evatech

Safety Management Services
Nelson, New Zealand

"Nufarm NZ have used the services of Evatech for many years now. Bruce Evans has a wide range of skills which we have found most useful as compliance demands have increased. He has trained both our factory staff and our experienced field and sales staff to appropriate Approved Handler status. Bruce has also been involved in securing and renewing our HSNO Location Certificates for our Otahuhu and Christchurch sites and assisting us with our Stationary Container Certification for all our bulk and process tanks. Bruce brings practical solutions to our complex range of compliance challenges."

Brendan Redmond
Production Manager
Nufarm NZ
Auckland .

Staff Training

 

Staff Training

Evatech specialises in and has been providing Approved Handler training courses for the chemical “Supply” industry since 2004.


 

Evatech’s specialist knowledge is in Agrichemical supply courses; but industrial chemical supply courses are also catered for. Contact me for non-agrichemical training courses.

[The following description applies to the agrichemical industry; many simarilties can also be found in the wider non-agricultural chemical industry].

Approved Handlers:


Under HSNO, the Act sets out requirements for persons to become a HSNO ‘Approved Handler’ if suppliers or users are to handle some of the more hazardous substances.
Agricultural spraying contractors have no choice, they all need to become Approved Handlers under the HSNO regime irrespective of the degree of hazardous substance they are applying.

Approved Handlers are responsible for product security when not in use and it’s safe and responsible application. Causing no harm to people, property or the environment when storing or using hazardous substances. Approved Handlers are expected to provide guidance to other people handling agrichemicals who are not Approved Handlers and to be available to assist them when needed.


Available Approved Handlers

A very common question is …“does everybody need to be an Approved Handler”, or “my wife is the Approved Handler for the property, is that okay?” or “do I need to have a tracking system for slug baits, sheep and cattle drenches and the weedkiller my son is applying by spray gun from the quad” ?

ERMA has produced a six page information sheet on Approved Handler interpretations: http://www.ermanz.govt.nz/resources/publications/pdfs/ER-IS-33-1.pdf


Not everyone handling hazardous agrichemicals is required to be an Approved Handler.

 

Another person may handle a hazardous agrichemical if an Approved Handler: Is present at the location where a toxic [6.1A, 6.1B, 6.1C], corrosive [8.2A], or ecotoxic [9.1A –>9.4A] agrichemical is being handled, has provided guidance to the person actually handling the agrichemical and is available to provide assistance at all times while the agrichemical is being handled.

An Approved Handler is required to be in the place of work at all times while the substance attracting the approved handler or AH requirement is in use:
On the day the toxic agrichemical is being used an Approved Handler must:
* guide the user on the particular application, including use, handling, disposal and application area, before application commences
* remain present at the property during the application.

However, the Approved Handler does not need to be present at the application area, but must be available (ie. contactable by electronic means, or in person) and able to be present at the application area within a reasonable period of time.

An Approved Handler does not need to be present if the product that triggers the AH requirement is not in use on farm or is not being handled in a retail store and is being kept secured so that a person cannot gain access.

Anyone using an ecotoxic agrichemical [9.1A –>9.4A] in a widely dispersive manner will also need to be an Approved Handler.

 

ERMA’s Tabular interpretation of ‘Wide Dispersive’ spray techniques.

Some agricultural spray techniques require an Approved Handler:

Spray Equipment types that trigger Approved Handler because the hazardous substance being applied through that equipment may be ‘widely dispersed’.

 

    Approved Handler:
    ALWAYS REQUIRED
        Approved Handler :
      CONDITIONALLY REQUIRED
      Approved Handler:
             NOT REQUIRED

Whenever the equipment is used

 

When the equipment is used within 30 meters
of the property boundaryor a water-course

Use of this equipment does not require an Approved Handler
Air-blast driven from vehicle

Air Blast back - pack

 

 

Hydraulic action back-pack (Kanapsack) Weed wiper

 
Boom spraying from vehicle, eg Tractor, quad bike Hydraulic-action handgun spray, where the supply tank is mounted on a vehicle  


Ref: ERMA Information sheet [ER-IS-33-1]number 33. April 2006.


Are all Approved Handler Certificates equal?

