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BASIS (Registration) Limited store inspection scheme

 

Even when greatly diluted most pesticides are toxic to fish and other aquatic life. In extreme cases, one teaspoonful can be enough to kill all the wildlife in a watercourse. Small quantities of pesticides can be detected in water and the limits set for water abstraction for public drinking water are exceptionally low. As little as a tea-cup full of concentrate could be enough to cause the daily supply to a city the size of London to exceed the permitted limits.

The Control of Pesticides (Sustainable Use) Regulations provide powers to control the storage of pesticides and reduce the impact of pesticides on the environment. The regulations require that all reasonable precautions are taken to protect people, creatures, plants and the environment when storing pesticides.

BASIS Registration Ltd is an independent registration, standards, certification and training organisation that works with, and through, industry organisations to implement relevant sections of the Control of Pesticides (Sustainable Use) Regulations and other legislative and industry Code of Practice requirements. The BASIS system is designed to be self-regulating by the agrochemical industry for the safe storage and transport of pesticides.

A pesticide spillage. The quantities involved are sufficient to have a significant impact on local drinking water and wildlife

The National Fire Chiefs Council (NFCC) and BASIS have established and agreed joint working arrangements which promote opportunities for the FRS to acquire operational risk information, including the risk to the environment, and to target fire safety resources towards higher-risk-to-life premises. The guidance is designed to assist FRS inspecting officers responsible for inspecting BASIS-registered premises. Some FRSs perform periodic audits of the self-assessments produced by the site but no longer inspect these premises

Agrochemicals are used extensively in modern farming. Their use is seasonal with much larger stocks being held in farm stores in the spring and autumn. The manufacturers of agrochemicals often store them on premises remote from manufacture.

Agrochemicals are normally distributed through a network of distributors and intermediate distributors who should be registered with BASIS Registration Limited. The locations of such premises and distributors are notified to the FRS. Operators are required to comply with the safety provisions of the scheme when storing and transporting these chemicals.

These arrangements are recognised and supported by Chemical Regulations Division (CRD) of the Health and Safety Executive as an industry standard for storing and distributing professional pesticides.

Protocol procedure

BASIS audits its members’ premises annually to ensure compliance with industry requirements. Part of this audit involves the BASIS Auditor reviewing the fire risk assessment. BASIS supplies a risk assessment model to all its members; but members can use another model if they wish. The satisfactory completion of a suitable and sufficient fire risk assessment is a critical feature for the BASIS audit.

If the BASIS Auditor determines that the risk from the storage and process is low or medium, they will advise the relevant FRS, so personnel can update any hazard information systems held. The FRS may not require a fire safety inspection, although the need for a risk information planning visit should be determined locally.

If the BASIS Auditor has assessed the premises as high-risk, they will advise the relevant FRS and request a visit by a FRS inspecting officer. The high-risk criteria will be allocated by BASIS according to the quantities and type of storage. BASIS will inspect each high-risk premises annually and request a report from the FRS once every five years, as long as it remains in the high-risk category.

For operational information purposes, BASIS will notify the FRS of the risk category, A, B or C with A being the highest, allocated by the environment agencies to each site.

An environment agency contact will also be provided if the FRS needs more information. In the absence of information to the contrary, non-registered premises will be categorised as high risk.

Administrative arrangements

To enable BASIS to handle the bulk of correspondence electronically, FRSs should update BASIS with their email contact details; to avoid updating problems, this should not be an individual’s email address.

BASIS will initiate the process by contacting the relevant FRS using a standard letter or email. Once email contact has been established, notifications will be emailed. Where a premises has been inspected recently, the local fire safety manager will decide whether a site visit or a remote audit of the fire safety file is most appropriate.

Following a FRS inspection or audit of a BASIS-registered premises, the FRS should inform BASIS of the outcome. They should respond to BASIS within four weeks of receiving a notification.

Inspection

BASIS-registered premises should be inspected using the same inspection criteria as any other premises. The inspector makes an assessment of the fire precautions and determines whether these are adequate for the hazard. It is not the remit of the FRS officer to assess the appropriateness of the storage facilities or process; BASIS will have done this. Approval of a premises by BASIS does not prevent the FRS taking enforcement action. If enforcement action is necessary, BASIS should be informed with details of the reasons for action so they can update records.

Inspecting officers should also consider whether the premises are subject to, and compliant with, the Dangerous Substances (Notification and Marking of Sites) Regulations (Northern Ireland) or the Dangerous Substances (Notification and Marking of Sites) Regulations (NAMOS Regulations).

The NAMOS Regulations require the person in control of any site or premises where a total quantity of 25 tonnes or more of dangerous substances is used or stored, or is to become used or stored, to give written notification to both the FRS and the HSE. The HSE is the enforcing authority for notification of the storage of dangerous substances and, once notified, the fire authority is the enforcing authority for the marking of sites with warning signs. The fire authority is responsible for giving directions as to the quantity, type and location of signs. Some exceptions do exist for example in London.

Warning signs required by the NAMOS Regulations at a BASIS site

Guidance for store holders

Those involved in the sale, supply and storage of pesticides approved for agricultural use must comply with the Code of Practice for Suppliers of Pesticides to Agriculture, Horticulture and Forestry, otherwise known as the ‘Yellow Code’ and subsequent codes of practice incorporating the Control of Pesticides (Sustainable Use) Regulations.

The code recommends that environment agencies, the FRS and others should be consulted during the planning of a new store or the redesigning of an existing one. Once a store has been built or commissioned, storeowners must notify the environment agency and the FRS in writing. All stores should hold written approval from the environment agency and the FRS issued after their primary inspection. These inspections consider means of escape, spillages of chemicals and firewater containment as well as firefighter safety.

A typical BASIS store

Contingency planning

Site operators who have complied with the registration scheme conditions will have a contingency plan for in-store and out-of-store spillages and fires. Employees will be trained in the correct response to incidents.

The contingency plan, should be kept away from the risk area and be provided to the FRS on arrival, should include:

  • Detailed plans of the buildings and drainage systems
  • A current stock list of chemicals stored and the maximum quantities likely to be held at any one time
  • Contact details of a suitable waste disposal contractor able to deal with emergency disposal operations
  • Name, address and telephone number of an out-of-hours contact

Drainage systems

On new sites, drainage systems outside the store containment areas should have a pollution control valve. Such valves should be clearly identified on the site drainage plans and provided with durable on-site notices.

If firewater volumes may exceed the bunded volume including the capacity of the blocked drainage system. Additional containment capacity may need to be considered, for example using of land booms and portable tanks.

If pollution control valves can’t be retrofitted on existing sites, portable pipe blockers may be used instead. Drain mats, portable tanks, sandbags, made of durable material, and sorbent materials can also be useful. These should be available in safe easily accessible storage away from the main store; their location should be clearly marked, and the position shown on the site plan. These should be in addition to any sorbents held within the store to deal with small spillages.