evatech
Safety Management Services
Nelson, New Zealand
AgriBusiness. Issue 63. May/Jun.2008. HSNO-Series. Bruce Evans
Being An Approved Handler Isn’t Just About The Certificate!
Many farmers incorrectly assume there is a grace period for buying agrichemicals without an approved Handler Certificate. There is a whole lot more to be an Approved Handler than just attending the training course.
Last issue we covered the Nielsen Company’s Farm Market Index (FMI) survey of December 2006*, in which 798 farmers nationwide were asked for their opinion on HSNO and its requirement for Approved Handlers.
Some media reports flowing from that survey refer to HSNO warnings appearing to fall on deaf ears, with many farmers incorrectly assuming there is a grace period for buying agrichemicals without an AH Certificate.
Equally concerning was the 20 per cent of AH trained farmers who said they found nothing new in the training they had undertaken.
These areas of concern about compliance uptake call into question the impact of the training which some survey respondents viewed as unnecessary law unlikely to ever be enforced.
These questions were being aired in the media at the same time as a very relevant agribusiness conference organized by the Agriculture Industry Training Organisation (Ag-ITO) took place in Christchurch.
‘Developing our People’ attracted some top overseas and local speakers and offered the prospect of some firm monetary gain to be had from investing in staff training.
Staff Training's a cost not an investment?
Often staff training is just seen as a cost and because it is “only a compliance thing anyway” little effective pre-course preparation and post-course follow up is actually carried out by management to make the best use of the actual training event.
Dr Robert Brinkerhoff from the US had all the facts and figures to tell the audience of agribusinness trainers that it isn’t the actual training course itself that’s important - pre-course preparation and post course follow-up make the whole training exercise worthwhile. Casting a long shadow over this training talkfest was the Tertiary Education Commission (TEC). As the Government’s provider of funding they have made it clear funding for training will be provided in a very different way known as “Investing in a Plan”. The Government reforms under the new system are going to have an impact on staff training budgets one way or another. Watch this space as the lobbying for education funding impacts on agribusiness in the future.
Some people are already scratching their heads about the direction and focus of TEC’s planned new funding regime.
TEC Funding plans:
Recently it supported a $96,000 scholarship awarded to a Waikato student to study Bogans and Heavy Metal Fans. TEC claimed this would enhance better understanding of younger people! In case you are wondering about the purpose of all this discussion on the effectiveness of compliance training… let’s look at three examples of HSNO non-compliance that occurred this autumn. Each rural retail store in question has at least two trained Approved Handlers.
Three examples of HSNO non-compliance:
- Example 1: The entire stock of a highly flammable pour-on is displayed in the retail area while there is ample room in the supplied Class 3 fire-rated storage zone. Total aggregate amounts of flammable product when combined with turps, meths and other flammables are well in excess of the HSNO threshold for a separate zone and Location Certificate.
- Example 2: The isolation zone set up for class 5 material is loaded with incompatible Class 8 dairy cleansers. What chance do suppliers have of encouraging farm compliance when customers see incompatibles alongside each other at their retailer?
- Example 3: Toxic tracked substances of 6.1B and 6.1C status are openly displayed for clients’ children to handle in the retail area.
These three stores were branches of different retail chains that use different trainers.
The common denominator was that staff knew what to do when the problem was pointed out, but they report there was no follow up after their HSNO training courses.
In other words their training wasn’t backed by an effective management plan of what to do now, post the training course.
Labelling being short changed:
There’s another issue here too – labels which do not convey the necessary signals that retail staff need to drive their compliance activities.
The storeperson with all his flammable pour-on out on display pointed out the complete absence of any class 3 signage to alert him.
The outer shipping cartons were all correctly displaying legal signage but once unpacked the inner packs had no Class 3 identification.
Many manufacturers do not label inner packs; this provides problems at the retail and use end of the chain.
Differing label policies adopted by various manufacturers cause confusion. Some don’t put HSNO Class numbers on at all.
Tracking statements and awareness is something that Agcarm is asking of members to help retailers avoid compliance mistakes.
There is an increasing need for both parts of the supply chain to be much closer in their efforts to supply farmers with effective compliance tools including information.
A reader of this magazine in February 2003 reminded me of something I predicted then.
“Without close relationships throughout the supply chain, suppliers will struggle to adequately meet HSNO’s requirements, let alone the user’ requirements to meet all sorts of compliance expectations. Users will expect and need help from the supply chain to comply with their information and documentation requirements.”
Agcarm is encouraging all manufacturers to support the Pest Genie scheme to enable the information requirements of HSNO to be met at point of sale (www.msds.co.nz)
* Nielsen’s Farm Market Index (FMI) is a bi-monthly survey of approximately 850 farmers across the nation. For more information on the FMI please contact Maree Luckman on (09) 970-3659.