As we continue to lobby for justifiable changes, NFU Scotland’s Environmental Resources Policy Manager Sarah Cowie is informing the farming sector that they must prepare for upcoming pesticide enforcement officer visits this month.
In November, pesticide enforcement officers (PEOs) will begin an initial phase of farm visits. This is the next step of the
Official Control Regulations (OCRs), which were introduced in 2020. The requirement placed a duty on professional users of plant protection products (PPP) to register with Defra. And the next step now involves inspection visits to check how well PPP users are complying with the law.
Sarah writes: We know that these inspections are seen as a duplication, and an additional and unwelcome burden on farm businesses.
In June 2023, along with Scottish Quality Crops (SQC), Quality Meat Scotland (QMS) and the Agricultural Industries Confederation (AIC) called on the Health and Safety Executive (HSE) and Defra to recognise that farm and trade assurance membership sufficiently demonstrates compliance with PPP law. We will continue to work with others and push for earned recognition in order to reduce the burden on on-farm inspections.
There have been some small changes. The
registration form on the Defra website now has an option to record membership of any assurance schemes. But unfortunately, there are unlikely to be any major changes ahead of the initial phase of inspections.
That means any professional user of PPPs can receive a PEO visit. Such visits have already been happening for the PPP supply chain, and for users in the amenity sector. They are now moving on to farm visits. In the interests of taking a risk-based approach to inspections, the PEOs will not be visiting everyone in the initial phase, but those they deem to be at highest risk of non-compliance.
Farms that are most likely to receive a visit in the first phase of farm visits will include:
- Farm businesses that are 150 acres or more.
- Farm businesses that are not currently registered as a PPP user under the OCR.
- Farm businesses that have not been visited by HSE in the past five years.
If you have registered as a PPP user, you will not be targeted for inspection in this initial phase of farm visits.
Most PEO visits will be carried out by appointment, but some may be unannounced, and they are likely to take two to three hours. The visit will focus on the management of PPPs, looking at storage, handling, application equipment, record keeping and LERAPs (Local Environment Risk Assessments for Pesticides).
A common issue PEOs are finding is the storage of unauthorised PPPs. Ahead of visits, they are recommending farmers check stocks and dispose of unauthorised PPPs appropriately. More information on what to expect from the visit can be found at the HSE website
here.