Have you checked your store lately? Many of the old stalwart pesticides of the groundsman have now passed into history -- or have they?
The recent case of groundsman' s family being paid £5000 damages by the Employer' Insurance Company, as the employer was not able to prove that he had adequately looked after his employee whilst using pesticides and sprayers, has highlighted our problems . Can you prove that you have provided adequate welfare facilities, training and supervision for your employee - every time you have asked him to spray?
Let us look to see how pesticides and their application have been updated over the past few years:
Remember several chapters ago we looked at the four basic pillars of H&S -
People : Plant : Practices : Premises, - to this we must add
Products used.
PEOPLE
Are your operators qualified to spray? Have they attended MAFF approved update courses? Have YOU attended a MAFF approved update course?
You may have learned from experience how to spray over the last forty years but you must attend a course to ensure you know what is required under the FEPA Regulations or the new H&S Regulations!!!! Ignorance of the law is no defence in court.
TRAINING
The new update of the Pesticide Regulations is now through ( as of 1/6/94). All operators are now being asked to understand the implications of COSHH and the COSHH Assessment. Operators will be asked to understand the terms of Maximum Exposure Limit (MEL) and Occupational Exposure Standard (OES) and will be asked about these during the PA1 test. The minimum age for applying for a test is now 16 years.
PRACTICES
Safe working practices must be made up and adhered to - these are
obviously based on the update courses attended and the Pesticide Approved Code
of Practice.
The update also suggests
PLANT
Engineering Controls
The development of controls in the amenity market has been troubled by some mis-information. Many salesmen are telling us that their products are now 'required by law' when no such law exists. They can be recommended and in some instances their product would appear to give the safest alternative, but law no. The latest incidence of this is the promotion of the mixing hopper to be fitted to a tractor hydraulic sprayer. On large sprayers this is almost 'de rigour'. However, in the majority of sprayers I see around grounds and golf courses, usually around 200 litre tanks, the mixer tanks would be almost as large as the sprayer tank!!
The APPROVED CODE OF PRACTICE requires you to look at how the pesticide is added to a tank and if this requires you to lift the measure and contents above chest height, investigate ways of preventing this - generally either to lower the sprayer on the hydraulics or if this is still too high to have steps and plinth to climb onto, to allow you to pour into the tanks at a better angle - the plinth would obviously have to be firm, the steps capable of being climbed with one hand carrying the measure, etc., etc.
PREMISES
There are some basic considerations which should be made
PRODUCTS
Many of the 'nasties' have now been taken the off the market.
Mercuric chloride has gone, as has Sydane in 1992. This year, we saw the
withdrawal of anything containing simazine or atrazine for use on areas of hard
standing. This was due not as protection to the operator but due to the
potential build up of these chemicals in our water supplies.
Gesatop (simazine) can still be used on nursery stock and
forestry as long as you do not get it into waterways - recommendation is that
whilst using a Tractor mounted sprayer keep at least 2 metres from ditches etc.
and 1 metre whilst using a knapsack.
Ioxynil is a problem in all its products, Actrilawn, Super Verdone etc., as it can only be used with a tractor sprayer - use with a knapsack breaks the law!!!
PREVENTION : Substitution & Elimination - are you using safest effective product? Is there a substitute? Why are you using a more toxic substance? Why are you using a more difficult to handle formulation?
I recently made out a list of the pesticides used on Golf Courses and Sportsgrounds and can see a clear trend towards using safer pesticides.
Obviously if the less the hazard - the less the consequential risk - all other things being equal.
The major breakthrough recently was ROUNDUP BIACTIVE and HILITE - glyphosate based pesticides from Monsanto - which, by the use of safer adjuvants, has allowed the product to be registered with no hazard classification on the label. This means that the risks must be lower for affects on the operator, general public, cats, dogs, etc. Can you reasonably choose a toxic pesticide to use in a public area when such a safe pesticide is available?
Remember that you still must do a COSHH Assessment on this product - a much simpler one admittedly - as it is still looked on a 'substance with comparable risk'.
CONTROL : Are the controls in place, maintained and used
PERSONAL PROTECTIVE EQUIPMENT : What PPE is required? is it
readily available? is it adequate to protect the operator in his circumstances
of use? is the operator trained to use it? is it personal? Is there adequate
storage facilities? where is it cleaned?
If you have products which no longer have clearance you must get rid of them to an Approved Waste Disposal Contractor This is an expensive operation ( figures of £25.00/ litre are suggested).
Don't cause the problem - keep stock levels to a minimum, buy the amount required, mix the amount required, use up all extras in the tank on suitable crop, use old stock first!
Have you checked your store lately?