Best Practice in the Amenity Sector has been widely publicised recently with the relaunch of the Amenity Assured standard at Pride Park on 22nd November, the Amenity Forum's response to SUD and an increased awareness within Amenity of the need to protect water courses and the potential impacts the Water Framework Directive could have.
It is very easy to concentrate on application practice and ensuring Sprayer Operators are applying pesticides correctly, but best practice comprises many other strands such as maintenance, disposal and storage.
Winter is an ideal time to get your Pesticides Store in order, you may even wish to consider building a new store if you do not have one currently. So, what do you need to consider when planning a Pesticides Store or making improvements to an existing store?
Location, Location, Location! Is your store a Des Res?
When planning a new store, consult the Environment Agency and Local Planning Authority. The design should comply with the Code of Practice for suppliers of pesticides to agriculture, horticulture and forestry (Yellow Code), this is available on the Pesticide Safety Directorate's website pesticides.gov.uk, along with the Code of Practice for using plant protection products (Green Code), which gives more general information on storage.
If you store in excess of 200kg or 200 litres of pesticides, which you sell or supply to others, then the store must be constructed to certain legal standards and you must have a qualified BASIS Nominated Storekeeper (NSK). You may also wish to become a BASIS Registered Store, which involves an annual audit to ensure compliance.
Regardless of the size of store, there are a number of key factors which should be taken into account at the planning phase:
• Location - stores must be well sited; make sure there is easy access for deliveries and collections and keep these access routes clear
• Size - is the store capacity large enough? Consider manual handling and avoid lifting bottles down from above shoulder height
• Access - there should be someone on hand who can put deliveries directly into the store, logging them into the Pesticides Record Log as they do so. Ensure good access for emergency services and make sure site staff all know what to do in the event of an emergency
• Contamination - when designing a new store, make sure it is situated well away from watercourses, including wells and boreholes. Also consider whether your site floods, and think about where the flood water runs off or drains to. Avoid situating the store in this area and areas with a high water table
• Fire Prevention - don't situate the store near combustible materials such as wooden pallets, fertiliser and fuel. Where it is not possible to have a separately built store, or the store is within a larger building used for a number of purposes, locate fuels and pesticides at opposite ends of the building ensuring that emergency exits are not impeded. Remember the Fire Triangle, for a fire to take hold 3 things are needed, fuel, heat and oxygen. The latter is a little tricky to control, so isolate your store from sources of heat and fuel
• Containment - the store must be bunded and capable of holding 110% of the maximum store capacity
• Protecting People - never situate a store inside offices, break rooms or anywhere food is stored
• Lighting - the store should be well lit with additional artificial lighting if the store has windows; lighting needs to be bright enough to allow you to easily read product labels
• Construction - there are various standards related to construction and ventilation; the Green Code and Yellow Code will give you more information on these
• Security and Signage - the store must be capable of being locked, protected from vandalism and clearly marked as a Pesticides or Chemicals Store with an appropriate sign
Running the Store
• If required, make sure that a storekeeper has been appointed and trained; the best managed stores are usually those with a well trained storekeeper
• Once the store is operational, maintain good housekeeping to make it as easy as possible for anyone delivering or returning stock to put it directly in the store, and resist the temptation to leave containers lying around the yard where they can be kicked over or spilled
• Keep the flow and location of stock logical, making sure different herbicides aren't mixed up. Part containers should be at the front to make sure they are used first, and practice good stock rotation by bringing old stock to the front and putting new stock at the back
• Invest a little time and effort in sorting out your stock; consider racking or shelves to keep stock tidy and easy to get at. Where the store contains powders and liquids, always store powders in sealed containers above liquids to prevent spillage and reaction. For more specific information on storage of individual pesticides refer to the product Material Safety Data Sheet
• Quarantine any damaged or leaking containers; these should be stored in a separate container, such as a lidded plastic box, whilst disposal is organised
• Quarantine any products with missing or illegible labels and anything which has expired; these products can be disposed of using a specialist contractor
• Seek specialist advice when storing any products requiring specialist storage, such as oxidising agents or gassing compounds. Poisons (as specified on the label) must be kept together, under lock and key, in a separate part of the store
• Empty containers should not be stored in the Pesticides Store; triple rinsed containers should be crushed, bagged and disposed of. Various plastic recycling schemes will take properly processed chemical empties off your hands, as will some distributors
• Accurate record keeping is a must. Each store needs to have a record of movements in and out of the store and dates of manufacture or delivery. As well as an in store log, a copy of this information should be held outside the store in case of emergencies, as it gives Emergency S ervices an accurate idea of what they are dealing with. Every time pesticides enter or leave the store it should be documented in the log, a simple record consisting of date, name of person, pesticide, batch number, amount removed, amount returned and volume used is sufficient
• Have a spill kit on hand containing absorbent granules or other inert material such as sand, drain covers if you have drains nearby, bags and ties and a dustpan and brush
• PPE is also required; as a minimum, there should be the following chemical resistant PPE which should be stored in a locker or box where it cannot become contaminated: face shield, coveralls, apron, boots and gloves; additional PPE such as a respirator may be required depending on what is in the store
• The store First Aid provisions should include an eyewash station and first aid kit
• Emergency procedures should be available. However, it is advisable that there be a copy situated away from the store in case of fire; all those using the store must be trained in the emergency procedures
Managing the Store
This element is key to compliance and maintaining best practice. The store should be well managed with a Nominated Storekeeper, well trained staff who are aware of procedures and a set of written procedures in place which cover the normal operation of the store, emergency procedures and record keeping. A programme of regular auditing should include a review of these procedures to check that they are still relevant, practical and in date.
Carry out an annual self assessment of the store, use a systematic approach to look at all aspects of the store from design to operation and management; it helps to have a ticksheet or formal audit form.
When considering design, look at whether the store does what it is supposed to, think about security and suitability. For example, is there enough room for the stock? Does the light work? Is it secure?
Moving onto the operation of the store. Consider the stock rotation, check that all the products are still approved and make sure everything is stored correctly and that empties are cleaned correctly and stored in a separate area.
Look at PPE and emergency preparedness. Is the spill kit intact or does anything need replacing? Is all the PPE where it should be and is the First Aid Kit and eyewash still in date?
Finally, look at management and training. Assess whether the procedures and emergency procedures are adequate, easy to understand and accessible to all staff. Check the pesticide records and logs to make sure that record keeping is accurate, and check whether staff are all trained.
Once the audit is complete, make a list of anything which is missing or not up to scratch and decide on a date that improvements must have been done by and allocate actions to individuals. To make sure improvements are put in place, set a review date and re-audit as necessary.
For more guidance on pesticide storage refer to the Voluntary Initiative's guidance note entitled Pesticide Storage. This includes a useful self assessment guide. Detailed information on good practice is given in the HSE Guidance Note: Safe Storage of Pesticides on Farms and Holdings (AIS16) in addition to the Yellow Code.
The Voluntary Initiative and the PSD are great sources of information and have produced a number of factsheets and guidance notes which are useful aids for training and staff development. Consider having a Pesticides Noticeboard or, if you are short on space, a folder in your workplace where staff can find up to date information and advice on pesticides, including guidelines for calibrating, mixing, rinsing containers and disposals.
Article writtten by Victoria Wall BSc Hons, MBPR & NPTC Assessor
SHEQ Compliance Officer