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A Technical Guide for Wine Producers
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IPW guidelines for handling, storage and disposal of agrochemicals (Part 1): Legislation and storage of agrochemicals
Elleunorah Allsopp & Keith du Plessis, ARC Infruitec-Nietvoorbij
LEGISLATION
The handling, storage and disposal of agrochemicals and empty containers are regulated by South African legislation. Just like GLOBALGAP (www.globalgap.org) and other similar schemes, the Scheme for Integrated Production of Wine (IPW) requires that producers adhere to national legislation with regard to the storage, handling and disposal of agrochemicals and empty containers.
Various acts pertaining to the handling and storage of agrochemicals on farms confuse producers attempting to comply with legislation. For this reason the SABS was charged by the authorities to compile a code or national standard, viz. SANS 10206, which summarises all the stipulations of the relevant acts. These regulations apply to all kinds of farming, including fruit, grain, vegetable and stock farming. The latest edition (2007) of this document may be purchased at any regional office of the SABS. A useful summary of the regulations applicable to farms, viz. the Guidelines for handling, storage and disposal of agrochemicals in the South African wine industry is available on the Winetech website (www.winetech.co.za). At the back of the IPW Manual for Farms is a checklist which producers may use to check whether they comply with these requirements.
An agrochemical is any product registered in terms of Act 36 of 1947 and includes herbicides, nematicides, insecticides and pesticides. Contravention of legislation pertaining to agrochemicals is a criminal offence and being found guilty of such an offence will result in a criminal record for the perpetrator.
Legislation stipulates that the buyer (i.e. the producer) is held responsible for each gram or millilitre of the product, as well as for the empty container, as soon as he/she takes possession of a container with any agrochemical. If any of the product falls into unauthorised hands, or is used in an unauthorised manner, the buyer (producer) is held responsible. The same applies if anybody who has not been trained to understand the risk of agrochemicals, uses a contaminated, empty container and is poisoned by residue in the container. For this reason strict adherence to all regulations pertaining to the storage of agrochemicals and the disposal of empty containers is extremely important.
The purpose of this article is not to list or discuss all the applicable regulations in SANS 10206, but to make producers aware of certain important principles.
STOREROOM FOR AGROCHEMICALS
Producers do not have to build a new store - it is often possible to adapt existing stores or structures to comply with the legislation.
The main objective of these regulations is to ensure that products that are potentially hazardous to people and the environment are stored in a place to which unauthorised persons do not have access and where they do not create a pollution hazard. The structure of the store therefore has to be sturdy, lockable, non-flammable and wind- and weather-proof. Sufficient isolation, especially for corrugated and asbestos roofs, ensures that the store does not overheat, thereby limiting the formation of noxious fumes in the store and protecting the effectiveness of products. Most labels recommend that products be stored in a ‘cool, dry, well-ventilated place away from direct sunlight’. The registration holder does not guarantee effectiveness under all conditions, because factors such as abnormal climatic and storage conditions may impact negatively on the functioning and effect of the product.
If a new store is erected for agrochemicals, building plans have to be approved by the local authority. An occupation certificate must be issued after the necessary inspection to ensure that the building complies with the National Building Regulations. If an existing building is adapted to serve as a storeroom for agrochemicals, a sketch plan of the building must be submitted to the local authority, so that an inspection may be arranged and an occupation certificate issued. This ensures that dangerous substances are not kept in derelict structures.
The floor should be made of concrete, without any cracks, impermeable and smooth so that spilt chemicals can be cleaned up easily. Doors should preferably be of steel and not wood, as locks may be chiselled out of wooden doors. If the storeroom has a wooden door, a steel security gate must be fixed outside the door. A small retaining wall, 20 cm high, must be built in front of the door, to prevent spilt or leaking agrochemicals from seeping out of the store and polluting the environment.
Windows are only installed to let in light and are not intended for ventilation, which is why they may not open. Frames should be steel, window panes may not exceed 450 mm x 450 mm and all windows must have burglar bars. Good ventilation is extremely important, seeing that noxious fumes may build up in the store, especially where isolation is not very good and the store gets very hot. Ventilation bricks (covered with gauze) or extractor fans should be able to exchange the air volume in the store five times an hour. It is, in fact, easier to eliminate windows altogether in the store and rather to install an extractor fan and electric lights.
The recommendation on the checklist that herbicides be kept apart from the other agrochemicals is not a legal regulation, but it is a Good Agricultural Practice (GAP). By placing herbicides in a separate room or in a separate compartment/division inside the store, there is less risk of confusing herbicides with fungicides or insecticides and accidentally spraying them onto the vines.
Containers should not be placed directly on the floor, as this complicates cleaning up if concentrated chemicals are spilt. Shelves and wooden pallets should be covered in plastic, because products may penetrate the wood and react with other residues, which may cause the formation of noxious fumes. Liquid formulations should not be stored directly above powder formulations.
Prescriptions regarding the provision of telephone numbers of emergency services, emergency procedures and first aid facilities (Annexure B in SANS10206), fire extinguishers and warning signs affixed outside and inside the store, as stipulated in SANS 10206, must be strictly adhered to.
It is important to note that SANS 10206 stipulates that a separate area with running water must be provided where products are weighed and measured. Run-off should be handled together with the run-off of the laundry for overalls, showers for spray operators and filling stations for spray equipment. This aspect will be addressed in a subsequent article. Measuring equipment cannot simply be rinsed and the water poured onto the ground.
The law also requires producers to keep a comprehensive, updated inventory of all purchases and applications of agrochemicals. At any given moment it should be possible to account for exactly what and how much has been purchased, used and remains in stock in the store. This inventory should be kept away from the store, although a copy may be kept in situ.
What risk does the producer run if the store does not comply with legal requirements? If somebody is poisoned by lost or stolen agrochemicals, the producer may be accused of negligence if the store does not comply with the requirements.
RECOMMENDATION
Producers should, at the very least, have a copy of the Guidelines for handling, storage and disposal of agrochemicals in the South African wine industry, which is available on the Winetech website, in their possession. Each consultant, advisor and controller should have a copy of the latest edition of SANS 10206, as well as a copy of the guideline document mentioned above. The purpose of the legislation is to protect people (including the producer) and the environment against pollution by agrochemicals and no concessions can be made in this regard.
For further enquiries, contact Elleunorah Allsopp at tel (021) 809-3007, fax (021) 809-3584 or email allsoppe@arc.agric.za.
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