F e bruar y 2010 TRACKING MINIMUM REQUIREMENTS FOR TRACKING VERTEBRATE TOXIC AGENTS. National Possum Control Agencies

Transcription

1 F e bruar y 2010 B8 TRACKING MINIMUM REQUIREMENTS FOR TRACKING VERTEBRATE TOXIC AGENTS A BEST PRACTICE GUIDELINE PRODUCED BY National Possum Control Agencies

2 ABOUT NPCA The National Possum Control Agencies was established in the early 1990s to help co-ordinate possum control. In November 2001 a constitution was approved that reaffirmed NPCA s aims and objects and the importance of co-ordination in possum control and vertebrate pest control in general. OVERALL AIM To provide a co-ordinating forum that will contribute to the effectiveness of all the agencies involved with the possum and vertebrate pest problem in New Zealand and to assist agencies with: protecting the farming industry from the effects of bovine Tb, and achieving conservation benefits and positive environmental outcomes. A B E S T P R A C T I C E G U I D E L I N E P R O D U C E D B Y National Possum Control Agencies

3 TRACKING MINIMUM REQUIREMENTS FOR TRACKING VERTEBRATE TOXIC AGENTS Published in new format February See front cover for date content was last updated. National Possum Control Agencies PO Box , Wellington Tel: (04) Fax: (04) ISBN: REMEMBER Follow Label Directions Have Safety Data Sheet On Hand National Poisons Centre 24 hour emergency service ERMA Helpline General Emergency Dial 111

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5 CONTENTS Purpose Cautions Acknowledgements Chapter 1. Purpose of Tracking and Regulatory Requirements 1.1 Overview 1.2 Person in Charge and Approved Handler 1.3 Substances to be Tracked 1.4 Hazardous Substance Tracking Forms 1.5 Record of Use Chapter 2. Forms and Guidelines for Use 2.1 Record Structure 2.2 The STORE form 2.3 The FIELD form 2.4 Explanation of the forms 2.5 Examples of using the forms 2.6 Some key points 2.7 A simpler alternative for the STORE Feedback and Evaluation 3

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7 Purpose These guidelines were commissioned by the Biosecurity Managers Group through the NPCA. Regulatory aspects for tracking of vertebrate toxic agents (VTA s) are summarised and made available. This project was initiated to expand on the chapter on tracking in the sister publication Minimum Requirements for the Use and Handling of Vertebrate Toxic Agents, also available on the NPCA website. These guidelines should be consulted in conjunction with this document, as this document has a very narrow focus, i.e. tracking. The primary audience is the field staff and contractors responsible for vertebrate pest control programs. Cautions When subject to legislative requirements readers are directed to the legislation itself and asked to consult their legal advisors. The legislation referred to in these guidelines is liable to change. Additional Best Practice Guidelines for various target species are available. These complementary guidelines are also available from the NPCA. Acknowledgements Thanks to the expert working group involved in the preparation of these guidelines. Updated version This edition was published in order to amend Section 1.3, where the reference to exceptions in the previous July 2007 edition has now been removed. 5

8 Chapter 1. Purpose of Tracking and Regulatory Requirements 1.1 Overview Some VTA s require tracking throughout their life cycle, from manufacture, through transport, use and disposal. At any time of the life cycle of such substances the regulations are designed so that an enforcement officer can physically locate the substance, and determine who is responsible for it. The applicable regulations are primarily the Hazardous Substances (Tracking) Regulations 2001, which can be viewed on and also Hazardous Substances (Identification) Regulations 2001 Part 2. Further relevant information can be found on the ERMANZ website, The Department of Conservation have also established a good SOP for tracking as part of their Safe Handling of Pesticides SOP, which can be viewed at and login details are pest contractor and pesticide. For those who were involved in handling pesticides prior to the HSNO legislation the main change is that the tracking process hinges on an Approved Handler, rather than just a place. Where in the past incoming product was assigned to general stock of the poison store, now it must be assigned to the control of an Approved Handler. So at every point in time, a substance must be in the control of an identified Approved Handler. And every Approved Handler must be able to show precisely how much of a substance is in their control. So if John has 5 tubes of cyanide recorded in his control, and Henry takes 3 tubes into the field, then John will have to record the transfer to Henry and show that he has 2 tubes left, while Henry will have to record on his record that he has received and is in control of 3 tubes. This will have to be a separate record, because Henry is required to have his record in his vehicle, while John s record must be near the depot. Every Approved Handler has to have their own personal record. This is quite a change, and needs to be managed carefully, so that the stock management can be achieved as well as compliance with the regulations. Where there are numerous staff taking delivery of stock, and without a computerized database system, it will be difficult to track total stock. This is because the records of each Approved Handler will need to be consolidated to create a picture of total stock. If there is only one Person in Charge of a depot s stock management, then tracking can be integrated in one recording system. However, for larger organisations it is probably easier to continue to use previous stock management systems where they are working well, and add in the tracking requirements such that every Approved Handler has their own record. 6

