Memorandum submitted by BASIS (Registration)
Limited (Z13)
1. BACKGROUND
1.1 BASIS (Registration) Limited is an independent
registration, standards and certification body serving pesticide,
fertiliser and allied organisations and interests, recognised
under the Food and Environment Protection Act 1985. It was started
in 1977 by the trade organisations in the crop protection industry
at the behest of the Government and was incorporated in April
1978. Interest in non-agricultural pesticides was included from
1991, and BASIS became a registered charity in 2001.
1.2 BASIS is a member of the Voluntary Initiative
(VI) Steering Group.
1.3 BASIS is in support of the VI and its
objectives. It believes that a pesticide tax would NOT be correct
or appropriate as an instrument to effect even greater safety
in the use of pesticides or to further regulate proper use.
1.4 The outcomes from the VI will prove
to be of greater benefit to:
— the Environment and Biodiversity;
— users of pesticides; and
— the ongoing skill of advisers, sellers
and application operators of pesticides.
2. BASIS ACTION
TO SUPPORT
THE VI
2.1 The introduction of BETA
A key target from one of the VI initiatives
is to demonstrate proven improvement of on-farm skill and knowledge
in Biodiversity and Environmental care through adviser training
and certification. In 2003 BASIS, in conjunction with the Crop
Protection Association (CPA), compiled a new training course and
qualification called BETA (Biodiversity and Environmental Training
for Advisers). Training of advisers commenced in summer and autumn
2003 and the first to be examined and successful, were certificated
in December 2003. Excellent progress has been made by BASIS in
conjunction with industry so that more than 300 advisers will
be trained and, where successful, will have achieved the BETA
certificate by the end of December 2004.
In conjunction with the VI Steering Group, BASIS
lifted the end of March 2006 target of 500 to 750 advisers and
it is expected this new increased target will be met. Training
and examining capacity prevents further expansion of numbers.
On-farm advisers of pesticide use were not,
prior to BETA, certificated and specifically trained to a recognised
independent national standard of Environmental and Biodiversity
skills. The VI has initiated this important step which will impact
positively for many thousands of farmers for years to come and,
as more advisers qualify, so the "snowball" effect will
grow.
It is expected that BETA training and qualification
of advisers will extend for years beyond the close of the first
VI period at the end of March 2006.
Work is progressing well to launch a BETA Amenity
course and qualification to ensure that advisers/managers of Sports
Turf, Ground Care, Railtrack, Parks, etc where pesticides are
also used, will meet the standards of Environmental and Biodiversity
care now being set in Agriculture.
The ICM (Integrated Crop Management) course
and certificate, which is also operated and examined by BASIS,
forms a linked part to the BETA qualification and, as such, many
advisers will attain both qualifications. The BASIS ICM qualification
started prior to the VI but the principles of managing, farming
and cropping in ways that integrate with Environmental and Biodiversity
care, are the foundation elements for sustainable agriculture.
Therefore the ICM and BETA qualifications are totally complementary.
2.2 Co-operation with NPTC for NRoSO
The National Register of Spray Operators is
organised and run by NPTC. The Register was launched in 2003 to
establish an on-going learning structure for pesticide application
operators, through the attainment of CPD points each year.
This principle had been established by BASIS
some years earlier, for advisers, through the BASIS Professional
Register.
It is important that industry does not see the
two registers as duplication or conflicting and so BASIS and NPTC
now operate with common recognition of appropriate training courses
for equal CPD pointing, where both advisers and operators attend
the same training course. Clearly, there are many more detailed
and longer training periods/courses for advisers that are academically
significantly above the level of courses for spray operators but
nonetheless, provision is now made by BASIS and NPTC where more
basic tuition covers common ground (eg the correct way to spray)
and where both groups of people need equal awareness of safety
and best practice.
2.3 BASIS Professional Register
In 1992 BASIS recognised, with industry and
government support, that advisers on the use of pesticides (often
referred to as agronomists for agricultural pesticide use) should
be kept up to date on the latest products, safety requirements,
legislation, crop variety specific needs, etc. It was further
agreed that the up-dating should be independently assessed and
annually appraised for each adviser and that a formal record should
be maintained for each individual.
