PESTICIDE USAGE SURVEY REPORT 254 · PESTICIDE USAGE SURVEY REPORT 254 AMENITY PESTICIDES IN THE...

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PESTICIDE USAGE SURVEY REPORT 254

AMENITY PESTICIDES

IN THE UNITED KINGDOM

2012

SECTION 1 – QUANTITATIVE REPORT

Dr. A. J. Goulds

Director, European Syndicated Services

GfK Kynetec Limited

Weston Court

Weston

Berkshire

RG20 8JE

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CONTENTS Page

Section 1 – Quantitative Report 1

Data Uses 3

Revisions Policy 3

Contact Information & Feedback 3

Amenity Report Overview 3

Quantitative Report – Executive Summary 4

Introduction – Pesticide Usage in Amenity (Background & Methodology) 5

Trends 6

Amenity Sub-Sectors 7

Golf 9

Industrial 11

Infrastructure 13

Public Authorities 16

Residential 21

Turf 24

Quantitative Report – Appendix 1 – Definitions 27

Appendix 2 – Formulations 29

Appendix 3 – Application Tables 30

Section 2 – Qualitative Report 40

Qualitative Report – Executive Summary 41

Qualitative Report - Appendix 1 – Case Study Summaries 58

Appendix 2 – Consolidated Replies to Closed Questions 141

Appendix 3 – Topic Guide – Questionnaire & Interview Structure 149

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DATA USES

The data are used for a number of purposes including:

• Informing the pesticide risk assessment (approval) process;

• Policy, including assessing the economic and/or environmental; implications of introduction of new active substances and the withdrawal/non-approval of pesticide products (the data reported to organisations such as the OECD and EU enabling the UK to honour international agreements);

• Informing the targeting of monitoring programmes for residues in food and the environment;

• Contributing to assessing the impact of pesticide use, principally as part of the Pesticides Forum’s Annual Report;

• Responding to enquiries (for example, Parliamentary Questions, correspondence, queries under the Freedom of Information Act or Environmental Information Regulations, etc.);

• Providing information to assist research projects which can support all of the above activities;

• Training/teaching programmes which are designed to improve practice in the use of pesticides by the farming/training industries;

• Informing the Wildlife Incident Investigation Scheme (WIIS) programme to help identify potential misuse of pesticides.

REVISIONS POLICY The figures presented in this report are finalised. We will provide information on any revisions we make to the report or the datasets if any inaccuracies or errors occur.

CONTACT INFORMATION AND FEEDBACK For further information please contact:

Pesticide Usage Survey Team – e-mail: [email protected] Telephone: 01904 462 694 Or visit the website: http://pusstats.fera.defra.gov.uk/surveys/ Alternatively please contact: FERA at: [email protected] QUALITY ASSURANCE For full details of the approach and methodologies used as part of the Pesticide Usage Surveys (PUS) and British Survey of Fertiliser Practice (BSFP) and the steps taken to ensure that the highest quality of data are collected, please refer to the following document: http://pusstats.fera.defra.gov.uk/surveys/documents/qualityAssurance.pdf AMENITY REPORT – OVERVIEW In contrast to the field based pesticide usage surveys, the Amenity PUS report is divided into two main sections. The first deals with the quantitative elements of the study, including estimates of UK usage; whilst the second provides case studies and verbatim answers from respondents which put their own usage in context with other areas of Amenity and field based pesticide usage.

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QUANTITATIVE REPORT - EXECUTIVE SUMMARY

This report presents information on the use of amenity pesticides in the United Kingdom during the 2012 calendar year within the following overall sub-sector headings: Infrastructure (roads, railways and aquatic use), Industrial (pipes, cables, commercial contracted and construction, for land clearance only), Public Authorities (contracted and educational institutes, footpaths and public spaces), Residential (gardens, trees and landscapes, residential dwellings and multi-dwellings), Turf (farms and commercial contractors), and Golf. The data on the area of pesticide treatments and the amounts of active substances applied were obtained by detailed interviews with manufacturers, distributors, specialist contractors and other users to obtain estimates at a national level. The use of biocidal products is outside the scope of the current study. Information for the segment “Public Authority: Self-applied’ was derived from an earlier (2009) commercial study of the UK amenity market completed by GfK. In 2012, an estimated 701,148kg of active substances were applied to 299,419 hectares. Of this total, herbicides accounted for 96% by weight (92% by area; approximately 276,257 hectares), fungicides accounted for 4% by weight (4.9% by area; approximately 14,661 hectares) and insecticides (including the molluscicide, metaldehyde) less than 1% by weight (2.8% by area; approximately 8,500 hectares). Of the six amenity ‘sub-sectors’ studied, <Infrastructure> accounted for 39% of the area treated with pesticides (52% by weight of active substance applied), especially main and local roads, with <Public Authorities> (36% by area, 18% by weight) and <Turf> (11% by area, 15% by weight) being the next largest types. Collectively, the sub-sector <Public Authority> and the segments ‘Road:main and Road:local’ (from the sub-sector <Infrastructure>) accounted for 57.6% of the area treated with pesticides (172,479 hectares) and 68% by weight (473,897kg). Approximately 72% of all pesticide applications were targeted against mixed infestations of grass and broadleaf weeds, with sprays against broadleaf weeds alone accounting for a further 18%. Pesticides applied for the prevention and/or control of turf diseases was the next largest target at 5%. A total of 17 formulation types were identified during the course of the research. Of these just four - soluble liquids (53%), soluble concentrates (22%), granules (16%) and emulsifiable concentrates (9%) - accounted for 99.6% of the weight of active substances applied in 2012. Tables identifying the most important active substances, alone or in combinations, are presented for each sub-sector, segment and pesticide type. Overall, 41 different active substances were applied, comprising 18 herbicides, 15 insecticides and 8 fungicides. Of these, three active substances accounted for c. 80% of the formulated product area treated: glyphosate (52%), dicamba (21%) and 2.4-D (6%). In terms of the estimated weight of active substances applied, three active substances accounted for 81% of the total: glyphosate (49%), ferrous-sulphate (15%) and 2,4-D (8%).

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INTRODUCTION – PESTICIDE USAGE IN AMENITY

BACKGROUND, METHODOLOGY AND REPORT STRUCTURE

The treatment of amenity areas is a specialist operation. The varied tasks, from weed control in and around installations, the management of environmentally sensitive aquatic environments, through to the production and upkeep of fine turf, are done by either experienced teams of in-house professionals, for example local authority environmental services or external, specialist contractors. These tasks are all the more challenging due to a comparatively limited range of authorised products and economic viability of alternative products or techniques. Treatments must be carried out with due regard to the environment and in areas of high foot-fall by the general public. The amenity survey comprised two major elements:

1. Quantifying the use of amenity pesticides during the calendar year 2012 for six major Amenity sub-sectors (comprising 20 separate segments; Appendix 1 – Definitions); Golf, Industrial, Infrastructure, Public Authorities, Residential and Turf as defined by the Chemicals Regulation Directorate (CRD). Between them, these sub-sectors/segments account for an estimated 96% by volume of pesticide use in amenity; the balance is accounted largely by pesticides used during forestry site preparation. Also at the request of CRD the survey excluded the use of biocides.

2. Qualitative depth interviews were completed between October and November 2013 amongst a national sample of 30 respondents split evenly between green-keepers, local authorities and contractors. The purpose of this aspect of the survey was to gain a deeper understanding of the working practices, levels of training, and understanding of, and adoption of practices consistent with, the 2006 Pesticide Code of Practice for Using Plant Protection Products, including the use of alternative products and techniques. The results of this survey are reported separately.

• The quantitative element of the survey was achieved through more than 40 face-to-face or telephone depth interviews involving manufacturers, distributors, professional organisations and users. By cross-referencing the responses of knowledgeable respondents, the executive interview approach enables the validation of product volumes by sub-sector (and segment) and targets to a national level. Respondents also provided estimates of the numbers of applications per season and average dose rates by segment. Combined with product volumes this information is then used to derive figures for area treated. It is a technique that has been deployed successfully by GfK for the plant protection market in 230 crop types across over 70 countries worldwide for more than 30 years. Unlike pesticide (shorthand for Plant Protection Products (PPPs) usage surveys for annual and permanent crops where area details are easily accessible, similar information is not available for amenity areas from which to calculate the proportion that is untreated.

• The segment, ‘Public-Authority: Self-applied’ was omitted from the 2012 survey. However, based on information received during the qualitative element of the amenity study, it is apparent that the areas treated with pesticides has changed little since the last independent commercial study of UK completed by GfK in 2009. Accordingly, data from this earlier study has been incorporated for reference purposes alongside the information obtained during the current 2012 amenity study.

Since 2012 represents the first year of reporting amenity pesticide usage for the UK in the current format, direct comparisons with previous surveys are not possible. However, from information provided some overall trends can be elicited:

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TRENDS

Figure 1 - Changes in the overall weight of pesticides applied to specified amenity sectors in the United Kingdom: 2006 - 2012 (tonnes)

0

200

400

600

800

1000

1200

1400

1600

1800

2000

2006 2009 2012

In contrast to agricultural and horticultural use in the UK, where 17,616,246kg of pesticides were applied in 2012 (source: PUSSTATS; http://pusstats.fera.defra.gov.uk/), pesticide usage within the selected amenity sub-sectors in the same year was comparatively small (701,148kg; Figure 1). Indeed, between 2006 and 2012, the overall use of pesticides is estimated to have declined 63% by weight applied for the six amenity sub-sectors studied.

Figure 2 - Changes in the weight of the major pesticide groups applied to specified amenity sectors in the United Kingdom: 2006 - 2012 (tonnes)

1837

1402

671

4650 25 57150

200

400

600

800

1000

1200

1400

1600

1800

2000

2006 2009 2012

Herbicides

Fungicides

Insecticides

Between 2006 and 2012, the use of herbicides fell by 64% by weight applied. During the same period, the weight of insecticides (including the molluscicide, metaldehyde) applied fell 67% and use of fungicides by 50%. Comparable data for the area treated with pesticides in earlier years are not available, but in 2012 herbicides accounted for 92.3% of the area treated within the selected amenity sectors (total area 276,257 hectares) and the fungicide treated area an estimated 4.9% NB. An area treated cannot be provided to the relatively small volume of insecticides (64kg out of 4,637kg) applied as pastes or gels.

Source: GfK Kynetec Ltd

Source: GfK Kynetec Ltd

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AMENITY SUB-SECTORS

Comparative summaries of the distribution of treated areas and weight of pesticide by amenity sub-sectors are presented in Figures 3 and 4. Between them, the sub-sectors <Infrastructure > (segments: aquatic, roads and railways) and <Public Authorities> (contracted and educational institutes, footpaths and public spaces) accounted for 70.2% and 75.4% of the area treated and weight of amenity pesticide applied, respectively. Golf courses account for 11.7% of area and 11.5% of amenity by weight applied. The smallest sub-sectors researched were <Industrial> (cables and pipelines) and <Residential> (Home and Garden landscapers, multi-dwelling and residential lawn control operators), which between them accounted for an estimated 3.2% of area treated and 2.2% by weight applied.

Figure 3: Relative areas of selected amenity sub-sectors in the United Kingdom - 2012

12%

1%

52%

18%

2%

15%

GOLF

INDUSTRIAL

INFRASTRUCTURE

PUBLIC AUTHORITIES

RESIDENTIAL

TURF

Figure 4: Relative weight of amenity pesticides applied to selected amenity sub-sectors in the United Kingdom - 2012

11%

1%

36%

1%

11%

39%

GOLF

INDUSTRIAL

INFRASTRUCTURE

PUBLIC AUTHORITIES

RESIDENTIAL

TURF

Base: 299,419 ha

Base: 701,147 kg

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OVERALL REASONS FOR USE

Figure 5: Percentage area treated by target

17.5%1.1%

0.1%

0.6%<0.1%

0.7%

0.1%2.0%

4.9%0.3%

72.3%

0.21%

AQUATIC WEEDS

BROADLEAF-WEEDS

CRAWLING INSECTS

CRAWLING/FLYING INSECTS

CROSS-SPECTRUM WEEDS

FLYING INSECTS

LARVAE (INSECTA)

MOSS (BRYOPHYTA)

SLUGS AND SNAILS

TURF DISEASES

TURF INSECTS

WOODY WEEDS

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PESTICIDE USAGE - GOLF

• 35,122 pesticide treated hectares

• 203,599kg of formulated products applied, or 78.2 tonnes of active substances

• 1.46 treatments applied

• Between them, soluble concentrates and liquids account for 67% by area and 78% by weight

Figure 6 - Usage of the major pesticide groups on golf courses - 2012

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5

10

15

20

25

30

35

40

Herbicides Fungicides Insecticides

Per

cent

age

of t

otal

Area

Weight

Figure 7 - Pesticide formulation types used on golf courses - 2012

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10

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50

60

Dry Flow. EmulsifiableConc.

Granule Sol. Conc. Sol. Liq. Wettable Gran.

Per

cent

age

of t

otal

Area

Weight

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Golf courses – Herbicides

• Area treated: 25,235 hectares • Weight of active substances applied: 60,322kg • The most common formulations by area treated were:

Active Substance Formulation area treated

(ha)

Weight of active substance

applied (kg)

% of herbicide treated area

% area treated

Average number of applications (where applied)

Dicamba/MCPA/MCPP 12,895 27,079 36.4 39.3 1.30 2,4-D/Dicamba 6,936 6846 19.6 13.7 2.00 Glyphosate 5,940 8,554 16.8 16.2 1.45 2,4-D 5,615 8,843 15.8 22.2 1.00 2,4-DP/Dicamba/MCPA 3,819 8,782 10.8 7.6 1.30

Most herbicide applications were for general weed control. However, use of glyphosate for invasive weeds on golf courses was noted in the qualitative element of the survey.

Golf courses - Fungicides


Active Substance Formulation area treated (ha)


applied (kg)

% of fungicide treated area

% area treated

Average numbe r of applications (where applied)

Tebuconazole/Trifloxystrobin 6,645 1,994 44.7 52.4 1.40 Carbendazim 4,485 11,759 30.2 24.7 2.00 Azoxystrobin 1,164 291 7.8 6.4 2.00 Propiconazole 1,101 512 7.4 5.7 2.14 Trifloxystrobin 542 190 3.6 4.6 1.30

Golf courses - Insecticides

• Area treated: 826 hectares • Weight of active substances applied: 420kg • The most common formulations by area treated were:


(ha)


applied (kg)

% of insecticide treated area

% area treated


Chlorpyrifos-ethyl 519 374 62.8 62.8 1.00 Imidacloprid 307 46 37.2 37.2 1.00

GOLF - REASONS FOR USE

100% of herbicide, fungicide and insecticide usage was attributed to cross-spectrum (grass and broadleaf weeds), turf diseases (mainly Fusarium) and unspecified turf insects, respectively.

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PESTICIDE USAGE - INDUSTRIAL


• 13,200kg of formulated products applied, or 5.3 tonnes of active substances


• Between them, soluble liquids account for 67% by area and 73.5% by weight, with emulsifiable concentrates the balance.

Figure 8 - Usage of the major pesticide groups in Industrial - 2012

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90

100


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cent

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Area

Weight

Figure 9 - Pesticide formulation types used in Industrial - 2012

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70

80

Emulsifiable Conc. Soluble Liquid

Per

cent

age

of t

otal

Area

Weight

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Industrial – Row Cables



(ha)


applied (kg)


% area treated


Glyphosate 1,169 2,104 52.9 62.6 1.00 2,4-D 1,026 1,694 46.5 36.6 1.50

Industrial – Row Pipelines

• Area treated: 777 hectares • Weight of active substances applied: 1,400kg • The most common formulation by area treated was:

Active Substance Formul ation area treated

(ha)


applied (kg)


% area treated


Glyphosate 775 1,394 99.8 99.8 1.00

INDUSTRIAL - REASONS FOR USE

Out of a total of 2,644 hectares treated with herbicides, cross-spectrum (i.e. a mix of grass and broadleaf weeds) accounted for 73.5% (1,943 hectares), followed by broadleaf weeds (25.9%) and woody weeds (0.6%).

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PESTICIDE USAGE - INFRASTRUCTURE

• Comprises: aquatic banks, water bodies, forest roads, railways (branch, mainlines, yards) and roads (local and main)


• 756 tonnes of formulated products applied, or 273,797kg of active substances


• Between them, soluble liquids account for 82% by area and 84.7% by weight, with soluble concentrates, emulsifiable concentrates, and wettable granules making up the balance (Figure 11).

Figure 10 - Usage of the major pesticide groups across all Infrastructure segments - 2012

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Pe

rce

nta

ge

of

tota

l

Area

Weight

Figure 11 - Pesticide formulation types used across all Infrastructure segments - 2012

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Emulsifiable Conc. Soluble Conc. Soluble Liq.

Per

cent

age

of t

otal

Area

Weight

Collectively, roads account for 76% of the <Infrastructure> area treated with herbicides, with railways a further 22%, aquatic spaces (banks or water) 1% and forest roads less than 0.5%.

INFRASTRUCTURE - REASONS FOR USE

Out of a total of 156,311 hectares treated with herbicides, cross-spectrum (i.e. a mix of grass and broadleaf weeds) accounted for 90.2% (141,025 hectares), followed by broadleaf weeds (5.7%), woody weeds (3.8%), and aquatic weeds (0.3%).

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Infrastructure – Aquatic: Banks




applied (kg)


% area treated


2,4-D 891 1,470 58.9 58.9 1.00 Glyphosate 622 1,119 41.1 41.1 1.00

Infrastructure – Aquatic: Water

• Area treated: 398 hectares • Weight of active substances applied: 716kg • The most common formulation by area treated was:



applied (kg)


% area treated


Glyphosate 398 716 100 100 1.00

Infrastructure – Forest: Roads

• Area treated: 743 hectares • Weight of active substances applied: 846kg • The most common formulation by area treated was:



applied (kg)


% area treated


Glyphosate 719 777 96.8 96.8 1.00

Infrastructure – Railways: Private

• Area treated: 837 hectares • Weight of active substances applied: 2,139kg • The most common formulations by area treated were:



applied (kg)


% area treated


Glyphosate 1,009 1,909 80.5 85.1 1.50 Diflufenican/Glyphosate 121 158 14.5 10.2 1.00 Triclopyr 56 72 5.0 4.7 1.30

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Infrastructure – Railways: Mainlines




applied (kg)


% area treated


Glyphosate 27,944 21,537 41.8 58.9 2.00 Diflufenican/Glyphosate 13,932 18,182 41.7 29.4 1.00 Triclopyr 5,537 7,370 16.5 11.7 1.00

Infrastructure – Railways: Yards

• Area treated: 647 hectares • Weight of active substances applied: 1,215kg • The most common formulations by area treated were:



applied (kg)


% area treated


Glyphosate 342 615 36.2 40.8 1.50 Diflufenican/Glyphosate 185 240 28.6 22.1 1.00 Triclopyr 301 360 33.9 36.0 1.40

Infrastructure – Roads: Local




applied (kg)


% area treated


Glyphosate 62,382 110,121 89.7 91.1 1.04 2,4-D 4,006 6,609 5.8 4.1 1.50 MCPA 2,173 3,803 3.1 3.3 1.00

Infrastructure – Roads: Main



Weight o f active substance

applied (kg)


% area treated


Glyphosate 48,754 89,132 90.0 92.1 1.05 2,4-D 2,848 4,698 5.1 3.6 1.50 MCPA 1,258 2,202 2.2 2.4 1.00

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PESTICIDE USAGE – PUBLIC AUTHORITIES

• Comprises: Commercially contracted: Pest Control Officers, Public authority: Educational Institutions and Contracted Lawn Care Operators, Public Authority: Pest Control Officers, and Public-Authority: Self-applied. NB Pesticide usage on main and local roads is included in the sub-sector <Infrastructure>. Information for the sub-segment, ‘Public Authority: Self-Applied’ is derived from an earlier (2009) amenity study completed by GfK.


• 1,040,776kg of formulated products applied, or 254,678 of active substances


• Between them, soluble concentrates and liquids account for 57% by area and 69% by weight. Emulsifiable concentrates account for a further 29% and 28% by area and weight, respectively

Figure 12 - Usage of the major pesticide groups across all Public Authority segments - 2012

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Per

cent

age

of t

otal

Area

Weight

Figure 13 - Pesticide formulation types used across all Public Authority segments - 2012

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Aq. Soln

.

Dust. P

ow.

Emul. C

onc.

Emul. G

el

Gran.

Liq.

Mist

spra

y

Not av

ail.

Pellets

Bait (R

TU)

Sol. C

onc.

Sol. L

iq.

Wet.

Gra

n.

Wet.

Pow

.

Per

cent

age

of t

otal

Area

Weight

Within <Public Authority> the segment ‘Public-Authority: Self’ accounted for 64% and 85% by area treated and weight, respectively. ‘Public Authority: Lawn Care Operators’ accounted for a further 22% of area and 10% by weight, with ‘Commercially Contracted’, ‘Public Authority: Educational Institutions’ and ‘Public Pest Control Officers’ making up the balance (14% area and 4% by weight).

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Figure 14 - Usage of herbicides by Public Authority segments - 2012 (%)

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COMM-CONTRACT: PCO

PUBLIC-AUTH:ED

PUBLIC-AUTH:LCO

PUBLIC-AUTH:PCO

PUBLIC-AUTH:SELF

Per

cent

age

of t

otal

Area

Weight

PUBLIC AUTHORITIES - REASONS FOR USE

Out of a total of 68,960 hectares treated with herbicides, cross-spectrum (i.e. a mix of grass and broadleaf weeds) accounted for 97.6%, moss for 2.4% and woody weeds 0.03%. Turf diseases accounted for the area treated with fungicides (=4,218 hectares (ha)).

Insecticides were applied to the following targets in these proportions: (Base area treated = 5,595 ha)

Insect type Area %

Crawling Insect 0.2

Crawling Insect/Flying Insects 41.1

Flying Insects 31.7

Larvae (Insecta) 7.4

Turf Insect 14.4

Treatments for slugs and snails accounted for an estimated 2,032 hectares.

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Public Authorities – Commercial-Contracted: Pest Co ntrol Officers

• Insecticides only • Area treated: 4,121 hectares; excludes two indoxacarb- (0.7kg) one pyrethrin- (31.1kg),

one permethrin- (8.2kg) and one abamectin-based (0.07kg) formulation applied as gels, an aqueous solution or dustable powder for which it is not possible to provide an estimate of the area treated.

• Weight of active substances applied: 1,439kg (including active substances listed above) • The most common formulations by area treated were:


(ha)


applied (kg)


% area treated


Cypermethrin 1,964 1,257 45.0 47.7 1.00 Pyrethrins 1,686 23.5 38.6 37.1 1.10 Deltamethrin 348 31 8.0 8.4 1.00

Public Authorities – Educational Institutions

• Herbicides • Area treated: 5,133 hectares • Weight of active substances applied: 8,312kg • The most common formulations by area treated were:



applied (kg)


% area treated


Glyphosate 1,997 2,875 37.6 38.9 1.00 2,4-D 1,323 2,184 24.9 25.8 1.00 Dicamba/MCPA/MCPP 943 1,734 17.7 18.4 1.00 2,4-D/Dicamba 686 677 12.9 13.4 1.00

• Fungicides • Area treated: 782 hectares • Weight of active substances applied: 753kg • The most common formulations by area treated were:



applied (kg)


% area treated


Tebuconazole/Trifloxystrobin 546 164 69.8 69.8 1.00 Carbendazim 236 590 30.2 30.2 1.00

• Insecticides • Area treated: 863 hectares • Weight of active substances applied: 621kg • The most common formulation by area treated was:



applied (kg)


% area treated


Chlorpyrifos-ethyl 863 621 100 100 1.00

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Public Authorities – Lawn Care Operators




applied (kg)


% area treated


Dicamba/MCPA/MCPP 5,061 9,300 33.9 35.8 1.00 Glyphosate 3,004 3,421 20.1 21.3 1.00 2,4-D 2,630 4,339 17.6 18.6 1.00 2,4-D/Dicamba 2,483 2,451 16.6 17.6 1.00

• Fungicides • Area treated: 2,501 hectares • Weight of active substances applied: 2,994kg • The most common formulations by area treated were:



applied (kg)


% area treated


Tebuconazole/Trifloxystrobin 1,824 547 65.1 72.9 1.00 Carbendazim 979 3,421 34.9 27.1 1.44

• Insecticides • Area treated: 232 hectares • Weight of active substances applied: 155kg • The most common formulations by area treated were:



applied (kg)


% area treated



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Public Authorities – Pest Control Operators

• Insecticides only • Area treated: 133 hectares; excludes one pyrethrins- (19.4kg), one imidacloprid- (1.4kg)

and one permethrin-based (4.0kg) applied as an aqueous solution or dustable powder for which it is not possible to provide an estimate of the area treated.

• Weight of active substances applied: 44kg (including active substances listed above) • The most common formulations by area treated were:


Weight of active

substance applied (kg)


% area treated

Average number of

applications (where applied)

Deltamethrin 72 7.9 54.3 54.3 1.00 Lambda-cyhalothrin 24 3.6 18.3 18.3 1.00 Alphacypermethrin 19 5.5 14.3 14.3 1.00 Alphacypermethrin/Flufenoxuron 11 1.6 8.1 8.1 1.00

Public Authorities – Self-Applied (information taken from a 2009 study completed by GfK)




applied (kg)

% of herbicid e treated area

% area treated


Glyphosate 45,398 99,783 93.2 92.1 2.00 Ferrous-sulphate 1,647 100,884 3.4 3.3 2.00 2,4-D/Dichlorprop-P 1,098 1,647 2.3 2.2 2.00

• Fungicides • Area treated: 317 hectares • Weight of active substances applied: 2,370kg • The most common formulations by area treated were:



applied (kg)


% area treated


Iprodione 260 1,301 41.1 41.1 2.00 Carbendazim 189 377 29.8 29.8 2.00 Chlorothalonil 184 692 29.1 29.1 2.00

• Molluscicides (grouped elsewhere for general reporting under ‘Insecticides’) • Area treated: 635 hectares • Weight of active substances applied: 427kg • The most common formulations by area treated were:



applied (kg)

% of treated area

% area treated


Metaldehyde 2032 427 100 100 3.2

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PESTICIDE USAGE – RESIDENTIAL

• Comprises: Home and Garden Landscapers, Multidwelling – Lawn Care Operators, Residential – Lawn Care Operators.


• 31,919kg of formulated products applied, or 10,371kg of active ingredients



Figure 15 - Usage of the major pesticide groups across all Residential segments - 2012

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cent

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otal

Area

Weight

Figure 16 - Pesticide formulation types used across all Residential segments - 2012

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otal

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Figure 17 - Usage of amenity pesticides across all Residential segments - 2012

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H+G-LANDSCAPERS MULTI-DWELLING: LCO RESID: LCO

Per

cent

age

of t

otal

Area

Weight

Within Residential, the segment <Lawn Care Operators> accounts for 79% of area treated and 80% by weight. Next comes <Home and Garden Landscapers> with 17.6% and 16.3% for area and weight, respectively, with <Multi-Dwelling: LCO> accounting for the balance.

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RESIDENTIAL - REASONS FOR USE

Out of a total of 5,451 hectares treated with herbicides, cross-spectrum (i.e. a mix of grass and broadleaf weeds) accounted for 59.9% (=3,265) and broad-leaf weeds alone a further 40.1%. Turf diseases accounted for the area treated with fungicides (=490 hectares) and Turf insects accounted for all the area treated with insecticides (=843 hectares).

Residential – Home and Garden: Landscapers

• All pesticide types and active substances • Area treated: 1,196 hectares • Weight of active substances applied: 1,696kg • The most common formulations by area treated were:



applied (kg)


% area treated


Glyphosate 980 1,411 81.9 81.9 1.00 Chlorpyrifos-ethyl 144 104 12.0 12.0 1.00 Carbendazim 73 182 6.1 6.1 1.00

Residential – Multidwelling: Lawn Care Operators

• Herbicides only • Area treated: 216 hectares • Weight of active substances applied: 356kg • The most common formulation by area treated was:



applied (kg)


% area treated


2,4-D 216 356 100 100 1.00

23

Residential – Residential: Lawn Care Operators




applied (kg)


% area treated


Clopyralid/Diflufenican/MCPA

2,185 3,670 48.8 51.4 1.00

Dicamba/MCPA/MCPP 840 1,543 18.8 19.7 1.00 Glyphosate 788 1,135 17.6 18.5 1.00 2,4-DP/Dicamba/MCPA 440 1,011 9.8 5.2 2.00




applied (kg)


% area treated


Tebuconazole/Trifloxystrobin 372.25 112 87.8 89.2 1.00 Iprodione 29 145 6.8 5.3 1.30 Carbendazim 23 57 5.4 5.5 1.00

• Insecticides • Area treated: 700 hectares • Weight of active substances applied: 428kg • The most common formulations by area treated were:



applied (kg)


% area treated



24

PESTICIDE USAGE – TURF

• Comprises: Commercial-Contract: Lawn Care Operators and Turf-Farms.


• 159,880kg of formulated products applied, or 78,845kg of active substances



Figure 18 - Usage of the major pesticide groups across all Turf segments - 2012

0102030405060708090

100


Per

cent

age

of t

otal

Area

Weight

Figure 19 - Pesticide formulation types used across all Turf segments - 2012

0102030405060708090

Emulsifiable Conc. Soluble Conc. Suspo-Emulsion Soluble Liq.

Per

cent

age

of t

otal

Area

Weight

Figure 20 - Usage of amenity pesticides across all Turf segments - 2012

0102030405060708090

100

AREA WEIGHT

Per

cent

age

of t

otal

COMMERCIAL-CONT: LCO

TURF-FARMS

Within Turf, <Commercial-Contracts: LCO> account for 96.5% of the area treated with amenity pesticides and 96.9% by weight, the balance attributed to <Turf-Farms>.

25

TURF - REASONS FOR USE

Out of a total of 42,718 hectares treated with herbicides, broadleaf weeds accounted for 95.3% (=40,724 hectares) with cross-spectrum (i.e. a mix of grass and broadleaf weeds) a further 4.7%. Turf diseases accounted for the area treated with fungicides (=1,508 hectares) and turf insects accounted for all the area treated with insecticides (=586 hectares).

TURF – Commercial-Contracts: Lawn Care Operators




applied (kg)


% area treated


Dicamba/MCPA/MCPP 34,444 63,291 75.9 82.0 1.00 2,4-D/Dicamba/Fluroxypyr 5,051 4,470 11.1 6.0 2.00 2,4-D 2,615 4,184 5.8 6.2 1.00 Glyphosate 1,614 1,417 3.6 3.8 1.00

• Fungicides • Area treated: 1,025 hectares • Weight of active substances applied: 707kg • The most common formulations by area treated were:



applied (kg)


% area treated


Carbendazim 633 365 55.0 55.1 1.12 Tebuconazole/Trifloxystrobin 479 144 41.6 42.5 1.10 Iprodione 40 198 3.4 2.4 1.60




applied (kg)


% area treated



26

TURF – Turf Farms

• Herbicides • Area treated: 694 hectares • Weight of active substances applied: 1,798kg • The most common formulations by area treated were:



applied (kg)


% area treated


Dicamba/MCPA/MCPP 595 1,718 60.0 42.9 2.00 Florasulam/Fluroxypyr 314 64 31.7 45.3 1.00 Isoxaben 82 15 8.3 11.9 1.00




applied (kg)


% area treated


Carbendazim 479 120 91.2 99.2 1.00 Iprodione 46 231 8.8 0.8 12.00




applied (kg)

% of insecticid e treated area

% area treated



27

APPENDIX 1

Amenity Sector and Non-Crop Sub-Sector & Segment de finitions

Golf (sub-sector)

Golf Total All turf care, and brush care operations contracted out or applied by employees of golf courses.

Industrial (sub-sector)

Row-Pipelines All herbicidal and insecticidal applications to pipes carrying petroleum, natural gases, and water, their pumping

stations and protective fencing.

Row-Cables All herbicidal and insecticidal applications to electrical and communication transmission rights-of-ways,

microwave repeater stations, electrical sub-stations, their buildings and protective fencing, and environs.

Infrastructure

(sub -sector)

Aquatic: Water

All herbicidal applications in publicly owned canals, rivers, lakes, irrigation ditches, but excluding operations

associated with fish farming or privately owned ornamental or farm waters. Insecticides and larvicides included

in Public Health.

Aquatic: Banks

All herbicidal applications around publicly owned canals, rivers, lakes, and irrigation ditches, but excluding any

operations associated with fish farming or privately owned waters. Insecticides and larvicides included in

Public Health.

Forest: Roads/Rights of

Way

All herbicidal, PGR, and insecticidal treatments alongside forest roads and rights of way, and in roadway ditches [+ berms] for control of grasses, broadleaves and brush, but excluding herbicides used beneath asphalt during construction

Roads: Main

All herbicidal, PGR, and insecticidal treatments alongside state and nationally maintained roads, and in

roadway drainage ditches [+ berms] for control of grass, broadleaves and brush, excluding herbicides used

beneath asphalt during construction.

Roads: Local

All herbicidal, PGR, and insecticidal treatments alongside locally maintained roads, and in roadway ditches [+

berms] for control of grasses, broadleaves and brush, but excluding herbicides used beneath asphalt during

construction.

Railways: Mainline/Long

Distance Lines (Public) Pesticidal treatments of weeds, brush, and insects, excluding any mechanical eradication procedures.

Railways: Private Pesticidal treatments of weeds, brush, and insects, excluding any mechanical eradication procedures.

Railways: Yards/Sidings Pesticidal treatments of weeds, brush, and insects, excluding any mechanical eradication procedures.

28

Public Authorities

(sub -sector)

Commercial

Contracted: PCO

All insect and other pest control operations contracted for or by private industrial and commercial facilities

including both interior and exterior applications of insecticides, but excluding turf care and any pesticides

incorporated within products produced at such facilities.

Public Authority:

Educational Institutions

All turf, landscape, brush control and pest control operations contracted for or by public authorities, or

conducted on their own behalf, for educational institutions and facilities, including public and private secondary

schools, and universities, and their sports arenas/playing fields.

Public Authority

Contracted: Lawn Care

Operators

All turf, landscape, and brush control, contracted for or by public authorities for cemeteries, local parks, public

housing and sports areas (not associated with educational facilities), offices, streets, drains, sewers, sewage

works, parking lots, hospitals and their grounds.

Public Authority

Contracted: PCO

All insect and other pest control operations contracted out by local, state or national public authorities in

cemeteries, parks, drains, sewers, streets, parking lots, hospitals, airports, etc., including both interior and

exterior applications of insecticides but excluding turf care.

Public Authority:

Self-Applied

All self-applied applications of herbicides, insecticides, fungicides, molluscicides by public authorities. Included

are cemeteries, parks, car parks, footpaths, hospitals, and other public spaces.

Residential

(sub -sector)

H+G-Landscapers All exterior pesticide spray operations contracted out for establishment or maintenance in relation to private and multi-dwelling residential buildings, including tree spraying and brush control, but excluding turf care.

Multi-dwelling Lawn

Care Operators Herbicides, PGRs, insecticides, and fungicides applied to turf under contract around multi-dwelling buildings.

Residential Lawn Care

Operators

Herbicides, PGRs, insecticides, and fungicides applied to turf under contract around private residential

buildings.

Turf (sub-sector)

Commercial-Contract:

Lawn Care Operators

Herbicides, PGRs, insecticides, and fungicides applied to turf under contract to commercial and industrial

facilities by professional lawncare operators.

Turf Farms All weed, insect and disease control associated with turf grown at turf farms for transplanting.

29

APPENDIX 2

Formulation & Formulation code

Formulation codes use the following nomenclature:

AB Grain bait LA Lacquer

AEA Aerosol dispenser LF Liquid fumigant

AI Active ingredient LI Liquid

AL Other liquids to be applied undiluted LP Liquid paste

AS Aqueous solution LS Liquid/solution for seed treatment

BB Block bait MC Microcapsule suspension

BR Briquettes MG Microgranules

CA Coating agent MS Mist spray

CB Bait concentrate NB Fogging concentrate

CG Encapsulated granule OF Oil-miscible flowable concentrate

CR Crystals OI Oil

CS Capsule suspension OL Oil-miscible liquid

DC Dispersible concentrate OP Oils dispensable powder

DP Dustable powder PA Paste

DS Dry seed treatment powder PB Plate bait

EC Emulsifiable concentrate PC Gel or paste concentrate

ED Electrochargeable liquid PD Poison drink

EM Emulsion PO Pour on

EO Emulsion, water in oil PR Plant rodlet

ES Emulsion for seed treatment PS Seed coated with pesticide

EW Emulsion, oil in water PT Pellets

FC Liquid cream PW Powder

FD Smoke tin PY Pump spray

FG Fine granule RB Bait (ready for use)

FK Smoke candle SA Spot on

FP Smoke cartridge SB Scrap bait

FR Smoke rodlet SC Suspension concentrate

FS Flowable concentrate for seed treatment SE Suspo-emulsion

FT Smoker tablet SG Water soluble granules

FU Fumigant/Smoke generator SL Soluble concentrate

FW Smoke pellet SO Spreading oil

GA Gas SP Water-soluble powder

GB Granular bait SS Water-soluble powder for seed treatment

GE Gas generating product ST Seed treatment

GF Smoke granules SU ULV suspension

GG Macrogranules TB Tablet

GL Emulsifiable Gel TC Technical material

GP Flo-dust TK Technical concentrate

GR Granule TP Tracking powder

GS Grease TW Twin pack

HN Hot fogging concentrate UL ULV liquid

IM Impregnated material VP Vapour releasing product

IS Impregnated strip WG Water-dispersible granules

KK Combi-pack (solid/liquid) WP Wettable powder

KL Combi-pack (liquid/liquid) WS Water-dispersible powder for slurry treatment

KN Cold fogging concentrate WT Water-soluble tablet

KP Combi-pack (solid/solid) XX Other formulations

30

APPENDIX 3 – APPLICATION TABLES

Table 1: Amenity 'sub-sectors' and segments, United Kingdom 2012 - areas treated (hectares) and weight of amenity pesticides applied (kilograms)

Area

treated (ha) AS volume

(kg) Product area treated (PAT)

(ha)~ Product volume

(kg) GOLF

GOLF: TOTAL 35,122 78,204 51,122 203,599 INDUSTRIAL

ROW-CABLES 1,867 3,838 2,209 9,315 ROW-PIPELINES 777 1,400 777 3,884

INFRASTRUCTURE AQUATIC: BANKS 1,513 2,590 1,513 6,050 AQUATIC: WATER 398 716 398 1,988 FOREST: ROADS/RIGHTS OF WAY 743 846 743 2,301 RAILWAYS: PRIVATE 837 2,139 1,186 4,775 RAILWAYS: MAINLINES 33,441 47,088 47,413 137,872 RAILWAYS: YARDS 647 1,215 837 2,860 ROADS: LOCAL 65,776 121,825 69,551 332,509 ROADS: MAIN 52,957 97,379 56,249 267,940

PUBLIC AUTHORITIES COMMERCIAL-CONTRACTED: PCO 4,121 1,439 4,367 23,591 PUBLIC-AUTH: ED 6,777 9,687 6,960 23,938 PUBLIC-AUTH: LCO 16,863 26,505 17,969 66,347 PUBLIC-AUTH: PCO 133 45 133 2,986 PUBLIC-AUTH: SELF-APPLIED* 25,590 217,002 51,375 923,913

RESIDENTIAL H+G-LANDSCAPERS 1,196 1,695 1,196 4,497 MULTIDWELLING: LCO 216 356 216 712 RESID: LCO 5,373 8,320 5,599 26,710

TURF

COMMERCIAL-CONT: LCO 43,224 76,401 46,876 154,078 TURF-FARMS 1,587 2,444 1,927 5,802

Grand Total 299,158 701,134 368,616 2,205,667

~ PAT = Area Treated x Frequency of Application, at the individual formulated product level * Source: 2009 study, GfK Kynetec Ltd.

31

Table 2a: Usage of amenity pesticides for selected 'sub-sectors' and segments in the United Kingdom, 2012 - formulated product level

Fungicides Herbicides Insecticides Total Product area treated (PAT) (ha)

Total Product volume (kg)

Product area treated (PAT)

(ha) Product

volume (kg) Product area

treated (PAT) (ha) Product

volume (kg) Product area

treated (PAT) (ha) Product

volume (kg) GOLF

GOLF: TOTAL 14,864 44,815 35,432 148,797 826 9,987 51,122 203,599

INDUSTRIAL ROW-CABLES 2,209 9,315 2,209 9,315 ROW-PIPELINES 777 3,884 777 3,884

INFRASTRUCTURE AQUATIC: BANKS

1,513 6,050

1,513 6,050

AQUATIC: WATER 398 1,988 398 1,988 FOREST: ROADS/RIGHTS OF WAY 743 2,301 743 2,301 RAILWAYS: PRIVATE

1,186 4,775

1,186 4,775

RAILWAYS: MAINLINES 47,413 137,872 47,413 137,872 RAILWAYS: YARDS

837 2,860

837 2,860

ROADS: LOCAL 69,551 332,509 69,551 332,509 ROADS: MAIN 56,249 267,940 56,249 267,940

PUBLIC AUTHORITIES

COMMERCIAL-CONTRACTED: PCO 4,367 23,591 4,367 23,591 PUBLIC-AUTH: ED 782 1,725 5,316 20,919 863 1,295 6,960 23,938 PUBLIC-AUTH: LCO 2,803 6,718 14,935 58,683 232 947 17,969 66,347 PUBLIC-AUTH: PCO 133 2,986 133 2,986 PUBLIC-AUTH: SELF-APPLIED* 633 7,343 48,710 902,346 2,032 14,224 51,375 923,913

RESIDENTIAL H+G-LANDSCAPERS 73 363 980 3,918 144 216 1,196 4,497 MULTIDWELLING: LCO 216 712 216 712 RESID: LCO 425 1,067 4,475 20,810 700 4,834 5,599 26,710

TURF

COMMERCIAL-CONT: LCO 1,152 2,001 45,375 150,611 349 1,466 46,876 154,078 TURF-FARMS 525 1,163 991 4,023 411 617 1,927 5,802

Grand Total 21,257 65,194 337,306 2,080,313 10,056 60,162 368,616 2,205,667 * Source: 2009 study, GfK Kynetec Ltd.

