There are a variety of terms used to describe the mixtures used to kill weeds: “plant protection product”, “herbicide”, “pesticide” – these words could all refer to the same bottle of Roundup sold over the counter at any one of hundreds or thousands of shops across the UK – or the professional products that INNSA members use to combat invasive species.
Personally, I am not afraid of any of these terms. Having studied chemistry at university and as a qualified pesticides advisor and a health and safety professional, I have a reasonable understanding of what these things are and how they work – although, of course, this is a field which a great many professionals have dedicated lifetimes of work to understanding, developing our collective knowledge and the regulation that underpins safe usage.
People often distinguish between “natural” and “artificial” or between what they regard as “chemicals” and some undefined other category of “things which aren’t chemicals”. To approach this topic objectively, however, it’s important to understand that the term “chemicals” technically describes basically everything in the universe apart from light… it doesn’t just mean bubbling vats of toxic green stuff oozing out of comic book laboratories.
I’m interested in the properties of the substances we use – from our cleaning products to our fuels to the products we apply on invasive species in the field… Herbicides, pesticides… terms like “toxic”, “carcinogen”, “teratogen”, “concentration”, “persistence”, “half-life”… understanding what these mean and the potential effects a particular substance has, how it behaves in the environment, whether it will break down, how quickly and into what… All of these factors determine how we should use these products, what measures we need to take to protect the people who use them and how we protect our environment from the potential harmful effects they could cause.
As I stated above, it’s not only the herbicides that contractors use on sites which have potential harmful impacts – for example, domestic bleach products raise concerns both in terms of manufacture and the by-products generated by their use.
That said, though, for mixtures expressly designed to kill plants, it’s critical that we store, manage and apply these products with the utmost care. Anyone who advertises, sells, supplies, stores or uses pesticides is bound by legislation. The Plant Protection Products (Sustainable Use) Regulations 2012 states “Anyone storing PPPs should follow practices consistent with those detailed in the existing Codes of Practice…”
The gold standard for the management of pesticide stores is the BASIS Store Inspection Scheme (including the BACCS scheme for amenity contractors), which covers an extensive list of standards which a store should meet in order to be safe and well managed. BASIS schemes (including those for agricultural stores certify around 530 stores in the UK – from stand-alone “chem-safes” used to store small amounts of product, small stores to supply single farms, all the way up to vast warehouses used by retailers to store their stock. Unfortunately, amenity stores are somewhat under-represented in the scheme, with those registered tending to be the larger stores of retailers and bigger contractors.
While the list of standards is way too extensive to reproduce here, there are some key underlying principles worth exploring.
- The key function of a store is to prevent the uncontrolled release of pesticides into the environment. A store must be able to contain liquids released by spillages or the uncontrolled breakdown of pesticides containers that might occur in a fire, for example. There are extensive provisions in the audit for checking the construction, layout and structural integrity of a store.
- A store is not just a building – vans or other vehicles used to transport pesticides may be considered as stores themselves and any vehicle used to transport pesticides must meet certain standards.
- A store must be safe to use. Layout, ventilation, lighting, signage, information and equipment should all be in place, and the store should be managed in line with health and safety best practice, including risk assessments, training, accident recording and other procedures. Appropriate protective equipment must be available for people entering and working in the store.
- A store must be managed properly. This includes record keeping, signage and other housekeeping, but also the requirement to have a trained Nominated Storekeeper in charge of the store and a certified pesticides advisor to provide recommendations on use of the products in the store.
- Proper stock control and management of waste (including procedures for managing spills and out-of-date or withdrawn pesticides) must be in place. It’s also important to have suitable controls to ensure that a store contains only products that are approved for sale, storage and use in the UK.
- Certain categories of pesticides (particularly rodenticides and other poisons) require much more strict regulation, storage and tracing.
- A store must be safe in the case of an emergency – this could include flood, fire or other emergencies, and it’s important that each store is set up to prepare for such occurrences and that there is an Emergency Contingency Plan in place to manage the actions required. Emergency equipment should be tested regularly and regular fire drills and spill tests should be carried out.
- A store should be registered with the relevant authorities – this particularly includes the local Environment Agency, fire authority and police.
While registering your store with BASIS is not a legal requirement, there are a wide variety of legal requirements that a pesticide store must meet – and annual auditing by BASIS ensures that these standards are met. It is also important to note that, because anyone who sells professional herbicides or who is an end user of professional products must register with DEFRA under the Official Controls (Plant Protection Products) Regulations 2020 (the “OCR”), basically any business with a pesticides store should be registered. BASIS works closely with DEFRA, DEARA, HSE and CRD with regard to OCR PPP Regulations.
INNSA supports both the BACCS scheme and the registration requirements and inspections carried out under the OCR (although we are lobbying DEFRA to try to help them to make the most out of the register they have built up), as part of our core aims, which include “Encouraging the highest standards within the industry” and “Providing customers and clients with peace of mind and quality standards assurance”.
Registration with a BASIS stores inspection scheme helps to ensure that you will be compliant with any DEFRA audit and that you will be compliant with the law, which would be particularly crucial in the event of any environmental incident.
It is crucial that the storage of pesticides is managed in a safe way and that all reasonable measures are taken to prevent potential environmental incidents due to pesticides, which is why these standards are core to being an INNSA contractor member.