the officers will want to inspect the farm’s Local Environmental Risk Assessment for Pesticides (LERAP), and in particular how buffer zones have been observed, and water courses and Sites of Specific Scientific Interest have been protected.
One of the most common breaches of the regulations is the storage of unauthorised PPPs. If you are fortunate enough to have notice of such a visit, you should check your stocks and dispose of any unauthorised PPPs using a licensed hazardous waste disposal contractor.
But perhaps the best way of avoiding the hassle and disruption of a visit is to register your business as an operator and user of PPPs in the first place, and ensure all record keeping and maintenance is up to date.
- To register as a professional user of plant protection products, visit: https://www.gov.uk/government/publications/professional-plant-protection-products-ppps-register-as-a-user/how-to-register-as-a-user-of-professional-plant-protection-products-ppps-and-adjuvants.
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