32

Table 2b: Usage of amenity pesticides for selected 'sub-sectors' and segments in the United Kingdom, 2012 - active substance level

Fungicides Herbicides Insecticides Total Area treated (ha)

Total AS volume (kg) Area treated (ha)

AS volume (kg) Area treated (ha) AS volume (kg) Area treated (ha) AS volume (kg)

GOLF GOLF: TOTAL 9,062 17,462 25,235 60,322 826 419 35,122 78,204

INDUSTRIAL ROW-CABLES 1,867 3,838 1,867 3,838 ROW-PIPELINES 777 1,400 777 1,400

INFRASTRUCTURE AQUATIC: BANKS 1,513 2,590 1,513 2,590 AQUATIC: WATER 398 716 398 716 FOREST: ROADS/RIGHTS OF WAY 743 846 743 846 RAILWAYS: PRIVATE 837 2,139 837 2,139 RAILWAYS: MAINLINES 33,441 47,088 33,441 47,088 RAILWAYS: YARDS 647 1,215 647 1,215 ROADS: LOCAL 65,776 121,825 65,776 121,825 ROADS: MAIN 52,957 97,379 52,957 97,379

PUBLIC AUTHORITIES COMMERCIAL-CONTRACTED: PCO 4,121 1,439 4,121 1,439 PUBLIC-AUTH: ED 782 753 5,132 8,312 863 621 6,777 9,687 PUBLIC-AUTH: LCO 2,503 2,994 14,129 23,356 232 155 16,863 26,505 PUBLIC-AUTH: PCO 133 45 133 45 PUBLIC-AUTH: SELF-APPLIED* 317 2,370 24,638 214,205 635 427 25,590 217,002

RESIDENTIAL H+G-LANDSCAPERS 73 181 980 1,411 144 103 1,196 1,695 MULTIDWELLING: LCO 216 356 216 356 RESID: LCO 418 314 4,256 7,578 700 428 5,373 8,320

TURF

COMMERCIAL-CONT: LCO 1,025 707 42,024 74,991 175 704 43,224 76,401 TURF-FARMS 483 351 694 1,797 411 296 1,587 2,444

Grand Total 14,661 25,132 276,260 671,364 8,238 4,638 299,158 701,134 * Source: 2009 study, GfK Kynetec Ltd.

33

Table 3: Usage of amenity pesticides on selected 'sub-sectors' in the United Kingdom, 2012 - number of active substances applied

Fungicides Herbicides Insecticides Grand Total

GOLF 7 7 2 16

INDUSTRIAL 0 3 0 3

INFRASTRUCTURE 0 8 0 8

PUBLIC AUTHORITIES 5 10 15 30

RESIDENTIAL 4 8 2 14

TURF 4 8 1 13

Total Number Unique AS 8 18 15 41

34

Table 4: Usage of amenity pesticides in selected 'sub-sectors' for the United Kingdom, 2012 (spray hectares)

GOLF INDUSTRIAL INFRASTRUCTURE PUBLIC AUTHORITIES RESIDENTIAL TURF Grand Total Herbicides

2,4-D 5,615 684 7,744 3,953 216 2,615 20,827

2,4-D/2,4-DP - - - 549 - - 549

2,4-D/Dicamba 3,468 - - 3,169 223 825 7,685

2,4-D/Dicamba/Ferrous-sulphate - - - 548 - - 548

2,4-D/Dicamba/Fluroxypyr - - - - - 2,256 2,256

2,4-DP/Dicamba/MCPA 1,909 - - 989 220 - 3,118

Clopyralid/Diflufenican/MCPA - - - - 2,185 - 2,185

Dicamba/MCPA/MCPP 9,919 - - 6,004 839 34,742 51,504

Diflufenican/Glyphosate - - 16,099 - - - 16,099

Ferrous-sulphate - - - 824 - - 824

Flazasulfuron - - 9 - - - 9

Florasulam/Fluroxypyr - - - - - 314 314

Glufosinate-ammonium 227 - - 146 - - 373

Glyphosate 4,097 1,943 144,513 27,699 1,768 1,614 181,634

Isoxaben - - - - - 82 82

MCPA - - 3,431 - - - 3,431

Picloram - - 176 - - - 176

Triclopyr - 16 5,918 19 - - 5,953

Grand Total 25,235 2,643 177,890 43,900 5,451 42,448 297,567 Fungicides

Azoxystrobin 582 - - - - - 582

Carbendazim 2,243 - - 1009 95 1043 4,390

Chlorothalonil - - - 92 - - 92

Iprodione 197 - - 130 22 29 378

Propiconazole 514 - - - - - 514

Pyraclostrobin 362 - - - - - 362

Tebuconazole/Trifloxystrobin 4,746 - - 2,370 373 436 7,925

Trifloxystrobin 417 - - - - - 417

Grand Total 9,062 0 0 3,601 490 1,508 14,661

35

Table 4 (cont): Usage of amenity pesticides in selected 'sub-sectors' for the United Kingdom, 2012 (spray hectares)~

GOLF INDUSTRIAL INFRASTRUCTURE PUBLIC AUTHORITIES RESIDENTIAL TURF Grand Total Insecticides

Abamectin - - - 0 - - 0

Alphacypermethrin - - - 110 - - 110

Alphacypermethrin/Flufenoxuron - - - 55 - - 55

Chlorpyrifos-ethyl 519 - - 1,074 710 586 2,888

Cypermethrin - - - 1,964 - - 1,964

Deltamethrin - - - 420 - - 420

Imidacloprid 307 - - 77 133 - 516

Indoxacarb - - - 0 - - 0

Lambda-cyhalothrin - - - 66 - - 66

Metaldehyde* 635 635

Permethrin - - - 42 - - 42

Phenothrin - - - 12 - - 12

Piperonyl-butoxide/Pyrethrins - - - 157 - - 157

Pyrethrins - - - 1,372 0 0 1,372

Grand Total 826 0 0 5,983 843 586 8,238 ~ Zeros indicate that the active substance has been used, but used as a bait or deterrent it has not been possible estimate the areas treated. Their active volumes are included in Table 5.

* The active substance metaldehyde is strictly a molluscicide but is included here under ‘Insecticide’ for convenience.

36

Table 5: Usage of amenity pesticides in selected 'sub-sectors' for the United Kingdom, 2012 (active substance applied, kg)

GOLF INDUSTRIAL INFRASTRUCTURE PUBLIC AUTHORITIES RESIDENTIAL TURF Grand Total Herbicides

2,4-D 8,843 1,694 12,778 6,522 356 4,184 34,377

2,4-D/2,4-DP - - - 1,647 - - 1,647

2,4-D/Dicamba 6,846 - - 3,128 220 1,628 11,822

2,4-D/Dicamba/Ferrous-sulphate - - - 11,836 - - 11,836

2,4-D/Dicamba/Fluroxypyr - - - - - 4,470 4,470

2,4-DP/Dicamba/MCPA 8,782 - - 4,550 1,011 - 14,3423

Clopyralid/Diflufenican/MCPA - - - - 3,670 - 3,670

Dicamba/MCPA/MCPP 27,079 - - 11,033 1,543 65,009 104,664

Diflufenican/Glyphosate - - 21,009 - - - 21,009

Ferrous-sulphate - - - 100,884 - - 100,884

Flazasulfuron - - 0.325 - - - 0.325

Florasulam/Fluroxypyr - - - - - 64 64

Glufosinate-ammonium 218 - - 140 - - 358

Glyphosate 8,554 3,498 225,925 106,079 2,545 1,417 348,018

Isoxaben - - - - - 15 15

MCPA - - 6,004 - - - 6,004

Picloram - - 211 - - - 211

Triclopyr - 46 7,871 55 - - 7,972

Grand Total 60,322 5,238 273,798 245,874 9,345 76,787 671,364

Fungicides

Azoxystrobin 291 - - - - - 291

Carbendazim 11,759 - - 3,414 239 485 15,519

Chlorothalonil - - - 692 - - 692

Iprodione 2,461 - - 1,301 145 429 4,336

Propiconazole 512 - - - - - 512

Pyraclostrobin 255 - - - - - 255

Tebuconazole/Trifloxystrobin 1,993 - - 711 112 144 2,960

Trifloxystrobin 190 - - - - - 190

Grand Total 17,462 - - 6,118 495 1,057 25,132

37

Table 5 (cont): Usage of amenity pesticides in selected 'sub-sectors’ for the United Kingdom, 2012 (kg active substance applied, kg)

GOLF INDUSTRIAL INFRASTRUCTURE PUBLIC AUTHORITIES RESIDENTIAL TURF Grand Total Insecticides

Abamectin - - - 0.073 - - 0.073

Alphacypermethrin - - - 45 - - 45

Alphacypermethrin/Flufenoxuron - - - 8 - - 8

Chlorpyrifos-ethyl 373 - - 773 512 1,000 2,658

Cypermethrin - - - 1,257 - - 1,257

Deltamethrin - - - 39 - - 39

Imidacloprid 46 - - 10 20 - 76

Indoxacarb - - - 0.703 - - 0.703

Lambda-cyhalothrin - - - 16 - - 16

Metaldehyde* - - - 427 - - 427

Permethrin - - - 22 - - 22

Phenothrin - - - 1.2 - - 1.2

Piperonyl-butoxide/Pyrethrins - - - 14 - - 14

Pyrethrins - - - 72 - - 72

Grand Total 419 0 0 2,687 531 1,000 4,638 * The active substance metaldehyde is strictly a molluscicide but is included here under ‘Insecticide’ for convenience.

38

Table 6a: Estimated area (ha) of application of all active substances applied to specified amenity 'Divisions' in the United Kingdom, 2012

Active Substance Product area treated

(PAT) (ha) % Total Cum. %

Glyphosate 207,709 38.0%

Dicamba 78,592 14.4% 52.4%

MCPA 66,630 12.2% 64.6%

MCPP 54,778 10.0% 74.6%

2,4-D 39,844 7.3% 81.9%

Diflufenican 18,285 3.3% 85.2%

Glyphosate-trimesium 14,567 2.7% 87.9%

Trifloxystrobin 10,409 1.9% 89.8%

Tebuconazole 9,867 1.8% 91.6%

Carbendazim 7,096 1.3% 92.9%

2,4-DP 6,237 1.1% 94.0%

Triclopyr 5,953 1.1% 95.1%

Fluroxypyr 5,365 1.0% 96.1%

Chlorpyrifos-e 3,063 0.6% 96.7%

Ferrous-sulphate 2,195 0.4% 97.1%

Clopyralid 2,185 0.4% 97.5%

Metaldehyde 2,032 0.4% 97.8%

Cypermethrin 1,964 0.4% 98.2%

Pyrethrins 1,767 0.3% 98.5%

Azoxystrobin 1,165 0.2% 98.7%

Propiconazole 1,101 0.2% 98.9%

Dichlorprop-P 1,098 0.2% 99.1%

Iprodione 867 0.2% 99.3%

Piperonyl-butoxide 577 0.1% 99.4%

Imidacloprid 516 0.1% 99.5%

Pyraclostrobin 435 0.1% 99.6%

Deltamethrin 420 0.1% 99.6%

Glufosinate-ammonium 373 0.1% 99.7%

Florasulam 314 0.1% 99.8%

Permethrin 226 0.0% 99.8%

Alphacypermethrin 210 0.0% 99.9%

Chlorothalonil 184 0.0% 99.9%

Tetramethrin 182 0.0% 99.9%

Picloram 176 0.0% 100.0%

Lambda-cyhalothrin 108 0.0% 100.0%

Isoxaben 82 0.0% 100.0%

Flufenoxuron 55 0.0% 100.0%

Phenothrin 12 0.0% 100.0%

Flazasulfuron 9 0.0% 100.0%

Abamectin 0 0.0% 100.0%

Indoxacarb 0 0.0% 100.0%

39

Table 6b: Estimated weight (kg) of all active substances applied to selected amenity 'sub-sectors' in the United Kingdom, 2012

Active Substance AI volume (kg) % Total Cum. %

Glyphosate 339,908 48.5%

Ferrous-sulphate 107,460 15.3% 63.8%

MCPA 67,117 9.6% 73.4%

2,4-D 53,237 7.6% 81.0%

MCPP 47,348 6.8% 87.7%

Glyphosate-trimesium 26,221 3.7% 91.5%

Carbendazim 15,896 2.3% 93.7%

Dicamba 9,693 1.4% 95.1%

Triclopyr 7,971 1.1% 96.2%

2,4-DP 6,750 1.0% 97.2%

Iprodione 4,336 0.6% 97.8%

Diflufenican 3,071 0.4% 98.3%

Chlorpyrifos-e 2,658 0.4% 98.6%

Tebuconazole 1,973 0.3% 98.9%

Cypermethrin 1,257 0.2% 99.1%

Trifloxystrobin 1,176 0.2% 99.3%

Fluroxypyr 1,124 0.2% 99.4%

Chlorothalonil 692 0.1% 99.5%

Dichlorprop-P 659 0.1% 99.6%

Propiconazole 512 0.1% 99.7%

Metaldehyde 427 0.1% 99.8%

Glufosinate-ammonium 358 0.1% 99.8%

Azoxystrobin 291 0.0% 99.9%

Pyraclostrobin 255 0.0% 99.9%

Clopyralid 219 0.0% 99.9%

Picloram 211 0.0% 100.0%

Imidacloprid 76 0.0% 100.0%

Pyrethrins 74 0.0% 100.0%

Alphacypermethrin 49 0.0% 100.0%

Deltamethrin 39 0.0% 100.0%

Permethrin 27 0.0% 100.0%

Piperonyl-butoxide 20 0.0% 100.0%

Lambda-cyhalothrin 16 0.0% 100.0%

Isoxaben 15 0.0% 100.0%

Flufenoxuron 4 0.0% 100.0%

Tetramethrin 2 0.0% 100.0%

Florasulam 2 0.0% 100.0%

Phenothrin 1 0.0% 100.0%

Indoxacarb 1 0.0% 100.0%

Flazasulfuron 0 0.0% 100.0%

Abamectin 0 0.0% 100.0%

UK AMENITY PESTICIDE SURVEY 2012 40

UK AMENITY PESTICIDE SURVEY

SECTION 2 - QUALITATIVE REPORT

Prepared by: GfK

Weston Court, Weston

Newbury, Berkshire, RG20 8JE, UK

Tel +44 1488 649130

www.gfk-kynetec.com

Version V2

Issue: January 2014

Job reference 373.130.00050

Disclaimer The views expressed in this report are those of individuals and should not necessarily be considered representative of any organisation(s)


QUALITATIVE REPORT - EXECUTIVE SUMMARY As part of the investigation in to the use of pesticides in the Amenity sector, GfK were commissioned by the Chemicals Regulation Directorate to gather qualitative information amongst a random sample of thirty contractors, Green-keepers and local authorities. The key selection criteria were that respondents are managers, experienced in the use of amenity pesticides and had responsibility for the development of policies, including the use of non-chemical approaches, within their organisations. The themes explored during these interviews were as follows:

� Training – extent of certification and participation in recognised national schemes � Protection of human health – measures employed � Testing/calibration of Application Equipment – frequency, timing, elements tested � Protection of water – awareness and impact of variables and protection measures taken � Minimising usage – steps taken to meet legal requirements � Storage, handling and disposal – nature of stores, use of PPE, disposal of concentrates,

dilute waste and containers � Alternatives approaches to pest, weed and disease control – including use of biologicals

Interviews were completed between October 28th and November 26th 2013, either face-to-face or by phone according to the respondent’s preferences. All interviews were taped and summaries of these, including key verbatims, are presented in Appendix 1. Appendix 2 provides summary tables of responses to the closed questions and Appendix 3 is the topic guide that was used throughout. 1. Amenity Use and Training

Across all respondents gravel/ballast surfaces and pavements/kerbs were mentioned most frequently for treatment with plant protection products (PPP), with forestry/woodland and open water the least. Contractors cited riparian areas for treatment with PPP most frequently, whilst the local authority group mentioned tree/shrub-beds more than other respondent types. A further nine surface types were mentioned by respondents, ranging from clothing drying areas in housing estates to domestic gardens. Fuller details by respondent type are presented in Appendix 1.

7.33

8.00

2.33

6.67

7.001.67

8.67

8.33

5.67

Mean number of citations - all respondent types

Amenity grass

Sports turf

Forestry/ Woodland

Tree/ Shrub beds

Riparian areas

Open water/ aquatic areas

Gravel/ ballast surfaces

Pavements/ kerbs

Roads

From a list of seventeen factors influencing their organisation’s current priorities for the control of vegetation, all respondents identified most strongly with <Public safety and/or possible litigation> (see below). This was as much about the need to protect the general public, at the same time as the environment, but to avoid the risk of bad publicity and the sense that litigation is on the rise, “…because of the claims culture we live in today we need to be very mindful of that” and “What we are using is as harmless as shampoo but as soon as the public see us wearing masks and other Personal Protective Equipment (PPE) they start to ask questions”. The factor <Public concerns> also scored highly for the same reasons, but less so amongst Green-keepers (3.3) largely as the general public are less exposed to PPP treatments on golf courses.


<Legal requirements (e.g. Weed Act)> is the next strongest influence on priority setting, especially amongst contractors and local authority respondents. Key drivers here are invasive weeds like Japanese Knotweed, Himalayan balsam and Giant Hogweed, though ragwort was also cited. Damage to infrastructure, especially buildings and impact of Japanese knotweed on the granting of planning consents and the ability of homeowners to secure mortgages were mentioned frequently by contractors. Indeed, the consensus amongst this group is that banks are increasingly refusing to make house loans unless guarantees are in place and that misinformation abounds, “We tell house surveyors that they do not need a guarantee if knotweed is more than seven metres from the property but they are not willing to listen”.

One respondent, quoting a study indicating that there are now 3000 ‘contractors’ offering services to control Japanese knotweed, questioned whether the relevant organisations had the resources to audit if these contractors have the necessary training.

Of the remaining factors, contractors also rated <drainage/flood control>, <conservation of nature conservation areas> and <protection of infrastructure> as important in influencing priorities for the use of PPP. Green-keepers unanimously gave <quality of grass/turf> the maximum score of 5, with the need to satisfy golf club membership given the current economy, and the absence of perceived alternative methods to fungicidal sprays, being the major drivers. As a group they also gave greater importance to <survival/growth of trees/shrubs/bedding> than the other respondent types. The importance of nature conservation and preserving the aesthetics of the golf course were underlying themes. <Quality of grass/turf> and the <health of domestic animals> were key factors for Local Authority respondents, both originating from a need to deliver important services and ultimately avoid the potential ‘wrath’ of the general public they serve. In terms of personal knowledge of the 2006 Pesticides Codes of Practice for using PPP, contractors rated themselves as <Fair> or <Very good> (mean score 5.0 out of 6.0), local authority respondents mostly <Fair) (mean 4.2) and Green-keepers <Fair> or <Good> (mean 3.60). Comments received from contractors included, “I’m a bit of a geek when it comes to weed control”, to “…we tend to be always be treating the same species via the same methodology so we are a little bit, I suppose to a degree, stuck in our ways…which means our wider understanding of things like the Code isn’t perhaps, at times, as good as it should be”. Comments from Green-keepers ranged from “I’ve not really looked in to it (the Code)”, to “A lot of it is common sense” and “I did my PA2 a long, long time ago, so yes, I’m surprised nobody’s asked me to do a refresher”, and amongst the local authority respondents, “I wouldn’t class myself as an expert, but I know about it” to “Yes when I first started I read it a hell of a lot. In my prime it was easy….needs to be more user friendly. It’s like most government documents”. Questioned about membership of organisations or schemes, the contractor respondents clearly had the greatest awareness of BASIS and Amenity Assured, but only six and four, respectively were members. Less than half of contractor respondents were members of NRoSO and only one had so far joined the more recently formed NASOR (Q4, Appendix 2). Membership fees and meetings that “fail to deliver” any

The degree to which the factors listed below have i nfluenced respondent’s current priorities for the control of vegetation

Factors MEAN

Protection of infrastructure 2.8

Financial pressures 3.0

Control of invasive (non-native) plant species 3.8

Protection of nature conservation areas/ wildlife habitat 3.8

Conservation of native plant or animal species 3.9

Local authority policy 2.9

Government policy/ targets 2.9

Financial constraints 3.2

Public safety and/ or possible litigation 4.4

Health of domestic animals/ livestock 3.1

Protection of fisheries/ angling interests 3.0

Drainage/ flood control 3.2

Quality of grass/ turf 3.9

Survival/ growth of trees/ shrubs/ bedding 3.4

Disease control/prevention (e.g. Rhododendron removal to prevent Sudden Oak Death spread)

2.7

Legal requirements (e.g. Weeds Act) 4.1

Public concerns 3.9


content of use to amenity practioners were cited as reasons for not joining/staying with NRoSO and waiting to see if NASOR will meet their needs better, “We did look at joining NRoSO but we thought there’s no real benefit…it is not giving us any additional qualification. We already pay quite a lot of money to BASIS…there’s no real benefit of joining the slightly smaller things that have limited power or anything”. Amongst Green-keepers awareness of the listed organisations was extremely weak and none of those interviewed held any memberships. Local authority respondents were intermediate, awareness being better largely a result of the documentation provided by contractors during the tendering process and some interactions with BASIS when reviewing whether a certificate might be needed for any pesticide stores. Actual membership of any organisations/schemes was limited to no more than one or two amongst the local authority respondent group. The following table summarises the training, qualifications and use of resources within the respondent’s reporting framework. Irrespective of respondent type, only those with relevant NPTC certification were permitted to apply PPP, though clearly amongst contractors many more had access to the 2006 Code of Practice and received some form of ongoing training.

Training, qualifications, resources

Contractor Green-Keeper Local Authority

# staff with qual

# staff total

% Staff

# staff with qual

# staff total

% Staff

# staff with qual

# staff total

% Staff

BASIS qualified 13 128 10.2 0 39 0.0 1 357 0.3

Members of the BASIS Professional register 10 128 7.8 0 39 0.0 0 357 0.0

BASIS POWER training course graduates 0 128 0.0 0 39 0.0 0 357 0.0

BASIS Nominated Storekeeper certificate 31 128 24.2 0 39 0.0 1 357 0.3

Biodiversity and Environmental Training for Advisors (beta) Amenity Horticulture course graduates?

2 128 1.6 0 39 0.0 1 357 0.3

Holders of NPTC certificates for the jobs undertaken? 62 128 48.4 25 39 64.1 192 357 53.8

NRoSO Members 60 128 46.9 0 39 0.0 0 357 0.0

National Amenity Sprayer Operators Register 12 128 9.4 0 39 0.0 0 357 0.0

Easily able to access a copy of the 2006 Codes of Practice? 120 128 93.8 24 39 61.5 192 357 53.8

Trained in the requirements of the 2006 Codes of Practice? 96 128 75.0 21 39 53.8 192 357 53.8

Other - CSCS 40 128 31.3 0 39 0.0 0 357 0.0

NB Based on interviews with 30 respondents, the inf ormation above is indicative rather than definitive For the majority of Green-keeper and local authority respondents the NPTC certification process for PA1, PA2 and PA6 were the last time they had received any form of training in the requirements of the Code. Noted earlier, one respondent was surprised not to be required to complete refresher training and another remarked, “A lot of people do the training but very few appear to offer refresher training”. Overall, contractor organisations were most likely to offer internal training during the winter months to spray operators and other staff during the winter months. With input from vendors, this could include HSE (RIDDOR) refresher training and updates, including PPP approvals, new nozzles or chemicals, etc. That is not to say other respondent groups did not keep updated - well-developed networks with commercial suppliers are clearly sources of information- but the impression gained suggested the process for knowledge transfer was more informal overall than with contractors. The last question in this section explored those activities where BASIS qualified personnel were used. Responses are summarised in the table below. Overall, Green-keeper and local authority respondents were equally divided between those that use a BASIS qualified person for at least one activity and those

that never involve a qualified individual. Even amongst contractors, we found two respondents that do

not defer to BASIS qualified personnel, both of whom focused purely on the control of invasive species.

Not surprisingly, contractors tended to use BASIS qualified personnel in developing policies or making

and/or checking recommendations. Of those interviewed, local authority respondents tended to use BASIS staff least for these activities, with Green-keepers being intermediate.


Activities Contractor Green-keeper Local Authority

Yes No Yes No Yes No

BASIS qualified personnel are not used 2 8 5 5 5 5

Development of organisation's policies for pesticide use 8 2 3 7 2 8

Making and/or checking recommendations 8 2 4 6 2 8

Tender preparation 7 3 1 2 4

Tender evaluation 2 1 2 4

Other - supporting new employees pre-basis training 5 5 0 10 1 9

The responses to tendering activities had an added complication as the study indicated this was not a common activity outside the contractor group, and then only in the preparation phase was a BASIS qualified individual employed. The information presented therefore indicates where tendering actually takes place and a BASIS qualified person is involved or not. For example, only one green keeper interviewed had issued a tender document whereas six local authority respondents had initiated a tender request of which only two had any input from a BASIS qualified person. As one contractor remarked, “It really does annoy us when somebody who doesn’t have a BASIS qualification tells us what chemical to use”. Asked why local authorities rarely have BASIS-qualified staff, one contractor replied “High throughput of staff. I doubt they could retain someone with BASIS qualifications”. As one Green-keeper summed up, “We basically get the spraying qualifications and it just comes with experience then”. 2. Protecting Human Health and the Environment The theme of this section is to understand what measures are taken to protect employees, the general public and the environment, particularly water.

0

1

2

3

4

5

6

7

8

9

10

Unprompted Prompted Unprompted Prompted Unprompted Prompted

Contractor Greenkeeper Local Authority

CoSHH assessments

Personal Protective Equipment

Health surveillance

Notice of spray operations

Without prompting, all contractor respondents identified Personal Protective Equipment (PPE) as a major step they would take to protect workers (Q7). This was followed by COSHH assessments and equal numbers unprompted/prompted identifying use of notices of spray operations to protect the public. The latter involved advertisements in relevant local newspapers on behalf of the local authority through deployment of appropriate physical signs where practicable as advisories to the general public during the spray operation; “We always mark-off areas where we are working and advise the public to take another route”.


With prompting, six contractors identified health surveillance as an important step to protect their workers. In the majority of cases this involved completion of a health survey on commencement of employment and checking for changes against this though in one case an external organisation did annual check-ups, including appropriate blood tests. Amongst the remaining contractors a typical view in relation to health surveillance is that this was “not relevant considering the chemistry of the products we are using”. Amongst the Green-keepers use of spray notices was cited more frequently than PPE. Measures adopted by this group to protect the general public and player members included the posting of signs two weeks ahead of spraying, closing the course until 10.00am or spraying only outside of normal playing times’ “I like it (PPP) to have dried on the leaf or having been absorbed before we have 20/30 people walking over the greens”. Use of COSHH assessments and PPE emerged through prompting, many of the respondents being actually responsible for spraying and/or considered the PPP used to be of minimal risk. Prompted about health surveillance very few Green-keepers have an active programme, “That’s not something we do, unless someone pulls up a problem”. Finally, most of the local authority respondents mentioned use of PPE and signage without prompting. As a group health surveillance programmes were more evident, though admittedly these tended to cover a wider range of activities, for example vibration damage from strimmer use, than the risks associated with PPP per se. In one case, an outside company is contracted to run annual health assessments of all staff. In the majority of cases, however, local authority respondents had made a conscious decision to adopted a CDA rather than knapsack system to further mitigate any potential risks associated with PPP; “the first thing is can we use a product that’s no mixing or anything like that, which is like a controlled droplet…to try and reduce operator contamination” . It was mentioned above that all respondents identified with the general public and had adopted a range of avoidance measures, including signage, marking-off spray areas and physical cordons, to minimise their exposure to PPP. These include:

• Use of shrouded booms or CDA equipment to reduce spray drift near hospitals, doctor’s surgeries or other areas with high footfall

• Use of stem injection or weed-wiping to reduce airborne drift around nurseries, schools and nursing homes, “Places where there’s certain people that are more susceptible to or sensitive to chemicals…It might take us longer to do the job but then it’s definitely beneficial to do so”

• Spraying early or late in the day, and in or near schools only spray outside of term-time, at weekends or if absolutely unavoidable during class times

• Avoid spraying when it is windy and timing of applications on playing surfaces that avoid matches With regards to the use of measures to protect the environment (Q9), the unprompted/prompted replies were as follows:

0

1

2

3

4

5

6

7

8

9

10



Close to water

Close to drains

SSSI’s and other conservation areas

Open parkland

Surface type and slope

Impact of weather

Both contractors and Green-keepers identified spraying close to water as being of highest risk, followed by proximity to drains; “We want to prevent spikes in glyphosate as we cannot afford to have this product taken off the market…it is the mainstay of our work”.


Local authority respondents identified less strongly with these situations as many were not responsible for vegetation management, this task falling to the EA or for roads the Highways Agency. With prompting, SSI’s and to a lesser extent parkland was also considered high risk areas by contractors when considering using PPP; “There are so many levels of planning that you have to do before actually doing the work (on SSSI’s)”. Lack of experience or a decision not to treat these areas generally accounted for the lower engagement recorded for Green-keepers and local authority respondents. As noted by a few local authority respondents, in parkland PPP applications tend to be targeted around footpaths, other obstacles, and mower margins, “Public perception is as important as actual risk when it comes to spraying in open spaces”. Weather as a risk factor resonated with all respondent types but surface type and slope less so. In the case of Green-keepers, treatment of golf greens (the principal surface treated) tends not to present a risk whilst for local authorities adoption of CDA technology or specialist cutting machinery (a spider) is believed to have reduced any risks associated with spraying steep surfaces significantly. As to specific measures adopted to protect the environment, including water, these can be summarised as follows:

• Minimal use of PPP around water, “It is only if absolutely necessary that we treat near water and only if it is with invasive species and then we would use a stem injector where it is very targeted”

• Mobile, computer-controlled equipment or shrouded booms to better target spray applications • Stem-injection in open parkland to minimise drift and as a further benefit, allay public concerns • Use of low-drift nozzles, “We treat the whole (golf) course as a triple SI…we are very conscious

of wind” • Use of covers or leaving a 30cm buffer zone either side of drains. In one case plastic sheeting

over a badger set to avoid chemical drift • Avoidance of spraying near bole holes, “They’re in the rough and we don’t spray the rough” • PA6AW training for operators • Observance of LERAPs and buffer zones; “We won’t spray within 10 metres of a water course,

we only use stem injection” and not to spray when it is windy • Minimise leaks and spillages from equipment to avoid point-source contamination • Full site surveys including checking what’s over a boundary fence, “There could be a SSSI on the

other side...they might have newts and things like that” • Use of contact PPPs like glyphosate as these are “Rainfast within one hour, it’s very effective, no

run off, no mist”. Some Green-keepers no longer use selective herbicides on fairways and if required, then the work is contracted out

Overall, many respondents, especially those in local authorities would rather outsource to the EA or the local rivers trust rather than incur the costs of specialist training and the required paperwork. As one contractor asked about specific measures adopted to protect water stated, “Keep away from it. That may sound slightly defeatist, but that’s almost the only thing you can do”. Respondents were asked to indicate where they would go to obtain information on sites where either pesticide use is restricted or the risk of use is greatest (Q10):

0

1

2

3

4

5

6

7



Chemicals Regulation Directorate

Plant Protection Product - manufacturer’s sites

Environment Agency’s, ‘What’s in your backyard?’

Amenity Forum


Overall, contractors referenced the four listed web-site sources more frequently than other respondent groups. Amongst the contractors 8/10 stated that they referred to manufacturer’s web sites for information on PPPs (printed labels are seen as particularly helpful), dropping to 6/10 and 5/10 for the Chemicals Regulation Directorate (CRD) and the Environment Agency’s (EA), respectively. Recall of the EA’s ‘What’s in my backyard?’ was rare even for this group; “I’ve only really been told about that this year…an awful lot of operators probably wouldn’t (know about this site)”. When prompted, 4/10 cited the Amenity Forum and then only as an occasional source of information. Some contractor respondents felt that the CRD site was not particularly relevant as glyphosate was well known and the main PPP used, though others had started to abandon the green book as “that tends to go out of date quite quickly” in favour of checking with the CRD . The EA was praised for its code of practice for Japanese knotweed, and one respondent felt that this organisation was more helpful than SEPA, because “They actually have BASIS qualified people you can talk to”. Prompted about the Amenity Forum, one contractor was extremely supportive, “The voice for amenity… we felt quite strongly that we weren’t being represented properly…people (HSE, EA, Highways Agency, etc.) were asking the agricultural community about us, rather than asking us directly”. In summary, contractor respondents like to refer to their BASIS registered suppliers for advice when confronted with an unfamiliar situation of difficult to control weed. The same can be said of Green-keepers who cited manufacturer’s sites (6/10) and industry associations or forums (e.g. BIGGA, Pitch care and the Green-keepers Association; 5/10) for product information and advice rather than the less familiar CRD and the Amenity Forum sites (1/10 each); “You’re roughly doing the same products most of the time, everything you need to know is on the labels”. Finally, local authority respondents tended to fall between contractors and Green-keepers in terms of awareness and especially use of the listed websites. Once again, manufacturer’s sites (8/10) were most frequently cited, followed by the CRD (3/10; “I use their website a lot but to be honest I find that I never get a straight answer. It’s always very grey is the answer”), and with prompting Amenity Forum (4/10) and the EA (3/10). As with Green-keepers, local authority respondents felt that the PPP’s they are using are well understood. When consulted, manufacturer’s sites are used to update COSHH assessments, but only rarely; “If we need anything like that the first thing we do is talk to our health and safety team, they will then look on the HSE sites, they would look on our suppliers websites to see what they would suggest we use”. Ultimately, for many suppliers reps are a major source of information that, despite some accepted commercial bias, “are always very much up-to-date on changes in legislation and obviously because of that products are ever-evolving”. 3. Application Equipment and Pesticide Storage The theme of this section is to understand what measures are taken to calibrate application equipment and the procedures for the safe storage, handling and disposal of pesticides. Within the respondent groups a wide variety of application equipment types and sizes are in use. Knapsack sprayers are the most common, though their use by Green-keepers is mainly restricted to greens and bunkers and only rarely used by local authority respondents for fungicidal applications on fine turf. Contractors reported using a number of tractor-mounted equipment ranging in size from 12 to 24 metre boom width. Use of this equipment by Green-keepers is limited to spraying fairways, including the application of liquid feeds, iron and PPP; though there is a suggestion the latter is becoming less frequent.

0 1 2 3 4 5 6 7 8 9 10

Knapsacks

Tractor mounted

ATV

CDA

Local Authority

Greenkeeper

Contractor


None of the local authority respondents interviewed use tractor-mounted equipment, CDA sprayers being by far the most popular apparatus for the application of PPP; “We try not to use knapsacks. I think knapsacks are really restricted to the bowling green, with 85-90% of all spraying achieved using the CDA approach” although this view was not universal, “To be honest, the knapsack, it’s easier to mix the glyphosate with the water than it probably is to faffle about calibrating a CDA lance”. Instead, work requiring the application of PPP, mainly to playing surfaces, tends to be sub-contracted. In some cases, a variety of booms mounted on All Terrain vehicles were mentioned, mainly by contractors, along with specialised computer-controlled pavement and highway equipment (not recorded in the above figure). Also noted, but not quantified, is the use of stem-injection equipment for invasive species, exclusively by contractors and some local authority respondents. Asked when application equipment is most likely to be tested and calibrated (Q12), unprompted all respondent groups indicated that this was at the beginning of the season. Equipment type is an important factor. For example, for the local authority group calibration of CDA equipment tends to be completed by

0

1

2

3

4

5

6

7

8



When to test/calibrate

Beginning of the season

When moved to a different location

Change of products/rates

After repair or maintenance

Not done

the supplier under contract at the beginning of the season. In a few cases respondents mentioned equipment is inspected before use, “any items broken, cracked, are the nozzles functioning properly? Is the battery functioning properly? The trigger mechanism functioning properly?” Faulty CDA equipment will be sent back to the supplier (“…they have a habit of leaving them in the back of trucks. They roll around and get damaged”) for repairs and many local authority respondents keep spares as a result. With prompting, testing and calibration after repair or maintenance is common across all groups for knapsacks and where used, mounted machinery. Sticking with the local authority group, of the few using this equipment attitudes vary from “No, I wouldn’t have said there is any regular testing of the machinery. We do replace machinery quite often. Anything that is at the stage that we feel its life cycle has had it, it just goes straight away” to daily, signed-off maintenance checks. A point made by several respondents, “Well hopefully they’re done every time the operator uses them because they are trained operators”. In all respondent groups, the frequency of responses to other options like calibrating when moving to a different location or changing rates or products were more limited, even after prompting. When it comes to location, pressure of work can be an underlying factor driving the frequency of calibration, “There are no jobs we do for different councils that takes us less than one week due to the sheer size of the urban areas that we are covering” said one contractor. Equally, many respondents indicated that the target problems are such that they rarely spray anything other than glyphosate and at the same rates. Overall, of the groups interviewed contractors tend to calibrate their application equipment more frequently, irrespective of type, probably reflecting the diverse range of contracts, although this was not explored, as much as the need to complete these to guaranteed standards. As one respondent commented, rates are rarely altered as there is “no point in over-dosing it as money is tight, and there is no point under-dosing as we will only get called back if something does not work”. The local authority group tended to calibrate less frequently based on the perception that CDA’s, the equipment of choice, and limited situations of use mean calibration is not required in season. Green-keepers tend to be more intermediate as a group with the driver here, especially for tractor-mounted equipment, being their use for the application of materials other than PPP. In terms of specific training for calibrating application equipment (Q14), in all circumstances only NPTC trained employees are responsible for this activity. However, noted earlier the frequency of annual or refresher training is variable, irrespective of respondent type, and an area that warrants further review.


The figure below summarises how PPP’s are stored by respondent type (Q15).

0 1 2 3 4 5 6 7 8 9

Chest freezer

Converted building

Steel cabinet or safe

Steel walk-in store

No store

PPP store type

Local Authority

Greenkeeper

Contractor

A variety of store types were identified. Amongst contractors and local authority respondents secure, large walk-in, bunded stores, often housed within a roofed building is the preferred means of storing PPP. In a few instances, local authority respondents use secure, steel cabinets or safes, mostly housed within a locked, roofed building. This store type was very popular amongst Green-keepers who generally purchase small quantities of PPP and then on an ad hoc basis. In one case, a green-keeper admitted to using an old chest freezer. One contractor only purchased PPP and had this delivered on the day of use, whilst one other and a green keeper claimed to have been visited by BASIS and told that the quantities of PPP stored did not require a specialist store. Amongst Green-keepers, the general sentiment was “…because everything is so readily available we keep very little in stock as this is like pounds sitting on the shelf”. Although PPP stores, especially the walk in types were said to be audited annually (e.g. by BASIS, the Fire Brigade, PCA, etc.), unprompted all respondents struggled to answer the key characteristics of a PPP store.

Key construction considerations Contractor Green keeper Local Authority


Resistant to fire (for 30 minutes or longer) 1 5 1 6 7

Capable of retaining leakage/spillage - to a volume of 110% of total quantity of products to be stored (or 185% in an environmental sensitive area)

2 5 8 4 5

The bund should be constructed of non-fragile materials, resistant to permeation by liquids, and rendered or sealed as necessary, especially at joints.

6 2 3 1 2 5

Bunding must not be compromised by exits/entrances 3 4 3 5 6

Avoid having a water supply passing through the bunded area 1 6 7 5

The store, or the area in which it stands, should be roofed 2 5 1 5 4 5

Should be secure from unauthorised access 5 3 5 5 5 5

Of the key features summarised from the 2006 Code of Practice, security and the presence of a bund were ‘construction’ features most frequently cited. With prompting, the capacity to retain at least the volume of PPP stored scored highly, though only two respondents could actually recall the figure of 110% suggested in the Code. In only one instance did a respondent know that there was an HSE information sheet (#16) detailing the appropriate standards for fixed and mobile stores. That said, where concentrated product was moved in all cases respondents stated that PPP was transported in lockable, approved chemical boxes, with vehicles locked when left. Questioned about what precautions are taken when filling application equipment, respondents again required prompting to obtain full answers (Q16) suggesting a different approach be used in future iterations of this study. Overall, contractors were better in terms of their unprompted replies against the prepared list, with local authority respondents next and Green-keepers least certain about what information was sought (figure below).


In terms of following label instructions, all respondent types recognised the need to read product labels; “So that you are applying the right thing and at the appropriate rate “ and “I always check I have got the right product because all the bottles look alike nowadays”. Although COSHH assessments often accompanied spray operators, one respondent remarked in terms of what to wear the “Product label is a great thing because everything is on there”. Of all the factors discussed, avoiding contaminating water supplies drew the most unprompted responses overall – “…try and fill up away from drains and sensitive areas” and a variety of precautionary measures.

Precautions used when filling application equipment Contractor Green keeper Local Authority


Label instructions - Follow instructions on the product label, especially when opening containers designed for a closed-transfer system

4 5 3 7 3 7

Avoid contaminating water supplies - Make sure pesticides cannot run back or be drawn back into any water supply. Ideally use an intermediate tanker

7 2 4 4 5 5

Match container size to the task - Use the appropriate size of pesticide container to reduce the need for measuring or weighing

3 7 4 1 7

Safety when pouring - Make sure you are steady on your feet if you have to pour directly into a tank. Use a platform set at the correct height

7 2 4 6 2 5

Rinsing - If possible, use a mechanical rinsing devise for containers, closures and seals, and triple rinse, each time using a water volume 10-20% of the container’s volume

4 5 7 2 5

Empty containers – replace caps after rinsing and draining containers and store upright in an outer carton 4 6 1 7 7

Mixing more than one product – add separately, and follow label instructions with regard to order 2 3 7 1

Spray operator – if different from the person mixing and loading, make sure they have a copy and have read the label 1 8 9 2 7

Spill-kit – make sure one is available at all times, how to use it and what other action to take if required 4 5 1 6 5 4

These included:

• Drawing water from stand-pipes with non-return valves and completing the filling operation within a bunded tank housed inside the vehicle

• Vehicles equipped with 100 litre fresh water tanks equipped with an electric pump to fill knapsacks

• 10,000 litre bowser, with secure chemical boxes on the side, “We fill out of a bairn using the bowser’s pump then take the bowser to an appropriate hard standing…where the water and chemical are drawn. With the risk of spillage, either diluted or concentrated product, containing it is a much easier operation”, or

• Filling knapsacks in drip trays or “…on a hard surface away from water and if there is any spillage this is easier to contain”.