Users of hazardous agrichemicals; those that trigger a requirement for an Approved Handler Certificate must obtain a Test Certificate from an ERMA approved Test Certifier. Applicants for an Approved Handlers Certificate must meet the requirements set out in the HSNO Personal Qualifications Regulations 2001.

Also obtain a copy of the ERMA “Quick Guide, Approved Handlers” leaflet ER-QG-21-1 from ERMA.

ERMA has provided a package of Assessment guidelines to aid the correct issue of appropriate AH Certificates:

‘Use’: The Agrichemical Approved Handler Assessment Forms have been designed to help Test Certifiers determine whether an applicant meets the regulatory requirements for certification as an Approved Handler for agrichemical ‘use’. Use, meaning the actual application end of the chemicals lifecycle. Thus these generic assessment forms apply to farmers, growers and rural contractors who use chemicals in the field.
There are also major differences between field use and use of agrichemicals in the ‘built’ or urban environment where human exposure is quite different to field use. Thus there is a specific ‘Urban Pest Management’ Approved Handler Assessment process as there is for ‘Suppliers’ who also have quite a different exposure to agrichemicals in their particular part of the chemical life cycle.

‘Suppliers’ have their own training course known as the “National Certificate in Agrichemical Supply” that has different strands in Plant Protection and Animal Health Products”.

This course is Evatech’s recommended pathway for Agrichemical Supplier staff training.

 

Approved Handler Differences:

Clearly there are major differences between those that manufacture, distribute and retail agrichemicals [Suppliers] and those who simply use them.
Their Approved Handler Test Certificates will need to reflect their quite different exposure to an agrichemicals lifecycle.
The generic assessment guidelines supplied by ERMA for users have therefore been tailored to provide a relevant assessment process for ‘Suppliers’.

Differentiation’s between the assessment of the approved handler’s knowledge and previous practical experience, in relation to minor storage (on farm) or warehouse storage (retailer stores, supplier’s warehouses) should be reflected in the special conditions on the Approved Handler test certificate. As an example, should a farmer seeking approved handler status for agrichemicals in the use, storage and disposal lifecycles, and that farmer’s knowledge and previous practical experience was assessed by the test certifier in relation to “on farm” activities, then the storage lifecycle should be limited to reflect this. In this case the limitation on the farmers AH Certificate must then read: Limited to “on farm” or minor storage.
Clearly storage on farm is quite different to a manufacturer’s warehouse and a retailer’s store. This is why a ‘Supplier’ needs to take longer to learn and face a more rigorous assessment when proving that he or she knows all that is required to operator a supplier store.

The Test Certificate for an Approved Handler will be specific to the particular hazardous substances they are working with but must also relate to specific stages in the lifecycle of the substance.

 

Recommended staff training procedure:

The best way to meet your HSNO compliance expectations is to follow the specific industry developed Codes of Practice known for Agriculture as the GROWSAFE® Code. NZS8409.  Other industries have Codes in development.

 

ERMA recommends that Industries utilise best practices adopted by that industry and publish their own Codes that can then be approved by ERMA.
The agrichemical industry has developed such a Code through the NZ Agrichemical Education Trust. See their website: http://www.growsafe.co.nz

This Code is known as the NZ Standard. NZS 8409. The 2004 version has been approved by ERMA and is published by NZ Standards. http://www.standards.co.nz or phone  04 498 5991 .

GROWSAFE® courses have been established to train users and suppliers to a level where relevant. GROWSAFE® Certificates and Approved Handler Test Certificates can be achieved in coordination with the GROWSAFE® Trainer and an ERMA Test Certifier. 

Transport


Backgrounding the topic of transport compliance is an article submitted by Richard Bean of Land Transport NZ in the 2009 version of “NZ Novachem Agrichemical Manual”.  http://www.novachem.co.nz   

The transport by road of dangerous goods, including agrichemicals, means exposure to a different compliance agency and set of requirements. Getting things wrong on the road home from the rural retailer to the farm means possible fines from the Police in the form of the Commercial Vehicle Investigation Unit.
The CVIU staff as part of the NZ Police use the Land Transport Act 1998 and the Land Transport Rule: Dangerous Goods 2005; plus the associated NZ Standard 5433:2007 Transport of Dangerous Goods on Land as their empowering legislation.
The Transport Act and Rule regulates the movement of dangerous goods carried by road and lays down requirements for driver training, packaging, identification and documentation, segregation and vehicle placarding.
The Rule applies to everyone who transports dangerous goods on land. However, its application varies according to the nature, quantity and use of the dangerous goods.

