APPENDIX 4
Letter from the Director General of the
Health and Safety Executive (B 4)
Thank you for your letter of 3 March, letting
me know that the Agriculture Committee is to carry out formal
inquiry into some aspects of the Government's recently announced
proposals on organophosphate sheep dips. I understand that the
inquiry is to be limited in scope and the HSE will not be called
upon to give oral evidence.
Please do take our earlier submission as formal
evidence to the inquiry. It may help the Committee to know in
addition that the Health and Safety Commission has expressly endorsed
the principle of reducing risk to concentrate handlers by improving
container design, one of the items in the government's four-point
plan and I believe likely to be one of the main points the inquiry
will examine. It is an approach very much in line with the philosophy
that underlies UK health and safety legislation: to engineer out
the risks as far as we can before relying on systems of work and
the personal protection of the individual worker. In parallel
and as part of the review of anticholinesterase pesticides, also
part of the plan, HSE is examining the design of containers used
for concentrated non-agricultural products, and will make recommendations
to the Advisory Committee on Pesticides for action on any found
to be unsatisfactory by the standards now being applied to dips.
Much of the work done by HSE on enforcement,
guidance and publicity, and referred to in our memorandum, is
similarly focused on achieving risk control by engineering methods
throughout the dipping operation. Our message is that much of
the risk should be dealt with in this way, without having to depend
heavily on the vagaries of operator behaviour. To the extent that
there is residual risk that makes safe work methods and personal
protection necessary our efforts are aimed at awareness raising
and at making sure that dippers are adequately equipped, trained,
instructed and supervised. The targeted inspection programme being
carried out by HSE inspectors is designed around these principles.
We use publicity about actions taken to spread the messages beyond
the farms actually visited.
16 March 2000
|