The other major approach adopted particularly by local authority respondents is to dispense with knapsacks and use CDA application equipment, “because it’s already mixed… it’s literally a fixing of pipe to the applicator, basically it’s a box, attaching the chemical mix on the back. The back is then attached to the applicator”. With regard to matching container size to the task, respondents acknowledged that manufacturers “…are getting better. It used to annoy me when the rate was 4 litres per hectare and the product was supplied in a 5 litre container”. Five litre packs were generally felt the optimum size across all respondent types either as these were easier to transport or “We find that traditionally two men spraying all day will use one container”. However, whilst some respondents would prefer a broader range of pack sizes given the areas requiring treatment some form of measurement will always be necessary; “…one of the hardest challenges is pouring from a 20 litre container in to a one litre measuring jug” and “Nearly impossible to match the container size to the task…especially with a 60 litre tank on the quad bike”.


Safety when pouring also resonated strongly with most groups, perhaps less so with the local authority group for whom CDA’s dominate. Steps taken to ensure the safety of spray operators (and the environment) included:

• “We clear an area away from everything else so chemicals can be mixed without disturbance” • Preparing sprayers on hard-flat surfaces and away from the general public

• Pouring from a measuring jug, “…no higher than waist height” • Chemical hoppers (and mounted sprayers generally) set “…at an appropriate height suited for

when they’re drawn out for filling”, and

• Try to avoid working under stress, “… is when accidents happen, like dropping containers” Rinsing too was also widely recognised as important step in the process, although all respondents failed to mention that a minimum water volume of 10-20% of the container’s volume should be used. Most contractors mentioned that containers be triple-rinsed, or “until there is no smell in the container…” and “we don’t just say three times, I mean some need a hell of a lot more cleaning than others”. Green-keepers were less secure about the recommended number of rinses, “We rinse all the bottles twice as the water is running, shake them” but did report using the induction hopper on mounted sprayers to wash containers and caps and generally return washings to the spray tank. Local authority respondents were split fairly evenly between those that knew to triple rinse and those who could “tell off the top of my head how many times each chemical container has to be rinsed”. In one case, knapsacks were labelled and assigned for the use of one PPP so “There are no issues with having to rinse out”. Of those questioned, once cleaned on site empty containers are mostly secured and stored inside the vehicles before being transported back to the base. In some circumstances spray operators were said to have bags in to which these containers were stored or stored upright in the chemical box. Regarding mixing more than one product the consensus across all respondent types is that this practice is now rare. This is even more the case now that modern glyphosate formulations include the adjuvants. Where done, “…as long as I read the label and I phone my supplier and as long as he said they’re compatible yes I just mix them as normal, not a problem”. If mixing PPP, products are always added singly and if “I wasn’t sure we would have a little test and see if they separated when mixed”. Universally, spray operators are responsible for filling, mixing and cleaning the spray equipment. As one respondent remarked long gone are the days when spray operatives go out in pairs. In addition, spray operators are also likely to carry all the documentation needed for the day’s tasks, which will include product labels and COSHH assessments, as well as risk assessments, SOPs, etc. according to the organisation’s policies. Only in a very few cases were spill kits not available to spray operators, and then mostly amongst the Green-keeper group. Asked what protocol was in place to manage accidents or chemical spillages, one Green-keeper replied “It doesn’t often happen but if I do I’ll get the hose and hose it down into my soakaway, that’s about it”. One local authority noted that turf operators do not carry spill kits, stating “If there was a particularly large spill they could use the granules, but I doubt that this would be necessary given the small amount of chemicals”. Another local authority, which has spill kits only at the point of filling in the depot and not on the job, also made the same point, ““I just don’t think it would be workable, whether or not I feel there is a need anyway, given the quantities of the product involved”. For the majority of respondents, spill kits can include a bund or “a sponge thing that goes around the drain” alongside absorbent granules which are applied over spillages, brushed, then shovelled into bag, labelled or not, and disposed of along with other waste PPP materials. Before exploring responses to the disposal of ‘washings’ and empty clean containers (Q17 – Q19), it is worth reporting the processes for the management of diluted spray materials, either the result of poor weather or surplus to requirements. Amongst those respondents questioned, this included:

• Moving spray equipment to the next site in the back of the vehicle • Knapsacks are stored overnight, with or without labels, and used the next (or another) day • Any spray material left over at the end of the day is “…pumped back in to a 25 litre container and

taken back to the depot ready to be used the following day” • Quad bikes are returned to bunded lorries over-night and used on the next job; “We never have

any disposal areas as we ultimately always spray out on the job that we are on”.


As one local authority respondent remarked, “I would sincerely hope there is no product leftover. They are trained to only mix the amount of volume required for the actual spraying of the area”. In the event of rainfall, “They would then go back out and finish the job at the nearest opportunity”. Turning now to the management of waste materials, contaminated water resulting from the cleaning of application equipment was disposed of via four main routes:

1. At the site of application 2. On a designated area, or occasionally 3. As a tidy-up around the depot 4. Tank-washings transferred to “…old water containers…so it doesn’t go down the drain or put onto

the ground” and removed by a specialist ‘waste transfer company”. Overall, respondents groups tended to favour option 1, at the site of application, “…providing the maximum dose isn’t exceeded, etc.” primarily as “…some form of weed control is always wanted… there's 160 acres, there's plenty of areas where if you’ve got 5 litres of weed killer you can go and put on a tee” and “I always go back to the yard with an empty tractor”. Inevitably, respondents use a mixture of routes

0 1 2 3 4 5 6 7

Disposed of at site of application

Disposed of at depot

Disposed of down a drain

Disposed of on a designated area

Disposal of contaminated spray equipment washings

Local Authority

Green keeper

Contractor

to dispose of tank-washings, for example, choosing to dispose of contaminated water resulting from the decommissioning of spray equipment at the end of the season or before repairs, either applied to designated areas like the “wild area behind the shed” and “an area like gravel or hard-core” or “no more than 20 to 30 litres of washings” applied as a tidy-up around the premises. In the main, all respondents either dispose of clean PPP containers or spent CDA cartridges via their distributors or a specialist waste disposal/recycling contractor, local authorities tending to favour the former, Green-keepers the latter.

0

1

2

3

4

5

6

7

8

9

10

Returned to distributor Waste disposal contractor Other - containers burned(special permission)

Other - disposal via general(domestic) waste

Options for the diposal of clean, empty containers

Contractor

Green keeper

Local Authority


Empty containers maybe bagged and housed in large bins, or held in metal cages, or crushed and assembled in to blocks on pallets prior to collection and disposal. One contractor respondent burns empty containers under special permission, “If I can do something on my business that I’m allowed to do and it doesn’t cost anything, other than a box of matches, then I think that’s sensible”. A Green-keeper admitted to disposing of clean PPP containers in the general waste, “Empty containers are bagged up and put into a wheelie bin in the club that the council takes away…” These exceptions aside, the majority of respondents had chosen to use distributors or specialist disposal contractors for their empty containers, and when necessary old concentrates and tank-washings, on the grounds of cost, simplicity and peace of mind. Illustrative comments included,

• “The cost of this approach is relatively small”, • “You can’t exactly incinerate them can you so you are stuck with them unless you go back to your

manufacturer” • “We just thought it would take a lot of the hassle out of everything really” • “They take containers, everything and then they give us a certificate every year. They might

come out two times, they might only come out once” • “Best practice. It’s something now we tend to stipulate with a supplier when we agree a contract

with them, that they include any costs for removing said product afterwards, empty container and such like”

• “I don’t want any of our lads having to worry about that. We’re not trained to do it” • “We look at it really as a responsible and legal obligation that we have. We’ve visited other

courses. We’ve walked around the back of some buildings with just containers all over”. 4. Minimising Pesticide use and Alternative approac hes The theme of this final section is to understand what measures respondents take to minimise the use of PPP, including the use of non-chemical alternatives. As can be seen from the figure below (‘How do you decide if it is necessary to use a pesticide, Q20), whilst there are some differences in the pattern of responses, overall respondent types agree with the need to identify the problem and evaluate the best approach (i.e. PPP, non-chemical or a combination) as key.

0 1 2 3 4 5 6 7 8 9 10

If using PPP, do you reduce the dose or areatreated?

Ability to take decisions alone or with outside help?

Follow-crop implications from using a PPP?

Impact of problem (financially, damage or visually)outweighs PPP cost?

Use PP, non-chemical approach or a combination?

Identify the problem

Contractor

Green Keeper

Local Authority

Inevitably, the underlying considerations differed by respondent type. Amongst contractors, for example, decisions about what to spray and the frequency are mostly decided by the client in the contract; “…the only decision I make within that that is ensuring that there is enough growth in that situation to warrant the operation”. Client choice is especially important for the treatment of invasive weeds; “It is up to the client whether they have it (Japanese knotweed) dug out or removed or have a five year monitoring and spray programme”. Not surprisingly, some contractors mentioned timescales and costs being a consideration; “We can strim everything down but how long would that last?… the residual effect we’re trying to get is at least as much as five to six months”. Willingness to use alternative approaches is high amongst this group.


However, one contractor stated “I’m also aware that a carefully applied chemical product will do a lot less harm generally to the environment than a non-chemical application” whilst another felt the use of burning, hot steam and foam approaches were, “…far less efficient than chemical approaches to weed control” and that these may even cause greater environmental harm, “It is costing people a fortune, and people are ripping up their surfaces with steel brushes and leaving 20kg of steel in the environment per week”. Not surprisingly, use of PPPs or not amongst Green-keepers “…depends on location, and the impact the problem would have on my golf course”. How the course looks and plays is paramount. Attention to soil pH to negate weed growth, aeration (often monthly) and hardening the grass sward with sulphate of iron to counter Fusarium were mentioned. As one respondent put it, “We try to manage the situation culturally first. The ethos of a good Green-keeper is to create something that is healthy, because if it (grass) is healthy you won’t have any problems”. Financial pressures have also impacted the frequency of PPP usage; “As a small club with very little money to spend we would always try and get away without using any chemical if at all possible” hence the importance of hand-weeding in the summer months. If PPPs are used, manufacturer’s rates are favoured, “…so that we have recourse to go back to them”, though for others rates may be adjusted through experience, “I need it to last four to six weeks” for budgetary and logistics reasons or to preserve the available chemistry; “Let’s face it, they all talk about phasing and not using them, but I can’t see we’re ever going to get rid of chemicals”. Asked whether they ever used PPPs approved for agriculture, it is clear that the temptation is highest to do so amongst Green-keepers; “The stuff (PPP) for us is so expensive compared to farmers. I can get the same stuff from the farm for about a fiver, if you want to go down that route, but of course – I'm sure there's some out there that do it”. Aside from fine turf, where considerations and approaches identical to those expressed by the Green-keepers prevailed, local authority respondents attempt to balance aesthetics, staff H&S issues, and resource availability with a diminishing budget. Overall, PPP’s are a preferred approach as they are less intensive than strimming; “…the estates, obviously we have a huge amount of obstacles, fence lines and you just would not have the manpower to go and strim those every other week so you’ve got to look at putting the chemicals down”, one respondent estimating that it would cost six times more to strim than it would using a PPP treatment. In addition, use of PPP around marginal areas (e.g. bases of walls, around trees or grass margins, “…reduces the hand arm vibration and the need to strim probably by about 50-60%”, though two respondents reported a seeing a reduction in the efficacy of broadleaf weeds to glyphosate. Alongside the avoidance of sensitive areas like schools and play areas, targeted applications are felt the key to reducing costs, “We only use what we need to use”; one local authority respondent mentioned 10% weed infestation being the trigger of their organisation. Reducing the area treated and frequency of application has been adopted by some; “We used to spray kerb edges three times so there was no weed growing up through the kerbs and paving slabs and that type of stuff, but we reduced it to two and the number of complaints increased but we’ve kept it at two and just tried to alter the timings”. Adoption of polywire brush attachments was mentioned by one respondent, “Obviously around schools, hospitals, high volume areas for footfall traffic, we tend to try and use the sweeping before we go in with chemicals”. One respondent felt that the current choice of moss-killers was ineffectual and had had to resort to mechanical brushing for better control, especially in housing drying areas. Overall though for local authority respondents cost is still the key, “…if you had to everything manually it would be horrendous” and that cost:benefit analyses “always come out that the treatment side is cheaper than employing staff to do the work manually. To actually do the full sweep and have no growth at all you would either have to double or triple the size of the workforce. Where we’re getting around areas of doing a manual sweep about every 24 days, to keep on top of it we would have to do it at least weekly”, a five-fold saving by using glyphosate. Turning to the factors which influence decisions to use chemicals rather than non-chemical alternatives (Q21), all respondent types reported that ‘Chemical treatment was the most practical method available’ (figure below). This was followed by the feeling that ‘Chemical treatment was more effective than alternative options’, largely due to the perceived (non-) ‘Availability of alternative products or techniques’. Amongst contractors, the overall feeling was that chemical approaches either work out cheaper or were more environmentally friendly than existing alternative approaches. Taking the control of invasive species, whilst a five-year chemical programme can cost £2-4K for 50-100m2 this figure increases to £12-16K for physical removal, soil scarification and annual monitoring. Reviewing the use of non-chemical approaches in more detail, another contractor stressed again concerns that “hot foam requires 20,000 litres of water per kilometre and the carbon footprint of this is massive compared with spot-treatment on foot with a knapsack...” That said, integrated approaches do work, for example tying in PPP applications three weeks after and three weeks before council street sweeping can “…reduce the need to street spraying by up to 30%”.


Factors influencing decisions to use chemicals rather than non-chemical approaches (Q21)

CONTRACT GREEN-

KEEPERS

LOCAL

AUTHORITY MEAN

The organisation’s policy 3.40 3.20 3.10 3.23

Chemical treatment more effective than alternative options

3.90 3.60 4.10 3.87

Lower cost of chemical treatments 4.10 3.00 2.80 3.30

Chemical treatment gives longer lasting effect than alternatives 3.10 2.60 3.30 3.00

Availability of chemical application equipment

3.70 1.80 2.90 2.80

Chemical treatment was the most practical method available

4.30 4.00 4.30 4.20

Always done that way 2.60 2.30 2.50 2.47

Did not consider non-chemical control 2.10 2.40 2.60 2.37

Chemical treatment was more environmentally friendly

2.70 1.70 2.50 2.30

Advice of consultant or contractor 3.80 3.30 3.30 3.47

Availability of alternative products or techniques

3.20 3.60 4.00 3.60

Lack of information on alternative products or techniques 1.90 2.90 2.60 2.47

Again, for contractors “…often the client has already decided pesticides must be used” though it is clear from those interviewed, “…if there was an alternative method of controlling a problem we would probably try it” and “I would be one of the first to say to my client, ‘look we can do this’ because I know they would embrace it because of the safety of their staff”.

As a group Green-keepers tend to use less plant protection products than in the past, “When I first came here I think it was about £3,500 and I’m down now to £1,000” and alternative techniques like scarification, soil aeration and hand-weeding amongst others are common place. However, comments like, “You're running with the minimum of staff, you haven’t got staff to actually physically move onto other jobs so you're looking at a chemical way of doing it” and “You're trying to do the best you can not to use them, but the problem is you can do all the work in the world and sometimes you can get away without chemical control, but if you get the disease you’ve got to do it. You can’t sit and let a green just die”, combined with a genuine lack of information on what alternatives existed, summarised the overall sentiment. As one Green-keeper who had explored non-chemical control, eradication of Fusarium with a PPP is more effective than a “bug in a bottle” approach. These findings are supported by the responses to the question how often the possibility of using non-chemical methods for vegetation control is considered before using a PPP (Q22)?

0 1 2 3 4 5 6 7 8

Local Authority

Green Keeper

Contractor

Always

Sometimes

Never

As a group contractors most likely to consider using non-chemical methods, including biologicals, but as noted earlier, “…very seldom used because there is often no alternative unfortunately”.


Green-keepers are already embracing alternative approaches, “If I can mow or dig it out rather than spray I will do this every time” and/or willing to consider another way, “The use of chemicals should always be a last resort…If there was some other way we could do it or if the golfers would not complain about it…it’s just a balance between what you believe in and what the member actually wants” and “If they were more cost effective I might well consider, but I don’t know”. Amongst local authority respondents there was an even split between those that ‘always’ consider alternative responses and those that ‘sometimes’ did. Examples provided, including reverting to a straw-based approach for algal control in ponds or mulching flower beds after the withdrawal of Casoron, “Once that decision was made then effectively that decision was made, we wouldn’t go back down that road because we’ve effectively used a non-chemical method”. Another pointed to a change in the way highway verges are treated, “We used to spray round out trees and obstructions but since diuron has been withdrawn we’re finding that the effectiveness of the glyphosate isn’t as long as it should be. What we’ve actually done now is remove that operation and just instructed operatives to strim mower margins again instead. It worked out there wasn’t any saving in using the chemical if it was only going to last for four or five weeks it was cheaper to say go back to cultural methods and strim”. Finally, respondents were asked to identify from a list which non-chemical approaches they used and where (Q23-Q25).

0 1 2 3 4 5 6 7 8 9 10

Hand weeding

Cutting, strimming, flailing and/or mowing

Brushing

Steam treatment

Burning

Grazing

Mulching

Soil aeration

Correct fertiliser application

Drainage

Biological control

Use of disease resistant stock

Other - Use of Harpins

Contractor

Green Keeper

Local Authority

Amongst contractors hand-weeding shrub-beds, especially these past three years when poor summer weather prevented spraying or where over-spraying is damaging, and cutting/strimming/flailing of larger, often invasive weeds, are the most common approaches. Burning is used mainly by contractors specialising in the control of invasive weeds; “If you’ve got a dense stand you would cut clear and incinerate all the surface growth so you’ve got a level playing field for next year”. One contractor had used hot water, rather than steam as “…you don’t have to expend as much energy (as steam)” for weed control on hard surfaces. However, the respondent believes “This approach can cost up to 10 times more than a chemical treatment” and works best with annual rather than perennial weeds, which tend to regrow from the root stock as they did after paraquat treatment. For Green-keepers the most often used non-chemical approaches are hand-weeding greens, soil aeration and the use of fertilisers; “Aeration, aeration, aeration, you can’t do enough aeration. Grass has to live in air and not a compacted environment”. Healthy growing grass is seen as essential to out-competing weeds, with over-seeding of green several times of the year to reduce the prevalence of soft grasses, like Poa annua. Also seen as important is the need to reduce humidity which would otherwise promote fungal growth, “If we are not cutting or mowing, we go out with a 3 metre brush to knock the dew off the greens”. Ultimately, the greens get most attention, “You're trying to keep a really perfect surface, so the greens get far more treatment than anything we do”. Within the local authority group, hand-weeding of herbaceous borders and annual bedding sites where PPP’s are not used, cutting/strimming/mowing, street-sweeping (“…as often as we can get on to them”) and mulching of shrub border and prime parks are the most commonly used non-chemical approaches;


“Any of the new schemes we’ve done with shrub beds we tend to put a terram down first then mulch over the top. I think if you get it right at the start that’s a big help”. As with the Green-keepers, soil aeration is deemed important amongst local authority respondents for fine turf, although “…it doesn’t guarantee that there’s not going to be the need for chemicals”. One respondent uses a hot wash (in town centre) on a daily basis, “We’ve got a £100,000 machine especially to do this” which as a secondary benefit gives weed control. Another had trialled burning a few years ago, but had not considered this successful, “Probably enlarged the ozone hole about three times the size amount of propane we punched out at the time. That was meant to be the new big thing wasn’t it but, no, mixed results”. A total of nine respondents admitted to using biological control as an alternative to PPP’s. Of these five were unable to recall the name, but pests were the targets. One contractor has used “…friendly nematodes” (Nemasys J) for leatherjacket control in fine turf to good effect, another had trailed a Psyllid aphid under licence from CABI. Another noted that they did “They do nothing for the rhizomes” of Japanese knotweed. A Green-keeper remembered using an endo-mycorrhizal product (Symbio) but had not seen any benefit. One local authority recalled “We have trialed the use of nematodes (Nemaslug) rather than pesticides in some of our shrub beds” for slug control in Hostas, especially in green flag parks. Over two seasons the results were very disappointing and the organisation had gone back to using pesticides again.


APPENDIX 1 CASE STUDY SUMMARIES

Case Study Contr1

Contr1 is a PPP contractor involved in the management, including the use of PPP applications, on a full range of amenity surface types: amenity grass, sports turf, forestry/ woodland, trees/ shrub beds, riparian areas, open water/ aquatic areas, gravel/ ballast surfaces, pavements/ kerbs and roads. Contr1 is also responsible for weed control on roundabouts and splitter islands. Streets, pavements, amenity grass and sports turf are the most important surfaces for this respondent.

Amenity Use and Training

Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, Contr1 indicated most influence coming from

• Local authority policy – “70% of our work comes from local authorities and whatever they are up to governs weed control in their area”

• Government policy/targets – “they want to see a reduction on herbicides and that is what we have been doing since 1997”

• Public safety and/or possible litigation – “We do not want bad publicity or anyone becoming injured through bad spraying practices”

• Quality of grass/turf – Within high value sporting venues, TV provides highly visibility of any faults or technical problems with the playing surfaces and contractors are under high pressure at all times to minimise these issues.

• Public concerns – seen as a major influence, “If we are out knapsack spraying people who are dog walking or who like bees or think we are killing plants are always asking questions”

Regarding knowledge of the 2006 Code of Practice for using PPP, Contr1 rated their knowledge as Good.

Contr1’s organisation is a member of all listed associations, plus NPTC and NAAC-Amenity. All of the organisation’s locations were aiming for Amenity Assured.

Within Contr1’s local organisation, of the 12 staff the number trained/qualified were as follows: BASIS – 1, BASIS register – 3, BASIS Power – 0, BASIS storekeeper – 3, BETA – 0, NPTC – 12, NRoSO – 12, NASOR – 12 (Contr1’s organisation have moved to NASOR this year as “it has superseded NRoSO for Amenity”), access to 2006 Codes of Practice – 12, trained in 2006 Codes of Practice – 4.

Also belongs to the Property Care Association. According to a recent Amenity Forum meeting there are over 3000 ‘contractors’ claiming to offer control of Japanese Knotweed (JK). Contr1 believes that the PCA auditors have no idea how to audit whether these ‘contractors’ have the necessary training to offer JK control.

A training programme is run every February/March for all operators; this is a refresher, focusing on HSE (RIDDOR), current and new nozzles, new chemicals, etc.

Within Contr1’s organisation, BASIS qualified personnel are used for developing policies, making and checking recommendations (especially important in support of new personnel pre-BASIS training) and tender preparation.

Protecting Human Health and the Environment

Unprompted to the question about protecting human health, Contr1 stated, “We all agree to apply pesticides in the safest way possible, in the right weather, using the right equipment, the right nozzles for the type of day or to produce the right spray quality. We do not spray near schools or people, we wear appropriate equipment.”


In Contr1’s organisation, COSHH assessments are made for every activity and PPP. Site specific risk assessments are prepared in advanced and reviewed on site before any spraying takes place. Contr1’s organisation requires all relevant paperwork resides with operators at all times. Health surveillance policy requires all operators have annual check-ups, blood tests, etc. Six tool box talks for all operators are done during the winter months, covering fire, COSHH and HSE policy. Spray notices are advertised on behalf of the local authority in relevant newspapers, and appropriate signage is used where practicable during spray operations.

Near hospitals, doctor surgeries, streets or other areas with high footfall, or on golf courses and near water, Contr1’s organisation would use shrouded booms or equipment to reduce spray drift.

Unprompted, Contr1 identified water, gullies, bore holes, and pavements as areas where they are particularly conscious of the need to protect the environment; “we want to prevent spikes in glyphosate as we cannot afford to have this product taken off the market…it is the mainstay of our work”. “We want to avoid what is happening in Holland”, a reference to the substantial use of non-chemical approaches for vegetation control. Prompted, Contr1 recognised the need to avoid applying soluble products like propyzamide on slopes where the run-off risk was high. Heavy rainfall was also identified as something to avoid, before and after spraying.

Contr1 used the EA website but was not aware about “What’s in your backyard?” Also mentioned the CRD and client’s websites unprompted and use of manufacturer’s sites for product information and MSDS and occasionally used the Amenity Forum website.

Specific measures taken to protect water include the use of machinery developed to target spray applications, all operators have PA6AW (“so that they are all aware about spraying near water”), and the use of shrouded booms, LERAPs and buffer zones.

Application Equipment and Pesticide Storage

Contr1’s organisation calibrates knapsacks weekly, which includes the pressure regulators. Hard surface spray equipment is also calibrated weekly, with nozzles changed twice per year as a minimum, and is NSTS certificated once per year. Prompted, Contr1 indicated hard surface equipment would be calibrated when moving to different terrain. Some machinery (JD Progator) allows the operator to select nozzle types appropriate to the required water volumes and a single nozzle test is done on each boom before spraying. Attention to detail is critical not least of which some turf fungicides can cost over £800/hectare whilst other products are being applied as low as 10gms per hectare.

All operators are fully trained and receive refresher training every February. They carry COSHH assessments, site specific risk assessments, MSDS for all products to be used during the season.

Unprompted, Contr1 described their organisation’s pesticide store as being ventilated, lit, inside another heated building, locked, bunded to EA guidelines (to retain in excess of the total volume of pesticide stored), sealed, with Eco spill kits, eye baths, and carrying appropriate signage. BASIS inspected annually, the store recently passed its five year EA inspection and annual Fire Brigade certification.

Questioned about precautions used at filling, unprompted Contr1 stated operators read the label first, do not fill near a drain, fill knapsacks from hydrants under licence using equipment with non-return valves, and then agitate. Asked about matching container to the task, Contr1 would prefer to have a broader range of pack sizes but accepted that given the areas requiring treating some kind of measurement will always be necessary; “one of the hardest challenges is pouring from a 20 litre container in to a one litre measuring jug”.

Measuring jugs are required by Contr1 to be placed on a flat surface and then fill mounted tanks using chemical induction systems. To avoid rinsing, Contr1 has moved to a 68% free-flowing granule formulation of glyphosate. Other packaging is triple-rinsed, the Progator having its own rinsing device on the induction bowl, rinsed containers being returned to an empty carton for later disposal.

If materials, in many cases glyphosate, are left over from one job they would be transported in knapsacks or the Progator to the next job and then part filled with fresh water for the next day’s spraying. Mention was made of the need to thoroughly clean after using residual products, with tank-washings applied to other areas on golf courses, “as some form of weed control is always wanted”.

Empty containers are returned and bagged before being collected by a local approved waste contractor; “the cost of this approach is relatively small”.


Minimising Pesticide use and Alternative approaches

Unprompted, Contr1 listed identification of the problem and evaluation of all approaches as key criteria when deciding whether to use a pesticide or not. Contr1 is convinced that from all the evidence presented thus far, the use of burning, hot steam and foam approaches were “far less efficient than chemical approaches to weed control”, and may even cause greater environmental harm: “It is costing people a fortune, and people are ripping up their surfaces with steel brushes and leaving 20kg of steel in the environment per week”.

Due consideration is given to chemical dose rates as damage of highly quality turf would not be tolerated by clients. Although Contr1 is BASIS qualified, he does not hesitate to refer to others for a second opinion before spraying. Finally, Contr1 is keen on the use of adjuvants both to optimise water pH (to 5.5) but also to improve the spread and penetration of PPP, especially if this also permits the use of lower dose rates. It was noted, however, that manufacturer support is important when using lower rates.

Reviewing the use of non-chemical approaches in more detail, Contr1 stressed again concerns that “hot foam requires 20,000 litres of water per kilometre and the carbon footprint of this is massive compared with spot-treatment on foot with a knapsack...”. Integrated approaches do work, for example tying in PPP applications three weeks after and three weeks before council street sweeping can “reduce the need to street spraying by up to 30%”.

Having stated they never considered the possibility of using non-chemical methods for vegetation control, Contr1 admitted to using hand-weeding of shrub-beds, especially these past three years when poor summer weather prevented spraying.

The most often used non-chemical approach by Contr1 is a mix of fertilisers and plant friendly products (e.g. Teemac and Turfite) with harpins (proteins from certain bacterial plant pathogens applied to trigger plant defensive and growth responses) to help improve grass strength and vigour, in conjunction with appropriate aeration and drainage, which collectively reduce the need to apply fungicides . Whilst unimpressed with the use of Psyllids for Japanese Knotweed control (“they do nothing for the rhizomes”), Contr1 has used ‘friendly nematodes’ (Nemasys J) for leatherjacket control in fine turf to good effect.

Case Study Contr2

Contr2 is a PPP contractor involved in the management, including the use of PPP applications, of gravel/ballast surfaces, pavements/kerbs and roads, and specialising in the control of Japanese knotweed and Hogweed.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, Contr2 scored all factors as strongly influences on priorities, excepting protection of infrastructure (little influence) and financial pressures (intermediate influence). Selecting some of the factors indicated where most influence on priorities is coming from:

• Control of invasive (non-native) species – For the past two years there has been increasing pressure from banks and other lenders for prospective home-owners to provide independent evidence that Japanese knotweed (and Hogweed) is treated and being monitored before loans are approved; “We tell house surveyors that they do not need a guarantee if knotweed is more than 7 metres from the property but they are not willing to listen”

• Public safety and/or possible litigation – To avoid any possible risk of impact of PPPs on human health, especially asthmatics Contr2 avoids spraying in the presence of the general public or will use stem injection as the preferred approach.

• Public concerns – “What we are using is as harmless as shampoo but as soon as the public see us wearing masks and other PPE they start to ask questions”

• Local authority policy – Contr2 expressed frustration that LAs are rarely treating knotweed effectively and land bordering private dwellings is becoming a problem for householders or those seeking a mortgage.



Contr2’s organisation is a member of the Property Care Association, but could not recall membership of any other industry associations or schemes.

Within Contr2’s local organisation, a majority of staff (20/30) all had NPTC sprayer qualifications (PA1 and PA6-AW) and a number were BASIS storekeeper certificated, otherwise none had BASIS or other qualifications. All members of staff have access to copies of the 2006 Codes of Practice and those with NPTC qualifications had received related training. No follow-up refresher training was mentioned.

Within ConTr2’s organisation, in-house BASIS qualified personnel are not used for developing policies, making and checking recommendations and tender preparation.


Unprompted about protecting workers and the public, Contr2 stated, “We always mark-off areas where we are working and advise the public to take another route”.

In Contr2’s organisation, COSHH assessments are made before starting any work, and full surveys of the site. Aside from the use of PPE, Contr2’s organisation does not offer annual health checks for workers.

Contr2 identified the need for greater vigilance when spraying in public or other areas of high footfall, for example supermarket car parks, with the use of physical cordons and signage being commonly employed.

Unprompted, Contr2 identified water, and associated drains, as areas where they are particularly conscious of the need to protect the environment. Prompted, Contr2’s organisation avoids the use of residual herbicides in conservation areas and chooses stem-injection in open parkland to minimise drift and the concerns of the public. It is also mindful of slopes more than surface types when spraying and identified with prompting that rainfall had a big impact on their ability to use PPP.

Unprompted Contr2 stated that they would refer to the Scottish EA website or the EA website used the EA website, but was not aware of the latter’s “What’s in your backyard?” initiative. Also mentioned the CRD and client’s websites unprompted and use of manufacturer’s sites for product information and MSDS and also occasionally used the Amenity Forum website.

Asked what other specific measures are taken to protect water, Contr2 stated “We won’t spray within 10m of a water course, we only use stem injection”.


Contr2’s organisation only uses knapsack sprayers (with a 1.2l lance), these being calibrated every month, “and if we have to change any parts then we calibrate again”. Sprayers are also recalibrated with a change of products, but not when equipment is moved between locations.

Noted earlier, all spray operators are NPTC trained, but currently do not receive any refresher courses, though Contr2 noted “I do hear that (a requirement for) annual courses is coming in”.

Contr2 was unable to comment on their organisation’s pesticide store other than to note that it was a converted building, with “drip trays” to prevent leakage of product and that the store was checked “annually by the PCA so it is up to scratch”. Contr2 stated that all vehicles have lockable steel boxes for transporting PPP containers.

Asked about precautions used at filling, unprompted Contr2 stated all product is measured with the appropriate PPE over drip trays to prevent spillage, but “we all have spill kits as well in case we do spill anything on the ground”.

Asked about label instructions, Contr2 said that they always follow manufacturer’s product labels, and although they do not use induction hoppers, each vehicle has a 100 litre fresh water tank and an electric pump to fill the knapsacks using a hose. Generally Contr2 did not perceive any safety issues during pouring from a measuring jug, “no higher than waist height”.


Containers are rinsed three to four times, “until there is no smell in the container” and waste water is transferred back in to sprayer. Contr2 also stated, “we hold back 2 litres of fresh water and use this to wash out the measuring jug” before adding to the sprayer. Any spray material left over at the end of the day is “pumped back in to a 25 litre container and taken back to the depot ready to be used the following day”. Washed and empty containers are secured inside the vehicles before returning to the depot. It is rare to have to mix more than one product, glyphosate used alone or with an adjuvant being a mainstay.

In Contr2, the spray operator also prepares spray materials and will have copies of the label and COSHH with them at all times.

All waste containers are stored and at the end of the month are collected by the supplier and removed for destruction. Noted earlier, any excess spray material is stored at the depot for use the following day. Contr2’s organisation never has the need to dispose of materials at the site of application nor on a designated area.


Unprompted, Contr2 listed identification of the problem and for example, “it is up to the client whether they have it (knotweed) dug out or removed or have a five year monitoring and spray programme.”

Prompted, Contr2 never considers whether the financial loss caused by the weed outweighs the cost of the pesticide. Consideration is given to the potential for a pesticide to damage the area treated, for example picloram is used “on where land where the customer is not particularly bothered if other plants are killed off” whereas glyphosate tends to be used in garden areas where it is desirable to preserve other plants.

Challenged how decisions on what pesticides are to be used in a specific situation, Contr2 stated “It is really through experience…it is always the same dosage and that goes by manufacturer’s rates”. A typical programme for knotweed for Contr2 would be two sprays per season for five years, “Hogweed is a problem because it seeds and you do not know the area it has seeded over”.

Considering factors which have influenced decisions to use chemical rather than non-chemical approaches, Contr2 was adamant that for knotweed “removal is always more effective than chemical treatments.” Whilst a five year chemical programme can work out cheaper – over 72m2 £3900 vs. £16,000 for knotweed removal, soil scarification and annual monitoring – banks will not release money for building unless complete removal of the weed is guaranteed. Questioned on the availability of alternative products, Contr2 felt that this had a strong influence on chemical approaches, “there is a lot of new stuff coming” and sponging and stem injection were useful options compared with overall spraying when it comes to protecting the public.

Contr2 stated that their organisation always considered using non-chemical methods for vegetation control. Principal amongst these are: hand-weeding (Himalayan balsam and small hog-weed), cutting/strimming/flailing and/or mowing, brushing and removal (off-site). Of these, removal and subsequent burial on an approve land-fill site is the preferred option, followed by cutting of knotweed, and brushing to remove material in car parks.


Case Study Contr3

Contr3 is a PPP contractor involved in the management, including the use of PPP applications, on a full range of amenity surface types: amenity grass, sports turf, forestry/ woodland, trees/ shrub beds, riparian areas, open water/ aquatic areas (though limited), gravel/ ballast surfaces, pavements/ kerbs and roads. Contr3 is also responsible for weed control on some car parks.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, Contr3 indicated most influence coming from:

• Protection of infrastructure – The frequency of work to control Japanese knotweed has been increasing steadily since the credit crunch, “A lot of lenders do not need much of an excuse not to lend these days”

• Protection of nature conservation areas/ wildlife habitat – as a contractor “We have a huge responsibility when it comes to stewardship of these areas” a reference to the Pellet-wise metaldehyde campaign.

• Protection of fisheries/ angling interests – “We are extremely mindful of the potential to damage these environments through surface run-off, for example”.


Contr3’s organisation is a member of all listed associations, plus NAAC and The Contractors Health and Safety Assessment Scheme (CHAS).

Within Contr3’s local organisation, of the 10 staff the number trained/qualified were as follows: BASIS – 2, BASIS register – 2, BASIS Power – 0, BASIS storekeeper – 3, BETA – 1, NPTC – 10 (PA1, PA2, PA6, PA4 x 2, PA6W X 2), NRoSO – 4, NASOR – 0 (Contr3’s not planning to move to NASOR and was candid in saying that NRoSO meetings “fail to deliver” content of use to spray practioners), access to 2006 Codes of Practice – 10/10, trained in 2006 Codes of Practice – 10, via local NPTC training centre, and Contrl3’s organisation also holds regular ‘tool-box’ Health and Safety talks every 4-6 weeks.

Within ConTr3’s organisation, BASIS qualified personnel are used for developing policies, making and checking recommendations. Asked why Local Authorities rarely have BASIS-qualified staff, Contrl3 believes that this is due to their “high throughput of staff. I doubt they could retain someone with BASIS qualifications”.


Unprompted to the question about protecting human health, Contr3 stated, “We try to ensure that all of our guys are fully trained, they know what they are handling and are using the correct PPE at all times and using the correct product for that situation. We always go for products with the lowest toxicity which is easy to achieve as 99.9% of all product used is glyphosate-based. We make sure our equipment is well maintained and tested.”

In Contr3’s organisation, COSHH assessments are made for every product used alongside RAMs (Risk Assessment and Method statements), bound copies of which are available for operators to consult whilst working. Health surveillance is done, but tends to be limited to maintaining accident records and keeping a check on operator’s exposure to pesticides rather than annual GP check-ups and blood testing.

Notices of spray operations are rarely used, mainly as “very difficult to put up notices when you are going to have to spray 40-50 streets in one day, which is the lion’s share of what we do”. Contr3 uses signage if spraying football pitches or across public foot-paths and bridle ways.

Unprompted, Contr3 identified the need to avoid spraying near water and over open drains and that heavy rainfall posed a threat of surface run-off, as does frosty conditions. If Contr3’s organisation does treat aquatic areas, this is always done with input from the EA. Surface type and slope tend not to be considered by Contr3’s organisation as their main activity is street treatment.

“From a spray situation we do not need to visit the CRD web-site” (most treatments applied are glyphosate), but Contr3 did admit to having visited the EA website, ‘What’s on your backyard’ after some environmental training, and has visited the Amenity Forum website.

Specific measures taken by Contr3’s organisation to protect water include ensuring use of the correct products, observation of buffer zones if required, minimise leaks and spillages from equipment to avoid point-source contamination.



Contr3’s organisation uses mainly quad bikes with 60 litre front and rear-mounted tanks, with a solenoid to achieve either partial or full-width spraying across the boom, a series of knapsacks and one small Hardy tractor-mounted sprayer.

All equipment is calibrated weekly, “there are no jobs we do for different councils that takes us less than one week due to the sheer size of the urban areas that we are covering.” Rates are rarely altered as “no point in over-dosing it as money is tight, and there is no point under-dosing as we will only get called back if something does not work”. Footfall or parked cars are often contributory factors why products ‘fail’.

Challenged about the use of agriculturally approved products in amenity situations, Contr3 stated that whilst the temptation is there, “as agricultural products are not premium priced, you have to resist the temptation (to use)…Cyren has an amenity label but costs £4/litre more than Equity that does not”.

All operators are fully NPTC trained and as mentioned earlier receive health and safety refresher training every 4 to 6 weeks during the season.

Contr3’s organisation does not have a BASIS-approved store, instead drawing in on a daily basis exactly what is required.

Questioned about precautions used at filling, unprompted Contr3 stated operators all have PPE, water is drawn from stand-pipes using equipment with non-return valves (“so water cannot be siphoned back in to the mains”), all vehicles have a “bunded tank and bikes and knapsacks are ‘chemed’ in the vehicles which are in effect a bunded store”. Measuring and filling also takes place within the bunded environment.

Prompted, Contr3 stated that all operators have copies of product labels with them, and that these should be read before filling the application equipment. Contr3’s organisation does not use a closed transfer system. “Nearly impossible to match the container size to the task…especially with a 60 litre tank on the quad bike”. With regard to rinsings, all containers are triple rinsed and “because we only ever use glyphosate we are fortunate that all of the rinsings always end up back in the tank.” After discussions with BASIS, due to the wide dose rate range for glyphosate and generally lower rates employed for weed control, Contr3 does not believe their organisation ever exceeds the maximum approved dose.

“Once the containers have been cleaned, and labels etc. have been removed they are disposed of by an official approved recycling scheme.” Each vehicle has two 1000 litre tanks, one to hold concentrated product, the other cleaned and stored empty containers. Products are rarely, if ever mixed. The spray operator is charged with mixing and loading product, and carries with them product labels, COSHH and any other relevant paperwork for the task ahead. Each vehicle has a spill kit, comprising “a boom that you can put around a spillage, through to absorbency granules, etc.”

Noted earlier, triple-rinsed containers are disposed of via an approved waste contractor. Contr3 stated that there was never any waste spray materials, quad bikes being returned to bunded lorries over-night, especially if the weather turns poor, and spray materials are used on the next LA job; “we never have any disposal areas as we ultimately, always spray out on the job that we are on.” Pressed further, Contr3 admitted that if the spray tank has to be stripped down at the end of the season, then washings (“no more than 20 to 30 litres of washings”) would be applied as a tidy-up around the yard.


