Memorandum submitted by Mr J Robert Campbell
(Z25)
1. My name is Robert Campbell. I started
farming in 1967 in Yorkshire and now farm 500 hectares of mostly
arable land in North Yorkshire and 900 hectares of upland grazing
near Galashiels. Throughout my farming career I have been involved
in many areas of farming representation and though I am at present
Chairman of LEAF this response is written as a result of my work
with the Agricultural Training Board and particularly my involvement
in developing training and certification programmes following
the introduction of the Food and environment protection act in
1986 or thereabouts.
2. The act known as FEPA introduced inter
alia a requirement that all operators of spraying equipment should
be trained. There was a subsidiary provision that after training
certain operators particularly contractors and those under a certain
age had in addition to pass a NPTC test and achieve a certificate.
I hold such a certificate even though I am not required to have
one.
3. A small group of us undertook to advise
the ATB on the content of the courses, which was then approved
by a full committee of the Board. The proficiency test was then
designed to check the effectiveness of the training.
4. There are a number of issues which arose
then which are still of relevance to your enquiry today. First
in taking an overall view our group immediately challenged the
absence of training and testing for those managing spraying operations;
only operators had to be trained. Second we suggested that there
was a need for refresher training at regular intervals for all
operators and third that some mechanism be developed to train
mechanics to ensure that sprayers were professionally maintained
beyond the scope of the operator training. All these three ideas
were refused either by the HSE or by some other branch of Government
involved in the legislation. This was a disappointment to us.
5. Further throughout our deliberations
it was made abundantly clear to us that the HSE had little interest
in the certificate except that it was required by law but proposed
that all their enforcement would be based on the need for all
operators to be trained. Thus, when the courses were available
through the training groups, organisers went to great efforts
to ensure that all operators were trained with farmers paying
the full cost of the course in accordance with the rules of the
time. This of course caused considerable disruption to farmers'
training schedules and undoubtedly reduced the amount of other
training taking place. While completing the courses in accordance
with the legal requirements they were resentful that the training
had to be designed to meet rules rather than to improve practice.
It could be argued that this single event was a major cause of
the subsequent reduction of training now known as "knowledge
transfer".
6. The problem was further compounded when
government changed on a number of occasions the role of the ATB
as it metamorphosised into LANTRA. Incidentally in this process
I understand that the training records were lost so the numbers
trained at that time is now unknown. Again it is interesting to
note that LANTRA is today funded by Defra for three years to study
the benefits of a training group system. The very system that
delivered the original FEPA training so effectively.
7. Some will argue that the FEPA act has
failed to deliver. I would claim that if that is the case then
it is largely due to the failure of the HSE to police the rules.
Personally I have seen in driving round the country many breaches
of these regulations and have on at least one occasion felt that
these were so blatant as to report the breach myself which resulted
in a prosecution. I can only draw your attention to my father's
words to me when I first learnt to drive. "Never break a
speed limit in Scotland, you will be caught but do not worry so
much in England". A situation which remained true until the
recent introduction of cameras.
8. My conclusions are that the role of government
is to enforce the law and inherently that means the law has to
be enforceable at a cost that government is prepared to bear.
In this case government has shown that it is not prepared to meet
the cost so must perforce resort to "partnership" with
the industry to move performance in the direction it seeks. The
voluntary initiative is an industry led partnership, which is
leading to better practice in the application of pesticides at
very low cost to government. The alternatives are effective policing
of existing regulations at high cost or the introduction of a
tax. This latter would firstly negate all progress made so far,
be costly to administer and place further burdens on HM customs
to enforce and seize illegal imports. While a tax may reduce pesticide
use marginally it would not influence the way pesticides were
used and the cost of a policing system to do this would I'm sure
use more than the revenue generated.
8 October 2004
| 
