evatech
Safety Management Services
Nelson, New Zealand
AgriBusiness. Issue 64. Jul/Aug. 2007. HSNO-Series. Bruce Evans
What sort of HSNO help are you getting?
Sources tell me farmers are happy about the fact they forced ERMA to back down on requiring Approved Handlers for petrol on farms. Codes of Practice advocated by ERMA.
When ERMA makes variations to its default controls it normally leads to howls of ‘why not let me off too?’
Some rural petrol users and suppliers are looking at their own compliance situation in the light of this latest decision.
They have to upgrade their deemed Transitionary Approved Handler Certificates into the full five year version and upgrade their location facilities. They wonder not only if ERMA is serious about petrol controls but also if the major fuel companies are committed to HSNO compliance. Some rural fuel suppliers are still being supplied with out of date Safety Data Sheets that carry absolutely no reference to new HSNO classifications and controls.
One surprised supplier pointed out the bulk fuel tank farm at his local port terminal was still proudly saying its business was conducted under the auspices of the long-defunct Dangerous Goods Act (see photo).
This supplier wonders why he has to comply with HSNO demands for new signage etc when the major source of his fuel is apparently still operating under old legislation.
Whether the major suppliers are compliant or not, the public signal provided by out of date signage and SDS’s is one of very slow response to HSNO. New Zealanders are a fair-minded people who believe in even-handedness - they don’t like seeing some appearing to be getting away with doing nothing.
Some rural fuel suppliers report a lack of leadership and commitment by some parts of the fuel industry in providing guidance and assistance with HSNO.
Fuel Industry dragging it's feet:
The fuel industry was a year or two ahead of the agchem industry in ERMA’s timetable of HSNO compliance and should in theory be somewhat ahead of the agchem industry by now, i.e. fuel companies should have fully compliant SDS’s and label type information.
Agchem interests bargained another year of precious label changeover time because of the length of their supply lines etc.
By now, however, most labels on new stock and safety data sheets should be fully compliant. Some sectors were given more time to comply because they started the HSNO transfer process later. Two years or more after transfer to HSNO, do a reality check of your store and observe for yourself the large number of agrichemicals not carrying HSNO compliance signals on either labels or SDS.
Then think about how difficult it will be to sort out your HSNO control strategy if you don’t know the classifications of substances you are dealing with.
Agriculture leads way with COP:
The agchem industry did what ERMA expected early in the transitionary period by publishing a Code of Practice (COP).
The Management of Agrichemicals NZS8409 is now well established as the industry’s training document and provider of HSNO guidance.
There are 20-30,000 trained agricultural Approved Handlers who have all had some exposure to the Code.
Compare this to the fuel industry’s lack of equivalent Codes. The service station industry with all those employed in it pumping and handling Class 3 products has just got its potential COP to the draft stage.
The document is now with ERMA in dossier format – a case of better late than never I suppose.
My supplier clients tell me the most consistent problem they face with getting staff to institute HSNO controls is the low percentage of products that are backed with upgraded HSNO compliant labels and SDS.
Although progress has been made by several crop protection suppliers via provision of HazNotes, most animal health products are still supplied with their old pre-HSNO labels and SDS’s etc. As I mentioned last time, differing label policies adopted by various manufacturers are causing confusion at the point where a retailer unpacks new stock arriving off the transporter and looks in vain for clear HSNO signals as to where and how the new product should be stored.
More labelling confusion:
This week a retailer told me how difficult it was to understand label signals on a brand new dairy sanitiser that is a class 5.1.1B oxidiser.
It has its own unique black and white version of the Class 5 DG label.
The retailer knew that Class 5 material should have a yellow pictogram.
In addition the product is a 6.1B and requires an Approved Handler but nothing on the pack drew his attention to this.
The hazard signal word used for the product was ‘Caution’ which is not what the SDS and industry COP recommend for such a hazardous substance.
Is your company using the Agricultural Chemical Industry COP? Go to the Agcarm website: http://www.agcarm.co.nz/Document.aspx?Code.