evatech

Safety Management Services
Nelson, New Zealand

AgriBusiness. Issue 67. Jan/Feb 2008. HSNO-Series. Bruce Evans

HSNO happenings

Some good and bad examples of compliance actions in retail and manufacturing stores.

As 2007 concluded with a flurry of consolidating activity in rural retail distribution, compliance activity wasn’t exactly the hot topic at Christmas BBQ’s.

Rationalisation and mergers:

The lead item instead was speculation regarding Merial/Ancare’s decision to supply solely through veterinarians and also the impact of the continuing reduction in the number of agrichemical retailers, particularly in Canterbury.

In the light of which it’s perhaps not surprising that all the HSNO compliance activity that was supposed to be all wrapped up and in place during 2007 ended up being overshadowed by wider industry activity.

Some suppliers faced their third Location Certificate revalidation; many their second during 2007. All relevantly trained Approved Handlers with their ‘Supplier’ qualification and CSL for Vertebrate Toxins were also supposed to be in place.

HSNO compliant Labels and Safety Data Sheets [SDS’s] were also all due to be available in 2007. As has been observed in these articles before, it is not uncommon for supplier staff to disregard or perhaps not understand the storage and segregation information on outer packaging, locating new stock in inappropriate places based upon their best guess from the labels on inner packs.

Often retail staff complain that all manufacturers are not yet labeling the inner retail packs with the critical HSNO and DG identifiers that would make their decision making more effective. There are some manufacturers who have provided their own ‘in-house’ information ahead of the HSNO deadlines and there are some suppliers who have provided the Agcarm recommended ‘HazNote’™ which is an excellent source of information for both retailer & farmer. See www.msds.co.nz As the 2008-year begins this pattern of patchy compliance uptake is worthy of further observation. In 2007 I had many first hand experiences with both manufacturer and retailer on this issue.

HazNotes a sign of proactiveness:

There are some excellent examples of pro-active activities, eg the Agcarm HazNote initiatives and the provision of their Code of Practice for labelling, both of which have been well-utilised by some companies.

There are also excellent examples where suppliers have provided at considerable expense a full range of emergency management items like spill kits, bunding, signage and segregation devices. However the well-intentioned provision of ‘hardware’ doesn’t always provide the compliance solution on its own. There need to be robust and well-rehearsed procedures and policies and the key item: effectively trained staff who demonstrate consistent safe practice.

The good, the bad and the costly:

Some examples of good and bad, from the mix of reality that is current practice in both manufacturer and retailer stores:

The retailer faced with the practical limitations of his old store and the extreme difficulty of providing secondary containment for all of his 9.1 Ecotoxic substances. Worked out that a healthy proportion of these products like Baton, Trounce etc are dry granules and that compliance could be more easily achieved by aggregating all the dry products in one area and simply providing close at hand shovels and brooms; no extra bunding being possible or needed. This allowed the store to provide a smaller bunded area elsewhere for the liquids. This store operator was facing the third revalidation of it’s HSNO Location Certificate and it was most encouraging from a Test Certifier’s perspective to see that product separation was just as effective the third year as it was in previous checks. The staff had all completed the industry recommended three-day National Certificate in Agrichemical Supply and the company had worked through an operating procedure with its staff.
The manufacturers with well established procedures pre-dating the HSNO era who failed their second HSNO store revalidations because the pressures of peak production had forced the storage of flammable finished goods in inappropriate storage zones in excess of their permitted HSNO threshold levels. In another case the proper Class 3 storage zone was being compromised by so-called ‘temporary’ storage of other classes in the pallet racking aisles. Thus the integrity of the agreed dedicated Class 3 area was effectively upset whilst that temporary product sat in aisles blocking any emergency response access. The common denominators in these cases was not the lack of sound policy, but the presence of untrained or new staff who had not been made aware of the companies’ and HSNO’s compliance expectations.
The manufacturers and retailers who had dedicated Class 5 storage cabinets seriously compromised by staff storing incompatible substances in the same cabinets. These were all revalidations, where these potentially dangerous situations should not have occurred. Untrained staff and lack of supervision or provision of any safe procedures were the common factor. One staff member said his one-day Approved Handler course did not cover the aspect of product separation for incompatibles in storage.
The retailers who have decided to cover many of their stores with a HSNO Location Test Certificate even though they do not need to because the storage quantities held by that store fall below the legal thresholds. This is a proactive move that provides at some annual expense a ‘third-party’ check on their overall compliance.

Some welcome a third-party check !

Some companies see the annual HSNO Test Certifier visit as a welcome check on the robustness of their systems. In the cases mentioned above the suppliers concerned all thanked me for pointing out the shortcomings and saw the whole process as being worthwhile.
On the other hand, there were a number of sites that saw the “whole HSNO thing” as a cost. Many point to the HSNO quantity thresholds as a mechanism to argue that because their stocks are below the HSNO limits, no compliance activity is required on their part. Some fail to recognize that spring time or other seasonal highs for some isolated Classes can invoke the HSNO compliance system if only for a short time. Some companies have let lapse their HSNO Location Test Certificate because they have destocked certain products to bring the stock levels below the HSNO thresholds, thus avoiding paying for the annual third party check.

Who’s to say who has got it right, the proactive ones or the minimalists? Either way, what is essential is a fail-safe compliance strategy that prevents accidents and legal costs.