9 1.2 Person in Charge and Approved Handler The Person In Charge of a Place and an Approved Handler, are for all intents and purposes the same when considering tracking. If you are an Approved Handler, and have a substance in your control, it will be in a place, and you will be the Person in Charge. 1.3 Substances to be Tracked Tracking is mandatory for VTAs which require an approved handler (any 6.1A, B, C product). The product label will specify if tracking is required. 1.4 Hazardous Substance Tracking Forms Each approved handler must use a Hazardous Substance Tracking Form for VTAs under their control and retain this record for 3 years after all VTAs on the sheet have left their control. The Hazardous Substance Tracking Form must be filled out every time a VTA is received, stored, used, transferred or disposed of. The tracking Form must be kept in close proximity to, but not inside the hazardous substance store. The Hazardous Substance Tracking Form must specify: The name of the approved handler who is in control of the tracked substance, including the position of the person within his or her organization. The physical address of the place of work of that person. The date on which the persons test certificate as an approved handler must be renewed. The hazard classifications of, and each phase of the lifecycle of, those hazardous substances for which that person has a test certificate. The identification of the tracked substance. The total amount of the tracked substance. The exact location of the tracked substance. If a tracked substance is transferred to another place: o o o The identification and amount of the substance transferred. The address of the place, the identity of the approved handler who will be in control of the substance at that place, and the position of that approved handler within his or her organization. The date on which the transfer occurred. If a tracked substance has been disposed of: o o The manner of disposal. The date on which the disposal occurred. 7

10 o o The amount of the substance disposed of. The location of the place where the substance was disposed of. 1.5 Record of Use Records of use are generally required whenever VTAs are applied in a place where members of the public may lawfully be present, or where the substance might leave the place via air or water 1. The record must be kept for at least 3 years, and include: The name of the substance. The date and time of each application or discharge of the substance. The classification or classifications of the substance. The amount of the substance applied or discharged. The location where the substance was applied or discharged. The name of the user of the substance and the user's address. These requirements can be met by ensuring the post-operational report specifies the required matters. Alternatively they can be incorporated into the tracking form. While not all VTA s are required to be tracked (most VTA s used in a public place do require a record of use), there is nothing to prevent a field worker meeting both tracking and record of use requirements in one set of documents. 1 Applies to class 6.1A, 6.1B, 6.1C, 6.6A, 6.7A, 6.8A, 6.9A, 8.2A, or 8.2B substances. Brodifacoum for instance, is not included in this list. 8

11 Chapter 2. Forms and Guidelines for Use 2.1 Record Structure Most Approved Handlers will need to maintain at least two separate personal folders. One folder will be kept at the Hazardous Substance Store (the store ), and the other will be carried with them in their vehicle as they go about their work. The folders must be readily available to anyone who might handle the substance, and in accordance with Part 2 of the Hazardous Substances (Identification) Regulations 2001 must also have a section containing a copy of the Safety Data Sheet (SDS) for each substance held. While having 2 or more folders per person may seem inefficient, remember that tracked substances attach to an Approved Handler and at a place. For example, John takes delivery of 5 tubes of cyanide and records in the receipt in his personal record as they go into the store. This record is kept near the store. When John takes two tubes out of storage to use in the field, he is now a Person in Charge of substances at two different places. Namely the cyanide at the store, and the cyanide in the field. The record of the 3 tubes of cyanide remaining at the store must remain at the store, and the record of the 2 tubes in the field must be kept in John s vehicle. Now if John never took delivery of product, being responsible for field work only, or alternatively had an administrative role, taking delivery of product and being the person in charge of the store but never doing field work, then he would only need one folder to maintain the records. And if John were to work from several stores, then he would need more than 2 record folders. In each folder, the store folder, and the field folder, John will keep a separate record sheet for every substance he uses. This is strongly recommended, because an approved handler must be able to show how much of a substance is in his or her control at any time. This means he must keep a running total, and this can become very confusing, if not impossible, if one form is used for different substances. The system described here assumes that John both receives product, and uses product from one location. And he is not alone, as Henry can also receive and use product from the same store. This scenario allows us to describe a system that should be able to be used or easily modified for any situation. 9

12 2.2 The Store Form While every Approved Handler has a folder for the store form, this can of course be one master folder, tabbed for every Approved Handler to maintain their separate personal records. So we still have one master store folder. Under each Approved Handler s tabs, there will be separate forms for each of the tracked substances the Approved Handler is licensed for. It might look like this (see next page); 10

13 Tracking Record of Hazardous Substance - STORE Scanned copy of Controlled Substances License Scanned Copy of Business Card, showing at a minimum full name, address (must be the same as the Hazardous Substance Store address), and position in the organisation. Substance Transfer Detail Disposal Detail Date ID Number In Out Total Held Approved Handler Organisation Approved Handler Place Method 11