In consequence the BASIS Professional Register
was established, with in excess of 1,600 training courses/events
evaluated each year where advisers can earn CPD points (Continuing
Professional Development) by attendance and learning involvement.
Adviser membership of the Professional Register
is only achieved by the individual attainment of the required
number of CPD points earned each year.
The number of advisers achieving and maintaining
membership has grown each year so that now more than 3,500 individuals
are members. The membership coverage has extended beyond the initial
on-farm agronomists to include Horticulturalists, Amenity advisers,
Forestry, Aquatic, Vegetable and Floriculture advisers as well
as including CPD points attainment for fertiliser sales and advice.
Many advisers are qualified for both pesticide and fertiliser
advice.
It is important to note that for pesticide advisers,
prior qualification with the statutorily required BASIS Certificate
in Crop Protection is essential before BASIS Professional Register
membership is allowed. For fertiliser advisers it is similar (although
not statutory) in that advisers must have prior FACTS qualification
(Fertiliser Advisers Certification and Training Scheme) before
membership of the BASIS Professional Register is offered.
Out of the 3,500 Professional Register members,
in excess of 2,800 are qualified to sell/advise on pesticide use,
which covers almost all UK pesticide advisers at point of use.
A VI target of all CPA distributor member companies
having their pesticide advisory staff as members of the BASIS
Professional Register, has been achieved. Distributors are now
part of AIC (Agricultural Industries Confederation).
In addition, BASIS has revised its Professional
Register CPD point categories to include, more formally, learning
and up-dating relevant to the application of pesticides skills.
This change has been effected to tie in closely with the link
to the NRoSO CPD points scheme as referred to above in Paragraph
2.2. Also, environmental and biodiversity training is now formally
recognised for CPD points achievement in the annual assessment
of BASIS Professional Register members.
2.4 Pesticide Users Qualification
The structure of qualification and CPD point
registration is now well established and successfully implemented
for both pesticide advisers and pesticide application operators
(spray operators).
The VI recognised that a training and qualification
structure was also required for managers/contract specifiers/users
of pesticides who have responsibility for ordering/arranging application/controlling
pesticide use in on-farm, amenity, horticulture and other situations.
Such people would not be qualified to advise which pesticide to
use or to give recommendations, nor would they be qualified to
apply pesticides (unless on-farm exempt by age). However, given
that they may often have control of spray operators or jurisdiction
over contract operators and so control the use of pesticides,
it was identified that this group of people also need to be trained
and certificated to demonstrate capability in their knowledge
of the safe use of pesticides.
At the behest of the VI Steering Group, BASIS,
NFU and NPTC are currently working on a suitable training syllabus
and examination structure to cover farm managers/contract specifiers
in local councils and other manager users of pesticides.
The new course and certificate will be launched
in early 2005 and will be called the POWER Certificate (Protection
of Water, the Environment and Recommendations). The POWER Certificate
will be operated jointly by NPTC and BASIS with NPTC as the awarding
body accredited with QCA and BASIS setting the standards for assessment
and the examining body.
The syllabus for the POWER Certificate is being
compiled so that it caters equally well for managers/supervisors
in amenity, horticulture, ground care and agriculture. As the
name of the certificate implies, the focus is heavily on the proper,
safe, best practice use of pesticides in order that water quality,
the environment and the integrity of pesticide recommendations
are not compromised.
3. OVERALL COMMENT
The introduction of the VI and its agreed targets
and objectives, has placed a heavy and expensive load onto the
UK pesticide industry. The additional commitment this requires
is at a time when the agricultural and horticultural economies
are under severe financial pressure.
However, the VI outcomes will show controlled,
directed and positive environmental, water quality and overall
educational benefits that will endure for many years to come.
Those benefits would NOT be the outcome of a pesticide tax, which
at best would be a crude, blunt instrument and, at worst, a totally
negative imposition on an already pressurised industry, and which
would not address any of the very positive environmental and training
skills improvements targeted by the VI.
There is industry concern that a pesticide tax
would reduce point of use pesticide advice, because users would
have to cut out the cost of advice to save money. Also, users
would revert to the use of cheaper, older and less environmentally
friendly, pesticide products.
BASIS is proud to be a part of the VI and its
objectives.
7 October 2004
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