 

What are Dangerous Goods?

Thirty per cent of agrichemicals and 15 per cent of animal remedies used in New Zealand are classed as dangerous goods, as are many other solvents dairy cleansers and chemicals used on farms. All such products, for transport purposes, have diamond-shaped class emblems on the package. The goods are also identified by the proper shipping name and United Nations number.
Agrichemicals can be both Dangerous Goods for Transport and a Hazardous Substance when ‘off the road’.


Transport Rules:

The Transport Regulations identifies two groups of people who typically transport agrichemicals in the course of their employment:

  1. Those who carry agrichemicals as tools of trade eg farmers and rural retailer reps. when they carry agrichemicals below a specified quantity; they need only comply with some of the requirements. However, when the quantity is above the level, they must comply with all the requirements.
  2. Licensed transport operators. eg 'Truckies'. They must comply with all the requirements of the Transport Regulations, regardless of the amount carried.


Tools of Trade:

Agrichemicals required on farm are considered ‘tools of trade’ in the same way as LPG bottles are for a plumber and flammable paint and turpentine are for a commercial painter.
If you carry agrichemicals as tools of trade, and the quantities are within the limits outlined in the Transport rule, you are exempt from some of the provisions that apply to commercial transport operators.
Nevertheless, you are legally obliged to take proper care when transporting dangerous goods, and are strongly advised to follow standards laid down in the transport section of the Agrichemical Code of Practice for the Management of Agrichemicals.NZS 8409.

As a minimum, you are responsible for:

Where the quantities are above the limit, you must comply with the same requirements as commercial operators do. [TSO's or 'Truckies']
The limits are determined by the Packing group of the product:

Pack Group I   = 5kg/L
Pack Group II  = 50kg/L
Pack Group III = 250kg/L

 

Commercial Operators of TSV's: [Transport Service Vehicles or 'Truck & Courier drivers] 

If you carry dangerous goods for hire or reward, irrespective of the amount carried, your vehicle becomes a Transport Service Vehicle (TSV) and must meet the requirements of the Land Transport Act and the Transport Services Licensing Act. If you fail to comply and there is an accident, the penalties could be very severe.
Beware! The legal difference between what does and what does not constitute hire or reward may be a fine one.
Drivers of TSVs carrying dangerous goods must have their driver’s Licence endorsed, stating that they have attended a dangerous goods course approved by the Land Transport NZ. Commonly named a “D” endorsement.

 

Evatech provides such a “D” endorsement course.

The same requirements apply to drivers like rural retail reps who carry agrichemicals as tools of trade, where the quantities are above the defined limits of 5, 50 or 250 kg/litres depending on packaging group.

In addition, before carting dangerous goods, TSV drivers must:

 All TSV drivers will require licence endorsement, documentation and segregation of their load, regardless of amounts carried, and they have strict limits on amounts they can carry before placarding.
For some classes of goods, placarding is required irrespective of the quantity carried. Where the goods are of low danger, and packed in small containers with strong outer packaging, some relaxation of the Act is allowed, provided no more than one tonne of these products is carried. Small packages of dangerous goods in limited quantities can be transported without dangerous goods documentation, as long as the total quantity does not exceed 50 kg.

 

Other Parties transporting DG's including Suppliers:

The HSNO Act also applies to everyone involved in the commercial transport of such goods, including manufacturers, retailers and consignors.

These parties are also responsible for a number of tasks, including:

Additional requirements apply where dangerous goods are being consigned by rail or sea, such as across Cook Strait.

"If you consign agrichemicals as part of your job, it is strongly recommended that you attend a GROWSAFE® National Certificate in Agrichemical Supply Accreditation Course or an approved driver training “D” endorsement course."

The same courses that Evatech provides and recommends.