Federated Farmers Submission on Health and Safety at Work (Hazardous Substances) Regulations 2016 – Draft for Consultation
Federated Farmers has a keen interest in regulations relating to hazardous substances because farmers are significant users of various classes of hazardous substances including agrichemicals (herbicides, fungicides and pesticides) and fuels (petrol, diesel and LPG).
Federated Farmers generally supports the draft regulations in the context that this is phase one of a review of the regulations as they pertain to hazardous substances and that a more comprehensive review and consultation will take place in a planned phase two. Although the regulations are primarily just a shift of the current HSNO Regulations across to the framework of the health and safety reform legislation, we do note that there are a number of proposed changes. We support those changes where they improve the safety of farmers but not where they add substantial compliance for little benefit.
Summary of Recommendations
- That Worksafe New Zealand to work with Federated Farmers and others to develop easy-to-use guidance material to help farmers understand their obligations for compliance.
- That during phase two of the review of the regulations there is significant effort and consultation from MBIE to simplify the regulations and tertiary instruments in order for ease of explanation.
- Proceed with plan to disestablish approved handler as a mandatory requirement.
- Proceed with Regulation 13.30 as drafted.
- Work with Federated Farmers to simplify the requirements for the storage and use of LPG on farm to facilitate the use of LPG in grain driers.
- Proceed with the bulk of part two while noting problems for phase two.
- Complete further work on the thresholds to establish a hazardous substances location to reduce the undue compliance costs.
- Ensure that the regulations cause an undue burden on aerial applications of 1080, and other similar measures to control TB, with particular regard to the need to establish a hazardous substances location.