Future pain or future gain?
Who would believe that the substitution of one English word for another, and the introduction of three initial letters, would give rise, potentially, to such big changes for so many people?
THE substitution of the word ‘Risk’ by the word ‘Hazard’ was approved by the European Parliament towards the end of last year, when an EU Directive established a change in the way that pesticides are approved and, in essence, set out revisions to the article 91/414. The approvals process for pesticides in the UK has worked well, and with an excellent safety record for many years, since the Control of Pesticides Regulations (COPR) was introduced in the UK in 1986 and then, in part, changed by the introduction of the EU Plant Protection Products Regulations in the early 1990s (PPPR). Until then, the effects on people, the
environment and biodiversity, from pesticides, had been assessed on risk issues and, so, if a potentially harmful product had a label or a formulation or a restricted field of use, or all of those, to ensure its use was safe, then that was the way it was approved, i.e. with a tight control on restricted use of the product in ways which avoided risk. However, for some people, that process
certificate are qualified and legally recognised as competent to give advice on the use of pesticides in the sector they selected, and on which they were examined. There is also the recent introduction of the
Foundation Award in Amenity, which is designed as a short (circa 2 days) training course to inform managers, supervisors, contract specifiers etc. of the ways that professional pesticides can be used safely and effectively. To recognise the required increase in training and qualifications that the SUD will bring, BASIS has also introduced the BASIS Amenity Register. This register is for managers, supervisors,
Letters of Exemption and the BASIS Certificate in Amenity
Rob Simpson, Managing Director BASIS (Registration) Ltd, outlines the Sustainable Use Directive
The Sustainable Use Directive consultation is now published and the industry is actively participating in discussions about how we wish to see the directive translated into regulations: BASIS is involved in a number of areas covered by the directive, not least Article 5 on Training and Certification requirements.
One aspect of this, which is highlighted from 5.30 to 5.33 of the directive, covers Letters of Exemption which were issued by BASIS some years ago and before COPR made the BASIS certificate a statutory requirement. Sellers, suppliers and advisers who had five years
was not enough. So now, in future, if the product (or it’s formulation ingredients) are considered “harmful”, then the product will not be approved, even if the risk is minimal. The other day, I heard the analogy that the situation we are now in is like owning a car that will do 140mph. Previously, driving tests, the Highway Code, Autobahn rules etc. permitted fast driving within the ‘Risk’ rules, but now, it would not be possible to even sell the 140mph car because it could be ‘Harmful’ - an interesting view! Of course, this whole issue hangs on the
definition of ‘Harmful’, and that is what scientists around Europe are seeking to define, so we will all just have to wait and see. That definition will eventually inform us which pesticides we can keep and which will go.
advisers, contract specifiers and those who have a need to be up to date with Amenity pesticide use and knowledge (spray operators will be members of the NRoSO Scheme with PA qualifications). The BASIS Amenity Register will enable those who are already qualified, and those who intend to become qualified, to be part of the independent, confidential register, to capture CPD events, training and qualifications and maintain ongoing records as an individual.
Register will demonstrate that the person is up-to-date and ‘a knowledgeable person’ in the use of Professional Amenity Pesticides. The POWER qualification is also being
experience of the industry in 1979 could apply for a ‘Letter of Exemption’ from the requirement to undertake the BASIS examination. Quite a number of these ‘exemptions’ were granted at the time, though it is now not clear how many of the original exemption holders are still working in the industry in any capacity. We do know that there are 370 exemption holders who are currently members of the BASIS Professional Register. The Sustainable Use Directive places obligations on member states to implement the directive and the requirement for certification and on-going CPD is not a negotiable point; it is a requirement and, therefore, the UK along with other member states will have to comply.
certificate will have to ‘renew’ their qualification, probably every 3 years. We could do this in two ways:
• Undertake the BASIS examination every 3 years
• Demonstrate 3 years Continuing Professional Development through membership of the BASIS Professional Register
There will be an annual points requirement to ensure membership is carried forward each year. Membership of the BASIS Amenity
As if that is not enough, along come the three initial letters – SUD – Sustainable Use Directive. This abridged wording relates to the second part of the new EU Directive which is due to be implemented in the UK by November 2011, and it is expected that it will affect the working practices of professional pesticide users more than any other legislation since 1986. How? - Answer, in many ways. The SUD focuses on a cross section of issues which include training, qualification and Continuing Professional Development (CPD) of advisers, managers, operators and others involved in professional pesticide use. There have already been some very
updated by BASIS and City & Guilds NPTC to provide training and focus for those who wish to concentrate on the Protection of Water and Environmental issues. More than two years ago BASIS introduced the Amenity Assured Scheme to audit and annually certificate Amenity contractors to show compliance with a set of standards (Best Practice) agreed between BASIS, NAAC and City & Guilds NPTC.
significant actions taken to facilitate the capability to deliver the directive’s requirements. Many of the actions are in the Amenity sector because all the information available shows that this sector is behind agriculture in qualifications, training and CPD type activities. In qualifications, BASIS has revised the Field Sales and Technical Staff Certificate to give it specific purpose for three skills areas from which candidates select, i.e. hard and permeable surface weed control; sports and amenity turf and shrubs and borders. Successful candidates, who attain this
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about 10% a year since its formation, and a survey last year showed that more than 18,000 miles of Network Rail mainline track, more than 200 local authorities (roads and pavements), and many golf courses, recreational areas, sports areas and utility sites were cared for and sprayed by Amenity Assured contractors. BASIS is now setting up the Amenity Assured audit as a standard which can be used across the whole amenity sector as best practice guidance. As in all walks of life, those contractors,
The Amenity Assured Scheme has grown
take an exam every 3 years and would urge people to support the option to ‘renew’ qualifications through CPD and Professional Register Membership.
How does this leave exemption holders?
Amenity exemption holders do not have a certificate in the same way that those who have taken and passed the exam do. We propose that CPD is the way forward for this
group and, where individuals can demonstrate 3 years Professional Register Membership (CPD), their qualification can be ‘renewed’ in the same way as certificate holders. Once individuals have qualified (examination or
BASIS fully understands that people will not want to Those sellers, suppliers and advisers with a BASIS
exemption letter), there should be no difference in the methods of keeping up to date through regular, monitored CPD activity. We would encourage everyone to support the use of CPD and the BASIS Professional Register as a recognised method for qualification renewal in the new regulations. It is likely that individuals will need to be able to demonstrate 3 years on-going CPD activity (history) by 2014.
operators, companies and local authorities who are employing qualified people and doing “best practice” work, have nothing to fear from the changes. The use of alternative, integrated approaches will also be key for the future, as part of best practice. However, to those who think “this doesn’t apply to me!”, beware! It will.
By Paul Singleton – Chairman of BACCS and Amenity Assured
to maintain their qualification post 2014, register for CPD (BASIS Professional Register) before the end of 2010. This will ensure that we can demonstrate to government that those individuals have a recognised qualification and 3 years relevant on-going CPD. Obviously, those Amenity people currently on the BASIS Professional Register are already doing what is and will be required of them to maintain their professional status. It is important that these individuals continue to maintain their BASIS Professional Register membership. The requirement for certificate renewal will also
apply to storekeepers, and it is likely that all BASIS qualified storekeepers will need to attend a refresher training course every three years. Those holding an exemption letter for the
It is, therefore, vitally important that those who wish
storekeeper’s qualification will need to attend refresher training in the same way as current certificate holders. All letters of exemption will be invalid under the new regulations.
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