Contr3 stated that the decision to spray three times during the course of the year was done by the LA issuing the contract…”the only decision I make within that that is ensuring that there is enough growth in that situation to warrant the operation”.

Unprompted, Contr3 listed identification of the problem and evaluation of all approaches as key criteria when deciding whether to use a pesticide or not. The next step would be “to consider whether the pesticide was the best for the job and had the lowest environmental impact. It does not have to be a sledge hammer to crack a nut”.

Reviewing the use of non-chemical approaches in more detail, Contr3 stressed “if there was an alternative method of controlling a problem we would probably try it…the reality is chemical treatments are going to be cheaper than hand-hoeing a highway.”

The use of non-chemical methods for vegetation control is <Always> considered by Contr3, but “very seldom used because there is often no alternative unfortunately”.


The most often used non-chemical approach by Contr3 is hand-weeding – typically in LA shrub-beds where targeting problems with an over-spray is not practicable – and flailing – typically for grass management where weed control is a secondary benefit. Contr3 has tried burning a few years back but this was not found to be viable.

Case Study Contr4

Contr4 is a PPP contractor involved in the management, including the use of PPP applications, on a full range of amenity surface types: forestry/woodland, trees/shrub-beds, riparian areas, gravel/ballast surfaces, pavements/kerbs and roads, other hard surfaces and domestic gardens.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, Contr4 indicated clients really dictate priorities, for example “we do a lot of work for (a named) Trust…dealing with invasive non-native plants and that becomes pretty much the focus of the business for one or two months each year”. Seasonality of the work therefore influences and changes the priorities during the year. Overall, however, most influence comes from:

• Control of invasive (non-native) plant species – Control of Japanese knotweed is important for Contr4. Indeed, public awareness of this non-native and depends from financial lenders for home-owners to deal with the problem before granting mortgages has led to a five-fold increase in domestic jobs for Contr4’s organisation. “A lot of Local Authorities deal with the weeds themselves…but they often struggle to eradicate (the problem) or miss substantial areas just through a lack of knowledge of the plant”

• Protection of nature conservation – Again knotweed is a major problem, often along the entire 30 mile stretch of river. Contr4’s organisation has a strong ethos about protecting the environment and conservation of local wildlife habitat, “The preservation of bio-diversity is key…we have to have correct procedures in place (so) that we don’t spread any of the non-native species”. Removal of Himalayan balsam from mud in the sole of boots between jobs was an example given.

• Public safety and/or possible litigation – Contr4’s organisation has made an effort to raise public awareness of Giant Hogweed locally. In addition, the organisation takes care to ensure they only select safe products “like Roundup Pro Biactive 450”, use correct signage and giving appropriate warnings of spray intentions. The respondent is also mindful that the public are also more litigious, “There are plenty of people around these days who are looking for any reason to try and get money off companies”.

Regarding knowledge of the 2006 Code of Practice for using PPP, Contr4 rated their knowledge as <Very Good>.

Contr4’s organisation is a member of many of the listed associations, plus the Invasive Non-Native Specialist Association (INNSAP). “We did look at joining NRoSO but we thought there’s no real benefit…it is not giving us any additional qualification. We already pay quite a lot of money to BASIS…there’s no real benefit of joining the slightly smaller things that have limited power or anything”.

Within Contr4’s local organisation, of the 4.5 FTE staff, the number trained/qualified were as follows: BASIS – 3, BASIS amenity register – 3, BASIS Power – 0, BASIS storekeeper – 1, BETA – 0, NPTC – 4.5 (plus ten seasonal staff, all PA1, PA6W), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 4.5/4.5 (plus 10 seasonal staff), trained in 2006 Codes of Practice – 4.5 (plus 10 seasonal staff); “We won’t employ anyone that’s not got PA6AW…I encourage all staff to read through the code of practice before they actually do the PA6AW exams”.

Within ConTr4’s organisation, BASIS qualified personnel are used for developing policies, making and checking recommendations, and in preparing tender submissions and evaluation.



Unprompted to the question about protecting human health, Contr4 stated, “To begin with we make an assessment of what the risks are likely to be and who is going to be at risk and then try and work out a strategy to minimise the risk”. This often translates to working at times when there are few people around, using signage and letting the public know what is being done, “if anyone comes along we stop working”. Treated areas are kept fenced until the pesticides are dry.

In Contr4’s organisation, unprompted COSHH assessments, use of PPE, signage, appropriate training were all mentioned. When prompted, “We have started monitoring the health of employees and encourage them to let us know if they are not feeling well for any reason”.

Contr4’s organisation is particularly vigilant around nurseries, schools and nursing homes, “places where there’s certain people that are more susceptible or sensitive to chemicals…or around watercourses, anywhere where there’s the likelihood of the herbicide getting into water”. Methods adopted to reduce risks further include the use of stem injection or weed wiping to reduce airborne drift. “It might take us longer to do the job but then it’s definitely beneficial to do so”.

Unprompted, Contr4 identified the need to avoid spraying near watercourses, schools, where there are children or animals. Prompted, Contr4 stated drains represent a high risk and they use covers when doing work near these. For SSSI’s, “there are so many levels of planning that you have to do before actually doing the work”. Although Contr4’s organisation does little work in open parkland, the respondent stated the need to stay vigilant, “making sure that you are not going to get a nasty surprise when two Labradors come running through the area of knotweed that you have just sprayed”. Regarding the weather, Contr4 stated wind was the biggest factor, followed by heavy rain and the risk of runoff down drains. Long lances (3-3.5 metre) are used on slopes to reduce the time needed to spray these.

In terms of which websites are consulted, unprompted Contr4 replied, the CRD website (“I find this really useful but it is not as easy to navigate as some of the commercial websites out there”, and manufacturer’s websites. Prompted, Contr4 stated that they prefer to use the SEPA site, though the EA “have a code of practice for Japanese knotweed which is a really good little document”. The EA is also considered a far more helpful organisation than SEPA, “they actually have BASIS qualified people you can speak to”. Asked about the Amenity Forum, Contr4 stated “I have been on that a few times over the years…but not for a long time”.


Contr4’s organisation uses knapsack sprayers and stem injectors. “We have put in a regime of weekly checks, well its daily checks for general faults and a weekly basis for flow rate and output”. Only one specific type of nozzle is used for knotweed, hogweed and balsam, and these are all “treated using the same herbicide, same dose rate and same nozzle”. Prompted about calibrating after maintenance and repair, “we have a standard form that we have for calibration...it might even have come from the Monsanto website”. If Contr4’s organisation was to change products, then they would check the label and make sure that they “were working within the parameters set on the label”. Regarding the stem injectors, these are not powered, instead used by turning a calibrated thread, “it is a fairly crude method to be honest and an expensive way of dealing with any weed as you use so much herbicide but some clients think it’s the best thing ever!”

Contr4 deals with all training on technical application and pesticide-related issues. Contr4 is currently studying to become a trainer and then be able to offer PA1 and PA6AW training, through Lantra.

Whilst Contr4 has completed the BASIS nominated store keepers course, they noted “we’re in a strange situation where to be part of the Amenity Assured Scheme we have to have a store but we never store more than about five litres of Roundup”. BASIS have inspected the store, “essentially a chem space in an outbuilding away from domestic premises that is locked”.

Asked about what key elements need to be considered when constructing a store, Contr4 replied “it needs to be lockable, able to contain 110% of the volume of chemical stored, needs to be fireproof to an extent. The Local Authority needs to be notified, crime prevention officer, fire brigade, planning consent…it needs to be BASIS approved, a nominated store keeper keeps records of everything that’s in the store (and a copy in the office)…chemical proof flooring, correct health and safety signage”.


Questioned about precautions used at filling, unprompted Contr4 identified working out the best area for filling (“try and fill up away from drains and sensitive areas”) as being the first priority. Next, ensure that all PPE is worn, sit the sprayer inside a container to avoid spills, then half fill the sprayer, measure out the herbicide on a level surface, pour into the sprayer, triple rinse the measuring jug, top up the sprayer with water, put the herbicide container into the lockable chemical safe in the van ad secure the van before starting the work. Prompted about reading the label, “you have got to follow it exactly…(with regard product and water volumes)…and follow any safety information”. Contr4 believes amenity users are limited in terms of packaging supplied by manufacturers, though did state five litres “is a perfect size for us and we can transport it”. Contr4 has a 16 litre sprayer but only fills to 15 litres, “you end up with a bigger risk with them spilling”. Used at 300millilitres of product per spray tank, “a five litre container can satisfy the needs of two people for the day”.

Those spraying also fill their own sprayers, “they have to take responsibility for making sure that they’ve done the job properly” and carry both the product label, and a job sheet specifying the area to be treated and volume of herbicide required. Spill kits are available in the cab and in the back of the van. Absorbent material is added to any spillages, brushed, then scooped in to a bag, which are tagged and taken to a relevant waste disposal facility.

In terms of waste materials, any diluted spray materials are left in the sprayer, which is labelled and used another day. Rinsed containers are collected by the supplier rather than use a waste management company.


Looking at what criteria used in deciding how to minimise the use of pesticides, Contr4 stated “there are plenty of alternatives to pesticides (for controlling invasive plant species) but the problem for the client, not for us, is the cost”. Contr4 considers digging up knotweed and disposing at a landfill site as “more detrimental to the environment then actually using some pesticides to begin with”. Government land fill levies mean that that the cost of a taking a tonne of knotweed contaminated soil to a landfill costs more than £100, “where £100 will buy ten litres of Roundup…” enough for 2.5 hectares of treatment. The respondent was also concerned about the environmental impact of burying knotweed below a plastic impermeable membrane.

Probing further, Contr4 quoted research on the use of biological control agents that showed a reduction in spread rather than eradication of the problem, “it’s like treading water”. Whilst CABI and the EA code of practice were cited as useful sources of information on alternative approaches, “it comes down to the client’s budget and timescales. A supermarket doesn’t want to wait for three years to get rid of the Japanese knotweed when it can be dug out in an afternoon. It is not an environmental decision…”

In terms of drivers for using chemicals versus non-chemical approaches, Contr4 stated that the lower costs of chemical treatments, availability of application equipment, overall better environmental profile of pesticides and plenty of advice on the use of pesticides as key to their organisation using chemical approaches to weed control. “For any job that we quote for where there’s scope for more than one method we will give those options”. In short, Contr4’s organisation will always consider non-chemical methods, but believes current alternatives for knotweed control are “more detrimental in most cases than pesticide use”.

The most often used non-chemical approach by Contr4 is:

• Burning – restricted to burning Giant Hogweed, especially seed heads in late season, and Japanese knotweed stems.

• Cutting and strimming – Himalayan balsam is cut initially • Hand-weeding – mostly domestic jobs, mostly for shallow-rooting balsam, providing no seeds are

present as these quickly spread everywhere.

.


Case Study Contr5

Contr5 is a PPP contractor involved in the management, including the use of PPP applications, on a full range of amenity surface types: amenity grass, sports turf (not golf greens), some forestry/woodland (spot treatment of invasive weeds), some trees/shrub-beds (“most done in house by our clients”), riparian areas, gravel/ballast surfaces, pavements/kerbs and roads, other hard surfaces for example shopping precincts, car parks and fence lines.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, Contr5 highlighted the following as most important:

• Protection of infrastructure – client-led requests for paths and kerb edges to be kept clear and free from damage

• Local Authority policy – until recently LA’s have been ahead of government policy. Diuron was withdrawn from LA tenders for hard surface weed control and replaced with three sprays of glyphosate well before being banned by central government. LA policy is also dictating approaches to the frequency of spraying highways or keeping public areas clean and tidy, “If they were doing three sprays 5 years ago they’re now doing two sprays”. In the past, LAs would also specify the actual brand of diuron or glyphosate that could be used, ideally without a St. Andrew’s cross, but todays “They’re a little less fussy on those kinds of things and they will ask you to just do it as cheap a price as possible”.

• Financial constraints – Since 2008, LA budgets have been cut. The focus has moved away from the cost effectiveness of the treatment to “We have got to make a 30% saving on our budget so we’re going to take 30% off what we spend on weed control”. Reducing the frequency of spraying is only commercial approach to achieving these objectives.

• Public concerns – Unlike agricultural pesticide usage, amenity usage is very visible and often done in full view of the public, “All our guys are trained to give way to people on footpaths…not to spray within 5 metres of the public”.

Regarding knowledge of the 2006 Code of Practice for using PPP, Contr5 rated their knowledge as <Very Good>; “I’m a bit of a geek when it comes to weed control, but I don’t think I’m alone in that”.

Contr5’s organisation is a member of most of the listed associations, except NRoSO and up to now, NASOR. With regard to NRoSO, Contr5’s organisation registered all staff but despite committing to week-long training sessions to earn the required CPD points for continued membership, “It was geared towards agricultural users…they did not recognise the amenity training we received from suppliers, but were quite happy to give us vast quantities of points for hedge laying and pheasant rearing”. Based on the experience with NRoSO, Contr5’s organisation is reluctant to jump in to NASOR until, “…it is adopted by enough people”.

In addition, Contr5’s organisation is a member of the British Association of Landscape Industries (BALI; Sector Scheme 18 – landscape, environment and ecology).

Within Contr5’s local organisation, of the 40 FTE staff, the number trained/qualified were as follows: BASIS qualified – 2, BASIS register – 2, BASIS Power – 0, BASIS storekeeper – 25, BETA – 0, NPTC – 4.5 (plus ten seasonal staff, all PA1, PA6W), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 40/40, trained in 2006 Codes of Practice – 40/40.

Contr5’s organisation is also a member of the Construction Services Certification Scheme, to ensure all staff has basic health and safety training when working on highways undergoing construction.

BASIS registered staff are used to draft the organisation’s policies, checking recommendations and during tender preparation. Contr5 often receives tenders recommending what chemicals to use. If challenged by Contr5’s organisation when the product has been either withdrawn or the use is no longer permitted, some client’s will actually push back, “you do what we say”. Of course, Contr5’s organisation cannot support illegal practices, but “…it really does annoy us when somebody who doesn’t have a BASIS qualification tells us what chemical to use”.



Unprompted measures used to protect human health, Contr5 stated, all work is covered by a method statement, a risk assessment and any chemicals used will have a COSSH assessment as well. Employees are all NPTC certificated and are given instructions on how to use each chemical. Staff will make their own judgement about whether conditions are right for spraying, even if the client on site visits challenges them to get the job done, a common practice.

Prompted for other steps taken to protect operator health or the public, Contr5 replied “They just follow the Code of Practice…not spraying within 5 metres of the public”, wearing protective clothing, and “we don’t use chemicals that require us to carry out mandatory health surveillance”. All staff complete a health questionnaire on joining and once per year and Contr5’s organisation review these documents for changes.

Prompted about use of signage, Contr5 replied these are used in a park or golf course situation, but not during motorway, footpath or highway spraying as the scale makes this “not feasible to do so”. Sometimes clients post notices of spraying on their websites and in local papers.

Areas where Contr5’s organisation is especially vigilant include not spraying around schools during the start and end of the day, “it makes sense that you wouldn’t go spraying when there are lots of people around”. Care is taken around hospitals too.

Unprompted, Contr5 identified the need to avoid spraying near watercourses, riparian habitats and nature reserves, “situations where they’ve got flora and fauna that need protection”. “An awful lot of our contracts have quite large exclusion areas around these (sites)…before going in you need to do a special risk assessment for the species in these areas”. Contr5 referred to the need to get a permit and complete a LERAP assessment if the product to be used “requires you to do so”.

Prompted, Contr5 stated that employees are told not to spray over drains “as part of our induction training”. Products for open parkland have been assessed as being generally safe to the public. Occasionally, picloram may be used for Japanese knotweed control and as this is root absorbed, “we would stay at least two ‘direct lines’ away from trees”. Regarding slope, with the exception of picloram, other products used tend not to present a problem, “there is no leaching potential with glyphosate (compared with diuron of old)”. Contr5’s employees are told not to spray when it is raining or too windy, and in a frost. The latter, combined with rainfall immediately afterwards, can lead to runoff.

In terms of which websites are consulted, unprompted Contr5 replied, the EA ‘What’s in your backyard’ – “I’ve only really been told about that this year…an awful lot of operators probably wouldn’t (know about this site)”. Contr5 stated, “If you work with water authorities they tell you where you can spray or not”, so uses their websites for information. Prompted, Contr5 tends to “use the CRD site now instead of the Green Book”, and occasionally manufacturer’s sites commenting on the latter, “amenity tends to become just a little page within their agricultural or global website so it can be quite difficult to pick out information”. Prompted about the Amenity Forum, Contr5 was extremely supportive of this “voice for amenity”, bringing together all aspects of the supply chain, customers, regulators, etc. and replacing a hitherto fragmented collection of amenity interests, previously “we felt quite strongly that we weren’t being represented properly…people (HSE, EA, Highways Agency, etc.) were asking the agricultural community about us, rather than asking us directly”. Application Equipment and Pesticide Storage

Contr5’s organisation uses knapsack sprayers, and several types of tractor mounted up to a sophisticated highway sprayer that uses clean water tanks and a computer controlled direct injection that allows part-area spraying and use of different products and dose rates, “This is an awful lot safer on highways than having to mix up 5000 litres of chemical”. Calibration of sprayers is done daily and information added to the application check sheet. Pressure tests are done daily and recorded, and if nozzles are worn or not producing the correct rate or quality, they are replaced before spraying, “We did get them NPTC checked this year”. At least one person in each depot has NPTC training and can calibrate sprayers. Regarding outsiders, “they might understand our sports turf sprayer because that is pretty much a small agricultural spraying machine, but an awful lot of our other equipment is bespoke…you’d have to tell them how it works for them to test it”. Prompted on CDA applicators, Contr5 find these useful where access to water is an issue, but generally this equipment is not used either as operators work remotely from their vans, inconvenient if the spinner stops, or “the cost of the chemical…and there’s a tendency to overdose with (a CDA)”.


Regarding the construction of stores, “you can get an awful lot from BASIS, and there is a guidance note from the HSE, a small black and white technical bulletin”. Contr5 identified that stores need to be neatly bunded and capable of holding 110% or 150% of the stored volume of pesticides. Glyphosate was mainly stored, along with some very small amounts of insecticides for leatherjacket control. Prompted, Contr5 identified that the store must be able to withstand fire for 30 minutes and that the roof should collapse in to smother flames, and “and nearby drainage has got to be protected or sealed”.

Questioned about precautions used at filling, unprompted Contr5 stated, “we tell people to make sure you fill up in a sensible location…all guys have a spill kit”, including spill pads and bags for contaminated materials. Prompted, Contr5 have PPE, “the standard way is to half fill tanks, put the chemical in then fill to the top. For certain tank-mixes they tell you to mix in a different way, but for most of our situations we’re only putting one bottle in at a time”. All containers are triple rinsed, empty containers being crushed and sent for recycling. Quite a few bottles do not have seals, “one of the things that Syngenta has come out with”. Regarding pack sizes, 5 litres was deemed optimal by Contr5, sometimes 10 litre packs.

In terms of waste materials, any diluted spray materials are left in the sprayer, and tends to be used the next day. If they had to dispose of diluted product then it would go through a licensed waste disposal contractor, “but we’ve never had to do that”. All triple rinsed containers are crushed centrally at HQ, assembled in to blocks on pallets and removed by a specialist plastics recycling company, probably no more than twice per year, “when we’ve got a full load”.


Looking at what criteria used in deciding how to minimise the use of pesticides, Contr5 stated this is not something that their organisation often gets to consider as the client has often already made the decision to treat with a chemical and Contr5’s organisation is commissioned to apply. Probing further, “In recent years we’ve started to use more adjuvants to reduce products rates and our use of chemical” and later in the interview, Contr5’s organisation first started using adjuvants to “minimise drift and increase rainfastness”, only more recently have they been prompted to use lower chemical rates and are finding that these work, “even a low dose glyphosate is more effective than a hot foamer or a burner or a weed ripper brush”.

In terms of drivers for using chemicals versus non-chemical approaches, Contr5 stated that the organisation’s policy, chemical treatment was more effective, lower costs of chemical treatments, and longer lasting effects, and that chemical treatments offered the most practical approach to vegetation control. Asked to consider what might change or influence the use of non-chemical approaches, Contr5 believes that even though Local Authorities would like to move more to non-chemical methods, especially with budget cuts, the reality is that they cannot, “chemical weed control is cost effective, the cheapest way of doing this…sweeping streets is more expensive”. Asked if Contr5’s organisation ever considered non-chemical methods of vegetation control, the answer given was <Sometimes>, “often the client has already decided pesticides must be used”.

Regarding the use of non-chemical approach, Contr5 said of biological controls, “I’ve looked at it a lot but I don’t think it’s anything feasible for any of our markets” and of disease resistant stock, whilst this is not used “it’s a shame, all those things that agriculture can use, quite often they’re not available to us”.

Contr5 has used hot water, rather than steam, “100 degrees C…you don’t have to expend as much energy (as steam)” for weed control on hard surfaces. In terms of cost, Contr5 believes that “this approach can cost up to 10 times more than a chemical treatment” and works best with annual weeds (perennial weeds tending to regrow from the root stock as they did after paraquat treatment) and on weeds growing through a porous surface than paving slabs.

• Burning – restricted to burning Giant Hogweed, especially seed heads in late season, and Japanese knotweed stems.

• Cutting and strimming – Himalayan balsam is cut initially • Hand-weeding – mostly domestic jobs, mostly for shallow-rooting balsam, providing no seeds are

present as these quickly spread everywhere.


Case Study Contr6

Contr6 originally focused on agricultural crop spraying but now works exclusively on the amenity sector, through sports turf, including golf courses, footpaths, driveways, car parks, areas adjacent to water, exercise areas for horses, Christmas trees, and weed control for a major facility including roads, under pipework and alongside an extensive network of active ditches.



• Control of invasive (non-native) plant species – Over the past half-dozen years, Contr6 has become experienced in dealing with Japanese knotweed, starting with a small infestation in a lake to one recently which had grown to seven metres and needed to be tackled with a telemast; “We’ve had odd situations where the local council or highways (authority) have informed landowners that they’ve a problem…it’s usually after the local guy has chucked it up with his verge cutter”.

• Health of domestic animals/ livestock – about the dog owning public, Contr6 identified the need to be “very, very aware of them” and the potential to harm people, or dogs off leashes and livestock near footpaths.

• Protection of fisheries/ angling interests – Scored highly as the local area to Contr6 has “quite a lot of very, very well-known and well fished rivers and overall fishermen actually know quite a lot about what shouldn’t be going in to the water”. Contr6 highlighted the need for risk assessments for all work alongside rivers and the need to say no to clients on occasions, “If you want your Rhodys down get a chainsaw out….rather than being bullied into doing other things”.

Regarding knowledge of the 2006 Code of Practice for using PPP, Contr6 rated their knowledge as <Fair>. Challenged why Contr6 thought it was not better, “There is a huge lack of regular updating…the business of earning X amounts of points per year in order to keep your licence…it’s a box ticker. There’s something stronger and more effective I think (that) needs putting in. I’ve seen farmers – I actually reported one- who was sucking water straight into their sprayer, straight from the bairn, I mean that’s just criminal”.

Contr6’s organisation is a member of NRoSO and use Lantra for training, “I have an envelope in my budget for training…and I either go with them (employees) just to keep the freshness of learning and keeping up to date”. Contr6 is “very familiar” with BASIS and BACCS but is not registered, nor is their organisation part of Amenity Assured.

Within Contr6’s local organisation, of the 2 plus 4 seasonal FTE staff, the number trained/qualified were as follows: BASIS qualified – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 4.5, NRoSO – 3, NASOR – 0, access to 2006 Codes of Practice – 1 (“they all operate through me and they’d get me to do the donkey work”), trained in 2006 Codes of Practice – 6, “our business has a pretty good reputation. Creating trust, you’ve got to xxxxxx well earn it and I think we did that by doing the job correctly”.


Unprompted about measures used to protect human health, Contr6 stated, key to protecting workers and the public is training, and “insistence that operations are carried out using the right equipment and wearing and using appropriate protective clothing”. Contr6’s organisation completes a risk assessment before any job is started, but stressed that this assessment needs to be on-going, if a “little old lady arrives giving her dachshund exercise, the job needs to stop and the little lady needs removing”. Contr6 also stressed awareness is important, “”does the football pitch have a footpath running along one edge…is there a tarmac road just on the other side of an 8 foot boarding that you can’t see?”, or avoiding spraying adjacent to public gardens at the weekend when most people are likely to garden is important.


Prompted for other steps taken to protect operator health or the public, Contr6 admitted that they did not think about health surveillance very much. Regarding use of signage, where there is possible access Contr6 uses a noticeboard with ‘spraying in progress’ sign. Contr6 felt getting the balance between informing the public versus unnecessarily drawing attention to an activity is important, “we get plenty of bad publicity because there’s a hell of a lot of ignorant thinking out there about chemicals so don’t necessarily attract attention to yourself”.

Areas where Contr6’s organisation is especially vigilant include the application of insecticides, “this last season we’ve had huge problems with aphids in Christmas trees…(Contr6 was advised to) put the vast majority through a mist sprayer and so you have an increased likelihood of drift”, putting not only the environment at risk but operators too.

Besides water and drains, unprompted Contr6 also identified the need for care when spraying hard surfaces with the attendant risk of run-off. Contr6 recalled seeing an employee from another local contractor company using a hand-held lance from inside a pickup truck to treat road gutters, “I appreciate glyphosate is a relatively safe product, but it’s the attitude towards it. They’re working under pressure those guys, they have to get so much done and that’s when things go wrong”.

Prompted, Contr6 stated extra care was needed when preparing risk assessments for work in SSSI’s. Regarding the weather, Contr6 commented “there’s no shortage of weather up here!” Awareness of product mobility was critical and if treating slopes, what was at the bottom of these? Weather is also a preoccupation for Contr6 (“part of my life is listening to the weather forecast at 5.30 and 6am”), from the point of view of financial constraints, “there’s no good putting weed control on if it’s going to get washed off within three minutes”.

In terms of which websites are consulted, unprompted Contr6 replied, “I use the internet a lot, but also two or three extremely experienced and reasonably long-serving agronomists”. In terms of websites, Contr6 uses those of the chemical companies; “I downloaded a great wodge of stuff recently from Belchim about the control of aphids in coniferous tree plantations”. Probing further, Contr6 revealed they never used the websites of the CRD, EA or Amenity Forum. Asked about any specific measures adopted to protect water, Contr6 said “keep away from it. That may sound slightly defeatist but that’s almost the only thing you can do”.


Contr6’s organisation uses a mixture of boom sprayers, ranging from self-propelled 24 metre types, a mist sprayer, and a smaller machine with a 1000 litre tank and an eight metre boom. Knapsack sprayers are also available but rarely used.

Asked about calibrating the equipment, Contr6 replied “testing is done once per year, usually in February when it is convenient. It’s MOTing”. Calibration of the self-propelled is done bimonthly, using a piece of land with distances marked out and travelling under field conditions, “we have machinery to measure what goes in to the tank as well as automatic set ups to measure what comes out again”.

Probing further about triggers for recalibration, Contr6 stated tyre wear (“we do quite a lot of roadwork getting to places”) and nozzle wear are the main focus; “the best way to keep aware is to double check as often as possible…”. Product types (liquids, powders, granules) are also a consideration, “(sulphur) comes out of a can as thick as mud….you consequently have to put more water in and dilute it more”. Asked about specific training for testing and calibrating equipment, Contr6 replied “I do most of it because this business is a proper MOT station for sprayers…the straightforward field calibration if you like, I pass the knowledge on”.

In terms of storage, Contr6’s organisation uses a 6.1m x 2.4m steel container, adapted with shelving as their chemical store. Asked about what specific advice was sought before purchasing the store, Contr6 replied the new store supplemented the chemical cabinets attached to the bowsers and was a cost effective, highly secure and sealable solution when the organisation started contract work for a large Christmas tree client; “they inspect contractors to make sure that everything is correct in the way we operate, how we store, how we handle, etc. So you could say I was given a nudge”. Asked what other considerations are important for a pesticide store, Contr6 replied, materials are logged in and out, correct lighting, appropriately bunded and has ease of access.

Probing further on the issue of fire resistance, Contr6 stated, “I’ve got big fire extinguishers in there with protective gear, there’s an automatic ventilation system”.


Questioned about precautions used at filling, unprompted Contr6 explained that their organisation used 10,000 litre bowsers, with secured chemical containers on the side, “The reason I like using bowsers is that we fill out of a bairn using the bowser’s pump then take the bowser to an appropriate hard standing…where the water and chemical are drawn. With the risk of spillage, either diluted or concentrated product, containing it is a much easier operation”. Contr6 does not like sprayers with their own pumps that can be used to draw water directly from bairns, “Technically it’s legal, I think it’s very, very bad”.

In terms of operators, Contr6 recommend that they wear appropriate PPE and try to avoid working under stress, “which is when accidents happen, like dropping containers”. Probing further about label instructions, Contr6 says all spray operators are encouraged to obtain information from the product label, and as the lead employee likes to point out issues for example, avoiding spray drift when using products containing glyphosate. Turning to pack size, Contr6 stated the optimum size container for their operation was 20 litres, “that’s about as big a container as I think we go to”. Chemical hoppers are “at an appropriate height suited for when they’re drawn out for filling” and in terms of rinsing, “we do that several times…we don’t just say three times, I mean some need a hell of a lot more cleaning than others”.

Questioned about surplus diluted product, Contr6’s organisation makes big efforts to mix an appropriate amount of chemical for the job. If surplus is left, then “We are very, very rarely putting on chemicals that cannot be run out on the field” Regarding record keeping, if 4 litres is drawn from a container of concentrate, the bottle is marked with a felt tip and if any complete container is not to be used again that season it is returned to the supplier.

In terms of waste containers, these are burned under special permission. Contr6’s organisation has looked at professional waste disposal, but “if I can do something on my business that I’m allowed to do and it doesn’t cost anything, other than a box of matches, then I think that’s sensible”.


Asked what criteria are used to decide whether or not to use a pesticide, Contr6 volunteered their experiences with an organic producer several years ago when the organisation was required to apply copper, sulphur, garlic and other products many times during the season as their effects did not last long, “I’m aware there are other systems, but I’m also aware that a carefully applied chemical product will do a lot less harm generally to the environment than a non-chemical application”.

Probing further about how much the respondent really gets involved in identifying the problem before deciding what to do, Contr6 replied “We don’t do anything illegal…but a lot of time we are applying products at levels that are miniscule (compared to agriculture)”. Contr6 does try and use the advice of qualified advisors to guide them on the use of chemicals, “But they don’t necessarily know a hell of a lot more about it than we do, just simply because the research has never been done” and later admitted to doing their own testing, “We’ll take out a plot, say an acre, and then double dose it (on Christmas trees) to see what the effect is”.

In terms of drivers for using chemicals versus non-chemical approaches, Contr6 commented that the only disasters they had ever experienced in a previous life using sulphuric acid for potato desiccation were when he had observed short cuts being taken, “If you apply that theory to all chemical applications they’re very, very safe, along with the fact that they are pretty effective overall, providing that you use the right chemical in the right situation, pre-empted by the expertise of the agronomist or whoever”. Probing further, Contr6 believes that the reason non-chemical approaches are not more popular because “A lot of other avenues are more expensive…”

Asked how often his organisation would consider using non-chemical approaches, Contr6 stated <Sometimes>.

Regarding the use of non-chemical approach, Contr6 identified cutting/strimming, grazing, correct fertiliser application and drainage as the main non-chemical approaches. Of these strimming and topping weeds of grassland paddocks was the most frequently used alternative to chemical weed control.


Case Study Contr7

Contr7’s organisation is a contractor and consultant specialising in the control of Japanese knotweed in amenity grass, forestry/woodland, trees/shrubs (at times), riparian areas, gravel/ballast surfaces, pavements/curbs (at times), roads (general weeds), and domestic gardens.



• Protection of infrastructure – “The vast majority of our clients are construction firms” and their primary objective is to protect areas of hard standing and structures from damage caused by Japanese knotweed.

• Control of invasive (non-native) plants – “Because we are specialist in invasive species, predominately Japanese knotweed, Giant Hogweed and Himalayan Balsam”.

• Legal requirements – Contr7 cited the Weed Act as the main driver here.

Regarding knowledge of the 2006 Code of Practice for using PPP, Contr7 rated their knowledge as <Fair>. Probing further, Contr7 stated “We tend to be quite niche in what we do although we are using products in a range of different scenarios we tend to be always be treating the same species via the same methodology so we are a little bit, I suppose to a degree, stuck in our ways …which means our wider understanding of things like the Code isn’t perhaps, at times, as good as it should be”.

Contr7’s organisation is a member of BASIS, BACCS, NRoSO, INNSAP, “It is relevant to our sector and, because we are working in the construction marketplace quite a lot, we have various accreditations relevant to that, things like CHAS”. Contr7 was aware but not a member of Amenity Assured, to the best of their knowledge.

Within Contr7’s local organisation, of the 19 FTE, the number trained/qualified were as follows: BASIS qualified – 4, BASIS register – 3, BASIS Power – 0, BASIS storekeeper – 0 (“As we do not keep herbicides on the premises we were told it was not necessary”), BETA – 0, NPTC – 10 (the balance of staff are administrative), NRoSO – 1, NASOR – 0, access to 2006 Codes of Practice – 19 (“It’s kept in the office. We have a library, a few bookshelves where we have all important generic documents… like the Environment Agency Code of Practice for dealing with Japanese Knotweed and other herbicide information”), trained in 2006 Codes of Practice – 10. Regarding training, Contr7’s organisation does monthly brain-storming sessions that “give people a chance to talk about particular events within the company and ways to move things forward and additional training courses”. BASIS qualified staff are used to develop the organisation’s policies, checking recommendations (“I tend to brief the teams on the work”), tender preparation and evaluation. Protecting Human Health and the Environment

Unprompted to the question about protecting human health, Contr7 stated “it depends on a site by site basis but usually infestations would be fenced off during spraying and appropriately signed and where necessary we’d have banks men in place as well. In terms of protecting the workforce obviously not only do they have the relevant qualifications the obviously have the relevant PPE for doing the task”. In terms of other steps, Contr7 indicated that all method and risk assessments are done prior to the work starting, and all “documents have to be signed off by the individual actually undertaking the works” to say that they have read and understood the information provided. LERAPs are also completed by spray operators if required.

Prompted for other steps taken to protect operator health or the public, Contr7 stated that operatives take extra care when spraying next to a public footpath and will consider stem injection when faced with treating plants above head height.

Unprompted, Contr7 believes areas of high risk when using a pesticide include water, and being extremely careful about preserving plants “if we’re working in or near a triple SI or some site of some conservation status or even if it’s just an area is heavily wooded or maybe.…a person’s garden”.


Prompted, Contr7 stated they rarely apply products near to drains but if they did would use a cover when applying via a sprayer, “We also did a project amongst a badger set. We were supervised by the Ecologist and we covered the holes with plastic sheeting to avoid chemical drifting down into the set, after seeking advice English Nature”. Considering slopes, Contr7 pointed out that from the operative’s view spraying was more dangerous here than on the flat and that even in the right spray conditions the general public could be more exposed to drift. Asked about situations where the weather might produce a higher risk, Contr7 stated “obviously if it rained afterwards there’s a higher risk of herbicides entering a nearby water course…but probably not for members of the public and operatives, apart from if the ground’s slippy”. In terms of the environment other areas where Contr7’s organization would be more vigilant would be near waste water treatment plants; “We are obviously restricted when applying herbicides within waste water facilities, and you’re only usually only allowed to use a form of glyphosate. Obviously they could directly get into the watercourse quite quickly”.

In terms of which websites are consulted, unprompted Contr7 replied, “We’d probably turn to HSE website at first. We obviously do COSHH assessments and everything, look at the data sheets of the product and there’s the green book isn’t’ there which has got all registered herbicides which you are able to use within it. However, that does go out of date quite quickly so we tend to check with the CRD”. In terms of websites, Contr7 had heard of the EA ‘What’s in your Backyard’, “I think I came across it on Countryfile” but had not visited this nor the Amenity Assured site. As a small business, “our chemical suppliers tend to update us to be honest, the vast majority of time on what’s new, what we might like to use, what’s going to go out of use, you know new methods of applying it, different equipment, things like that, so they probably keep us up-to-date more than we do ourselves really”. Finally, in regard to specific measures taken to protect water, Contr7’s organisation obtain all necessary approvals from either the EA or SEPA when applying herbicides anywhere near water, “as a company, (we) keep to a 10 metre buffer zone on all watercourses in terms of using Picloram. I know you can in certain circumstances go a lot closer, but as a firm we don’t, just because we don’t like it really, we don’t want anything leaching or drifting into any particular watercourses”.


Contr7’s organisation uses mostly knapsack sprayers and chemical injection guns. Operatives are required to calibrate equipment before starting the operation. Regarding repairing equipment, “The vehicles have lots of different nozzles and spares and different lance lengths and things like that for doing particular different jobs, then we just replace them every time they get broke and have a couple of spares in the vehicle”. Contr7’s organisation tends not to use hollow cone nozzles only a deflector type. As they are treating the same plant species year round the only major challenge is dealing with plants ranging in size from seedlings (in May) to ones 2.5 meters tall (in July), “If that’s the case then you need to change the way you actually apply herbicide to the plant”.

All operatives are NPTC trained, but the foreman will take overall responsibility for the vehicle and any equipment. If something is not working this will be identified and either fixed or the Operations Manager will procure a new lance, etc.

In terms of storage, as indicated earlier Contr7’s organisation purchases product as required and does not store materials on any of their premises. This section of the survey was therefore omitted.

Questioned about precautions used at filling, unprompted Contr7 explained operatives “have to comply with the product guidelines, regulations, which are obviously on the product label as standard. They fill up the knapsacks in drip trays so that any spillage is contained within that tray and it can be dealt with at a later date if it occurs. I’d probably be lying if I said there’s never a spillage but they are pretty careful and we hardly ever, ever, have any spillages or anything like that”. Probing further, Contr7 stated that all vehicles have the relevant spill kits at all times. Asked how they avoid contaminating water supplies, Contr7 stated that operatives tend to fill on an area of hard-standing away from watercourses and drains, and use “water drawn from a water tank or bowser housed in the vehicle with a hose attached to it”. Spray tanks are half filled before adding chemical then filled to the required level.

Contr7’s organisation prefers using 5 litre containers, “We find that traditionally two men spraying all day will use one container”. Tank-mixing is rarer than in the past as most modern glyphosate formulations include adjuvants; “Something we’re looking at potentially next year is water softeners”. Prompted about measuring and rinsing, Contr7 stated product is measured using a jug and empty containers, caps and seals are triple rinsed before being disposed of via the product supplier.


Questioned about disposal of containers, Contr7 replied that disposal via the supplier was the “Easiest thing to do and the most cost effective. You can’t exactly incinerate them can you so you are stuck with them unless you go back to your manufacturer”. Any diluted product left in the spray tank is moved to the next site in the back of the vehicle and any left over after the day’s work is applied “over the treatment area providing the maximum dose isn’t exceeded, etc.”


Asked what criteria are used to decide whether or not to use a pesticide, Contr7 stated “It’s usually the client’s requirements for the site”. If a client wants to build in three months’ time this is insufficient to eradicate Japanese knotweed so a spray is applied to reduce the viability of the plant, “we would then implement a non-chemical strategy moving forward from there. So for example we might excavate and bury the material on site, or might move it to landfill or we might retain it on site in a bund or something like that. We always look at alternative options, however, if a client is not building on top of the land, the most cost effective way for actually achieving eradications of the species Japanese Knotweed, Giant Hogweed and Himalayan Balsam is to actually to apply a product”. Asked about specialist external advice, Contr7 replied, “Well there’s nobody really, apart from the Environment Agency, to seek further advice from on different methodologies”.

Asked what steps are taken to reduce the amount of pesticide used Contr7 again replied clients tend to dictate the criteria, “they might say ‘we’ve had it sprayed by somebody else or we don’t we want you to spray it we just want you to dig it out and remove it from site or bury it over here for example, that’s all we want you do’. They may dictate the criteria for the treatment but obviously that criteria will have to be put together by either them internally or by another specialist consultant or obviously I will then advise them to say ‘hang on a minute chaps I think you need to do x, y and z first’. It’s a mixture really.” Contr7’s organisation tend to adapt their approach according to the size of the knotweed (below two meters in height) or the proximity of valuable plants, using stem injection in gardens for example.

In terms of drivers for using chemicals versus non-chemical approaches, Contr7 commented that for Japanese knotweed “herbicides are often the most practical solution for our clients and perhaps our marketplace. There’s always an element of chemical control involved. The Environment Agency Code of Practice actually recommends that you apply herbicide prior to doing something else with it because it will reduce the viability of the plant and therefore if you’re moving materials around site containing invasive species, they are less likely, in the event of a spillage, to regenerate if it had herbicide applied than if it hadn’t”.

Challenged on the response that chemical costs are cheaper than non-chemical approaches, Contr7 replied, “You could for example spray a strand of Japanese knotweed over twelve months for your eradication and it costs in the region of £2,000 but for the same strand of Japanese knotweed if they (developers) want to develop it instantly it could cost £10-£12,000 to bury it on site”. Contr7 also rated chemical treatment as more environmentally friendly (score of 3), “…because although you may think that applying herbicides isn’t’ the most environmentally friendly way, digging a load of material off to licensed landfill surely must have a bigger carbon footprint than applying herbicides”.

Asked how often his organisation would consider using non-chemical approaches, Contr7 stated <Always>.

Regarding the use of non-chemical approach, Contr7 identified those most used frequently as hand-weeding of Himalayan balsam, followed by strimming of balsam. Burning would normally take place in November to facilitate further treatment of Japanese knotweed next year, “If you’ve got a dense stand you would cut clear and incinerate all the surface growth so you’ve got a level playing field for next year. Obviously you wouldn’t incinerate the surface growth if it’s had herbicide applied to it previously because you don’t want the herbicides being released into the atmosphere”. Contr7’s organisation had also considered steam but felt that this would not work effectively.


Case Study Contr8

Contr8’s organisation is a contractor specialising in vegetation control on the railways and associated surfaces, including riparian areas, gravel/ ballast surfaces, pavements/kerbs, roads and other hard surfaces.



• Protection of infrastructure – “With the renaissance of the rail industry, various train operating companies, Network Rail, are opening up new depots”, or recommisioning ones that have been mothballed. The presence of weeds can also affect track width, undermine bridges, etc.

• Control of invasive (non-native) plant species – Removal of Buddleia and Japanese knotweed are high priorities.

• Public safety and/or possible litigation – Clearance of Japanese knotweed and Giant Hogweed from public footpaths.

• Drainage/ flood control – “Too much vegetation on a railway line will affect drainage...so that’s another factor why it’s (lines) are always kept clear”

• Legal requirements – Respondent considering knotweed and ragwort here. • Safety of rail staff – Embraces maintenance staff, the safety of drivers walking along sidings to

their trains, “The shunter who is shunting trains, he’s pulling the points over and all he needs to do is trip on some vegetation, fall under a train”, and vegetation can conceal whether the points have been set properly with potential dire consequences to all rail travellers.

Regarding knowledge of the 2006 Code of Practice for using PPP, Contr8 rated their knowledge as <Very Good> and immediately produced a copy.

Contr8’s organisation has put all their spray staff through NPTC courses, but was otherwise not a member of any of the listed associations. They are involved in Achilles-Link-up, a community that audits suppliers to the UK rail industry, which for Contr8’s organisation includes COSHH and pesticide records (areas treated, reason for treatment, equipment used, product, dose volume, tank-size, etc.).

Within Contr8’s local organisation, of the 4 FTE, the number trained/qualified were as follows: BASIS qualified – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 4 (PA1, PA2, PA6), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 4; trained in 2006 Codes of Practice – 4. Contr8’s organisation defer to their BASIS qualified supplier for advice on pesticide policy setting, making and checking recommendations and tender preparation staff. Protecting Human Health and the Environment

Unprompted about measures to protect human health, Contr8 listed in addition to COSHH “Method statements are drawn up before the work is undertaken. Risk assessments are undertaken and PPE provided to all staff. We do health monitoring which also covers vibration”. Prompted about the use of signage, Contr8 replied “We obviously inform the depot manager that we will be here on a particular date” and they in turn inform staff, but no formal signage is deployed.

Asked for situations where extra vigilance is required when using pesticides, Contr8 volunteered watercourses, “If we have a watercourse nearby I carry out a survey, then might adjust the type of chemical I was going to use. I’d have a buffer zone and if I had intended to use a residual I would probably change that to Roundup which is friendlier to aquatic life”. Contr8 then went on to say that stem injection was the preferred approach for Japanese knotweed adjacent to water.

Probing further, Contr8 also identified taking care near boundary fences, “there could be a SSSI on the other side...they might have newts and things like that”. Prompting, Contr8 said that for safety reasons extended lances were used on steep slopes and that always avoided spraying when it rained or blowing a gale. Buffer zones were also created around drains which were likely to go directly to a watercourse.


Asked where they would go if presented with an unfamiliar situation or difficult to control weed, Contr8 always refers to their BASIS registered supplier, “I had a big problem with mare’s tail and glyphosate and Tordon didn’t have much effect…(supplier suggested Tribute). So once I got the information, I never use anything until I’ve got the datasheet and we have done a COSHH assessment, I used it and it was absolutely brilliant”. Contr8 also admitted to ‘experimenting’ with combinations of products with the permission of the depot manager. In terms of which websites are consulted, prompted Contr8 replied that they used the CRD website, “You need to consult it now and again don’t you?” but had not heard of the EA’s ‘What’s in your backyard?’ nor the Amenity Forum websites. Application Equipment and Pesticide Storage

Contr8’s organisation uses knapsack sprayers alongside a 4x4 and ATV mounted boom sprayer. Unprompted, Contr8 stated that knapsacks are checked and calibrated daily, “If they don’t do that you’re not going to get the quality”. Contr8 pointed out that being plastic the spray nozzles are most vulnerable to damage, “I do quality checks on my staff and I went to one site and I could see from almost 100 metres away that one of them had a damaged nozzle”.

Boom sprayers are checked four or five times a season, dictated by the task, “I mean you might use different products as well so it depends on what area you are using…your has got to be altered (as well)”. Machinery is also calibrated after maintenance as well, “One of the things with Link-up is that I have to demonstrate service intervals, so they are normally serviced at the beginning of the season and then tested”. Through their NPTC training, all staff is considered proficient in being able to calibrate equipment.

In terms of storage, Contr8’s organisation uses a double locked and bunded metal cabinet to store pesticides. Contr8’s organisation keeps meticulous inventory records (shown to the interviewer) for the store and extending to strict records of product used during the course of each job.

Questioned about precautions used at filling, unprompted Contr8 explained operatives “will be wearing a face shield, sprayer suit, apron and gloves. The area where they are filling is not hopefully near watercourses and we also carry spill kits. So full PPE whilst decanting and mixing”. Prompted about matching the container size to the task, Contr8 stated “I measure up by Google earth. From that I know how many litres of how many hectares I’ve got and I know the dose rate from that”. Prompting further on rinsing, “we triple rinse on site and it’s (container) not taken off site until it’s been triple rinsed”. Each employee is responsible for filling, mixing and cleaning their own sprayer.

Unprompted, Contr8 stated that containers were “brought back and placed in large plastic bags” and disposed of via a professional recycling company. The Link-up scheme requires a full audit trail, including waste disposal, “What I am saying is that Network Rail have covered everything”.


Asked what criteria are used to decide whether or not to use a pesticide, Contr8 stated one of the factors was the timescale for each job, “We can strim everything down but how long would that last? There are also the weather conditions to consider. It would also be the client’s choice and best practice as well”.

Prompted whether the respondent ever thought about using alternatives to herbicides for vegetation control, Contr8 replied, “Unfortunately there isn’t, you haven’t got that choice”, and then went on to explain that the principal clients requires safe running of the trains, “It’s a health and safety issue”. Whilst the cost is important to clients, complete weed control is their main objective. Residual herbicides are proven and a mainstay because “the residual effect we’re trying to get is at least as much as five to six months. We know after that it’s going to come up again”.

Probing further about alternatives, Contr8 stated, “If there was something that came out I would be one of the first to say to my client, ‘look we can do this’ because I know they would embrace it because of the safety of their staff”. Contr8 then went on to say, “If the EU came up with a total ban on chemicals then the railway industry would grind to a halt”.



Regarding the use of non-chemical approach, Contr8 identified those most used frequently as cutting/strimming/mowing. Hand-weeding and brushing were not considered practical options and although improved drainage was identified as something that could reduce weed growth, Contr8 replied, “That is beyond our sphere because that would affect the infrastructure of the client”.

Due to a technical problem with the equipment, verb atim responses from the last two interviews were not recorded. The responses summarised below t herefore reflect information recorded by hand on the Topic Guides.

Case Study Contr9

Contr9’s organisation is a contractor specialising in vegetation control around tree/shrub beds, riparian areas, gravel/ballast surfaces, and pavements/kerbs.



• Protection of infrastructure – when working to preserve older properties • Protection of nature conservation – e.g. bats in older properties • Conservation of native plant or animal species – ibid • Public safety and/or possible litigation – Contr9’s organisation always has a general awareness of

possible litigation • Health of domestic animals/livestock – especially when working near farm buildings • Protection of fisheries/angling interests • Legal requirements – general awareness of legal threats • Public concerns – ibid

Regarding knowledge of the 2006 Code of Practice for using PPP, Contr9 rated their knowledge as < Fair>.

Contr9’s organisation is not a member of any of the listed associations, but is a member of the National Register of Property Preservation Specialists.

Contr9’s organisation has one NPTC trained operative. No other training and qualifications were noted, but Contr9 was in possession of the 2006 Codes of Practice and had received training when completing NPTC certification.

Contr9’s organisation defer to their BASIS qualified supplier for advice on pesticide policy setting, making and checking recommendations and tender preparation staff.


Unprompted to the question about protecting human health, Contr9 listed the use of PPE and notices of operations (containing advice on emergency telephone numbers) and pre-isolating areas to be treated. Prompted, Contr9 replied that they also prepare COSHH assessments. Health surveillance has not been adopted.

Asked for situations where extra vigilance is required when using pesticides, Contr9 replied where there is lack of good access or space to operate.

Looking at measures used to protect the environment, unprompted Contr9 identified the following areas believed as high risk: Where public access is possible or where pyrethroids are to be used, and prompted, when spraying close to water or drains and near SSI’s or other conservation areas.

In terms of which websites are consulted where either pesticide use is restricted or the risk of use is greatest, unprompted Contr9 replied that they used manufacturer’s websites and when prompted confirmed that did not use the CRD, EA or Amenity Forum websites. Finally, specific measures taken to protect water, Contr9’s organisation avoid pyrethroids and are extra vigilant for spray drift.



Contr9’s organisation only uses knapsacks. Unprompted, Contr9 stated that these are fully checked and calibrated every six months. Probing further, Contr9 said that knapsacks are also calibrated after repair. All testing and calibration is done by a NPTC trained operative.

Contr9’s organisation stores small quantities of pesticides in a steel container. Without prompting, bunding was mentioned as important to prevent unwanted releases. Prompted, Contr9 also identified that stores must be fire resistant, bunding must not be compromised by exits/entrances, the store or where it stands must be roofed, there should be no water running through the bunded area and that the store must be locked against unauthorised access.

Questioned about precautions used at filling, unprompted Contr9 stated the need to wear appropriate PPE, avoid spillage and complete all operations within a bunded area. Prompted, Contr9 identified with all of the precautions used when filling application equipment (listed from the 2006 Codes of Practice).

Unprompted, Contr9 stated that containers were returned to the distributor, and considered this “A good solution”.


Asked what criteria are used to decide whether or not to use a pesticide, Contr9 stated that they did consider whether a pesticide was required or not before treating, alongside whether the financial loss, damage or visual effect of the problem outweighed the costs of using a pesticide. Contr9’s organisation consults with their suppliers and if they can “find a suitable alternative to pesticides we will use it” or select a pesticide that has least environmental impact. Contr9 also admitted to regularly using less than the manufacturer’s maximum dose rates.

Asked what factors most influenced the organisation’s decisions to use chemicals rather than non-chemical alternatives, Contr9 listed the following: the organisation’s policy, chemical treatments more effective and lower cost, chemical treatments give longer lasting effect and most practical method available, availability of chemical application equipment, always done that way, and on the advice of a consultant (or supplier).

Asked how often his organisation would consider using non-chemical approaches, Contr9 stated <Always>. Contr9 was open to using alternative methods, especially biologicals, but usually found the chemical approach was the best.

Regarding the use of non-chemical approach, Contr9 identified those most used frequently as: hand-weeding, cutting/strimming/mowing, brushing, burning, mulching, correct fertilizer application, drainage and biological control. With regards the latter, Contr9 could not recall any brand names.

Case Study Contr10

Contr10’s organisation is a contractor specialising in vegetation control for amenity turf, sports turf and riparian areas.



• Control of invasive (non-native) species – protection of the environment is the key to Contr10’s priorities.

• Protection of nature conservation – ibid • Conservation of native plant or animal species – ibid • Public safety and/or possible • Health of domestic animals/livestock • Protection of fisheries/angling interests • Drainage/ flood control • Quality of grass/ turf • Legal requirements


Regarding knowledge of the 2006 Code of Practice for using PPP, Contr10 rated their knowledge as <Very Good>.

Contr10’s organisation is a member of BACCS, BASIS and the Institute of Groundsmanship. They are considering joining NASOR. Contr10 commented, “The amenity sector is nothing like as well organised as agriculture”.

Within Contr10’s organisation, of the 2FTE, the number trained/qualified were as follows: BASIS qualified – 1, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 1 (PA1, PA2, PA6), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 1; trained in 2006 Codes of Practice – 1. Contr10’s organisation uses an in-house BASIS qualified person for the development of policies for pesticide use, making and checking recommendations, and tender.


Asked about protecting human health, unprompted Contr10 listed COSHH assessments, use of PPE and notice of spray operations. In addition, Contr10 identified common sense, vigilance and training as key elements. In terms of health surveillance, this is not done in Contr10’s organisation, because this “not relevant considering the chemistry of the products we are using”.

Asked about situations where extra vigilance is required when using pesticides, Contr10 replied where working near members of the public, but stressed that all situations should be approached the same way.

Looking at measures used to protect the environment, unprompted Contr10 identified avoidance of spraying near water, drains, SSI’s, in open parkland, on heavily sloped land, and where weather is not conducive, “If the risk is too high just don’t do it”.

In terms of which websites are consulted where either pesticide use is restricted or the risk of use is greatest, unprompted Contr10 identified using the EA ‘What’s in your backyard?’ When promoted, Contr10 has used manufacturer’s websites (printed labels are helpful) and CRD (for registration information). In addition, Contr10 always consults the client’s websites (“each Local Authority has their own policies and these vary a lot”) or English Heritage, for situations near their properties. Finally, asked what other specific measures are taken to protect water, Contr10 is licensed to work near water (“unlike some contractors”) and has completed a local environmental risk assessment training course relating to water. Application Equipment and Pesticide Storage

Contr10’s organisation mainly uses knapsacks. Unprompted, Contr10 stated these are usually calibrated at the beginning of the season, and then when moved to different locations or when there is a change of products and rates. Prompted, Contr10 added sprayers are calibrated after repair or maintenance and when purchased.

Regarding specific training, Contr10 stated that whilst the NPTC training should cover this, “In practice it is not so good”. Contr10 commented that the level of training of college students is not as good as it should be, “I am an assessor and trainer…I have to get it right”. Contr10 went on to say that local management is key, commenting that in some organisations there is a big variance in terms of quality across geographic areas.

Contr10’s organisation stores as little pesticide product as possible. Without prompting, bunding and not compromising this with exits/entrances was mentioned as important to prevent unwanted releases. Prompted, Contr10 also identified that stores must be fire resistant, that there should be no water running through the bunded area, that the store or where it stands should be roofed, and that the store must be locked against unauthorised access. As with a previous respondent, Contr10 noted that their organisation keeps a detailed inventory of stock movement.


Questioned about what precautions are used at filling, unprompted Contr10 stated the need to complete a risk assessment, to wear appropriate PPE, use of drip trays when filling, and above all else have the appropriate NPTC training. Prompted, Contr10 stated that reading the label was statutory, avoidance of contaminating water, use of spill kits, triple rinsing containers, and only mixing one product at a time. The same person mixes and sprays in Contr10’s organisation.

Unprompted, Contr10 stated that washed containers were bagged then removed by a licensed waste contractor, as this is considered not only a cost effective solution but a necessary legal requirement. Any spray washings are applied at the site of application. Minimising Pesticide use and Alternative approaches

Asked what criteria are used to decide whether or not to use a pesticide, unprompted Contr10 would first identify the problem then consider if there was another method of control, for example hand-weeding weeds from turf, before considering a pesticide. Prompted, Contr10 will also consider whether the financial loss associated with the problem outweighs the cost of a pesticide. Rarely using a residual herbicide, Contr10 is not normally concerned with damaging the area for any subsequent plantings. Whilst BASIS qualified, Contr10 will seek out third party advice if he is unsure what to do.

Commenting generally on alternative methods, Contr10 feels that flame throwers and boiling water treatments are just too costly. As for biological control approaches, these may ok in glasshouses, but Contr10 believes the results to be poor in the open. Control of Chafer grubs was mentioned.

Asked what factors most influenced the organisation’s decisions to use chemicals rather than non-chemical alternatives, Contr10 listed the following: lower cost of chemical treatments, chemical treatment was the most practical method available, and especially often the outcome from a site risk assessment.


Regarding the use of non-chemical approach, Contr10 identified those most used frequently as: brushing, soil aeration (but not directly for pest control), correct fertilizer application, drainage, biological control (occasionally though could not recall the names of products used), and use of disease resistant stock. Of these the correct use of fertilisers to improve plant nutrition was the most important, dictated either by the client or specific site constraints.

Case Study GreenK1

GreenK1 is the head green-keeper for a privately owned golf course, involved in the management, including the use of PPP applications, on a full range of amenity surface types: amenity grass, sports turf, forestry/ woodland, trees/shrub-beds, riparian areas, gravel/ballast surfaces, pavements/kerbs and roads, including a car park, and patio surfaces around the club-house and other buildings.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, GreenK1 indicated most influence coming from:

• Protection of nature conservation areas/ wildlife habitats – GreenK1 was concerned about the long-term impact of pesticides to the environment, “…how do they know they break down completely?

• Conservation of native plants/ animal species – “We are a parkland golf-course, with mature trees and shrubby areas” so tying back to the earlier point this respondent is concerned about the long-term impact of pesticides on plant species.

• Public safety and/or litigation – GreenK1 concerned about the threat of litigation, “People complain about the slightest thing”, and will, for example only spray early in the morning to avoid the public.

• Drainage/ flood control – GreenK1 will intervene culturally, physically or by spraying if weeds prevent drainage of any flood waters.


Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK1 rated their knowledge as <Fair>.

GreenK1’s organisation is not a member of any of the listed a member of all listed associations, but is an active member of the county-section of the Green-keepers Association. The latter provides a forum to discuss strategies to control particular weed, pests and diseases, both chemically and using alternative means.

Within GreenK1’s local organisation, of the 6 staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 5 (PA1x 5, PA2 X 5, PA6 x 5, PA6W X 1), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 6/6, trained in 2006 Codes of Practice – 5/6.

Within GreenK1’s organisation BASIS qualified personnel, mainly suppliers, are used for advice.


Unprompted and in answer to the question about measures to protect human health, GreenK1 stated, “We provide all of the necessary PPE for the particular material they are applying. We do not spray anything that is particularly noxious”. Signage is deployed to inform the public that spraying is taking place, and club staff inform members what is being sprayed.

Prompted about other steps to protect workers, GreenK1’s organisation keeps sickness records for all staff but do not have an occupational health scheme in place. COSHH assessments are in place for all activities.

GreenK1 pointed out that all spray operations tend to be either first thing in the morning or towards the end of the day, “at our quiet times, avoiding members of the public as much as possible”.

Without prompting, GreenK1 was unable to identify use of any specific measures used to protect the environment. GreenK1 avoids spraying over drains as these all flow into the lakes from which water is drawn for irrigating greens and fairways. Two public footpaths cross the course and signs are erected at all ends before spraying. Avoidance of poor weather conditions was noted earlier, and as GreenK1 noted here, “we only spray as a last resort”.

Regarding use of web-sites, GreenK1 identified the Green-keeper’s Association was “a really good place to seek advice. Although we are friendly competitors there is always someone that we can turn to for advice”. In addition to advice from suppliers, GreenK1 will occasionally go to manufacturer’s sites for help with completing COSHH assessments. Whilst aware that they existed, GreenK1 did not use the CRD, Amenity Forum or EA websites for information.


GreenK1’s organisation has a 600 litre tractor-mounted sprayer and two Cooper Pegler knapsack sprayers. The former is calibrated every 3-4 months, depending on use, the latter once per year. The tractor-mounted sprayer will be calibrated especially after iron applications to fairways as the gritty spray quality damages nozzles. Calibration is not done when moving equipment, unless the product is changed, and product quantities are rarely reduced below manufacturer’s approved rates, “This is a safe guard for us”, in the event a product fails.

With regards training, all staff has internal refresher training during the winter months or when there is snow on the ground. If there are changes in the regulations then a supplier will inform GreenK1 and they may get someone in to brief the team.

GreenK1’s organisation has two secured steel stores accessed from the top, which are “bunded to a point…Because everything is so readily available we keep very little in stock as this is like pounds sitting on the shelf”.


Questioned about precautions used at filling, unprompted GreenK1 stated the first thing to do would be to read the label, “so that you are applying the right thing and at the appropriate rate”. Next, would be to don the appropriate PPE, gloves, suit mask, eye protection, followed by “having the sprayer set to the right height to pour the chemical in or have a set of steps”. Opening the container, on a flat surface, so that it is “opened on a stable surface”, and open as close to the sprayer as possible so minimising the risk of spillage. Product is handled in the organisation’s yard, “on a hard surface away from water and if there is any spillage this is easier to contain”. Prompted, GreenK1 admitted that they had a closed transfer system on the sprayer, but this “tends not to be used as this is cumbersome”.

Once emptied, containers need to be rinsed out (prompted “three times”), and “rinsings put in the sprayer”. Prompted, GreenK1 stated they usually fill the container with fresh water half-way per rinse (“it is better to be safe than sorry”). The inner seal is put back in to the container and empty containers are stored along with other waste store ready to be taken away by a contractor. When prompted, GreenK1 stated that they always have a spill kit to hand, and water for the tank is drawn from the course irrigation system via a hose pipe clipped to the top of the sprayer, the irrigation system having a non-return valve at the point of exit.

Looking at mixing products, GreenK1 stated that this was done only rarely. Products would be added separately and if “I wasn’t sure we would have a little test and see if they separated when mixed”.

Looking at container size, “…manufacturers are getting better. It used to annoy me when the rate was 4 litres per hectare and the product was supplied in a 5 litre container”. GreenK1 went on to say, “When you look at the rates of use for agricultural products versus those used on amenity turf the rates are huge. And the difference in costs are horrendous…it is because the label is for amenity only”. Probing further GreenK1 admitted that it is tempting for green-keepers to use products with agricultural labels is great, as prices can differ by as much as 30% in some cases; “If I could save a third on everything I need to buy my boss would be a very happy man”. This respondent believes quite a few green-keepers would use agriculturally approved ‘equivalents’, “if they had the opportunity”.

Noted earlier, Greensmen (a waste disposal contractor) removes empty containers. Tank-washings may be sprayed over a waste area adjacent to the yard that is not in public use. Concentrates that are no longer required are removed by the disposal contractor but given GreenK1’s policy of buying as required, this situation rarely happens.


Unprompted, GreenK1 listed the criteria of whether to use a pesticide or not “depends on location, and the impact the problem would have on my golf course, and of course the cost, nothing is getting cheaper”. Probing further, weeds growing in heavy rough rarely get sprayed but would spray on greens or fairways, though GreenK1 went on to say, “if you get the pH of soil correct then you can tend to negate weed growth anyway”.

Prompted, GreenK1 stated it was of concern whether pesticides used could damage the treated area, “which is why we only every use the manufacturer’s rates so that we have recourse to go back to them”. GreenK1 noted some weed killers advise not to replant within six months, but again management practices can be adjusted to counter these restrictions. GreenK1 will seek advice as required, “I don’t know everything”. When asked about planning to use pesticides correctly, GreenK1 stated “look, we try to manage the situation culturally first. The ethos of a good green-keeper is to create something that is healthy, because if it (grass) is healthy you won’t have any problems”.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, GreenK1 identified amongst others the following key factors:

• Chemical treatment was the most practical method available: In situations like Fusarium on fine turf, GreenK1 believes eradication with a chemical is more effective than alternative “bug in a bottle” approaches.

• Availability of alternative products or techniques: noted earlier, as GreenK1 is not convinced that manufactured products are not harmful to the environment they would prefer to use cultural or natural products as a first choice


Asked how often the possibility of using non-chemical methods for vegetation control is considered, GreenK1 replied, “All the time. If I can mow or dig it out rather than spray I will do this every time”. From a cost benefit perspective, greens tend to be hand weeded, whereas “the 40 acres of heavy rough would definitely be sprayed”.

The most often used non-chemical approaches used by GreenK1 are:

• Aeration: “aeration, aeration, aeration, you can’t do enough aeration. Grass has to live in air and not a compacted environment”

• Fertiliser: Key to a healthy growing grass, to out compete weeds. • Disease resistant cultivars: “Grass seed breeders are always coming up with new varieties that

are resistant”. Over-seeding of greens takes place two or three times per year to reduce the prevalence of Poa annua.

• Brushing – “If we are not cutting or mowing, we go out with a 3 metre brush to knock the dew off the greens”, which otherwise creates a humid environment to promote fungal growth.

GreenK1 has also considered using burning the rough to aide weed control and regeneration; mulches are used around plant bedded areas and seaweed is applied a lot for its phytotonic effects.

Case Study GreenK2

GreenK2 is the head green-keeper for a privately owned golf course, involved in the management, including the use of PPP applications, on a limited range of amenity surface types: sports turf, footpaths and a car park.



• Public safety and/or possible litigation – “Need to consider possible risk of drift” near a heavily

used public footpath (locals and tourists) and a local campsite. “Nothing we use will affect anyone but we don’t want anybody to be worried about what we are doing”.

• Quality of grass/ turf – “If greens are not up standard then membership drops off...and there is less money available”.

• Disease control/ prevention – “A lot of Fusarium on the greens affects numbers (of players) for the following season”.

• Public concerns – “People are more likely to make a complaint to the local council if they see drift”.

Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK2 rated their knowledge as <Poor>; “I’ve not really looked into it (the Code)”.

GreenK2’s organisation is not a member of any of the listed associations.

Within GreenK2’s local organisation, there is only one person responsible for spraying (the respondent) and their qualifications were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 1 (PA1, PA2 and PA6), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 0 (interviewer sent respondent a copy of the Code after the interview), trained in 2006 Codes of Practice – 1 ( “no training since the certificates”).

Within GreenK2’s organisation BASIS qualified personnel, mainly suppliers, are used for advice; “We use very little pesticides, but if a new situation comes up or a different product is needed we talk to our supplier”.



Unprompted to the question about protecting human health, GreenK2 stated, “We provide all recommended PPE, and product is stored in a locked chemical store”. High winds are a problem locally leaving very few actual spraying days, “that’s why we use very little pesticide”. All spraying is done early in the morning to avoid the general public.

Prompted about other steps to protect workers, GreenK2’s organisation has COSHH assessments for all tasks on the course but do not have an occupational health scheme in place. Signage is used on the entrance to all public footpaths across the course.

GreenK2 stated they try and keep as far away as possible from golfers when spraying, and noted earlier will spray the highest footfall areas early, then work deeper inside the course when there are people about.

Without prompting, GreenK2 identified specific measures used to protect the environment, as avoidance of spraying during high winds, avoidance of water courses/ponds, “all rough areas we do not use any chemicals at all”. When prompted, GreenK2 avoids spraying over open drains (“these are in the rough where we do not spray”), or if there is a chance of surface run-off on greens due to rainfall.

Regarding use of web-sites, GreenK2 admitted using “the Pitch care forum to see what other golfers do”, but was not familiar with the CRD or EA websites and had not visited any manufacturer’s websites.


GreenK2’s organisation has a knapsack sprayer which is calibrated the day before it is planned for use. In an average year, GreenK2 sprays less than 10 days per year. A contract tractor-mounted sprayer is used on the fairways once per year and is calibrated immediately before use.

With regards training, the respondent had not received any follow-up/refresher training since securing their NPTC sprayer certificates.

GreenK2’s organisation has a secured steel cabinet (“about the size of an American fridge freezer”) with a drip tray inside a brick-built shed, which itself is locked. The cabinet is accessed via the front and has a drip tray in the bottom for spills but the tray is not deep enough to retain the volume of all stored pesticides.

Questioned about precautions used at filling, unprompted GreenK2 stated the first thing was to wear all appropriate PPE, then check the sprayer is clean and has no blockages (filters).

Prompted, GreenK2 stated “we have the safety data sheets for all the chemicals we use in an A4 binder stored in a separate cupboard to the chemicals and read off there rather than the actual label”. A closed transfer-system, whilst available, was not used on the tractor-mounted sprayer. Water is drawn via a simple hose from a mains water supply with no evidence of a non-return valve. Regarding container size, all products needs to be measured, “for knapsacks we need only a very little amount of product”. Around filling, all operations are done on a flat surface in the yard and the tractor-mounted sprayer is dropped so as to remove the need for steps when adding product. Containers are washed out once and tank-washings are disposed of “in a wild area behind the shed”. Products are never mixed. On the topic of managing spillage, GreenK2 stated “we do not have a spill kit”. Probing further about management of spilt product, GreenK2 stated “we would probably just wash it off”.

Regarding the disposal of containers, “Empty containers are bagged up and put into a wheelie bin in the club that the council takes away…” This was confirmed as general waste. As noted earlier, waste water is disposed of on a designated area.



Asked what criteria they would use in deciding whether or not to use a pesticide, GreenK2 stated, “if it was something we had not seen before we would probably contact (named supplier) and ask them what we could use”.

Prompted, GreenK2 stated “as a small club with very little money to spend we would always try and get away without using any chemical if at all possible”. For example, “In the middle of summer some weeds like Hogweed we will hand weed”. Probing about pesticide dose, GreenK2 will reduce dose rates of herbicides for daisy control during dry periods as he had observed yellowing of the turf. Noted earlier, GreenK2 would always resort to a qualified 3rd party if presented with an unfamiliar situation.


• Chemical treatment more effective than alternative options: “We only spray for daisies and we can treat all fairways in six hours. I cannot think of any other approach that is more effective than that”

• Lower costs of chemical treatments: The costs of two chemical sprays are far cheaper than “if were to hand weed the greens it would take three men on minimum wage”.

• Always done that way: Given a score of three, once a practice has been established and proven to work policy is rarely altered. For example, five years ago GreenK2 increased soil aeration and the use of verticut, virtually eliminating the need to use fungicides. For daisies, green are treated twice per year, tees and fairways once per year, and for leatherjackets greens are treated once per year. “We could not use any less (pesticides) than we are at the minute”.

• Lack of information on alternative products or techniques: “I don’t know about any alternatives for leatherjackets and there is only hand-weeding for the weeds”

Asked how often the possibility of using non-chemical methods for vegetation control is considered, GreenK2 replied, <Sometimes>, mainly as spraying is so limited.


• Strimming, mowing: “general mowing of the rough to keep weeds at bay…in our wild areas we tend to strim or cut them (weeds) out with a knife”

• Aerating: Greens are aerated 2-3 times in the summer then once per month in the winter • Hand-weeding: Generally for hog weed in the summer, removed rather than strimmed.

In addition, brushing is used by GreenK2 to remove dew from greens for disease prevention, and fertilisers are kept to a minimum “keep plant growth leaner you encourage bents and fescues” rather than softer Poa spp.

Case Study GreenK3

GreenK3 is the contract head green-keeper for a privately owned minor league football club involved in the preparation and management of the playing surface, with pesticide applications sub-contracted to a privately owned national contract management company under the authority of the respondent. The only area treated with amenity pesticides is sports turf.



• Public safety and/or possible litigation – GreenK3 has a duty of care primarily to the players and “it is down to me to ensure that they are nowhere near the pitch during spraying”

• Quality of grass/ turf – “The state of the grass must be as good as I can get it all of the time” both for the players and the general public who come to watch.

GreenK3 would like to pay more attention to disease control but the budget currently does not permit this.


Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK3 rated their knowledge as <Fair>; “I do not really need to know any more than I do” as spraying is sub-contracted.


Within GreenK3’s local organisation, whilst the respondent does not have any formal NPTC certification to spray they have applied pesticides in the past. The contract spray company staff are all BASIS registered and have contemporary NPTC certification (PA1, PA2 and PA6), and with a programme of annual refresher training. GreenK3 had a copy of the 2006 Codes of Practice in the office.

Within the tender document, GreenK3 provides a statement of works required and a budget, and the BASIS qualified contractor decides on the appropriate amenity pesticide regime.


Unprompted about measures used to protect human health, GreenK3 stated, “We only ever use on the pitch is a weed-killer or for worm control”. Signage is always present on the entrance to the pitch during spraying.

Prompted about other steps to protect workers, the spray contractor carries COSHH assessments for all works. GreenK3’s organisation does not have an occupational health scheme in place. At the request of GreenK3, the spray contractor “never sprays three days before or after a game, and would never spray if it was windy”.

Without prompting, GreenK3 identified specific measures used to protect the environment, as avoidance of spraying when it was windy, water ways, when the general public are around, and near people’s gardens; “it is common sense really”.

GreenK3 did not use websites for information on amenity pesticides, but was aware of the Chemicals Regulation Directorate’s site when prompted.


GreenK3 is not required to spray amenity pesticides, but unprompted stated they would calibrate at east annually and ideally before use. Whilst aware of PA1 and PA2 certification, GreenK3 stated he “had never needed it”.

GreenK3’s organisation had no need for a chemical store on site. Unprompted, GreenK3 believed a suitable store would be a locked container, with appropriate signage (“I have done a Hazchem course”). Prompted, GreenK3 thought the store should be of metal construction, capable of withstanding fire (though the duration was not known), and should be bunded, although GreenK3 had no specific knowledge of the recommended composition and characteristics of the bund.

Questioned about precautions used at filling, unprompted GreenK3 stated the first thing was to wear all appropriate PPE (“i.e. mask, gloves, disposable overalls, probably wellington boots and goggles”), then read the label to check rates, noting any specific precautions, and mixing as advised.

Prompted, GreenK3 stated the tank should be filled ensuring that a non-return valve is in place, though they noted “we haven’t got one here, and probably every other place they (the contractor) goes to doesn’t have one either”. A proper measuring container is required, and care must be taken to avoid spillage. Once the container is empty, it should be rinsed, “3 or 4 times I guess”. Asked about disposal, GreenK3 said that in the past these would have been burned, but now recognises that they should be collected and removed by a qualified contractor. If product was spilt, GreenK3 would apply some absorbent materials, shovel this up into a bag for disposal by a contractor.

Regarding the disposal of containers, these are managed in GreenK3’s organisation by the spray contractor.

Finally, asked whether the spray contractor always used products approved for amenity use, GreenK3 could not be 100% sure but trusted the company and more importantly the contractor to only buy from “Headland and Rigby-Taylor”.



Asked what criteria they would use in deciding whether or not to use a pesticide, GreenK3 stated, “during the summer maintenance if I spotted four or five plantain on the pitch I would just get a knife and cut them out”. If the problem was more extensive, GreenK3 would contact the contractor, describing the problem and whether the grass was fit to treat and ask them to come in as soon as possible.

Prompted about dose rates, GreenK3 recounted an experience where lower dose rates were discussed with the contractor but the results, probably due to the weather were poor; “look I take their advice on rates, at the end of the day I pay for them (the contractor) to do a job”. Worm control is problematic for GreenK3 especially as the choice of materials is now very limited; “last year we had to spray the grounds three times”.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, GreenK3 stated whilst “the budget is nearly always the deciding factor”, overall “chemical approaches are more cost effective”. From the list presented, key factors identified by GreenK3 were:

• Chemical treatment more effective than alternative options: “Only if there were one or two weeds out there would I consider a non-chemical approach”

• Chemical treatment was more environmentally friendly: “Yes, if done properly” • Lack of information on alternative products or techniques: Was a strong motivator for GreenK3 to

use chemical approaches, “I am just not aware of alternatives”. Probing further, GreenK3 believed defra should do more to promote alternative approaches.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, GreenK3 replied, <Never>; “I don’t really know too much about the alternative method and knowing what a spray costs me is a deciding factor. If they were more cost effective I might well consider but I don’t know”.


• Aeration – Verti-drained three times per year, and slit twice per month during the growing season, “You cannot aerate a pitch enough”.

• Hand-weeding – as required, but only if on a small scale.

Case Study GreenK4

GreenK4 is the contract head green-keeper for an independent golf club and an associated bowling green, with responsibility for the use of pesticides on amenity and sports grass, trees/shrub-beds, riparian areas, aquatic areas, pavements/kerbs, roads and car parks.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, GreenK4 gave pretty much ‘black and white’ replies, with almost all factors as essential (score of 5) or irrelevant (scored 1 for Local Authority policy, Health of domestic animals/livestock, and Public concerns). Probing further on individual factors:

• Protection of Infrastructure – “We spray Roundup around trees every spring…it saves us a lot of time when it comes to cutting and strimming, also paths around the clubhouse, infrastructure around the clubhouse”.

• Financial pressures: “The most economical way to maintain this golf course is actually using Roundup”

• Control of invasive (non-native) plant species – Japanese knotweed and Himalayan balsam are strimmed on the property (“we don’t spray as it is too expensive”). GreenK4 makes a conscious decision to strim near ponds, “where we’ve got wildlife”, including rare orchids, “where we have stopped cutting now because of it”.

• Drainage/flood control – Local flooding is common in the winter and GreenK4 avoids spraying and “…obviously any chemicals would go back in”.

• Disease control/prevention – GreenK4 only uses fungicides at the end of September when the problem is really bad, “We tend to do more now more aeration, a lot more sanding”. “It’s only recently I found out about Rhododendron’s relationship with oak. We do prune trees with any die back”.


Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK4 rated their knowledge as <Fair>; “A lot of it is common sense”.


Within GreenK4’s local organisation, of the 5 staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 5 (PA1x 5, PA2 X 5, PA6 x 3, PA6W X 1), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 5/5, trained in 2006

Codes of Practice – 5/5. “Everyone one of us has been to college to get qualifications in horticulture, turf and spraying”.

Within GreenK4’s organisation, BASIS qualified personnel, mainly suppliers, are used for advice; “We basically get the spraying qualifications and it just comes with experience then”.


Unprompted about measures to protect human health, GreenK4 stated, “The employees are all given the correct clothing (coveralls, gloves, masks, etc.) … if we do spray on the course we put a notice up (two) weeks in advance to say we are spraying and we put signs on the course…We close the course until 10 o’clock, we’ve done most the spraying, we’re well ahead before they come back on the course and they are advised then to wash their hands when they come in”.

Prompted about other steps to protect workers, GreenK4’s organisation has COSHH assessments and up until two years ago the company organised a medical, but this was stopped two years ago, “There’s no nasty chemicals that we do use anymore”.

As about specific measure adopted to protect the environment and water, noted earlier GreenK4 makes a conscious decision not to spray in the winter when the course gets flooded, which is common after heavy rainfall, “the river can rise twelve to fifteen feet in a day”. GreenK4 also avoids spraying near drains and the riverbanks, “There’s public access to the river…and an area for disabled as well. That’s why we leave the Japanese knotweed. The Water Board come up and spray the banks themselves”.

Asked where they would turn for advice if there any doubts about using a pesticide, GreenK4 replied that they would phone the company’s advisor; “They know the situation I’m in here with the water, and I ask them if it’s safe to use in waterways…we keep it down to a minimum. We’ve got our selective, we’ve got our total, which is Roundup, we’ve got a fungicide”.

This prompted a discussion, where GreenK4 revealed that the selective herbicide is applied over the whole course (fairways and greens) by a contractor, “They’re in at five o’clock in the morning. By 10 o’clock they’ve finished the whole course, where it would take us a couple of days to do it. It’s actually more cost effective because they can buy it so cheap compared to us, so they come in, they blitz it, they spray it once a year. That’s the only time we put a selective weed killer on it.”

Regarding use of web-sites, GreenK4 admitted only to referring to manufacturer’s websites, at the suggestion of their distributor.


GreenK4’s organisation only uses knapsack sprayers for pesticide applications. These are calibrated ‘regularly’; “It comes with experience we’ve used it (a knapsack sprayer) for 20 or 30 years. Every time we use them they get checked”. Prompted, GreenK4 equipment is overhauled in the winter and all work is done by “The three most experienced people because they’ve been doing it long enough”.

With regards training, GreenK4’s team review their activities including spraying every so often in-house. Special attention is paid when introducing a new chemical.

GreenK4’s organisation uses a signed, stand-alone steel cupboard that is secured with a special key. Records are kept of stock movement and product usage. Prompted, GreenK4 stated that the store had a concrete base, “For diesels we have a bund but not for the chemicals. I don’t buy large quantities because at the local Countrywide we can buy as little as 5 litres at a time so we don’t store it (Roundup)”. The cabinet is fire-resistant and away from any water.


Questioned about precautions used at filling, unprompted GreenK4 stated “Well there’s not a lot that can go wrong. We use funnels, we use gloves. We use the right protective clothing, we clear an area away from everything else so chemicals can be mixed without disturbance and that’s basically it really”.

Prompted, GreenK4 stated that “If it is a new product we check the label straight away and go through the COSHH sheets.” But for Roundup and other familiar products, “If it’s a product we’ve been using for years we don’t need to because we know the product so well”. GreenK4 uses a blue dye when spraying to see where they have been and to avoid overlapping and therefore over-dosing. Safety is a consideration when filling the sprayer and once triple rinsed, containers are punctured and disposed of. Products are never tank-mixed and spill kits are available in case of accidents.

Regarding the disposal of containers, these are taken a depot and from there collected by a specialist waste disposal contractor. Cost is the main policy driver; GreenK4’s organisation does not pay for this service due to the pattern of ownership of the golf-course. Any spray washings are disposed of at the site of application.


Talking generally, GreenK4 revealed that “We were encouraged to use garlic rather than carbendazim for worms but it didn’t really do a good job. I’m looking for alternatives… because obviously they’ve banned all worm killers off the market. Carbendazim is about the only thing left, but that will eventually go, so we have tried the garlic product”.

Asked what criteria they would use in deciding whether or not to use a pesticide, GreenK4 stated, “Presentation is obviously very important on a golf course. If we do get a weed problem, like daisies, it’s very, very bad. Daisies come so badly here that it looks unsightly so we do spray once a year for daisies and that’s basically it. Daisies come when the ground is more alkaline. If you could acidify the ground you probably wouldn’t get so many daisies but then what is the alternative?”

Prompting whether concerned about using a residual herbicide GreenK2 stated “I suppose we do yes, because if it does build up in the ground it could alter the pH of the ground, or change the condition of the grass for instance, it could change the grasses. That’s why we only spray once a year. We should be spraying twice a year for daisies with selectives. And also the price of it as well, it’s not cheap and with cutbacks these days. The golf industry is going through a bad time unfortunately”.

Asked whether manufacturer’s rates are always used GreenK4 admitted they mostly did, but “They may say you need three litres per hectare and I feel sometimes it’s too much and I may drop it down to two and a half litres. It all comes with experience”.


• Lower costs of chemical treatments: “Putting someone on the strimmer for days, it’s just not cost effective”.

• Always done that way: scored as 3, but “Coming back from my days in the 80’s I’ve cut chemicals down by half. When I first came here I think it was about £3,500 and I’m down now to £1,000”.

