Peter Arkle of Syngenta Corporate Affairs provides a comprehensive overview of what risk and hazard management look like in a pest control business.
Risk and hazard management can be complex in some work environments. Most of the time it can be relatively simple if we follow a few basic steps. We, as manufacturers of pesticides, and you as employers, need to ensure we are not only abiding by laws but also proactively managing these risks.
Product stewardship is the responsible and ethical management of a product from its discovery to its ultimate use and beyond.
FAO International Code of Conduct for the Distribution and Use of Pesticides
The FAO International Code of Conduct for the Distribution and Use of Pesticides sets out the principles of product stewardship which are required to ensure increased food security at the same time as protecting human health and the environment and supporting a sustainable future.
Product stewardship is a life-cycle approach and thus addresses all major aspects related to the development, regulation, production, management, packaging, labelling, distribution, handling, application and use and control, including post registration activities and disposal of all types of pesticides, including used pesticide containers.
The overall aim of product stewardship is to ensure that all pesticide products are used safely, appropriately and responsibly. Product stewardship can be seen as a range of activities to minimise the inherent risks associated with pesticide use. These risks might be to human health, or to the environment, in particular to water and non-target organisms.
Why does product stewardship matter?
Beyond our basic obligations and corporate responsibility, product stewardship brings value to the business by:
- Mitigating risk and minimising potential issues
- Helping to maintain product registrations
- Creating opportunities to engage at different levels with stakeholders such as distributors, advisers, governments and NGOs
- Helping pest managers to use products more efficiently and appropriately and facilitating access to technology, thus increasing productivity
- Enhancing our corporate reputation
- Creating a communication platform for raising the profile of the industry.
Good stewardship is based on good communication.
How do we define risk?
Risk analysis is based on the outrage and hazard dimensions. Understanding the nature of the risk elements can help you develop the most effective communication strategy. Given outrage and hazard are barely correlated the communication strategy has to address the nature of the risk differently.
Risk is the probability that a particular adverse event will occur during a stated period of time under specified conditions. If we take measures to minimise potential exposure, then we can minimise risk.
If we think about it, everything in life is a potential hazard. There are risks we can reduce or control, but for practical purposes there is no such thing as a zero-risk life.
In terms of hazardous substances, the critical factor is not the intrinsic toxicity of a substance, but the risk associated with its use. This point is one of the basic principles of toxicology and is important to keep in mind.
Risk and hazard are not the same. A hazard is something that can cause harm, whereas a risk is the likelihood that the hazard might actually occur in a given time or under certain circumstances. For example traffic is a hazard, as it has the potential to cause harm to pedestrians. But the risk is reduced if the pedestrians cross at the lights when the walk sign is green and the traffic has stopped. Therefore, we can assume it is safe to cross when the walk sign is green. This of course is not always true, as unexpected circumstances might occur, such as a truck’s brakes failing.
Examples of harm are injury, illness, disease, death, mental illness or emotional distress. Sometimes psychological effects can be just as damaging as physical.
If we take measures to reduce exposure to the hazard, then we reduce the risk – this is the core principle of risk management.
How is the risk assessment for pesticides done?
The hazard is based on the results of toxicity studies with the active ingredient. For pesticides these are mainly studies with animals, with data from humans only available in some rare cases. A huge number of studies are conducted on each new chemical to build a database on its potential hazards. This data is then used to conduct a risk assessment incorporating safety factors. The data forms the basis of the regulatory submission that is assessed by government authorities to gain registration of the chemical.
Work Health and Safety (WHS) legislation and duty of care
Section 19(1) of the WHS Act states:
1. A person conducting a business or undertaking must ensure, so far as is reasonably practicable, the health and safety of:
- (a) workers engaged, or caused to be engaged by the person; and
- (b) workers whose activities in carrying out work are influenced or directed by the person, while the workers are at work in the business or undertaking.
2. A person conducting a business or undertaking must ensure, so far as is reasonably practicable, that the health and safety of other persons is not put at risk from work carried out as part of the conduct of the business or undertaking.
In this Act, reasonably practicable, in relation to a duty to ensure health and safety, means that which is, or was at a particular time, reasonably able to be done in relation to ensuring health and safety, taking into account and weighing up all relevant matters including:
- (a) the likelihood of the hazard or the risk concerned occurring, and
- (b) the degree of harm that might result from the hazard or the risk, and
- (c) what the person concerned knows, or ought reasonably to know, about:
- (i) the hazard or the risk, and
- (ii) ways of eliminating or minimising the risk, and
- (d) availability and suitability of ways to eliminate or minimise the risk, and
- (e) after assessing the extent of the risk and the available ways of eliminating or minimising the risk, the cost associated with available ways of eliminating or minimising the risk, including whether the cost is grossly disproportionate to the risk.
Some simple questions to ask when working with chemicals are:
- Is this product registered?
- Does the product work effectively?
- Is there a suitable product that is less toxic to my staff?
- How is product being transported?
- What is the poison scheduling of the product?
PPE and administrative procedures are often the first solution applied to assist in the management of hazards in the workplace. However to a certain extent they rely on the human behaviours and are less reliable than eliminating a hazard or substituting a safer alternative.
Controls based on elimination or substitution
Is it possible to find a safer substitute for a product? Integrated Pest Management is the systematic combination of the safest, effective methods to reduce or eliminate pests.
- Is pest control necessary?
- Is a chemical control method the best option?
- What product is most appropriate and how should I apply it?
Before applying a professional pest control product chemical, it is important to establish the need to spray (and through doing so rule out elimination).
Controls based on separation/isolation
Is it possible to separate the hazard by distance or a physical barrier?
- Ensuring mixing and loading is done in still or low wind conditions facing away from the prevailing wind
- Avoiding pouring chemicals at eye level
- Ensuring products are kept in lockable storage
- Erecting signage and barriers to ensure that only authorised people are allowed into the mixing and loading area
- Constructing a designated mixing and loading facility with a spill containment pad to capture and contain any spill or runoff
- Using no-spray buffer zones.
Can the process or piece of equipment be re-engineered to isolate the hazard?
Can new procedures/processes be introduced to minimize exposure to a hazard?
Personal Protective Equipment (PPE)
PPE should be viewed as the option of last resort and should not be seen as a substitute for higher order risk control. Whichever methods you use to control hazards, remember in each case their effectiveness should be monitored regularly.