Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by the National Farmers' Union (HSE 05)


  The National Farmers' Union (NFU), representing the interests of some 120,000 members involved in commercial agriculture and horticulture, farmer controlled businesses and those with a genuine interest in countryside issues, would like to thank you for giving us the opportunity to give evidence to the above inquiry.

  The agricultural industry is committed to practical, beneficial and cost effective health and safety in the workplace. The industry concurs with the general view that healthy and safe work environments promote good productivity in addition to preventing accidents. The industry, through the NFU, believes in co-operating closely with HSE to promote sensible policies on health and safety. In this respect the NFU are involved with HSE on a number of industry liaison panels and are involved in one off projects to further responsible action on health and safety. The NFU commit time and resources through its permanent staff and the direct involvement of its farming members in achieving these aims. This should be a continuing process.

  The NFU believes that a good working relationship should, and indeed does, exist with HSE but also continual assessment of current and proposed legislation is required. There are, therefore, areas of the HSE's role that could be improved and these will be explored later in this document.


  The majority of farms represented by the NFU fall into the category of small to medium sized enterprises. The consolidation currently under way in the agricultural sector coupled with increasing competition in the marketplace have created additional commercial pressures in recent years. This has led to a situation where:

    —  Capital expenditure has been squeezed to the point where investment has been halted and the lifecycle of machinery has had to be increased.

    —  There are less physical resources (both mechanical and human) undertaking more work.

  The HSE needs to recognise these factors when considering the impact of current and new regulations in agriculture. To benefit the industry and its employees the HSE's approach needs to minimise the impact of health and safety regulation whilst securing the necessary safety standards required.

  The approach to new Directives and Regulations needs to:

    —  Be pragmatic and minimalistic. Rather than exceed the requirements laid out in European legislation UK legislation should mirror the requirements.

    —  Reflect the current trend and be, as far as possible, non-prescriptive in application.

    —  Maintain the "so far as is reasonably practicable" approach. It is accepted that there are occasions where there will be absolute and reasonably practicable duties on employers but the need for employers to be able to balance cost/risk must be maximised.


  The NFU have always endorsed good quality enforcement activity. However, the approach to enforcement by HSE does not always reflect the nature of our industry.

  Account must always be taken of:

    —  The seasonal nature of agriculture and therefore the difficulties encountered when using casual staff.

    —  The specialist machinery and equipment used in agriculture is often mothballed and only used for short periods each year.

    —  The unpredictable climate conditions often endured in UK agriculture mean that those who work in the industry have to, by necessity, work long and unsociable hours.

  The NFU believes that enforcement needs to be carried out by suitably qualified and professional staff. Enforcement activity is currently undertaken by HSE inspectors and Environmental Health Officers appointed by local authorities.

  The NFU wish to see the continuation of enforcement in this manner and would not support any diminution in the quality of enforcement by use of individuals or bodies who lacked the expertise of HSE inspectors and local authority EHO's.


  There is widespread feeling in the industry that the written information and that available through the Internet by HSE is generally both useful and of high quality.

  There is concern, however, that when seeking advice from HSE inspectors or EHO's there is a risk of inevitable attention being drawn to the agricultural concern from where the query originated.


  There is a constant move towards a requirement for independently assessed training in a whole range of work activities related to agriculture.

  There is a wealth of experience held by thousands of individuals that need not be backed by a certificate. There is a need for a greater recognition and application of "grandfather rights" to be applied in relation to new legislation.

Mark Bratt

Transport and Health and Safety Adviser

September 1999

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Prepared 26 October 1999