• Availability of alternative products or techniques: “Unfortunately the chemical companies send their reps round here, where the other alternative people we don’t tend to hear from them, so if there is alternative products out there I would love to hear about them. And if it is a little bit more expensive I would still use them”.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, GreenK4 replied, <Always>, “I’m not one for chemicals to be honest”.


The most often used non-chemical approaches used by GreenK4 are: hand-weeding, cutting/strimming and mowing, mulching of the roughs – “if you don’t mulch the roughs it tends to leave lines, it’s unsightly”, soil aeration – important to reduce fungal problems – correct fertilisation, and drainage, but mostly as the course is so flood-prone. Use of biologicals (garlic) was mentioned earlier, but the name could not be recalled.

Probing about the use of disease resistant grasses, GreenK4 inherited a lot of weed grasses 16 years ago and would like to start over, but it is not cost effective, “There is a product out there Rescue that will kill the rye grasses but again it’s very expensive and you’ve got to be brave because if you don’t put the right dose on you could lose the lot.”

Case Study GreenK5

GreenK5 is the head green-keeper for an independent golf club with responsibility for the use of pesticides on amenity grass, riparian areas, aquatic areas, gravel/ballast surfaces, pavements/kerbs, and roads.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, GreenK5 identified most with strategies that protect the environment, “Personally I think there's an overuse of pesticides, I think it’s become too easy. We’ve had it here in the past where we’ve probably gone over the top with pesticides, but by changing the cultural practices we’ve reduced pesticide use, by a significant amount. I think sometimes it’s just an easy option, a quick fix, as opposed to long-term with good management you can reduce the use of pesticides. I’ve been here since the late eighties, fungicides, they were probably spending £4,500-5,000 a year on fungicides because of the type of grasses they had in the greens, but over the last 10 years we’ve changed the grasses within the greens, they're disease resistant now and I would say over the last 10 years we’ve probably averaged under £200 a year on fungicides, just by changing the grasses”.

Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK5 rated their knowledge as <Fair>; “If I'm being totally honest I probably haven't read it since I was a student”.


Within GreenK5’s local organisation, of the 3 staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 1 (PA1x 1, PA2 X 1, PA6 x 1), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 1, trained in 2006 Codes of Practice – 1. Asked if they could access a copy of the 2006 Codes of Practice easily, GreenK5 replied, “I suppose I could, yeah. Are they issued every year or is that the last one?”

Within GreenK5’s organisation, no BASIS qualified personnel are involved in policy making and checking recommendations, but would be used for advice.


Unprompted to the question about protecting human health, GreenK5 stated, “We put information out on the course information board if we’re spraying. We try and spray first thing in the morning, so quite often the spraying is done before there is anybody out on the course anyway, particularly if it’s on the greens. I like it to have dried on the leaf or having been absorbed before we have 20/30 people walking over the greens”.

Prompted about other steps to protect workers, GreenK5’s organisation prepare COSHH assessments and issue PPE. Probing further about situations extra vigilance is required, GreenK5 replied “…if we had a problem with disease and there hasn’t been a window to spray and it’s just got to be done whenever we can, that might mean going out when there's members out on the course and spraying. That doesn't happen very often”.


Asked about specific measures adopted to protect the environment and water, GreenK5 replied that they consciously encourage vegetation near ponds containing great crested newts, “Personally I’d rather go out and strim it, not right down, maybe 4 inches than go in with a spray and leave bare ground, it’s nice to keep a little bit of vegetation there if we can”.

Probing further, GreenK5’s organisation has all but abandoned the use of selective herbicides which were common place on the fairways 8 to 10 years ago, “In the past every second year we probably used to go out and spray 40 acres of fairways but we don’t anymore unless there's a real need for it.. We might have wet areas on the fairways that are more prone to certain types of weeds and we’ll just spray that particular area, we won’t just go in willy-nilly and do a whole fairway for the sake of a couple of hundred square metres”.

If requiring advice, GreenK5 will turn to “the supplier I suppose. No, I’d talk to one of the (manufacturer) reps. They're BASIS qualified now a lot of the reps, they know the products. We have had dealings with the local authorities in the past, when we’ve been spraying ponds, we’ve had them in and they’ve given us advice, they’ve said things like spray a third this year, do it over three years instead of going in and doing 100% of it and it’s just informing them when we’re going to do it”. GreenK5 has not used any of the websites listed.

Finally, in terms of what other specific measures taken to protect water, GreenK5 replied that in the past ponds were cleared of all vegetation, but now “We have ponds across the other side, we’ve got a lot of bulrushes in them, but personally I quite like them there… in the past everything was strimmed down, but there's so much in it, with the newts and frogs”. Application Equipment and Pesticide Storage

GreenK5’s organisation uses a knapsack and a boom sprayer for pesticide applications, “With the boom sprayer I’ve been spraying the greens for so long now you’ve almost got it down to the last sort of 10-15 litres when you’ve done all the greens…If I was going to go out and do fairways and things like that I’d put a jug under the nozzles and calibrate, but if I'm only putting 600 litres in, I know exactly what's going on”. In summary, through experience GreenK5 would calibrate if doing the fairways, but not the greens unless, “If I was going to go up to a different rate (than the usual 500 litres per hectare), if it was 200 litres a hectare, straightaway I’d do it (calibrate)”.

Prompted, GreenK5 will also calibrate after repair or maintenance; ”The boom sprayer is set up pretty good, I know our greens are about 8,500 square metres, it’s 20 litres a hectare of fungicides, I know we can get away with around 18 litres of fungicide and so it must be pretty accurate. Like I say it’s too expensive not to have it right”.

Regarding calibrating the knapsack sprayers, GreenK5 agreed that that being used for spot treatments they probably got less attention than the boom sprayer, “Personally I think the tendency is to probably to overdo it or give them a little bit more just in case. Our policy, if we had a little bit of disease and I was going to go out and use the knapsack, I know the greens are 500 square metres say, I will mix up enough in the sprayer to do 500 square metres, I’ll do it one way and then I’ll do it the other way and if there's anything it will all go on the green”.

Finally, GreenK5 is responsible for calibrating equipment, but had not received any training since taking the NPTC certification training.

GreenK5’s organisation uses an approved metal chemical box for the storage of pesticides. Prompting, GreenK5 stated that the store is fire resistant, secured, but not situated within another building, and is away from water.

Questioned about precautions used at filling, unprompted GreenK5 stated “It’s just good practice that we were taught when we took the test (NPTC) really. Things like if we do fill with hosepipes we’ve got the thing to keep the hosepipe above the level, we’ve got anti-siphon on the taps. We do fill up from the ponds as well, the thing is self-filling”. Prompted, GreenK5 follows the approved label and the boom sprayer has a low filling, “chemical induction bowl on the side of the sprayer, so all the washings go straight back into the tank”


Regarding the disposal of containers, these are removed by a waste disposal contractor, “We just thought it would take a lot of the hassle out of everything really. We have a three year contract with them, they come and take the containers as and when, it’s just nice to have that bit of paper there. It puts the responsibility onto them really doesn't it? You get all the paperwork to say it’s been disposed of. I’ve been here 20 years, I think we’ve had somebody checking up once”.


Asked what criteria they would use in deciding whether or not to use a pesticide, GreenK5 stated, “If we were talking about fungicides and we had an outbreak of Fusarium on the greens, the first thing we’d do is go out and put a sulphate of iron down to harden the sward, that would be our best line of attack. Then we’re looking at the forecast, if we know there's a cold snap coming that generally kills it off as well. Good cultural practice, things like keeping the greens as dry as we can”.

Probing further about situations where there is simply no other alternative but to use a pesticide, GreenK5 replied “It does happen, but spraying is a last resort. I suppose disease and worms are the biggest problem we have here. Again with worms, we can go out with sulphate of iron and acidify the surface. That deters them. Again if you know you're going to have some cold weather they generally go deeper anyway”. Asked whether the appearance of the course was a deciding factor, GreenK5 replied “Personally I’ve never been one for colour, you play on grass, the colour is secondary, if the playing surface is good, that’s number one”, a reference to the use of sulphate of iron that effectively dyes the course green, “I mean it’s not a natural colour”.

GreenK5 was not concerned about the residual effects of herbicides, as glyphosate is only ever used “about shrub beds, pathways and things”. With regard to using label rates, GreenK5 stated they always used approved rates for fungicides or wormicides, “You go in at what's on the label I’ve always found, otherwise it might knock it back but it doesn't do the job”.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, not surprisingly given the attitude towards chemicals expressed earlier GreenK5 scored the majority of factors listed in Q21 as 1, little influence, “pesticides are a last resort”. Most concern was expressed about the general lack of information on alternative non-chemical approaches to plant protection products.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, GreenK5 replied, <Always>.

The most often used non-chemical approaches used by GreenK5 are: hand-weeding on the greens, strimming around trees in the spring to reduce the need to spray so frequently during the rest of the season, brushing, soil aeration is important for growth and disease suppression, as is drainage. Regarding use of biological control, GreenK5 had considered this approach for nematode control but had so far not done so, nor could he recall the brand.

“Most of it is good practice. It’s keeping things natural isn't it? I think if you keep things natural you're halfway there”.

Case Study GreenK6

GreenK6 is the head green-keeper for an independent golf club with responsibility for the use of pesticides on sports grass (mainly greens), shrub beds, riparian areas, gravel/ballast surfaces, and pavement/kerbs.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, GreenK6 identified most with:

• Strategies to minimise herbicide usage: “I will spray around our greens and the tees every other year rather than every year. The years in between we do have weeds on the tees in places and we put up with them for the fact that we don’t want to spray every year. That’s not a financial thing. A spraying operation is time consuming and we’re very short staffed. We call it our optimum staffing level, so any extra operation is taking away the opportunity to do a different job”.


• Protection of nature conservation areas/ Conservation of native plants or animal species – “We have huge amounts of wildflowers on the course, Campanulas and Violas and if we spray a surface we are going to hit some of them. The beauty of this golf course is it’s the wilds, we’re a moorland golf course, we don’t want to lose it do we. A lot of people play here because of the wildlife. The kites are only here because we have a good mouse and vole population, so it’s all related. I treat it as a SSSI”

Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK6 rated their knowledge as Poor; “I’m aware of its existence. I think I have read it at some stage but nothing’s rung any bells”.


Within GreenK6’s local organisation, of the 2 staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 2 (PA1x 2, PA2 X 1, PA6 x 2), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 2, trained in 2006 Codes of Practice – 2.

Within GreenK6’s organisation, no BASIS qualified personnel are involved in policy making and checking recommendations, but would be used for advice.


Unprompted about measures used to protect human health, GreenK6 stated they observed spraying conditions, going early morning when the wind tends to be lighter and when there is no one around on the course and “if there is anything that needs a warning about we warn the members that we’ve been spraying”. The principal concern is the use of ferrous sulphate – for disease resistance and durability – as this can interact with copper-faced golf clubs.

Sometimes clients challenge the safety of products but in general; “I think on the golf course if we were spraying intensively, if we were spraying a couple of times a week, like some golf courses do then the members would get concerned”.

Prompted about what other steps are taken to protect human health/the general public, GreenK6 indicated that PPE (masks, goggles, gloves, waterproofs and wellies) are always used, but he no longer prepares COSHH assessments, “I started off years ago doing it but it’s so repetitive and I didn’t feel it really necessary”. There is no health surveillance scheme for workers at this course.

About specific measures adopted to protect the environment and water, GreenK6 replied again “We treat the whole course as a SSSI and we are using anti-drift nozzles on every spray operation. We are very conscious of wind and such. Where there is water we allow 12 meters but in reality we don’t get anywhere near, our operations don’t go near ponds”. Most of the steep slopes are deep rough on this course. GreenK6’s organisation has invested in equipment with widened wheelbase and sprays these slopes every other year.

Probing around sources of advice, GreenK6 stated that tend to use the manufacturer’s technical advisor for information “…usually this is when we are looking at new products but I have this big thing, which is very frustrating for sales reps where I have a selection of products that I use, my key products, and I don’t go off them, unless I’ve got a good reason”.

Regarding the use of specific websites as sources of information, GreenK6 never uses the CRD site, has heard but not used the EA’s ‘What’s in my backyard?’, and had never heard of the Amenity Forum.

Finally, in terms of what other specific measures taken to protect water, GreenK6 mentioned earlier about giving their ponds a wide berth when spraying, “We abstract from ponds for irrigation but the ponds are just a wildlife haven really and a feature”.


GreenK6’s organisation uses a knapsack and a boom sprayer for pesticide applications. Asked about calibrating equipment GreenK6 stated “Well the knapsack, not very often because we use that for spot treatment and we like to think from experience we know when we’re using it right, you know. I never really think calibration comes into a knapsack, unless we were doing an area, which we don’t”.


For the boom sprayer, GreenK6 calibrates every four or five outings, “I mean calibration wise I know I’ll get a hectare out of a tank full on the most regular used nozzles. If there’s any difference I mean I’m going to know by the end of that tank”. Probing further, “When we put a selective weed killer down I’ll calibrate it then because that’s quite important so I mean it’s more timed with the products that we’re using”. Calibration is also done after repairs and if any advice is required, GreenK6 refers to the dealers.

GreenK6’s organisation has two old deep freezers, both compliant according to the local H&SE officers, one of which is used to store a limited quantity of pesticides, “You do tend to order a little bit ahead. We don’t keep huge quantities because you don’t need it nowadays”. The top-accessed freezer is housed within a roofed and walled shed with a floor set below the entrance, “that bund would contain a couple of hundred gallons at least. I wouldn’t like to test it”. Both the shed and freezer store are locked and away from water.

Asked about what precautions are used during filling, unprompted GreenK6 stated “…well we fill from a hose from a well, we don’t have mains water here, so we come off a collector from a little spring. The hoses have got a one-way valve. We fill the tank half full before we add any product”.

Prompted about reading label instructions, GreenK6 replied “I always check I have got the right product because all the bottles look alike nowadays”. With experience, GreenK6 knows that they have a hectare of greens to treat and as this is a full tank measurement is straightforward. Prompted about precautions taken during spraying, GreenK6 say that the sprayer is lowered to the ground during filling. After emptying pesticide containers, GreenK6 stated “We rinse all the bottles twice as the water is running, shake them, tip them in, two rinses. Our disposal contractor insists that bottles are clean”. Caps are replaced after cleaning.

Prompting further, products may be mixed at times, always following manufacturer’s instructions and a spill kit is available at all times.

Regarding the disposal of containers, these are removed by a waste disposal contractor and any spray washings are applied over the course. GreenK6 considered disposal of empty containers via a specialist contractor is the only option available, “I can’t dispose of product waste myself so who’s going to do it for me?”


Asked to think whether there was a legal obligation to consider means other than using plant protection products to control weeds, pests and disease, GreenK6 replied there was “A morale obligation. We do most of our control of pests, diseases and weeds culturally. To give the quality of service we want to present we still occasionally need to use a product”.

Prompted whether the financial implications of not controlling at all, or the expense to achieve control has any bearing on the decision to use a PPP, GreenK6 replied “Not now no. We have a budget for pesticides and fungicides and we never spend half of it…we have got money there to spend three times what we use”. Probing further about the quality of turf being one of the guiding goals, GreenK6 stated “I think appearance has changed over the last few years on golf courses. Where green and lush used to be the optimum for the golf course now brown and barren has taken over. We are looking at hard wearing grasses that look right with stress so I think the appearance of golf grasses has changed, in favour of less product”.

Challenged whether residual effects for other vegetation or next year were a concern, GreenK6 replied “Only with wildflowers”. GreenK6 is responsible for making these decisions. Asked whether this extended to using lower than recommended manufacturer’s rates, GreenK6 replied “I think with manufacturers there is a little bit of sell in it. Like I say, I know how a product is going to perform for me and I know now I can go three quarter rate with most things and get the performance manufacturers are claiming, every time”.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, GreenK6 tended to score all the factors listed as 1 or 2. It is the organisation’s policy to use PPP but only when warranted and only if they offer the most practical solution. GreenK6 disagreed strongly with the notion that chemical treatment was more environmentally friendly than non-chemical approaches and also considered that there was no lack of information on alternative products.


Asked how often the possibility of using non-chemical methods for weed control is considered before any decision to use herbicides is finalized, GreenK6 replied “(when) we’re working on the course we do hand weed a lot. Let’s say this year we sprayed a selective, so our tees and surrounds and greens are clear. As one weed pops up we will bend down with a screwdriver or a penknife and pull it out. That is our main form of weed control”.

Aside from hand-weeding, other non-chemical approaches used by GreenK6 are: cutting/strimming/mowing, brushing, soil aeration, correct fertiliser applications, drainage and use of disease resistant stock. Regarding the latter, GreenK6 seeds annually, but the strains used also offer other benefits than disease resistance per se.

Probing further on the use of biologicals, GreenK6 has used these, but not for some time, “We used the charcoal stuff once…I don’t think we actually gained anything. We use a lot of seaweed products at the moment, for the last 10 years as a biological stimulant which we are getting masses of success. Our soil life is absolutely crazy up here and we put that down to the use of seaweeds. In green keeping our turf is constantly stressed in the playing season so its stress management and we can only do that if we’ve got good health turf anyway”.

Case Study GreenK7

GreenK7 is the head green-keeper for an independent golf club with responsibility for the use of pesticides on sports grass (including bunkers), trees/shrub-beds, riparian areas, gravel/ballast surfaces, and pavement/kerbs (around the clubhouse).


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, GreenK7 scored most of the factors listed as 1 (little influence). The exceptions were not surprisingly, quality of grass/turf and survival of trees and shrubs.

On this course, financial constraints are not a major issue, “We do have budgets, but they're not too bad. If I need to do something I do it”. Keeping drains free of weeds was considered a priority, and GreenK7’s organisation hand-weed ragwort not because of Legal requirements, but because “It’s just something we do because it looks unsightly. I would get a couple of lads pulling it out because otherwise it gets mad”. Public concerns are something “We do keep an eye on obviously” but not an overriding influence.

Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK7 rated their knowledge as <Fair>; “No, it’s not that great. I mean I’ve got blokes that have been through college, done all the things, they're the ones that do the spraying”.

GreenK7 had not heard of BASIS nor was the organisation a member of this, nor BACCS, or any of the other organisations listed.

Within GreenK7’s local organisation, of the 9 FTE staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 2 (excluding “One of them has got it on grandfather’s rights”), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 3, trained in 2006 Codes of Practice – 2.

Within GreenK7’s organisation, no BASIS qualified personnel are involved in policy making and checking recommendations, all decisions being taken by the respondent.


Unprompted about measures used to protect human health, GreenK7 replied “I make sure everyone is wearing the right stuff, I can’t afford not to”.

Prompted, GreenK7 stated that the organisation prepares COSHH assessments, including monitoring the general health of workers. Signs are erected when spraying, and they “Just try and keep out the way of people”. Operators also spray early or late, “we have to go around when there are no golfers about”, but expressed frustration “You want it done and dusted. They (golfers) don’t like to see it, they're like ‘what's that?’ it might only be a wetting agent, but they always think it’s something harmful”.


About specific measures adopted to protect the environment and water, GreenK7 replied “The only place would be near water, anywhere else, it depends what you're using, I mean otherwise it would be your neighbour’s crops, you can get drift if you're spraying at the wrong time”.

Prompting for other situations, GreenK7 said that drains were not a concern, there were no SSI’s or other conservation areas to consider, but that operators had to be more careful on slopes or during uncertain weather conditions, “If it’s too windy or rainy or anything like that. We make sure we do things right because the stuff costs a lot of money. If you've applied it and lost it, it’s a waste of time”.

Regarding advice about a specific product or situation, GreenK7 stated “I would go to the person supplying it (distributors) obviously and they wouldn’t want to give you anything that’s wrong. They are proper advisors that come out… but most of the time we know what to use, we use the same stuff more or less all the time, year after year”. Probing further, GreenK7 proffered “…we try not to use it (PPP), it’s expensive, it’s more expensive to us than it is farmers”.

Regarding the use of specific websites as sources of information, GreenK7 has never used any of the websites listed (i.e. CRD, EA or the Amenity Forum).

Finally, in terms of what other specific measures taken to protect water, GreenK7 replied “We certainly keep away from it (water) as much as possible”. Application Equipment and Pesticide Storage

GreenK7’s organisation uses both knapsack and boom sprayers for pesticide applications. Asked initially about calibrating the boom sprayer GreenK7 replied “They do it probably once a year and that’s the driver, they’ve done the test, they know how to do it, they check it out and they calibrate it. The machines go away about every five years, something like that to have a check over”.

In total, GreenK7’s organisation uses around four or five products during the year and when prompted admitted that the equipment does need to be calibrated when changing from one product to the next.

According to GreenK7 stated that knapsacks tend to be calibrated more frequently, “The machine (mounted sprayer), once they're set up, usually it’s fairly good as long as you clean them, the knapsacks get knocked about don’t they?” The NPTC-trained employees are responsible for calibrating all equipment.

GreenK7’s organisation uses a secured chemical safe, which is fire resistant and with sufficient capacity to retain the volume of PP stored at any one time, but is not formally bunded. The store is away from water and has a roof.

Questioned about what precautions are used during filling, unprompted GreenK7 stated all equipment is filled in an area with an underground tank designed to collect spillages and waste water and, according to the respondent, “purified” here. With prompting GreenK7 confirmed that operators are required to read product labels and to take care when filling. Containers are double rinsed, “Rinse it out, put the hose in it and rinse it around, they (washings) go through the machine, you just pull the hose out and rinse it and clean to the top” with rinsed caps replaced on empty, cleaned bottles. The mixing of PPP “is very rare but we do it, there are some times you can get a couple of products that are compatible”. GreenK7 confirmed that spill kits are available should these be required.

Regarding the disposal of containers, these are removed by a waste disposal contractor, “They take containers, everything and then they give us a certificate every year. They might come out two times, they might only come out once”, according to whether the empty container store is full. Questioned why this approach was chosen, GreenK7 replied “Just piece of mind really. You can’t be too careful with anything like that”. This approach is taken for both containers and any surplus contaminated spray washings.



Questioned about the criteria used in deciding whether or not to use a pesticide, GreenK7 replied “We try and leave things as long as possible really. The last time I sprayed my green it cost me £1,500. That thing sort of holds you back, there are times when you think ooh, maybe I ought to, but you wait a little longer and just keep checking until such time as you think oh I’ve got to go”. Probing further, GreenK7 volunteered, “The stuff (PPP) for us is so expensive compared to farmers. I can get the same stuff from the farm for about a fiver, if you want to go down that route, but of course – I'm sure there's some out there that do it”.

Prompted whether it was a case of balancing quality – how the course looks and plays – versus saving money, GreenK7 replied “…there’s a certain amount you can put up with, there's a certain amount you can’t” and at the end of the day “It’s the greens really” for Fusarium and dollar spot control, “They're about the only ones”.

GreenK7 is less concerned about the residual effects of herbicides than he is pH which can have a profound effect for moss control. With regards to dose rates, GreenK7 only ever uses those recommended by manufacturer’s otherwise losing the opportunity to complain if the right result is not achieved.

Regarding how often the possibility of using non-chemical methods for weed control is considered before any decision to use herbicides is finalised, GreenK7 replied the overriding concerns were

• cost - “We try and use as little fertiliser, sprays and things as we can, we like to try and find a way around it, because it costs you so much more than mowing”, and

• minimising any effects of PPP on the environment - “It’s nice to think you're not using something like that really, that’s going to harm anything. If you can get away with it you do don’t you? I mean there are roads here, where the weeds and that growing around the fringes…It may look unsightly at times, but there’s no reason to cut it, no reason to spray it or anything”.

Probing further, GreenK7 felt that PPP were more effective than alternatives like mowing, but they tend to be more costly and only really useful, “If you’ve got a real problem”. Overall, GreenK7 always thinks about using alternatives to PPP but that enough information was “probably not” readily available.

Aside from hand-weeding, other non-chemical approaches used by GreenK7 are: cutting/strimming/mowing, brushing, mulching, soil aeration (“that’s a big thing, we bung holes in it. It’s a massive one”), drainage (“we need good drainage, we spend a lot of time on that“) and use of disease resistant stock (“That has made it better because certain grass is less susceptible to disease”). Regarding the use of ‘biologicals’, GreenK7 replied that the organisation had used Symbio in the past.

Case Study GreenK8

GreenK8 is the head green-keeper for an independent inland, link-style golf club with responsibility for the use of pesticides on amenity and sports grass, gravel/ballast surfaces, and pavement/kerbs


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, GreenK8 identified the following:

• <Protection of nature conservation areas> and <Conservation of native plants> - “There are certain large areas I do leave so that’s quite important to me”, and

• <Quality of grass/turf> and <Growth of trees/shrubs> – The former is not surprising, but with regards to shrubs, GreenK8 replied “I protect the gorse because birds come in there. I’ve got a lot of gorse so there is maintenance involved… I do spray for the weeds around them”.

Probing further, GreenK8 commented “In a word I suppose it’s the aesthetics of the course, protecting the natural look of the place. Yes, there’s a lot of conservation, especially the birds, the starlings, so there are areas I have to leave for them…Yes, we’ve got to protect the gorse obviously, make sure that keeps flowering every year, so I do my best to look after that”. In terms of course management, “I have to cut it (the rough) down sort of late February/early March and then just leave it. (until June when the starlings have nested and flown). It sort of suits me really because it keeps that natural look of the golf course, the


inland link sort of style, which is what we’re all about. I like to give the course character and shape and definition so I use the grass in those ways to do that, so leaving it long actually does me a favour”.

In addition, GreenK8 also identified the presence of a public footpath through the course as an important factor, “They have to be made aware of what’s going on the course and when”.

Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK8 rated their knowledge as <Very Poor>; “I did my PA2 a long, long time ago, so yes, I’m surprised nobody’s asked me to do a refresher. The NPTC who I did the course with, they should have me back if anything changed really shouldn’t they?”

GreenK8 was aware of BASIS, via a supplier’s website had not heard of the other organisations listed (Q4).

Within GreenK8’s local organisation, of the 3 FTE staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 3 (PA1 – 3, PA2 – 1, and PA6 - 3), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 3, trained in 2006 Codes of Practice – 3, but for the respondent “Not recently, sorry. I done them (NPTC courses) a long time ago”.

Within GreenK8’s organisation, no BASIS qualified personnel are involved in policy making and checking recommendations, all decisions being taken by the respondent.


Unprompted about measures adopted to protect human health and the public, GreenK8 replied “Well first thing I do is I put a sign up at the front gate. On the public footpath I have to put one there and put another one down at the clubhouse. Make people aware that I am going to be spraying that day and I leave that for forty eight hours. Other than that I wait until they are well clear of the green before I spray it or the target area and that’s about it really”.

Prompted further to think about the use of PPE, GreenK8 replied “Sorry I thought more about the public. Yes overalls, Nitrile gloves obviously, face shields, yes, wellington boots, the full shebang. Everything we are supposed to have we’ve got there in the site safe”. Probing further about the use of COSHH assessments, “…of course yes, you do that without thinking don’t you? Yes COSHH and the data sheet can be made available if anybody wants them, various sites, next to the chemicals as well. So yes if someone wants to have it or if somebody gets an irritation with their skin they can come and see me and I can say well I’ve been spraying this, give them a sheet and they can seek medical advice from there”

There is no specific programme of health surveillance in GreenK9’s organisation.

In answer to an earlier question, GreenK8 identified water and certain wildlife rich/conservation habitats as places to avoid treating with PPPs. Prompting about other specific situations where there is a need to be extra vigilant, being a link-style course the terrain is very variable, and can present a challenge to spray, “it’s tough with the control and boom height very well. You could come a cropper so yes the higher the crop, yes it does affect the spraying”.

Asked where they would turn for information on whether a PPP was restricted or where the risk of use is greatest, GreenK8 replied, “Well my supplier for a start because if they supply me something I shouldn’t be using then I’d want to know about it.” Prompted about websites that GrrenK8 might consult, “I haven’t looked at any, no. I do look at the BIGGA website now and again. The British International Golf Green-keepers Association. Pretty cool”. GreenK8 is not aware of the following organisations or their websites: CRD, EA and the Amenity Forum.

“It’s good to be in touch. Green-keepers are quite an isolated trade, we very rarely get to sit down and talk to another green-keeper about stuff like this and any possibly changes. Years ago there was a ban of pesticides, going more like Denmark and Germany, down that sort of route. We’ve all talked about it and feared it coming but we’re aware it’s a possibility. So I suppose it’ll happen in stages, there’ll be certain products that will be banned first and then slowly have a complete ban on the products then, but I’m not sure, I wouldn’t know. I would like to think somebody would contact me”.



GreenK8’s organisation uses a 300 litre tractor-mounted team sprayer. Use of a 15 litre knapsack is limited to bunkers and paths.

Asked initially about calibrating the mounted sprayer GreenK8 replied “I got this sprayer second hand from a colleague. As soon as I got it to the golf course the first thing I did was calibrate it. It’s been a while but as long as you keep it clean, I work on six hundred litres a hectare and it stays that way, so I’ve got no need to re-calibrate it really. It’s doing what it’s supposed to for me, it works fine”.

Asked if there was a need to calibrate when changing products, GreenK8 stated “If it says four litres a hectare I know that I put four litres, six hundred litres of water and I’ll spray a hectare because that’s what my sprayer does. Six hundred litres on two thousand revs will spray a hectare and it works every time. I’ve got nothing in a tank when I finish the last green. It works out a treat but it obviously look a lot of maths and a lot of patience to get it right but yes it’s there. I always use that amount of water as well. I could go down to three hundred litres a hectare if I change the nozzle but I’m so used to doing it like this so I’m not going to adjust it in case it goes wrong and change it again. It’s set just right”.

Probing further about situations that might arise when there was a need to calibrate the mounted sprayer, GreenK8 replied “Obviously if I got to the last green and I still had fifty litres in my tank I’d know something was wrong. So that’s when I would re-test”. GreenK8 confirmed that they were responsible for calibrating the sprayer, “I have to do it right because obviously I can’t waste the products with my budget. I’ve got to protect my budget, so I’ve got to get it spot on”.

Asked if they did anything different for the knapsack sprayer, GreenK8 replied “No knapsacks are fine, they’ve got pressure regulators on to keep them at whatever bar you want and as long as the nozzles appear to be working fine there’s not a lot to do really – you just add the chemical and away you go”, changing any nozzles only if they appear faulty.

GreenK8’s organisation uses a secured site safe, housed inside a shipping container, “Fantastic security but it don’t look very pretty… barely get the machinery in there”. Asked what would be considered as important for a pesticide store in terms of its construction and siting, GreenK8 replied, “Well it has to be clearly labelled and identified… it should have a stock list on the front of it so you know what’s in there and you know it’s used, what should be in there and you keep those recorded up to date as often as you can. Yes it should be lockable as well and just a generally solid piece of protective storage really”.

Prompting from the list (Q15), GreenK8 recognised PPP stores need to be fire proof and capable of retaining a spillage (“…can’t have holes in it obviously”) but admitted that the site safe was not bunded. Asked what sorts of quantities of PPP are stored, GreenK8 stated “Not a lot, I write my program out at the beginning of the year and I have a monthly delivery quota so it comes in, it goes out and it’s emptied. … I always have a little bit of weed killer mucking around just in case. But other than that you’re talking a lot of money’s worth, I don’t like it lying around. I’ve always got some total weed control in there to kill the weeds on the paths, which you don’t use all of that at once, you get five litres in there. It lasts, I’ve had it two years now, it lasts a while”.

Questioned about what precautions are used during filling, unprompted GreenK8 replied “First thing is it’s got to be flat, level ground obviously. Nothing around you, no trip measures around you, putting my gloves on, my suit on, my face shield on. I’m quite lucky because I’ve got a separate chemical tank on the side of it, the sprayer I have so I don’t have to raise the bottle up too high. So yes I always pour sideways, turn the bottle sideways obviously so it doesn’t splash”.

Prompting from the list (Q16), GreenK8 recognised the need to read label instructions and a uses a metal bracket on the sprayer to hold the hose away from any pre-mixed chemical. In terms of matching the pack size to the task, GreenK8 replied “Unfortunately there you’re governed by the product. For example I’ve just sprayed a fungicide, which goes out twenty litres a hectare. So you use four or five litre containers and that’s just the way it is. I get wetting agent, that comes in twelve point five litre drums and it goes out at fifty litres a hectare, it’s a strange one. So I’m pretty much governed by the product really”.

Some product mixing is done, and “as long as I read the label and I phone my supplier and as long as he said they’re compatible yes I just mix them as normal, not a problem”.

Empty containers are triple rinsed, and once clean the tops are screwed back on. Asked what happens if there are accidents or chemical spillages, GreenK8 replied “It doesn’t often happen but if I do I’ll get the hose and hose it down into my soakaway, that’s about it”. Whilst admitting to not having a spill kit, GreenK8 stated “it doesn’t often happen but if I do I’ll get the hose and hose it down into my soakaway, that’s about it”.


Turning to the management of surplus diluted product, GreenK8 replied “It will be sprayed on a similar target area originally intended. I always go back to the yard with an empty tractor, let’s put it that way”. For empty containers, GreenK8’s organisation puts clean empty containers in one tonne bags, “They stay in the corner in the yard out the way and I’ve got a contract with X, twice a year they come and empty the yard”. The same organisation also supplies oils and lubricants and will remove any unwanted or old chemicals.


Questioned about the criteria used in deciding whether or not to use a pesticide, GreenK8 replied “That’s a tough one. My boss asks me that all the time, ‘do you really need to spray’? …sustainability of the playing conditions, that is the biggest factor. If the greens get disease then I’ve got to spray them. If they’re not growing and they look hungry I’ve got to feed them, if they’re not holding water I need to use wetting agent”.

In terms of advice, “I do have a supplier that comes in once a year. We sit down and thrash out a programme for the year but a lot of it is down to my own personal knowledge of the course and what it needs for it to remain open, playable and most of all profitable for my governor and the public”.

Prompting from the list (Q20), GreenK8 stated he used “…lots of cultural methods…I mean I aerate thoroughly monthly so that the water we do use, we can get the maximum out of it. I’ve stripped it (use of PPP) right back to the bare minimum this year to see what we can get away with and we have suffered here certain times of the year and we’re going to have to address that when we look at next year’s budget”.

Probing whether they have tried lower rates than recommended, GreenK8 said “I never have I’ve always gone at the recommended, well the lowest recommended rate. I need it to last four to six weeks to get me to my next delivery”. It is a case of “basically budget and logistics and not having a stupid amount of chemicals sat around”.

Asked to identify which factors have influenced the organisation’s decisions to use chemicals rather than non-chemical approaches, GreenK8 strongly identified with the following:

• Chemical treatment more effective than alternative options – The perception is that is true “a lot of the time it is so I’d say that’s got quite a lot of influence”

• Chemical treatment was the most practical method available – “Practical no, but on time it’s the most convenient, it’s the easiest, it’s the quickest”

• Always done that way – “Pretty much, doesn’t mean to say it’s right” • Advice of consultants – “…that’s quite high obviously I’ve got my supplier plugging the sales so

I’d put that up to a four” • Availability and Lack of information on alternative products or techniques – “Without using

pesticide I don’t know of any, I wouldn’t know how to kill a weed without using a herbicide…If it’s the way forward and its safer and the rest of it I’d give it a go but it’s just not happening”.

Asked If they ever considered the use of non-chemical methods for vegetation or weed control, GreenK8 replied <Sometimes>; “A couple of times a year we’re looking at it, what else can we do? Yes, especially if it’s an area where we’re spending a lot of money or wasting a lot of time”.

From a list of non-chemical approaches, GreenK8’s organisation uses: hand-weeding, cutting/strimming/failing/mowing, brushing, mulching, soil aeration (“Yes I do plenty of that”), and correct fertiliser application. GreenK8’s organisation also uses bio-stimulants, especially seaweed but “it’s a bit like snake oil and not a hundred percent sure of it”.

Of those non-chemical approaches listed, hand-weeding is “by the most frequent. We maintain the bunkers three times per week”. Probing further, spraying total weed-killers is out of the question as the risk of drift on to the greens is considered “dangerous”. Total herbicides are restricted to use on the pathways, with selective herbicides limited to around the gorse and certain other areas, “I prefer the hand-weeding…you can get them by the roots and you know they’re not coming back”.


Case Study GreenK9

GreenK9 is the manager and head green-keeper for a Local Authority owned golf club with responsibility for the use of pesticides on amenity and sports grass, and gravel/ballast surfaces.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, GreenK9 identified the following:

• Protection of nature conservation areas – originally part of a large, private estate due to some of the trees parts of the course have restrictions on what can be done there.

• Local Authority Policy: – the site is managed on behalf of the local authority • Public safety and/or litigation – There is a large public rights of way running through the course • Quality of grass/turf – Greens in particular and influenced initially by television, with golf clubs

turning people away from the mid-90’s up to 2004 when memberships of 60,000 were common. Now any course with 35,000 is considered to be doing well.

• Disease control/prevention – “… disease control on the greens. We have meadow grass greens which are the most susceptible to any fungal attack.”

• Legal requirement, e.g. the Weed Act – “The only one I'm worried about is we’ve got a couple of Japanese knotweed and the members of the public are so much aware of all these things…”

• Public concerns – “We’re a public pay and play golf complex, predominantly a lot of times you're out spraying, they ask you ‘what are you doing and is it legal?’, so we have to be conscious. I keep saying to them you can go down to buy stuff in B&Q that’s more lethal than what I can use on this golf course”

Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK9 rated their knowledge as <Fair>;

GreenK9’s organisation is a member of BIGGA but none of the listed organisations.

Asked about qualifications, GreenK9 stated “I'm the only one on site that does any of the spraying whatsoever, we’re tending to contract a lot more (fairways)…the staff are well trained, but they’re predominantly grass cutters”.

Within GreenK9’s local organisation, of the 4 FTE staff the number trained/qualified were as follows: BASIS – 0 (contractor yes), BASIS register – 0 (contractor yes), BASIS Power – 0, BASIS storekeeper – 0 (contractor yes), BETA – 0, NPTC – 1 (certification types not recorded), NRoSO – 0 (contractor probably), NASOR – 0, access to 2006 Codes of Practice – 1, trained in 2006 Codes of Practice – 0.

Within GreenK9’s organisation the contractor provides input in terms of developing the organisation’s policies for pesticide use, etc.


Unprompted about measures to protect human health and the public, GreenK9 replied “We do COSHH training, COSHH assessments, we keep all safety data sheets where it’s going to be used on site, whether it’s a chemical we don’t use anymore or not, they're always kept for history. We do risk assessments for every chemical that’s used as well. There's a log of all chemical usage. All chemicals are stored properly. Signage, if we’re spraying on the course, there's always signage on the first and tenth tee, warning players before they go out and the other one, it may be relevant to that area, but it’s always done early in the morning before golfers are on the course”.

Prompted about the use of PPE, GreenK9 replied “As a company we can actually go out and buy whatever we want, when we want, there's no restriction. The other thing that we have done more than most other courses is we’re independently health and safety audited by an outside company. We use a company called XXX, they come in and health and safety audit us for everything, but chemical use is a big part of that”. Asked about health surveillance, GreenK9 said “That’s not something we do, unless someone pulls up a problem”.


Questioned whether there are situations or circumstances where extra vigilance is required, GreenK9’s answer referred to the public rights of way. This is used extensively by the Ramblers Association to the point that they keep a folder in the clubhouse for signing members in an out of the course, “Yes, you just try not to spray on a Wednesday, that’s when the ramblers come in”. The other problem is dogs; “Dogs shouldn’t be on the golf course, if they're using the footpaths, the dog should be on a lead at all times. If there's a sign or anybody knows that the course belongs to the local authority, they think it’s a public path”.

Turning to the environment and situations considered at high risk when using PPPs, GreenK9 stated “I don’t think there's any because we have no water areas or anything like that”. Prompted to think about drains, GreenK9 replied “The only drains we have here are on common greens. It was farmland before on heavy clay and there's very, very little drainage anywhere else, hence we close for 31 days a year roughly, on average”. Probing further, GreenK9 had not experienced any of the listed areas (e.g. parkland, SSSI’s, etc.) where application of PPPs might be considered risky.

Asked where they would turn for information on whether a PPP was restricted or where the risk of use is greatest, GreenK9 replied, “My rep who we buy the chemicals… and if they don’t know they will get one of their experts to give us a ring. Other than that it’s just researching ourselves on the internet”. Probing further, GreenK9 explained that their approach to using PPPs had not changed much in the last 10 years, “I’d probably say we’re using the same selective – because we protect the tees and greens ourselves, we do areas around the greens and the contractors look after the other areas, the fairways. We don’t spray semi-rough or rough, so the fairways are looked after by contractors. We do have weeds in the green and because it’s a public course we tend to spray everything once a year”.

Prompted about the use of specific websites, GreenK9 replied that he only ever referred to Scotts’ website. GreenK9 had not used the CRD website, and had not heard of the EA nor the Amenity Forum websites.


GreenK9’s organisation uses a 300 litre tractor-mounted sprayer. They have no knapsack sprayers. The mounted sprayer is “tested annually, it’s calibrated monthly or before use if we’re not using it monthly. The majority of the stuff that’s coming in now, if you look at our chemicals, nearly everything is 600 litres of water, so once you’ve got it set up once, irrespective of what fungicide you're using, it’s the same application”. Probing further, GreenK9 would recalibrate if the machine malfunctioned, “we’ve actually fitted as extras onto our tractors, like MRDS, which gives us accurately 6 kilometres per hour, so we’ve got that calibrated to 2.8 litres per minute and that’s 600 litres per hectare”.

In terms of training specifically for calibrating the mounted sprayer, GreenK9 stated that he only ever followed manufacturer’s instructions but had received additional training recently from a nearby approved agricultural college.

GreenK9’s organisation uses a 250 litre metal chemical safe, “which is a bunded unit, so any spillages will be kept within the unit”. Asked how the store is bunded, GreenK9 replied “It’s got a metal shelf, not on the floor, so if anything drips out it goes into that and if anything is spilled it’s collected which you then have to cleanse”.

Prompted from the list, GreenK9 stated that the store was fire resistant, could contain 110% of the volume of product stored, that the bunding was not compromised by exits and entrances, had a roof and was situated away from water. Probing further, “…you can almost get chemicals from anywhere at 24 hours’ notice so actually you don’t need to keep stock. At the moment I know what I’ve got in there, there's 2 x 3 litres of Primo Maxx, 2 x 10 litres of Indicator dye and one 5 litre of fungicide”.

Questioned about what precautions are used during filling, unprompted GreenK9 replied “PPE for the operator we’re obviously using it all the time, but more so when you're handling the concentrate. The area where we fill the sprayer is not accessible to members of the public. Invariably when we fill the sprayer the hose is always four inches above the tank, so we can’t get contamination on that. Would you believe that the Water Authority tested it all last year, tested all our taps to make sure there couldn’t be any suck back. They made a pack of recommendations for us, for the whole place, before they would give you approval for you to carry on being able to do it”.


Prompting from the list, GreenK9 said that he always followed label instructions and uses an induction hopper to feed the main spray tank. Mixing of products has been tried, but the respondent stated that he had “never found it to be any better than just doing them individually”. As to spill kits, they have access to one supplied a local company that is also contracted to remove all waste.

Regarding waste disposal, any spray washings are disposed of at the site of application, and empty containers are removed by an approved contractor. This company is popular amongst golf course managers locally and provide an oil barrel-sized container for all clean containers and any disposable spray suits, removing this entirely when the barrel is full. The waste contractor will also remove old chemicals if required and was chosen as they “look after all of our waste and not just our containers, we were looking for a one stop shop really”. Probing further, “We look at it really as a responsible and legal obligation that we have. We’ve visited other courses. We’ve walked around the back of some buildings with just containers all over”.


Questioned about the criteria used in deciding whether or not to use a pesticide, GreenK9 stated that his prime focus is the roll of the golf ball, “I could take you out onto our greens, and see the weeds on our greens…I'm not going to name the clubs, but they're going out there and blanket spraying every few months just so when you go there it’s pristine and to me that’s totally irresponsible. We do not go down that route whatsoever. We spray, as I say, only once a year, it doesn't ever change. If we do get weeds then we deal with that through cutting”.

Probing further about using an alternative method of control or combination with a PPP, GreenK9 replied “The only other one we could do on the greens, and we’ve done it before, is hand weeded them. The minute you pull something out of the ground you're leaving a hole, which again affects the roll of the ball. We will not be influenced by the demands of the golfer for aesthetic purposes only. If this was a private club then it would be a totally different story”.

Questioned whether he ever reduced the amount of pesticide used, GreenK9 replied that he would only use the manufacturer’s recommendations. Using anymore was pointless, “It’s still going to kill the weeds, it’s not going to do anything else. You're just going to waste a lot of money”.

Asked to identify which factors have influenced the organisation’s decisions to use chemicals rather than non-chemical approaches, GreenK9 strongly identified with the following:

• The organisation’s policy – “We’re run by a Sports Trust, a charity, but they allow me to make my own policies. What the councils did years ago, 5 or 6 years ago, there was a golf course, 5 sports centres, athletics track, extreme sports centre, they were all local authority run facilities, by putting them into a charity you don’t pay rates on them”

• Lower cost of chemical treatments – “If you get somebody like the local authority they’ll bring it up. You're running with the minimum of staff, you haven’t got staff to actually physically move onto other jobs so you're looking at a chemical way of doing it”

• Chemical treatment was the most practical method available – “There is some cultural use age you can do to stop the fungicide attacks, but we’ve found that the only way you can control them effectively is by chemical controlling them. If you were to go out and reduce the amount of thatch in the top layer, the fungus wouldn’t have anything to feed on, even brand new greens that have got no thatch, they get fungal attacks”. Probing further, GreenK9 felt that cultural methods take too much time, “…and with no guarantee”.

Asked if they ever considered the use of non-chemical methods for vegetation or weed control, GreenK9 replied <Sometimes>; “We do risk assessments and things, the use of chemicals should always be a last resort and the fact that we do it once a year and by selectives, is only out of necessity. If there was some other way we could do it or if the golfers would not complain about it – I don’t mind them complaining if it’s a legitimate complaint, but there's so much choice now that the golfer can just leave the pay and play golf course and just join the one down the road who maybe is doing it, who maybe is spraying monthly – it’s just a balance between what you believe in and what the member actually wants”.


From a list of non-chemical approaches, GreenK9’s organisation most uses cutting, “…to keep certain weeds out because when you're cutting down to 3 mm, the weeds will not survive. It’s definitely weed control as the reason. We can control daisies, dandelions on the green without too much trouble, but plantains, that’s a different story”.

Asked about the use of disease resistant grass varieties, GreenK9 replied “We’d love to, we have tried to change, we went through a period, we went to the STRI to try and change the grass species on the green, but because Poa grows so vigorously in the growing season it just smothered most of the grasses out. So yes, we have tried it, but without too much success. I mean you can have good greens for eight or nine months of the year and struggle for three months of the year”.

Case Study GreenK10

GreenK10 is the manager and head green-keeper for an independently owned golf club that leases much of the land from the town council with responsibility for the use of pesticides on amenity and sports grass, gravel/ballast surfaces and pavements/kerbs.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, GreenK10 identified the following as key:

• Protection of <Nature conservation areas> and <Conservation of native plant or animal species> – “We’re on the common, so members of the public like to look after the wildlife and so do I. It’s nice to do the best you can”.

• Local Authority Policy – With the land leased from the council, permission to apply is required for every chemical. “As long as we show them what we want to do, why we want to do it, it’s OK. We’re not allowed to treat certain areas”. The 60 acres that is privately owned is not treated any differently.

Regarding knowledge of the 2006 Code of Practice for using PPP, GreenK10 rated their knowledge as <Fair>; “It’s not something you're going to sit and read every day”.

GreenK10 had heard of BASIS, NRoSO and NASOR but the organisation was not a member of these associations. The respondent had not heard of the Amenity Forum or BACCS.

Asked about qualifications, GreenK10 stated that the organisation was responsible for treating the greens but that a BASIS registered contractor sprayed the fairways, “That’s all we’re allowed to do, it’s part of our agreement” with the local council.

Within GreenK10’s local organisation, of the 5 FTE staff the number trained/qualified were as follows: BASIS – 0 (contractor yes), BASIS register – 0 (contractor yes), BASIS Power – 0, BASIS storekeeper – 0 (contractor yes), BETA – 0, NPTC – 5 (a mix of PA1, PA2 and PA6, numbers of each were not known by the respondent), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 5, trained in 2006 Codes of Practice – 5.

Within GreenK10’s organisation the council provides significant input regarding what PPPs can and cannot be used on the course.


Unprompted to the question about protecting human health, GreenK10 replied “Obviously you’ve got to have the right PPE which we’ve got, we try and spray early in the mornings when there's no one about on the common”. Weather is also a consideration, “If it’s too windy and things like that, you have to abandon it for another day”.

Prompted about risk assessments, GreenK10 confirmed that COSHH assessments are in place for all tasks and they deploy signs when spraying at the first and tenth tees. On the issues of health surveillance, GreenK10 replied, “We’ve obviously got a health and safety book, we’ve got spray books and things, up to now, touch wood, we’ve never had any accidents”.


Asked about specific circumstance when extra vigilance is required, GreenK10 commented “Obviously if you’ve got people walking nearby you’ve got to wait, things like that, but you know, it works really well” despite the course being centred on a common and open to the public.

Looking at measures specifically to protect the environment when prompted, GreenK10 identified the need to avoid spraying near two bore holes, “They're in the rough anyway and we don’t spray the rough” and some “Some sensitive areas, we’ve got heathers and things, but we never get near them, we all know they're there”. Open parkland is strimmed rather than treated and whilst there are no designated SSSI’s both the STRI and Essex Trust have developed a policy for the course that GreenK10’s organisation work within.

Asked where they would turn for information on whether a PPP was restricted or where the risk of use is greatest, GreenK10 replied, “The internet is a great place to start”. Probing what was top of mind, GreenK10 replied “the BIGGA sites, green keeper sites”.

Prompted about use of the CRD website, GreenK10 stated “No, the council do it for me anyway because I tell them what I want to do, the products I'm thinking of using, I go through their book to make sure they're happy for me to use it”. GreenK10 admitted referring to manufacturer’s sites, had not heard of the EA’s ‘What’s in your backyard’? website but had visited the Amenity Forum site. Asked if this had been helpful, GreenK10 replied “I don’t really, you're roughly doing the same products most of the time, everything you need to know is on the labels and like you say, it’s done with the product labels and the town council and it works very well”.


GreenK10’s organisation uses knapsacks and a tractor-mounted sprayer. Asked how frequently the latter is calibrated, GreenK10 replied “I don’t do it every time because it’s not as though you're using it 8 hours at a time, the most you use it is a couple of hours at a time. It’s not going to get out in that time”. When prompted admitted it was calibrated “…about every three months”. The same products tend to be used either through the mounted-sprayer or the knapsack which GreenK10 felt minimised the need to have to recalibrate frequently. All equipment is recalibrated if repaired whether repairs are done in-house or via a specialist company.

With regards training, GreenK10 organises training with either the local agricultural college or more recently with a training and assessment centre.

A few years back GreenK10’d organisation purchased a very small chemical safe from a specialist company. It is used only as a temporary store, the organisation preferring to purchase PPPs as required. This safe is fire proof, secure, contains bunding, and is housed inside a roofed building.

Questioned about what precautions are used during filling, unprompted GreenK10 commented that PPE is a pre-requisite and for advice on what type to wear the “Product label is a great thing because everything is on there”.

Prompted on filling, GreenK10 stated that this is done at the back of the property drawing water from the mains. Asked what would happen if the mounted-sprayer was over-filled, GreenK10 replied a “Very good point, probably something we haven't thought about”. Regarding pouring PPP, jugs are used for measuring quantities and the operator uses an induction hopper. There is also a facility on the sprayer to triple wash the containers and caps. In the event of an accident, the chemical spillage is managed with a “Clean-up kit”.

Regarding disposal, asked what happens to any surplus spray solution after the job is finished, GreenK10 replied “You’d find an area, there's 160 acres, there's plenty of areas where if you’ve got 5 litres of weed killer you can go and put on a tee”. Cleaned and empty containers are stored on site in a big drum supplied by the waste contractor. This company was chosen as it removes all of the club’s waste, including any contaminated materials if required, as and when the ‘bin’ is filled.



Questioned about the criteria used in deciding whether or not to use a pesticide GreenK10 immediately replied, “If there are signs of disease that would be the most important”. Asked why use a fungicide when improved drainage could help, GreenK10 retorted “It doesn't matter how good your drainage is, we’ve got seven sand greens and the weirdest thing is everybody says that you don’t get the disease, but you do get the disease. That’s with the best maintenance in the world, with plenty of scarifying, plenty of aeration, you still get disease”.

Probing further about sources of advice on what to use for disease control, GreenK10 stated that aside from reps the organisation also has an agronomist that “…comes in two or three times a year… has a look at how we’re progressing”. With regard to using lower rates, GreenK10 replied “We do use lower rates…it’s just the norm isn't it, everybody seems to think you can get away with it, if it works, why not?...

Let’s face it, they all talk about phasing and not using them, but I can’t see we’re ever going to get rid of chemicals”.

Asked to identify which factors have influenced the organisation’s decisions to use chemicals rather than non-chemical approaches, GreenK10 commented initially, “I think we obviously use (some) sort of control anyway because the scarification and aeration is keeping the soil healthy and trying to discourage weeds, but you do get weeds whatever way you do it, you still get them. We go around and spot spray, we dig them out with the daisy forks and all sorts of things…With the best will in the world, you think you're doing really well and they’re (the greens) really clean and within a few weeks the whole place is alive with them”.

From the list, GreenK10 identified most with:

• Chemical treatments are more effective than alternative approaches – “You're trying to do the best you can not to use them, but the problem is you can do all the work in the world and sometimes you can get away without chemical control, but if you get the disease you’ve got to do it. You can’t sit and let a green just die”.

Probing further, GreenK10 did not think that chemical approaches were necessarily longer-lasting, “we use them because we have to”.

Asked If they ever considered the use of non-chemical methods for vegetation or weed control, GreenK10 replied <Always>

From a list of non-chemical approaches, GreenK10’s organisation uses: hand-weeding, cutting/mowing/strimming, brushing, mulching, soil aeration (“We do tons of that”), correct fertiliser application, drainage, and use of disease resistant stock (bent grass). Asked which of these is used most frequently GreenK10 replied, “Most of them. Obviously the greens get more treatment than anything because you’re trying to do something different aren’t you, you're trying to keep a really perfect surface, so the greens get far more treatment than anything we do”.

Probing further about the use of biological products in this industry, GreenK10 replied “They're there, but most of them are expensive and I think it comes down to cost, that’s the biggest thing. You’d love to try some of it, because I know they’ve been out for years some of them and I know we’ve talked about it but it’s the cost. We’re only a little club. I’ve been here years, we’ve done an awful lot, but we’re always short of money”.


Case Study LocalA1

LocalA1 is the head of the grounds team for an English borough council with responsibility for the management, including vegetation control of the following areas: amenity and sports turf, shrub-beds, riparian areas (minimal), gravel/ ballast surfaces (minimal), and other hard surfaces such as garage areas, estate drying areas, and open footpaths across common land. Pavements and kerbs are the responsibility of the County Council.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, LocalA1 indicated most influence coming from:

• Public safety and/or possible litigation – LocalA1 stated there are many issues here, but “public safety is paramount in any local authority’s operation. Everything we do we risk assess with regard to the operatives, the public and wild life, looking at alternatives if these are financially feasible”

• Health of domestic animals/livestock – “We would be deep trouble if we killed someone’s cat. We only use chemicals that are safe to use…it is too much for a Local Authority to have the front page news…we are under the microscope (by the general public)”.

• Legal requirements – Overall legislation with regards the EU directive, “We have to be more mindful of public protection and the environment”.

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA1 rated their knowledge as <Fair>; “It is usually a case of if there is something specific I would need to refer to it”.

LocalA1’s organisation is not a member of any of the listed associations, but is a member of the Institute of Groundsmen. The respondent was also aware of NRoSO.

Within LocalA1’s local organisation, all spraying is done in-house baring a small element which is scheduled for tractor-spraying of selective herbicides by an outside organisation on fine turf but this contract has not been executed in recent years. In terms of staff, nine employees are NPTC trained (PA1 and PA6) of which eight actually do the spraying. None of LocalA1’s team is BASIS storekeeper certificated, but the respondent believes this training has been done within the organisation. All spray operatives have access to the Code of Practice, but need to consult with the respondent for access.

In terms of training beyond initial NPTC certification, staff will receive updates “as and when usage or legislation changes”. There is a process of cascading relevant information verbally and in writing every two months for all tasks. With regard refresher training, LocalA1 stated “This is something that I am looking into as I am conscious that some people gained their sprayer certificates some years ago. The only constraint would be financial. A lot of people do the training but very few appear to offer refresher training”.

In terms of the use of BASIS qualified staff for development of policies, checking recommendations and (rarely) tender documents, LocalA1 will sometimes talk to product suppliers. Glyphosate is the major active used by this authority, plus some moss control and fine turf fungicides.


Unprompted to the question about protecting human health, LocalA1 stated, “We only use trained people to spray” having abandoned the guardian approach some years ago. All staff have access to appropriate PPE and “We only use controlled droplet applicators for very targeted and minimal run-off”

Prompted about other steps to protect workers, the spray operators have access to COSHH assessments for all chemical jobs, and have to complete check-sheets and understand the task before any work starts. On health surveillance “…this is done corporately” but this tends to focus on work absence rather than health screening. Asked about the use of signage, LocalA1 replied “We don’t tend to due to the low risk of glyphosate and the operation is pretty much borough-wide, walking from street to street. We do tend to put signs out when treating bowling green”.


Asked if there particular scenarios where extra vigilance is required, LocalA1 replied “One lady on one of our housing blocks has an alleged allergy to glyphosate and we inform her when we are spraying in the area”. For most schools, highways have authority to treat, but LocalA1’s organisation would tend to avoid treating during in and out times, “It is common sense really…and this is part of the risk assessment. In the town centres most weed control is mechanical, mechanical sweeping, hand-weed control. Almost all of the Civic Centre is manually weeded”. Probing further, standards rather than public safety is the major driver in these areas.

Looking at steps to protect the environment, unprompted LocalA1 identified water courses as being the biggest issue, and “…we don’t spray conservation areas unless there is knotweed (or other invasive species) to treat”. Prompted about other situations, drains are not an issue for LocalA1 as kerbs are outside their remit, “We tend to use CDA around bollards and trees so we are nowhere near drains”. Again in parkland these tend to be targeted applications around footpaths and other obstacles, “Public perception is as important as actual risk when it comes to spraying in open spaces”. Regarding slopes, these tend to be strimmed rather than sprayed, and “We don’t treat sloped hard surfaces. And we don’t spray in windy or wet conditions, that is a given”.

Unprompted LocalA1 would visit the Chemicals Regulation Directorate’s website for the latest product information, but “…could not see the need arising” in their organisation. Prompted, LocalA1 had visited manufacturer’s websites in the past and the EA site for information on watercourses and was aware of ‘What’s in your Backyard’. They had also visited the Amenity Forum website in the past.

Finally, in terms of other measures taken to protect water, LocalA1 replied “Minimal use of chemicals around any water. It is only if absolutely necessary that we treat near water and only if it is with invasive species and then we would use a stem injector where it is very targeted”.


LocalA1’s organisation uses CDA and knapsack equipment, the latter for the fine turf situations. CDA equipment is given an annual service and then repaired if the operator notices that the spinner is not working properly. Knapsacks are calibrated each time they are used, especially with different products. They are not calibrated when moved to different locations. All spray operators are trained to PA1 and PA6.

Pesticides are stored on site and the store is a metal walk-in chem safe. The choice was made as this type of store allows staff to sign in and sign out chemicals. “It has spillage tray in the bottom in case there are any problems and it has enough space to allow the guys to see all the chemicals without having to look through boxes and bottles to find what they want and it is very secure”. Probing further on the spillage tray it is a “…false floor so that if there is an incident it can be removed and cleaned”. In terms of quantities, LocalA1 guessed that store could retain 110% of the product held. Whilst the store itself is external to any building it is correctly signed and has a step up to get in. For moving concentrates to and between jobs, vehicles are equipped with top accessed steel and lockable boxes. Asked where to go for information on the appropriate standards for fixed and mobile stores, LocalA1 replied “No, I would probably Google this”.

Questioned about precautions used at filling, unprompted LocalA1 stated “They would probably talk through with the supervisor what products to use. They would assess what the problem is, select the appropriate product and read the label.” Next, would be to select the appropriate PPE, and probably mix on site as the majority of fine turf sites, for example, have water on site. The knapsack would be filled with water then add the chemical. Probing about how exactly the knapsacks are filled with water, LocalA1 says these are filled directly below a standpipe, not using hoses.

Prompting about matching containers to the task, LocalA1 replied that “Generally they are using a few 100 millilitres…they are in 1 litre containers and they do not need to mix more than one product on site”. At the end of the operation, spray tanks are cleaned on site with fresh water and diluted product is applied to the treated area. The respondent was not aware that spray tanks and pesticide containers needed to be triple rinsed, nor the volume that needs to be used on each occasion.

Any spillage “…would be minimal due to the volumes involved…and would be cleaned up with water”. LocalA1’s turf operators do not carry spill kits, “If there was a particularly large spill they could use the granules, but I doubt that this would be necessary given the small amount of chemicals”. The same operator mixes and applies.


Empty containers are stored in black bags in the organisation’s chemical store and are then removed by a specialist contractor. Any old products or concentrates no longer required would also be disposed of via the contractor.


Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA1 stated they identify the weed, disease or pest, and then “…look at the approaches that are available. If there is a small infestation on a bowling green then we would expect the fine turf technician to use a knife. If it was a major infestation on a football pitch we are not going to be able to do that cost-effectively…and we would use a chemical treatment”. Prevention is also adopted, for example the use of iron sulphate to harden the turf on bowling greens to prevent fungal infection, “We swish to remove dew, they are fed and are aerated”, various methods to prevent disease developing and “…minimise the need for chemicals”.

Before actually using a pesticide questions asked would include “Is it cost effective to use a chemical? Can we put up with the infestation?” For example, LocalA1’s organisation has not treated the headlands of football and rugby pitches for several years, and it now shows. They may well start a programme of works to improve these areas and then leave again for several years, “There are times when we will put up with a problem…” Prompted about dose rates and potential for pesticides to leave residual effects, LocalA1 will tend to avoid treating areas “…where we are aware that major planting is to going to take place. We don’t tend to use residual herbicides anyway. Dual, for instance, is only used for obstacle spraying”. Rather than reduce manufacturer’s rates, LocalA1’s organisation tend to consider whether a treatment is required that year or not, “We have not sprayed our shrub beds (with a residual) for several years”.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, from the list presented, key factors identified by LocalA1 were:

• Chemical treatment more effective than alternative options: “For us it is the control of fungi on fine turf”. Although using aeration, swishing, iron treatments, chemical control remains the only means to eradicate the problem.

• Lower costs of chemical treatments: “We strim our obstacles once every six weeks and we use one or two chemical treatments just to allow us to leave it that long. I guess if we didn’t use chemical treatments then we would be haring around”. Prior to joining LocalA1’s organisation did a cost assessment and found this mechanical and chemical approach to be the most cost effective.

• Chemical treatment gives longer lasting effect than alternatives: Public and local councillor pressures in the borough mean that obstacles cannot be kept neat without the use of chemical treatments.

• Chemical treatment was the most practical method available: “It is the speed with which we can move through obstacles and shrub borders with the same chemical at the same time…it allows us to be the most efficient, and therefore has cost savings for the council”. Probing further whether this respondent could see a day when they could stop using chemicals, LocalA1 replied, “I can see that we can do it without a doubt but we would need more resources and we would have to accept slightly lower standards”

• Availability of alternative products or techniques: For LocalA1 alternative products would include heat or flame guns, “At the moment it doesn’t make economic or practical sense because of the time taken to apply these…it doesn’t stack up”.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA1 replied, (almost) “Always”.

In terms of alternative non-chemical approaches, LocalA1 mentioned hand-weeding and strimming, street sweeping (“…as often as we can get on to them”), mulching (“…shrub borders, prime parks”), soil aeration, correct fertiliser applications, drainage (sports surfaces), biological control agents (“…very rare to treat pests, some leatherjackets and casting worms”), and use of disease resistant stock (“…for nursery planting of shrubs, yes”).

The most often used non-chemical approaches used by LocalA1 are:

• Strimming – “Just because of the scale of the operation”. • Street sweeping – “We aim to hit every road in the borough every three weeks”.


Case Study LocalA2

LocalA2 is the area parks manager for an English city council with responsibility for the management, including vegetation control of the following areas: amenity and sports turf (latter includes two golf courses), shrub beds, gravel/ ballast surfaces, pavements/kerbs, and roads/paths (occasionally).



• Control of invasive species – Here the focus is Japanese knotweed • Local Authority policy – EMAS (Eco Management and Audit Scheme) policies cited, “The council

is very much looking at the environment all the time, at what we’re actually putting down. It’s not just the chemicals, but in everything, in pollution, fertilisers”

• Health of domestic animals/livestock – “We have to make sure we use safe chemicals because we do work out in the public and in people’s gardens. We’re very public and it’s strange how many people will say ‘will it kill my dog?’”

• Protection of fisheries/ angling interests – as a result PPPs are not used • Quality of grass/turf – high priority given the responsibility to manage golf and cricket courses,

“We’ve always put selective weed control down at certain times of the year” • Legal requirements – linked to control of invasive species, “We do have a problem in the city with

knotweed...the removal of certain products now which makes it harder and harder to do the job”

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA2 rated their knowledge as <Non-existent>; this was the manager’s response “I mean obviously it’s a long while since I’ve done my training” a colleague was also in the interview that dealt solely with pesticides.

LocalA2’s organisation had heard of BASIS (“That’s the one we used to pick our points up from if we went for any training, seminars or whatever”), and Amenity Assured (“I’ve heard of that as well, we had some contractor spraying done… some of our football pitches, the big boom stuff now, it’s more cost effective to have a contractor come and spray it for us than to do it ourselves”). LocalA2 had not heard of the other listed associations.

Within LocalA2’s local organisation of the 6 FTE staff the number trained/qualified were as follows: BASIS – 0 (contractor yes), BASIS register – 0 (contractor yes), BASIS Power – 0, BASIS storekeeper – 0 (contractor yes), BETA – 0, NPTC – 6 (all PA1 and PA6, but only a few have PA2, respondent did not know exact numbers), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 6, trained in 2006 Codes of Practice – 6.

Within LocalA2’s organisation a BASIS trained individual is responsible for developing the policies for pesticide use, making and checking recommendations and in tender preparation and evaluation, the latter for some contract spraying on bowling greens and golf courses, football and golf fairways.


Unprompted to the question about protecting human health, LocalA2 stated, “Firstly it’s training. Obviously we’re quite hot on PPE. We’ve also got COSHH training, not yearly, but it’s as required… Obviously we do have signs to put out if we’re on the estates”

Prompted about other steps to protect workers, the spray operators have access to COSHH assessments for all chemical jobs, and have to complete check-sheets and understand the task before any work starts. Prompted on health surveillance “We do have a corporate health surveillance policy, but I don’t think that covers this. The chemicals that we use, with a couple of exceptions, are fairly friendly”.

Asked if there particular scenarios where extra vigilance is required, LocalA2 replied “The only chemical that we do use, and everyone is a little bit more careful with that, and that is Timbrel (picloram) because obviously that is one that can cause harm, so the guys are a bit more aware of that”.

Looking at steps to protect the environment, unprompted LocalA2 could not think of any situations of high risk, “…all the stuff we use is pretty harmless”. Prompted, LocalA2 stated that they avoid spraying near water, conservation areas and SSI’s, “I’d probably say that it comes into the whole reducing the chemical


you use anyway, using woodchip on parks particularly, that’s what I'm thinking, to try and move away from using chemicals… it’s back to the EMAS again”. Probing further about open parkland, spraying here is only an issue if contractors are required to use a boom-sprayer, not so when using CDA’s locally. With regard to the effects of weather, LocalA2 replied “We’re quite lucky in respect the Nomix stuff we use is rainfast in an hour, so that does give us a bit more leeway than you’ve got perhaps with wet spray, but yeah, if it’s raining then no, and the same for wind as well. Again with the CDA’s, they're not prone to drift like the knapsacks are, but you’ve still got to be careful”.

In terms of advice, LocalA2 works with the local Conservation Officer, the council’s EMAS team or their supplier. Asked about the listed websites, LocalA2 had heard of the EA’s ‘What’s in your backyard?’ site but had not visited this, nor those of the CRD and Amenity Forum.

Finally, in terms of other measures taken to protect water, LocalA2 reiterated that they do not spray around or near the lakes under their management.


LocalA2’s organisation uses CDA’s. These are serviced annually, over winter under contract with the supplier. In terms of calibration, LocalA2 replied “Lampposts, fence lines – fence lines are much easier to calibrate with, but the obstacles and trees, just going around them, it’s very difficult to calibrate for them”. Knapsack sprayers are rarely used in LocalA2’s organisation.

Probing further about any difficulties associated with calibrating, LocalA2 replied “It’s certainly the knapsack, that’s the reason why we’ve gone away from the knapsack, because obviously with the Nomix, you can go out, you’ve got a pack that you just click in and away you go, there's no mixing, there's no need to take water. It’s knocked out so many of the variables and the problems we used to have.”

In terms of training, aside from being NPTC certificated then reviewing COSHH assessments and product labels each year is done.

Unprompted about the construction of chemical stores LocalA2 replied, “We store chemicals in a locked steel container, inside which is a chemical bin and that bin is then bunded”. Prompted form the list, the bund is considered sufficient to retain 110% of the total quantity of product stored, and is not compromised by exits and entrances. The container is situated away from water and is clearly roofed.

Questioned about precautions used at filling knapsack sprayers, unprompted LocalA2 stated “Gloves, proper PPE, gloves, overalls, etc., face shields, as required by the product. We make sure we’re mixing in a place where it can’t get nowhere, so any spillages are contained”. Probing further about any other precautions, especially away from the depot, LocalA2 replied “All the vans have locking backs, so it (PPP) can be stored locked away safely, not in the vehicle. Again make sure they're in the containers, not just tipped out into a bottle. Obviously if they were taking it out they’d have to take water with them as well”.

Prompting from the list, operators are instructed to follow label instructions and avoid contaminating water supplies. Asked about rinsing, LocalA2 replied that for the one knapsack in use this is cleaned back at the depot and washing applied to a designated area. The same goes for any empty containers.

All empty PPP containers are stored in a bin, along with any spent CDA cartridges. A subsidiary of the supplier is contracted to collect any waste materials.

Asked about why these disposal options were chosen LocalA2 replied, “The whole reason we went to Nomix isn't only because of the disposal but it was that we could get rid of mixing, get rid of water, the whole system, it works a lot better for us and again you're negating a lot of manual handling issues with having X amount of water on your back. They are more user friendly. And also when staff are working out in the environment, like in the streets and that, in the old days when you were all dressed up, you wore masks and everything, you looked like a spaceman coming along, nowadays walk around with coveralls with their CDAs, they don’t look quite so conspicuous… (the general public) think you're watering or the other one is metal detecting because it beeps”. LocalA2 also stressed that the CDA approach saves transporting chemicals, avoids the risk of spillages, and “…when you finish spraying you just stop, that’s it, nothing left in the tank”.



Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA2 immediately replied “Just an observation, it sounds like a lot of that has been put into our EMAS manual, because what you’ve just said sounds like it’s come out of our EMAS manual!”

Local2A stated that the priority for hard surfaces was focusing on areas that must be kept weed free. PPP’s are a preferred approach as they are less labour intensive then strimming, “The estates, obviously we have a huge amount of obstacles, fence lines and you just would not have the manpower to go and strim those every other week so you’ve got to look at putting the chemicals down”.

Probing further about the management of fine turf, LocalA2 replied “…it’s cultural methods, we’ll be looking at putting down things to treat Fusarium and things like that, that would be a last resort”. LocalA2’s organisation also mulch shrub beds, using chippings from other jobs on the borders, “again a lot of it is from the EMAS manual, we’re trying to recycle as much as we can”.

Prompting from the list, LocalA2 clearly recognised the need to identify the problem first “…because you need to be treating it with the right products otherwise you may not achieve anything”. Managing weeds due to their visual impact can be important at times, “Our housing department have put lots and lots and lots of knee rail type fences around the housing properties, which OK, when it comes to mowing we have to spray out the fence lines to keep a margin for the mowers to get in there or everything looks overgrown and a mess”. LocalA2’s organisation also considers the residual effects of herbicides. In the past they would have made extensive use of chlordane for Japanese knotweed but have now moved to stem injection where “…you’re only killing the target and not everything else”.

On the issue of manufacturer’s rates, LocalA2 commented that they have experienced a loss in efficacy from glyphosate on broadleaved weeds, “…broadleaves come back now quicker than anything, yeah and obviously we’ve gone onto a different chemical, which works in some places and doesn't in others”. Overall, LocalA2’s organisation follows label rates “It’s looking at the instructions to see what the rate is for whatever you're dealing with”.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, from the list presented some of the key factors identified by LocalA2 were:

• Chemical treatment was the most practical method available – “Chemical treatment is the most practical certainly”

• Did not consider non-chemical control – Actually LocalA2’s organisation often consider non-

chemical approaches as part of their commitment to reducing chemicals under EMAS but often

find that they are not a solution

Probing for any factors that were missing from the list (Q21), LocalA2 replied “Staff time is something, because if there were enough of us we’d be out there strimming, but obviously there's not”.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA2 replied, (almost) <Sometimes>.

In terms of alternative non-chemical approaches, LocalA2 mentioned hand-weeding, strimming and mowing, brushing, grazing (cows are grazed on the meadows), and mulching (“Mulching is great, but we’ve only got so much mulch”), and for amenity/sports turf soil aeration, correct fertiliser applications and drainage (“…something we think about all the time”).

Case Study LocalA3

LocalA3’s organisation used to be a department of an English District Council until a separate commercial entity was created. Now holding a long-term contract with the council LocalA3 is responsible for their management, including vegetation control of the following areas: amenity and sports turf, shrub beds and gravel/ ballast surfaces.




• Control of invasive species – “If something is flagged up to us immediately we have council members onto us straight away so it’s very important that we keep them happy”

• Conservation of native plant or animal species – ibid • Health of domestic animals – “When we are doing open spaces we see a lot of dog walking and

things like that so we have to be very careful where we spray and make sure the chemicals we are using aren’t going to harm them”, it’s a proactive step to avoid the public accusing the organisation of killing their animal.

• Drainage/flood control – “Again, obviously open spaces do have drainages areas and we have to make sure that these are kept clear”.

• Legal requirements – “Knotweed was an issue. We’ve kept that under control and we’ve nearly got rid of it all, only very small areas now. A lot of the Parish Councils and Town Councils now have us to come in and do various areas that they have problems with so we’ve set up small (three year) contracts with them. If you spray knotweed obviously with glyphosate it takes a long time to kill it, but you can set up a programme that will kill it in time”.

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA3 rated their knowledge as <Fair>.

LocalA3’s organisation is not a member of any of the listed associations (Q4).

Within LocalA3’s local organisation of the 13 FTE staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 13 (all PA1and PA6), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 13, trained in 2006 Codes of Practice – 13.

Within LocalA3’s organisation there is no BASIS qualified person involved in developing policies, making/checking recommendations or the creation of tenders for any sub-contracting work. That said, all sub-contractors are BASIS registered according to LocalA3.


Unprompted to the question about protecting human health, LocalA3 stated, “Obviously they (spray operators) work within the rules of the NPTC and that’s signs, protective clothing…Risk assessments are carried out for the spraying and they would not spray if was too windy, they would not spray if it was too wet and if they have any concerns”. Areas are also treated when they are not many people around.

Prompted about other steps to protect workers, the spray operators have access to COSHH assessments ad there is a questionnaire-based health surveillance programme in place, “We also carry out three appraisals a year of each employee, so if they have any issues with anything they’re carrying out”.

Asked if there particular scenarios where extra vigilance is required, LocalA3 replied that during the summer months spraying near beach huts takes place either very early (sometimes 4 am) or very late and “You have to check the area first and have to work around the people. I can’t ask them to move because it’s their area”. The same precautions are taken in other public areas with high footfall, for example public parks. “During the summer they wouldn’t be spraying any longer than 9 o’clock in the morning because of the heat. We wouldn’t want anyone to be wearing a spray suit that is struggling”.

Looking at steps to protect the environment, prompted LocalA3’s organisation avoids treating near water and uses a cutting machine (a spider) for steep slopes rather than spraying. Training also ensures spray operators avoid treating near drains or where there is a risk of run-off contaminating water. The organisation does not get involved in vegetation management for SSI’s or conservation areas.

In terms of advice, LocalA3 “We’d go to the manufacturers, the people we’d bought it off. We wouldn’t be using it unless we were 100% sure of it”. The organisation also works with other departments to see if they have any experience of a particular product.


Prompted, LocalA3 stated that they had not visited any of the listed websites but the respondent had heard of the Amenity Forum.

Finally, in terms of other measures taken to protect water, LocalA3 reiterated that although he was trained to spray on water the organisation prefers to let others do this kind of work if required by the council.


LocalA3’s organisation uses “…knapsacks for the general day to day work and we have a very small hand held, they’re not even called booms, they are about a metre and a half long what we do the football pitches”. No one is PA6 trained.

On the issue of calibration, LocalA3 replied “No, I wouldn’t have said there is any regular testing of the machinery. We do replace machinery quite often. Anything that is at the stage that we feel it’s life cycle has had it, it just goes straight away”. Prompted whether there was a need to calibrate moving equipment over large distances the organisation covers or if changing products, LocalA3 was adamant that “We don’t have any large problems at all. We (also) tend to stick to products we know”.

Asked what kind of training spray operators receive after completing their NPTC certification, LocalA3 admitted that “Some of them are more highly experienced than others”, and suggested that junior staff were supported on the ground.

Unprompted about their choice of chemical stores LocalA3 replied that the organisation has several chemical metal and secured stores, “Properly bunded and within the law and everything”. Prompting further, the stores are all fire resistant, can contain the volumes of PPP stored, the bund is not compromised by entrances/exits, and stores are situated away from water.

Questioned about precautions used at filling knapsack sprayers, unprompted LocalA3 stated “The most important precaution is that the gentlemen follow their training and wear all the proper equipment and proper eye protection and carry out the filling of the knapsacks and things in the correct way and in the correct area, away from people that are generally near them”. The organisation’s policy is to mix product either at the depot or transport PPP concentrates inside secure chemical safes by vehicle, all of which are equipped with wash facilities and spill kits.

Prompting from the list, LocalA3 confirmed that staff are required to read product labels, that they fill their sprayers without contaminating water supplies, and “We wouldn’t ask them to work off any platforms” when filling. Interestingly, LocalA3’s organisation knapsacks labelled and assigned for the use of one PPP, “There are no issues with having to rinse out. If you’ve got a selective and you’ve been using Roundup there’s no worries about it not being washed out”. The tank-mixing of products is not practiced.

In terms of disposal, empty and cleaned containers (the amount of rinsing was not specified) are stored at each depot until such times as they are collected by a specialist waste disposal contractor, “It’s the easiest way of doing it to be honest with you. I don’t want any of our lads having to worry about that. We’re not trained to do it.” LocalA3 claimed that surplus spray was not an issue as correct quantities were only ever made up.


Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA3 replied “It depends on the area to be honest with you. If it’s a play area we would not use pesticides. If it’s an open space we would use very small amounts because of dog walkers. We only use what we need to use. We would then carry out certain other operations so we don’t have to spray those areas”. Asked whether this meant the use of alternatives, LocalA3 replied “Yes, we look at all options”.

Asked whether appearance was ever balanced against the financial cost of treatment, LocalA3 replied “The health and safety of our men is upmost with us. We wouldn’t have them cutting costs at all otherwise we wouldn’t be doing our work”.

All decisions on whether to use a PPP are taken by the respondent and staff that are trained to do so, “We make decisions on where we spray. We do a lot of checking into areas first”.

LocalA3 was an advocate of using lower than the manufacturer’s recommended dose rates, “It’s just knowing your chemicals… and that’s why we stick to the same ones”.



• Chemical treatment more effective than alternative options – “It is unfortunately more effective” • Chemical treatment gives longer-lasting effect than alternatives

Questioned whether alternatives to PPP were available, LocalA3 replied “I’d say it’s 50/50 to be honest on that. No we will look at everything. I’ve been spraying chemicals since I was 18, I’ve had my license since I was about 27 and I’m now 50 so we’ve been using them a long time”.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA3 replied, (almost) <Sometimes>.

In terms of alternative non-chemical approaches, LocalA3 uses the following approaches: hand-weeding, cutting/strimming/mowing, brushing, mulching, correct fertiliser application, drainage (“We always make sure everything is drained properly”), and disease resistant varieties. Probing further, LocalA3’s organisation had tried steam and burning, but the results for both were “Pretty poor to be honest with you”.

Case Study LocalA4

LocalA4 is a team leader in a Scottish Unitary Council with responsibility for the management, including vegetation control, of the following areas: amenity and sports turf, woodland, tree/shrub beds, riparian areas, open water/aquatic areas, gravel/ballast surfaces, pavements/kerbs, roads and playgrounds.



• Financial pressures – “Because everything we’re doing, it’s obviously a big factor regarding budgets and money… we don’t use any residual weed killers now. Again they were getting expensive”

• Survival of trees/shrubs/bedding – “…obviously we don’t want to kill the stuff!” • Legal requirements – “From a legal point of view we’ve got to follow the rules. It doesn't matter

how cheap it is, if it’s not in the rules we can’t do it”. Probing further about whether the activities of LocalA4’s organisation are being monitored, the respondent replied “We get quite a lot of members of the public now phoning us up about ragwort, Japanese knotweed, that sort of stuff, people seem to be more aware of it and they're in touch with us more often. I can remember in years gone by nobody mentioned Japanese knotweed 15-20 years ago, but lately, I don’t know if it’s because it’s been on the television but people are certainly aware of it now and we’re getting quite a lot of calls to treat it on land that belongs to us”.

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA4 rated their knowledge as <Good>, “I wouldn’t class myself as an expert, but I know about it”.

LocalA4’s organisation is not a member of any of the listed associations.

Within LocalA4’s local organisation of the 50 FTE staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 30 (all PA1and PA6, one with PA2), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 30, trained in 2006 Codes of Practice – 30.

Probing about the lack of BASIS storekeeper certification, LocalA4 replied “We just buy small quantities at a time so we’re not registered for BASIS for storekeepers because we keep our stock below the minimum level”. Regarding training, refresher training is organised via Lantra every 5 years, and for new staff they are fully trained “before they can use weed killer”.

Within LocalA4’s organisation there is no BASIS qualified person involved in developing policies, making/checking recommendations. The organisation does not commission outside contractors.



Unprompted to the question about protecting human health, LocalA4 stated, “We’re obviously using Roundup Pro Biactive virtually 100%. Our guys are all trained, as we’ve already mentioned, and we have a health surveillance programme”. Probing further all staff is monitored by an occupational health doctor for any symptoms relating to the use of herbicides, usually annually or as required.

Prompted about other steps to protect workers, the spray operators have access to COSHH assessments, risk assessments and method statements. In addition, “All our guys are issued with PPE relating to the product they're using”. Questioned about the use of signs, “Lately we’ve only been putting a note in the local paper saying spraying operations will be taking place during the growing season, but it’s not too specific”.

With regard to steps taken to avoid spraying in areas of high footfall or occupied schools, LocalA4 replied “For schools we try and do them at the weekend or at the very worst when the classes are in. Some of the stuff it’s impossible, but for example we spray the main streets at 6 o’clock in the morning when it’s quiet. Sometimes you can’t avoid spraying some of the areas when there are people about”.

Asked if there particular scenarios where extra vigilance is required, LocalA4 replied “Public parks and obviously play areas is a big problem. We try to close them off just for a period of time”. LocalA4’s organisation has also changed the way they treat football pitches, moving from applying a selective herbicide to an approach where the herbicide is incorporated with a fertiliser, “It wasn’t what we were doing that was dangerous, it was people’s perception that was dangerous when they saw a sprayer. The amount of people whose dogs seemed to be ill when they saw a sprayer was unbelievable”.

Looking at steps to protect the environment, unprompted LocalA4 considers water courses and associated drains where the risk from using pesticides is highest. Prompted about other at risk situations, LocalA4 agreed that SSSI and/or conservation areas could be included, and also “I suppose any parkland, countryside walks, that kind of stuff. We’ve got quite a big mileage”. Probing further, surface type is a consideration where there is a risk of run-off, and “Obviously verges, we’d be doing that next to drains. With regards the weather, we’ve had to use some of the quick acting stuff, the 450 as opposed to the normal 360 in periods of showery weather so that obviously it’s not getting washed into the drain”.

Questioned whether there are any particular websites they would use for get information on pesticides, LocalA4 stated “No, not really, not with the type of stuff we’re spraying, I’ve not found the need for that”. Prompted about the use of the CRD website, “I have done in the past, but not for a long time”. Manufacturer’s websites are used to update COSHH assessments but rarely, and the respondent has not used the EA or Amenity Forum websites.

Finally, in terms of other measures taken to protect water, LocalA4’s policy is to leave a 6 metre buffer around waterways and strim this area.


LocalA4’s organisation uses knapsacks mainly and a buggy for treating kerb edges. Both sets of equipment are only calibrated at the beginning of the season. Noted earlier, the organisation only uses one product and observed, “We don’t produce plants, we don’t have a golf course, we don’t have a bowling green. It’s a very basic area, there's no formal gardens or anything”. They would calibrate after repair and maintenance.

Noted earlier, all staff are NPTC trained to calibrate their equipment, and LocalA4 commented “We get a contractor in to service our equipment, the knapsacks and that once a year”.

On the topic of how the chemical store is constructed, unprompted LocalA4 replied “It’s a proper store. It’s one of these container type things with shelves, a sump in the bottom and a fan in the roof”. Of metal construction, the store is situated away from water and is audited yearly.

Questioned about precautions used at filling knapsack sprayers, unprompted LocalA4 stated “Obviously the guys are trained so that they're not filling the knapsack next to waterways or drains, just for spillage”.

Prompted about their policy on label instructions, LocalA4 replied, “…it’s knapsack filling so you're decanting from a container into a measuring jug into the knapsack, obviously following the labels on the containers”. Operators had no problem matching the container size to the task, “…we’ve been using the same thing for the last 20 years”. Probing further about what steps are actually taken when filling the


knapsack, LocalA4 replied “You're assuming that I can spray, obviously fill the container, pour the water in and then rinse it three times, store the measuring jug back in the secure area, put the weed killer back in the safe store”. LocalA4 confirmed that “…each squad has got a spill kit just in case, they’ve never used them”.

Turning to the disposal of empty PPP containers, LocalA4 stated “Well the containers are triple rinsed, punctured and then they're took away for plastic recycling” by the council’s waste disposal team. Any surplus diluted product or waste water is “Sprayed out in an area like gravel or hard-core. I would to know how many gallons are flushed down the drain by the general public”.


Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA4 replied “At the moment we tend to automatically use (a pesticide) which I know is the wrong thing to do, because I'm not aware of a system that’s as effective as spraying. I'm not that clued up on alternatives and I’ve not had any experiences in any alternatives”. Probing further, “We only spray herbicides and it tends to be just turf edges and areas where strimming has not worked”.

Enquiring what is the financial relationship between strimming and herbicide use, LocalA4 replied “I reckon it’s 6 times more expensive to strim than it is to weed kill”. Exploring further whether the organisation ever considers leaving an untreated area as the cost of a PPP is more than the damage or visual effect of the weed, LocalA4 replied “What we’re doing now is starting to leave more and more areas and we’re applying less weed killer. Instead of spraying maybe three times a year with a non-residual, i.e. Roundup, we’re doing it twice. Obviously it could end up with being worse”. The key drivers are cost savings and with a view to the environment, “For example kerb edges, we used to spray kerb edges three times so there was no weed growing up through the kerbs and paving slabs and that type of stuff, but we reduced it to two and the number of complaints increased but we’ve kept it at two and just tried to alter the timings, but it’s not easy”.

Asked if the organisation ever adjusted the PPP dose to avoid damaging an area, LocalA4 replied “We read the label and that’s it”.


• Chemical treatment more effective than alternative options – “…at the moment I haven't got a lot of experience of alternatives”

• Availability of chemical application equipment – “Again it’s easy to get a hold of, as opposed to some of these new things that are coming out, burners and what have you”

• Chemical treatment is the most practical method available – “That’s a 5 for me at the minute” • Availability of alternative products – “I'm not aware of any, nobody is sat on my door saying come

and have a look at this, this is the answer to your problems” • Information on alternative products – “I'm not aware of them, why are people not coming around

and showing us them and how good they are?”

Looking further at some of the responses given, LocalA4 stated they could not remember when the organisation’s policy on PPPs was ever reviewed. Asked who should be responsible for disseminating information on alternative products, LocalA4 replied “…initially the government and then hopefully contractors”.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA4 replied, <Sometimes>.

In terms of alternative non-chemical approaches, LocalA4 uses the following approaches: hand-weeding, cutting/strimming/mowing, brushing, mulching, correct fertiliser application, drainage and disease resistant varieties.

Of these, the most commonly used in order are:

• Mulching – in shrub beds mostly, “We used to buy a product called Casoron G, it’s come off the market, so we decided we’d mulch our beds as an alternative to using a residual spray”

• Strimming and cutting – along walls and fence lines around play areas


Case Study LocalA5

LocalA5 is an Environmental Services Manager for an English unitary authority with responsibility for the management, including vegetation control, of the following areas: amenity and sports turf, forestry, tree/shrub beds, riparian areas (limited), gravel/ballast surfaces, pavements/kerbs, roads and car parks.


Asked to identify from a list which factors most influenced the organisation’s current priorities for the control of vegetation, LocalA5 indicated most influence, amongst others, coming from:

• Local authority policy – “We’ve got a duty of care to everybody…we follow the Code of Conduct for the actual pesticide use and basically it’s one of these things where if a member of the public identifies our guys out there, they will write in and ask us what's going on? It’s freedom of information basically, if they ask us the question, they get the information”. Probing further, the council make two spray passes a year and these generate questions from around 10 people which policy dictates are met with and their concerns discussed.

• Disease control/prevention – Again activities near a high profile generates a lot of interest from the public

• Financial pressures – “We used to do a 3 spray a year and we’ve had to go down to a 2 spray. Where we used to pay a contractor to come in, we’ve now brought it back in house, so the financial constraint was that we had to get the guys all PA1, PA6 trained to use the products we were using, so there was a pressure on the financial budget”

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA5 rated their knowledge as <Fair>; the respondent is comparatively new in to role but has two colleagues who are very experienced spray operators who “…know the Code of Conduct inside out, they’ve actually told me a few things as we’ve been going through the season”.

LocalA5 believes the organisation is a member of Amenity Assured, and the BASIS advanced contractor certification scheme.


Probing further about NPTC training, all certificated staff completed a familiarisation course last year at a local college, “…just to make sure they're still up to speed”. Going forward this will be done annually.

Within LocalA5’s organisation there is a BASIS qualified person member of staff. LocalA5 will also consult with outside BASIS registered people to help the organisation develop its policies and for making/checking recommendations. The organisation does not use outside contractors.


Unprompted to the question about protecting human health, LocalA5 stated workers have access to full PPE, and “For protecting the public we put signage out to say we’re in the area spraying. If the public are in the vicinity the guys actually stop spraying until the public walk by. If it’s high profile areas….like the city centre we do early morning sprays rather than when people are about. We’ve got employees who know if they come in early they know they can go home early”.

Prompted about other steps to protect workers, the spray operators have access to COSHH assessments, “The guys carry COSHH assessments and risk assessments on their van as well. They’ve got access to that and they also carry the Code of Conduct with them as well”. In terms of health surveillance a team from BUPA checks staff with a battery of tests annually and if anyone falls ill they are sent over immediately for an assessment.

Looking at steps to protect the environment, unprompted LocalA5 replied “If you're working near water courses and things like that we don’t actually touch the footpath, that’s all down to the Environmental Agency, which is good”.


Prompted about precautions taken near drains, LocalA5 replied “…we don’t have a lot of open drains. We’ve got the normal storm drains in the highways, but again the guys, if they come up to a drain what they would do is stop say 8-12 inches before the drain, then start again after the drain, so they don’t actually spray across the top of the drain”. SSSI’s and conservation areas fall outside of LocalA5’s remit as are all but the hard surfaces in parklands where care is taken to avoid spraying near the general public. Regarding weather conditions, “…the guys will not go out if it’s raining because of the product we use (glyphosate-based) needs a 20 minute drying time”.

Asked where the respondent would turn to for information where the PPP may have restricted use or the risk of use was greatest, LocalA5 replied “If we need anything like that the first thing we do is talk to our health and safety team, they will then look on the HSE sites, they would look on our suppliers websites to see what they would suggest we use”. Prompted about the Amenity Forum site, “I’ve heard about it, but I’ve never used it myself” and the same response was given for the EA ‘What’s in my backyard?’ website. Overall, LocalA5 prefers consulting manufacturer’s sites, “I find it easier going the way I go because I get everything, I get all the data sheets”.

Finally, in terms of other measures taken to protect water, LocalA5’s policy is to leave this to the EA, “We do a lot of stuff for them, but they do a lot for us”.


LocalA5’s organisation uses primarily CDA equipment (90% of all tasks) and knapsacks. In terms of testing and calibrating the CDAs “The guys obviously do their daily checks on it. If we find anything wrong, we send it to a company in Bristol (Nomix) they check it all over and bring it back”. The organisation keeps five sets of equipment so there are always ‘spares’ if required. Probing further, spray operators will do a test area before starting as well as “…look back to the area they’ve done the previous day to make sure they're OK”.

All equipment across the organisation has a maintenance check weekly, with knapsacks done daily. If there are any problems with calibration and these cannot be fixed the sprayer is sent away for repair.

On the topic of chemical stores, LocalA5’s organisation uses a converted building, with a lockable steel door. Prompting from the list, the is store bunded, fire resistant, large enough to hold contain any leakages, but does have a water supply running alongside, housed though within 3 inch pipework. The store is audited annually by the council’s property services, who the respondent believes is familiar with the Pesticide Code of Practice.

In terms of managing concentrates, PPPs are transported to the job in lockable steel containers in the back of their vans.

Questioned about precautions used when working with the CDAs, unprompted LocalA5 stated that they would check the equipment and chemical bungs for signs of leakage, connect the CDA and prime the system before checking with the other team member, “What they do is they double check each other all the time”.

Turning to the knapsack sprayers, “What they do is look at their instructions and they work out what they wanted to do for the day and how much they’d need”. Operators try to take the minimum they need for that day’s work. Prompting from the list, operators also carry enough water for the day’s work, plus “…they carry either two or three 5 litre containers of fresh water in case of spillage or they get anything on top of them and they’ve got the clean water to swill it straight off”. Sprayers are always prepared on a “…flat, hard surface, away from any vegetation whatsoever…” mostly at the back of their van; “…they would look for any water courses, drainage and things like that”. In terms of the process used for rinsing, fresh water is used, “The official guidelines are that they're meant to do a three rinse. What they do actually out on site I can’t comment on because obviously I'm not behind them 24/7”. Any contaminated wash water is applied at the application site.

Probing further about management of clean and empty PPP containers, “They carry big bin bags with them and each container is put into a separate bin bag, tied up and left in the back of the van until they come back”. All vans have a spill kit comprising “…a sponge thing that goes around the drain, if they spill anything by a drain, they also carry granules with them, spill granules and they carry a brush and shovel as well to pick it all up”.


Turning to the topic of disposal, LocalA5 stated any unopened product not used at the end of the season is returned to the supplier. Empty containers are stored in a ‘cage’ provided by the supplier and removed by them for formal disposal. This particular options was chosen for its ease of operation and “…we haven't got the hassle of disposing of any waste at our end”.


Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA5 replied “What we do is look at the area first, we determine what is in the area. Basically if it’s outside of a school we would rather go along, smack the heads off the weeds with a shovel and the guys would dig the area out and sweep it. What we’re trying to get through to our staff at the moment is if you don’t sweep an area in the right way and do a good job you are giving the ground for a weed to grow”.

Probing further on the topic of brushing, LocalA5’s organisation is looking to invest in polywire brush attachments for their mechanical sweepers with a strand of wire, “That sort of digs out the roots” trying to remove the plant before it becomes a problem, “Obviously around schools, hospitals, high volume areas for footfall traffic, we tend to try and use the sweeping before we go in with chemicals”.

Enquiring whether the visual impact of the target problem is ever weighed against the cost of the PPP, LocalA5 replied “We don’t go out and do every weed. We would probably go to no more than 10% of weed being there. 10% of an area, so that’s the trigger point. After that point you start getting the general public interested”. Asked whether the organisation ever uses a lower dose of PPP to avoid damaging the area being treated or risk the next crop planted, LocalA5 felt that this was something high on the agenda for the fine turf and major parks operatives.

In terms of seeking outside input to help with decision making, LocalA5 consults with outside contractors before each season and also networks with other authorities, “…to see what they're doing, how they're doing it. What we do is we visit each other as well and we identify things”.

Asked whether the organisation looks whether it is possible to reduce the amount of PPP used, LocalA5 replied, “I would like to see zero tolerance on chemicals personally, I would like to see more sort of people on the ground, brush, shovels, trowels, things like this and just digging it all out”. The limiting factor quoted was budget constraints, a cost:benefit analysis “…always come out that the treatment side is cheaper than employing staff to do the work manually. To actually do the full sweep and have no growth at all you would either have to double or triple the size of the workforce. Where we’re getting around areas of doing a manual sweep about every 24 days, to keep on top of it we would have to do it at least weekly”, a five-fold saving by using glyphosate.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, LocalA5 gave a strong influence score (4) to virtually all. A selection of these was probed further:

• Lower cost of chemical treatment – “We only use the one product because of the area we’re in” • Chemical treatment was the most practical method available – “My views on non-chemical, if you

can do it without a chemical then you should do it. The reality is doing the most effective way and the quickest”

• Chemical treatment was the more environmentally friendly – “Well again it depends on what chemicals you use. No chemical doesn't harm the environment in some way”

• Availability of and lack of information on alternative products or techniques – Broadly the respondent feels there is too little information out there on alternatives. The respondent feels that central government should take the initiative in bringing together a package of alternative approaches and then “It should be pushed to local government and then they should be given performance indicators on how they're working with it and they should reach a certain standard within a certain time”.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA5 replied, <Always>.

In terms of alternative non-chemical approaches, LocalA5 uses the following approaches: hand-weeding, cutting/strimming/mowing, brushing, steam, grazing, mulching (“We use what we mulch to go back onto the park areas”), and disease resistant varieties. Probing further about the use of steam, LocalA5 replied


“We use a hot wash (in the town centre) on a daily basis. We’ve got a £100,000 machine especially to do this” which as a secondary benefit gives weed control.

Of these, the most commonly used:

• Brushing – a daily activity in the town centre. • Strimming and flailing - is done on a rota system on the outskirts, with a scheduled cut of all

verges, “They're reaching an area every month to five weeks on the outside” • Hand-weeding - more in the major park areas, the botanic gardens, the town gardens, and the

high profile parks • Mulching – “We would do that at the end of each winter season when we do the actual pruning of

shrubs and stuff like that, we would mulch it all and put it back on the main flower beds in the spring to supress weeds”.

Case Study LocalA6

LocalA6 is an Operations manager for a Welsh unitary council with responsibility for the management, including vegetation control, of the following areas: amenity grass, sports turf, tree/shrub beds, riparian areas (occasionally), gravel/ballast surfaces, pavements/kerbs, roads, highways (verges/landscaping), and building roofs.



• Protection of nature conservation areas/wildlife habitat – “We’ve got a number of areas, conservation areas, etc., where we do not use herbicide at all”

• Conservation of native plants or animal species – linked to the above, “If we would have ragwort within areas, we would not apply chemical, we literally pull them by hand. We don’t put chemicals anywhere near our conservation areas”

• Protection of fisheries/angling interests – “Prior to applying herbicide adjacent to water courses, etc., we get a licence from the Environment. We don’t carry out any herbicide treatment to aquatic areas and obviously in relation to run off, we adhere to best practice”

• Drainage/flood control – As with water courses, herbicides are not used near drains and plants are hand-weeded.

• Quality of grass/turf – Bowling greens and cricket wickets, “It’s penultimate, but to maintain quality of grass/turf within our fine turf facilities, that we eradicate weeds, pests, disease, etc.”

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA6 rated their knowledge as <Good>

LocalA6’s organisation is a member of the IOG and NRoSO only.

Asked whether the council uses contractors or own staff to the do the spraying, LocalA6 replied that “all highway herbicide application is done by subcontractors” leaving the minor works to council employees and that the council are “…also a contracting organisation, we carry out work on behalf of developers and health authorities. We’ve probably got about a 100 external clients”.

Within LocalA6’s local organisation of the 75 FTE staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 28 (all PA1and PA6, two are PA2), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 28, trained in 2006 Codes of Practice – 28.

Regarding training, LocalA6’s organisation uses both the local agricultural college and other external sources and an in-house training school.

Within LocalA6’s organisation no BASIS qualified personnel are involved in the development of policies for pesticide use and the making/checking of recommendations.



Unprompted to the question about protecting human health, LocalA6 replied “First of all obviously accreditation, they must be accredited and know what they're actually doing and trained in the application of product, PPE, Personal protective equipment…each individual sprayer has copies of direct access to any relevant data sheets (COSHH assessment), obviously the transportation of the chemical, it’s carried out within containers”.

Elaborating further on the COSHH data sheets, “So if a member of the public wanted to know what we were spraying then each individual will have access to the COSHH data sheet and obviously that shows exactly what we’re spraying and any hazards associated with that”.

Prompted about the use of signage, LocalA6 stated that as the council spray all the roads and footpaths of all towns and villages in the county, “We do not advertise the fact of what we’re spraying and when we’re spraying”. On the topic of health surveillance, this is done periodically by the Health and Safety team in LocalA6’s organisation. Individuals complete a chemical log application sheet and record time spent spraying, “We don’t really hit thresholds. For that out guys would literally go out and if they were spraying for maybe 4-5 hours a day over a month, maybe even a 2 month period then that would probably be about it”.

Asked in what situations it was necessary to be more vigilant with regards workers or the public, LocalA6 replied that for non-glyphosate sprays, for example when treating fine turf with fungicides, the PPE requirements are greater; “The herbicides that we apply are strict glyphosate, which is very environmentally friendly, very safe to use, limited PPE”.

Looking at steps to protect the environment, unprompted LocalA6 replied “None simply because it’s a glyphosate product we’d be using”. Probing further, spraying adjacent to water requires an extra administrative step and authorisation from the Environment Agency. Prompting from the list, drains are classed as part of the road infrastructure in this organisation and treatment is sub-contracted, “…there's no residual chemicals applied, it’s only a contact glyphosate, translocated herbicide. Glyphosate because inert once it hits the ground”.

SSSIs and other conservation areas are not treated at all within this authority, “We predominantly spray what we call our mowing margins – basically trees, walls, that type of thing”. Questioned whether open parkland could be considered as high risk, LocalA6 replied “No, we do not. The only instance we would spray parks and open spaces, again it’s mowing margins, so there's no blanket spraying of grassed areas, it’s margins only”. Further, LocalA6 believes that given its safety record using glyphosate mitigates any risk from spraying slopes or different surfaces and given that it is “…rainfast within 1 hour, it’s very effective, no run off, no mist” the organisation also has more opportunities to spray than with other solutions.

Asked where the respondent would turn to for information where the PPP may have restricted use or the risk of use was greatest, LocalA6 replied “I would get that information from our suppliers, so if there was a fungus that we have to treat then I would obviously look for the least environmentally disturbing”. Prompted about the use of websites LocalA6 was adamant the only information source was their supplier, “We would trust them explicitly”.

Finally, returning to water LocalA6 looks to be targeting Giant hogweed, Himalayan balsam and Japanese knotweed, “They're notifiable weeds and that’s the only vegetation we spray adjacent to water… we do not blanket spray, so we only spray the identified plant”.


LocalA6’s organisation uses primarily CDA equipment which are “…calibrated on an annual basis, they're inspected every time that they're used”. Probing further inspection covers “any items broken, cracked, are the nozzles functioning properly? Is the battery functioning properly? The trigger mechanism functioning properly?”

Knapsacks are used for fine turf spraying and receive a quarterly inspection which is recorded. The equipment is also calibrated depending on the width of the lance. Any knapsacks that are “…deemed defective we replace”. NPTC trained staff are responsible for calibrating equipment.


On the topic of chemical stores, LocalA6’s organisation uses steel chemical containers, large enough to store 200 litres of product. The organisation also has mobile chemical containers that are fixed inside the backs of the vehicles. Returning to the fixed stores, “They're all within outbuildings, they're locked, they're bolted to the ground. The access point of those buildings have the COSHH sticker, obviously making people aware there are chemicals within the building”. Probing further, the buildings are former garages.

Prompted about their awareness of HSE agriculture information sheet #16, LocalA6 replied “Yes, safe storage, use and disposal of pesticides, yes”. Asked about resistance to fire, LocalA6 replied “All our buildings and premises have annual fire inspections…This is done via corporate building maintenance health and safety guys”.

Turning to what precautions are used when filling application, LocalA6 referenced their use of CDAs, “It’s literally suspended in oil, there is no mixing of chemical, it’s literally a fixing of pipe to the applicator. Basically it’s a box, attaching the chemical mix on the back. The back is then attached to the applicator. There's no mixing, calibration is the speed and width of the nozzle and flow rate. Once that chemical has been used in those applicators they (operators) literally shut off the flow to the applicator, they ensure then that any chemical within the applicator is spent, once that has been done the applicator must be cleansed with a cleansing agent just to wash through”.

Prompted whether operators read the label instructions, LocalA6 replied “Yes, according to data sheets, they would always cover all bases, depending on chemical, if they’ve got a leather boot on, they would put a cover over the boots. If they were to mix on the fine turf in the applicators they would obviously need masks, etc., but again as per data sheet”. On what precautions are used to avoid contaminating water, LocalA6 stated “…there is no hosepipe, so there is no possibility of backwash through a hosepipe, they will literally fill a container, a 10 litre container, a number of them with water, before they go out and they would then use water from the container to mix with the chemical”.

Asked about mixing of products using knapsack sprayers, “No, we don’t, it’s all single chemical” and in the case of spillages, “If they were to spill they’ve got like a granule that they use”.

Looking at the issue of disposal of empty containers, “They're actually collected. The containers that we use are a cardboard box which inside is contained chemical in bag, the cardboard box itself is taken away from the bag, that’s recycled and the chemical bags are put into special receptacles and they're collected on a periodic basis by our supplier”. The cardboard box goes through a normal waste recycling process. The chemical distributor collects any spent bags and other chemical containers, plus any concentrated product that is no longer licensed for use.

Probing for the management of diluted product in knapsack sprayers, LocalA6 stated “I would sincerely hope there is no product leftover. They are trained to only mix the amount of volume required for the actual spraying of the area”. In the event of rainfall, “…they would then go back out and finish the job at the nearest opportunity”.


Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA6 replied when prompted about the use of alternatives “No we don’t go down that road. The authority have actually stopped spraying completely and it’s got itself into a little bit of a muddle through it. Basically they’ve stopped spraying their highways and now they're left with buddleia and everything else within highway, the infrastructure highway is being compromised. No, we don’t go down that road, we apply herbicide”.

Probing further for circumstances where pesticide use is minimised, “Certainly we would only apply herbicide to the actual plant, we do not apply to uninfected areas, so the chemical is not dispersed broadly, it is literally localised on plant only”.

Asked what they did in terms of identifying whether the weed or pest is likely to be a problem, LocalA6 referenced a fine turf example, “Fusarium, which is a temperature, humidity affected fungal growth, depending on the extent of it, more often than not we would leave. Basically, depending on weather, etc., there's a strong possibility it would diminish without the use of chemical”.


Questioned whether an evaluation of other factors like financial loss, damage or visual effects ever outweighed the need to use of a pesticide, triggered LocalA6 to reply “By using the pesticide we obviously enhance the aesthetics, there are no weeds within the areas. The main reason we spray out amenity areas, the grass areas, of open space, the margin of areas, it’s for health and safety reasons, to reduce the amount of hand arm vibration received by operators of strimmers”. By spraying marginal areas (e.g. bases of walls, around trees or grass margins), LocalA6 believes this “…reduces the hand arm vibration and the need to strim probably by about 50-60%”.

Asked whether the effects of pesticide applications to a target area is considered important, LocalA6 retorted “It’s only glyphosate products and we could even apply seed within 2 days, once the herbicide has come into contact with soil it becomes inert”.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, LocalA6 identified most strongly with the following:

• Chemical treatment more effective than alternative options – LocalA6 was considering hand-pulling and strimming, the latter being against the authority’s hand-arm vibration policy. Interesting though that the factor, <chemical treatment gives longer lasting effect than alternatives> scored a 2, “Whereby we would apply once with a residual and a contact herbicide mix, now we need to apply two or three times”

• Chemical treatment was the more environmentally friendly – “That is why we’ve basically chosen to go down the Nomix method, we only use a glyphosate product on the larger areas”.

• Advice of consultant or contractor – “We’ve got a school site now with some fungi and things coming up within grass areas and basically what we’ve done before we’ve even gone and treated or purchased, we have taken pictures, sent back to our suppliers, they’ve then analysed, looked at and advised best way forward”

• Availability of alternatives – LocalA6 felt that the apparent lack of alternatives means that “…it’s a lot more efficient to apply the herbicide and it would certainly be as far as the operator concerned, a lot less risk”.

Questioned how often the organisation reviewed its policy in terms of chemicals compared with non-chemical approaches, LocalA6 replied “It’s discussed at health and safety forums, we have quarterly health and safety forum, lots of different things will come up within them and yes, that has been discussed. Certainly as I say we are watching neighbouring authorities just to see which way they are going, we would monitor success”.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA6 replied, <Sometimes>, “It is brought up I would say pretty infrequently within our forums…we took the decision following the Casoron product, once that was deemed unsafe for use, we then corporately took the decision to mulch the beds. Once that decision was made then effectively that decision was made, we wouldn’t go back down that road because we’ve effectively used a non-chemical method”.

In terms of alternative non-chemical approaches, LocalA6 uses the following approaches: hand-weeding, cutting/strimming/mowing, brushing, mulching, soil aeration, drainage, use of disease resistant varieties.


• Hand-weeding - “We wouldn’t apply a chemical around our annual bedding sites” • Strimming – areas for Himalayan balsam adjacent to water, cut before seeding. In addition,

outside the scheduled herbicide application periods (May and September) patches of groundsel and other weeds are strimmed during grass-cutting operations.

• Mulching – “Oh absolutely, all our horticultural sites, with the exception of annual bedding sites, are mulched”

• Brushing – “We have safety surfacing under our play areas, it’s basically a carpet, a synthetic carpet which is prone to moss and we would brush. We don’t spray those”

• Disease resistant stock – The authority has a lot of floral displays. The intent is to reduce the number of F1 hybrids as these suffer from disease and plant loss

LocalA6 has never used a biological control.


Case Study LocalA7

LocalA7 is a Grounds Specialist Officer for a unitary council with responsibility for the management, including vegetation control, of the following areas: amenity grass (bowling greens), sports turf, tree/shrub beds, riparian areas (Japanese knotweed and Giant hogweed), gravel/ballast surfaces, pavements/kerbs, and roads.



• Financial pressures – With budget cuts “Now we’re probably just getting away with the bare minimum”. Also without the financial constraints, “We might have used a different method of doing it. For example, around schools in the past hand-cutting would have been practiced but now do the costs of labour it is more cost effective to spray around the edges”. This has been a gradual transition over the last ten years, but has intensified in the last two.

• Control of invasive (non-native) plant species – down to serious problems with Japanese knotweed and Himalayan balsam.

• Protection of nature conservation areas – “We’ve got the nature reserves where we may have sprayed before or we may have had a different cutting regime and that’s been changed dramatically because of species that are one offs” that now limit spraying

• Financial constraints – “Every year we’re being cut so we have to adopt different methods. We’re just carrying on doing the cheaper version… yes and it might not be the cheaper version in the long term”.

• Legal requirements – This is about compliance and the organisation’s need to deliver against a programme of cyclic maintenance specified by the local Trunk Road Agency

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA7 rated their knowledge as <Good>.

Regarding membership of any of the listed association, LocalA7’s organisation used to a member of NRoSO, “But that’s gone by the wayside”. They did consider joining NASOR, but “…what we’ve done is we’re actually putting in place our own thing in line with that and in fact we’ve got one of the lead technical verifiers from City and Guilds coming round next year to update (and assess) all the staff”. The intention is to repeat this training every 5 years. LocalA7 organises regular fresher training and distributes relevant literature, ‘Like the ten golden rules of using pesticides” to all spray operators.

Within LocalA7’s local organisation of the 50 FTE staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0, BETA – 0, NPTC – 50 (all PA1and PA6, some also have PA6AW), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 50, trained in 2006 Codes of Practice – 50.

Within LocalA7’s organisation no BASIS qualified personnel are involved in the development of policies for pesticide use and the making/checking of recommendations.


Unprompted to the question about protecting human health, LocalA7 replied putting up signage to “Stop people walking across when we’re spraying” and “I think our most important protection is the educating of our staff”.

Prompted, LocalA7 said that the organisation has an annual appraisal as its health surveillance programme. Probing further, “We kind of have a matrix of what we use and the first thing is can we use a product that’s no mixing or anything like that, which is like a controlled droplet …to try and reduce operator contamination”.

Asked in what situations it was necessary to be more vigilant with regards workers or the public, LocalA7 replied that where they were using an anti-cholinesterase product, for example on bowling courses, operators would wear extra PPE and take extra care during handling.


Looking at steps to protect the environment, unprompted LocalA7 stated water courses, drainage, and run-off on hard surfaces due to surface type and slope. Prompting from the list, for SSI and other conservation areas, “…most of those are identified anyway and we don’t spray those areas” and for parkland, a conscious decision to go “…the safe route” and use glyphosate for any hard surfaces, where still permitted to treat due to cut-backs. In response to the impact of weather, LocalA7 replied “The lads are all aware of the drift… and six hours without rain, which is an impossibility at the moment”.

Asked where the respondent would turn to for information where the PPP may have restricted use or the risk of use was greatest, LocalA7 replied “Probably British Crop Protection and people like that”. Probing further, “We use the UK Pesticide Guide…We also have, which we forwarded the other day (to staff), information from Natural Environment and Agricultural Team from Aberystwyth”.

Prompted about websites, LocalA7 says that they obtain information from the CRD site, they use and receive annual updates from their supplier (Nomix), “Every other year now we get them in and they do a refresher training on the products that the guys are using… and they do send through the labels to me as well”. LocalA7 confirmed that they do not use the EA or Amenity Forum websites.

Finally, on any other measures used to protect water, LocalA7 replied “Yes don’t go near it. We tend to stay away from water… we’ve got some people coming to train with AW now. But a lot of the water stuff is actually done by a local rivers trust… we can only spray on our own ground”.


LocalA7’s organisation principally uses CDA lances, “Which are taken back and then calibrated every year by Nomix themselves”. Questioned about calibrating knapsack sprayers, LocalA7 replied “Well hopefully they’re done every time the operator uses them because they are trained operators”. Prompted, LocalA7 also stated this includes when changing products and moving to a different location.

On the topic of chemical stores, LocalA7’s organisation uses a metal chemical store, “…with the sump in the bottom in case of spillage and that sort of thing. And they can be segregated for liquids on the bottom and granules on the top if we use powders or granules”. The organisation has also invested in metal containers which can be placed in vehicles, “They’re just a smaller version of the big one where you can put half a dozen Nomix five litre containers in there but there is a sump at the bottom again so if there’s any spillage it’s contained within that”.

Prompting from the list, all stores are confirmed fire resistant and with sufficient capacity to retain 110% of the PP volume that is stored. The ‘sump’ is not compromised by exist/entrances and the fixed stores are located away from water and are roofed. The fixed store is audited every six months.

Questioned what precautions are used as standard when filling, LocalA7 replied “We try to keep that to a minimum and that’s why we use Nomix because it’s already mixed…Otherwise it would be a drip tray…(and) because a lot of time we’re out of site…it would be garden drums of water (for filling the knapsacks)…and we would also have clean water on site for the operator, just in case of spillages and that sort of thing, and they’d carry a spill kit as well”.

Prompting from the list, asked about following label instructions, LocalA7 replied “Well hopefully following the label instructions closely”. Probing further, “We try not to use knapsacks. I think knapsacks are really restricted to the bowling green, with 85-90% of all spraying achieved using the CDA approach”. Asked about safety when pouring, “Getting the glug in and wearing the protective equipment and doing it in a safe environment where they’re going to reduce spillage”. As to rinsing, the norm is triple rinsing with any contaminated water applied “Back on where they’ve been spraying”. There is no mixing of products. Cleaned and empty PPP containers are transported back to the depot in the chemical safes.

Regarding disposal of containers, these are collected together in bags and then “removed by the distributor”.



Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA7 stated that the first question to ask is “What is the weed and at what stage of growth?” The problem comes with something like Ragwort, “We can’t really identify that until we see it and then it’s too late to spray it so we hand pull it”.

Probing further as to the next steps, LocalA7 would assess if the problem needs to be sprayed. In some circumstances, for example Himalayan balsam, “…sometimes it’s a lot easier to cut it rather than spray it or pull it”. If a decision was made to spray, LocalA7 stated the next step would be an “Environment risk assessment, which will bring in the weather conditions and everything like that. Know what product we are going to use, which is going to be least harmful to the environment but effective in the same thing. No good using Roundup on Japanese Knotweed. Well it is if you want to do it for about nine years”. Another factor would be determining whose property the problem resides on, and this is not always clear in the case of road improvements; initially stay with the authority before reverting to the land owner.

Asked whether the effects of pesticide applications to a target area is considered important, LocalA7 replied that they rarely use residual herbicides, “…it would be for health and safety reasons like crash barriers where we want to keep the grass barrier clear, where it’s dangerous to put staff there, to strim them on a roundabout”.

Questioned if they ever used outside help to make a final decision on pesticide selection and dose rates, LocalA7 stated that they were not shy to consult with others, including the Biodiversity officer for timings, or people outside the organisation.


• Chemical treatment was the most practical method available – a focus here on Japanese knotweed and Giant hogweed

• Advice of consultant or contractor – “…because other people have got more specialist knowledge than we may have”

• Availability of alternative products or techniques – “I think there’s different ways of doing things…things are evolving aren’t they?” For example, “Some of our areas now we don’t cut or treat, they’ve actually gone back to natural and a lot of that is from cost restraints. So we don’t spray it, we don’t spray around the bottom of the tree…It’s just left to regenerate on its own. Times are changing”.

LocalA7 also asked why <Biodiversity Management> was not on the list of factors? “We have management plans and biodiversity action plans on certain sites. We have made a commitment to adhere to these plans and they have a strong influence in terms of our decisions on whether to use chemicals”.

Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA7 replied, <Always>, for example “Like the county old pond, we’ve decided to put a membrane down and going back to the straw system for the algae. It’s only a small scale but it’s something we can manage”.

In terms of alternative non-chemical approaches, LocalA7 uses the following approaches: hand-weeding, cutting/strimming/mowing, brushing, mulching, soil aeration, correct fertiliser application, and drainage.


• Cutting – Verges and hedges, “All our amenity areas actually wasn’t it?” • Brushing – Kerbs, kerb lines, hard surfaces and paving

Probing about the use of regeneration mentioned above, this is important on slopes, the drivers being physical access and in term financial considerations.


Case Study LocalA8

LocalA8 is a department head for an English borough council with responsibility for the management, including vegetation control, of the following areas: sports turf, trees, gravel/ballast surfaces (rarely), pavements/kerbs, and roads. A contractor is responsible for vegetation management, mainly hand-weeding) near or in aquatic areas. Much of other spraying for the authority is done by sub-contractors.



• Protection of infrastructure – “Because we get paid by the Highways to spray near roads and pathways”. LocalA8 felt that if the roads were of a better standard they probably wouldn’t need spraying

• Legal requirements – “Well when I first came here (3-4 years ago) we had a chem store…lots and lots of chemicals which shouldn’t have been used for a very long time. I don’t think any of them were being used to be honest but just being there, had to get them all shifted by the proper waste transfer. One of my JD’s (job descriptions) was to sort out all the chemical spraying and everything because they were ten, fifteen years behind. They were washing the knapsacks sprayers with fairy liquid and stuff like that…We did have an actual weed spraying document procedure and everything but no-one seemed to know it was there. We didn’t have any COSHH, no risk assessments, no proper chemical storage, anything”

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA8 rated their knowledge as <Fair>. “Yes when I first started I read it a hell of a lot. In my prime it was easy…. it’s a hell of a document… needs to be more user friendly. It’s like most government documents”.

LocalA8’s organisation is not a member of any of the listed associations but sub-contractors are members of BASIS and BACCS; the latter “…send lots of certificates but they also have trouble remembering that we are not contractors”.


Training is done through an outsourced company.

Although LocalA8’s organisation has no BASIS qualified personnel an external auditor helped prepare a pesticide policy document (in 2009) and tenders documents are prepared with the assistance of a BASIS registered individual, who also monitors what has been sprayed, including areas completed by the sub-contractors.


Unprompted to the question about protecting human health, LocalA8 replied “COSHH is the main one and spray times”, by that spraying in the early morning when no one is about. Probing further, LocalA8 noted “Making sure they’ve got the relevant training as well. PPE”.

Prompted, no formal health surveillance is done, and with regards signage, “No, we just haven’t got the time for that to be honest”.

Asked in what situations it was necessary to be more vigilant with regards workers or the public, LocalA8 replied “We’ve got a wall garden, it’s got chafer grubs at the minute so next spring time I’ll be using insecticides so we’ll close that off for a few days, just because its insecticide and it’s not a particularly nice chemical. That will be the first time to my knowledge we’ve used an insecticide”.

Looking at steps to protect the environment, unprompted LocalA8 stated “All our parks and public spaces, generally we don’t use chemicals. But we’ve got three Green Flag sites, which we never use chemicals on”. Probing further on this point, “We have one (SSSI) but that’s a flowerbed…wild flowers will grow naturally so we don’t use chemicals around that. We mow it a couple of times a year”.


Prompted about avoiding spraying near waterways and drains, “We do have rivers going through our parks and that but again we don’t use chemicals”. Slopes, around hard standing pavement, are not an issue for LocalA8 as the contractors are responsible. They only use glyphosate and in minimal quantities. Regarding the impact of weather, LocalA8 replied “Obviously when it’s raining…the contractors don’t spray and neither do ourselves. Obviously if it’s windy as well, although it doesn’t have too much of an impact with wind because we use CDA sprays so it’s not like the old days (with knapsacks)”.

Asked where the respondent would turn to for information where the PPP may have restricted use or the risk of use was greatest, LocalA8 replied “I’d go to the Codes of Practice. I’d also go to the guys who have been here a long time so they know site conditions…Also Google is a good one to be honest”.

Prompted about use of the CRD website, LocalA8 retorted “I use their website a lot but to be honest I find that I never get a straight answer. It’s always very grey is the answer. They never say yes or no about anything. I find it quite a frustrating website, not just for chemicals but everything”. Regarding manufacturer’s websites “I always get their safety data sheets from their websites…and that’s how I do the COSHH”. Turning to the EA, LocalA8 was again forthright “…they’re very grey on matters as well. I’ve quite a lot of dealings with the EA in regards to the rivers and stuff and they can complicate matters. Again you can never seem to get a straight answer from them”. LocalA8 had also used the Amenity Forum site in the past but could not recall for what.


LocalA8’s organisation principally uses CDA lances, and in response to how frequently they are calibrated, LocalA8 replied “Well we use CDA’s so they are like self-calibrated. When the guys did their PA1 and PA6 they got trained on the old knapsacks as well as CDA’s because we said to the trainers we don’t use knapsacks really”.

Probing further on the policy for calibrating knapsack sprayers, “Each person will have a different calibration because they’ll have different walking speed and things like that so they have to calibrate it to their own personal thing. Now whether they do that or they just stick a certain amount of chemical in I don’t know. I say they follow it but I doubt it personally”. Prompted again about the frequency of calibrating equipment, LocalA8 replied “The CDA’s like I said they’re self-calibrated, but the main thing you have to check is that they’re working so every time you take them out you’ve got to check the batteries are working and obviously that it’s working as it should. The guys have a habit of leaving them in the back of trucks. They roll around and get damaged”. Further questioning revealed that knapsacks are “Very, very rarely used”.

On the topic of chemical stores, LocalA8’s organisation has two chemical stores that are “…bunded to a certain litre, I can’t remember what litre it is off the top of my head but they are, well they’re proper chemist stores. Yes they’ve got heat and lighting, fans, they’re bunded to contain any leak”. Prompted, LocalA8 noted that both stores were locked at all times, roofed, fire resistant, sited away from water, and that the bunding was not compromised by entrances/exits.

Questioned what precautions are used as standard when filling, unprompted LocalA8 replied “Make sure they’ve got PPE. Make sure they’ve read the COSHH and risk assessments and signed it. Sign the chemical out as well. Make sure they’re not filling it in an enclosed area. Make sure they’re trained to use the chemical, ones they use anyway”.

Prompted from the list, LocalA8 confirmed spray operators are trained to prepare their spray equipment away from water and dispense glyphosate in to turtle packs which they can top up of share with other teams when on site. Prompted about rinsing, LocalA8 replied “They would triple rinse if they used a knapsack, yes and the containers yes, triple rinse”. