Tracking is a WorkSafe regulation and involves recording what happens to hazardous substances throughout their lifecycle (i.e. from the point of import or manufacture in New Zealand, through distribution and transport to the point of use and/or disposal).
The only agrichemicals that are tracked are highly toxic substances (class 6.1A, 6.1B) or high capacity to oxidise (class 5.1.1A).
||Prior to 1 December 2017, it was a legal requirement to track class 6.1C substances as well.
- ensures that competent persons are handling the substances
- reduces the risk of the substance going astray
- helps demonstrate that highly hazardous substances are being managed in compliance with HSNO controls and regulations
- provides information for managing emergencies involving the substances.
Who can use tracked substances?
Tracked products can only be used by a "competent person":
- who is a Certified Handler or
- to whom a Certified Handler has provided guidance on their safe use and handling and a Certified Handler is present while the substance is being handled.
Tracked substances are required to be under the personal control of an Certified Handler or otherwise secured under lock and key when they are not being used.
What records must be kept?
The PCBU is responsible for keeping tracking records.
When you take possession of a tracked agrichemical, the following information must be recorded:
- the name, position within the company, and physical address of the competent person who is in charge of the product and details of their Certified Handler certificate
- the name of the product (its trade name or common name)
- how much is held and where it is held
- usage of the product, including where it was used, and how much was used
- whether the product was transferred to another place (e.g. another orchard) or person (you must ensure the person taking control of the product is a "competent person"
- if the product was disposed of, the quantity, how, when and where it was disposed of.
How should the records be kept?
This form shows a simple agrichemical use and tracking record. Each tracked agrichemical in your store would have its own sheet.
Ready availability and quick access to the records is very important:
- The records must be readily accessible to any worker handling the substance
- An enforcement officer entering the site must be able to identify the location and quantity of a substance within two minutes of viewing the records
- An enforcement officer must be able to physically locate the substance within one hour of arriving at the workplace
- The records must be readily understandable to any fully trained person required to have access to it
- Tracking records must be kept at least 12 months after the substance has been transferred; or three years in the case of use, treatment or disposal of the substance.
Note: If multiple record systems, such as a database and hard copy records are used, they will need to be cross referenced to ensure all the information is retrievable.
Record of Transfer
There is another group of products that have restrictions on who may use them. Agrichemicals in the following classes of products may only be supplied (sold/given) to a “competent person” in a workplace:
- 6.1C (Acutely toxic)
- 6.7A (Carcinogen)
- 8.2A (Skin corrosive)
A competent person is someone who has had training, instruction and experience
in the safe use of hazardous substances.
The following information must be recorded and kept for 12 months:
- The product name
- Name and address of the competent person receiving the product
- Date of transfer
- Written notification from the receiver stating that a competent person at a workplace will accept responsibility for the product.
Retailers will be asking for this written notification when you purchase products in this group.
||This is a new requirement from EPA but covers the products that are no longer required to be under the control of an Approved Handler.