14 2.3 The Field Form The field form is designed only for tracking purposes in relation to use, and record of use. It might look like this (see next page); 12

15 Tracking Record of Hazardous Substance - FIELD Scanned copy of Controlled Substances License Scanned Copy of Business Card, showing at a minimum full name, address (must be the same as the Hazardous Substance Store address), and position in the organisation. Substance Transfer Detail Use Detail Date ID Number In Out Total Held Approved Handler Organisation Place Method 13

16 2.4 Explanation of the Forms The fields of the forms should be completed to the following standards; Substance A clear description of the substance or tradename(e.g. 0.15% 1080 pellets, Feratox capsules). Date the date the product is received, transferred, used, recovered of disposed of. ID number This must be a unique number which can identify a specific product lot. It may be presented as a sequence. That may mean you have to join several codes or numbers together, for instance the PRF, batch and pack numbers. In/Out The amount. This can be either by weight, or volume, or units. Approved Handler State the name (at least first initial and surname) and organisation of the person. This may in case of transport be a DG license holder rather than an Approved Handler. Organisation Company or organisation employing an Approved Handler, if self employed state private. Place A physical address or place description that will allow someone else to quickly locate the tracked substance. Method of use or disposal. 2.5 Examples of using the Forms How will this work? We will show how the 1080 pellet example will work for John and Henry. In this example, John is transferring to Henry for his use. But remember, that it would work exactly the same if John was using the product. He would then be transferring to himself, and the entries would be the same (other than name). We explain the example below, and then show the two forms as they would have been filled out during this process. John and Henry both work for Fred n Bob Ltd. 1 John receives 100 kg of 0.15% 1080 pellets from Animal Control Products Ltd. (ACP) on 10 June John transfers 40 kg of 0.15% 1080 pellets to Henry to go and kill some possums in a bait station operation at World s End on 15 June Henry uses 20 kg of 0.15% 1080 pellets on the 15th, and returns the other 20 kg back to the store, but maintains control himself (he could just as easily have transferred it back to John s control, but for this example that did not happen). 4 On 30 June Henry recovers 10 kg of uneaten bait from the bait station and signs it back into the STORE (again he keeps control of it). 5 Henry then disposes of the uneaten bait on 10 July by burial in the local landfill, Dump. 6 On 26 July John transfers the 60 kg remaining in his control to Sly, a mate of his wife s brother s second cousin, who happens to be an Approved Handler in need of some product at the right price. 14

17 The running totals at the end show that John has control of 0 kg of pellets in the store, Henry has control of 20 kg of pellets in the store. Of the original 100 kg, 10 kg are recorded as having been dumped, 10 kg are recorded as used, 20 kg remaining in Henry s control in the store, and 60 kg transferred to Sly. This may seem like excess paperwork, but it does work. At any time in the process, there is an exact record of the total amount of product in the control of each Approved Handler, and its location. 15

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21 2.6 Some key points This system differentiates between use and disposal. The STORE form deals with disposal, while the FIELD for deals with use. Both can accommodate transfer for the purpose of use or disposal. Therefore it is assumed that any unused or recovered bait is signed back into the STORE form for subsequent disposal. This reflects the common reality where field workers bring product for disposal back to base for subsequent disposal runs. In both the STORE and FIELD forms, the Approved Handler can be the same person. John can receive 1080 pellets from his store for use in the field, and can then sign the balance back into STORE later. Transfers to other stores or approved handlers are dealt with by the STORE form. Do not transfer a substance to a FIELD form, and then to another place. If that is necessary, transfer it back to the STORE, and then transfer it away from there. The only purpose in relation to tracking of the FIELD form is for use (though it is also a record of use). The FIELD form can be used for all VTA s, not just those requiring tracking, as that form also meets the requirements of record of use. 2.7 A Simpler Alternative for the STORE The forms do not necessarily need to be signed by the approved handler transferring or receiving a VTA. This means that it is possible in larger organisations to have one person (Person in Charge), who should be present during normal work hours, take control of the VTA s at the depot. In this case, every approved handler working out of the store would not need to have their own personal store record. The store record would instead have a record sheet for every VTA product likely to be present, and multiple approved handlers would sign product in and out, keeping a running total for the store. The store record would show that one named person was in charge of all the product in the store. 19

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23 EVALUATION AND FEEDBACK FORM NPCA PUBLICATION B8: TRACKING MINIMUM REQUIREMENTS FOR TRACKING VERTEBRATE TOXIC AGENTS Best Practice Guidelines Name:..Date:... Contact Details: . Fax: Phone:.. The NPCA welcomes any feedback and comment you might have on these guidelines, and sees this as an important part of the continuous improvement and development of this best practice. Please quote the page and reference that your comment(s) relates to, provide a short comment and return to: NPCA, Fax: (04) (04) npca@xtra.co.nz Note: This form can be downloaded from the website: Page, Reference Comment 21

24 w w w. n p c a. o r g. n z National Possum Control Agencies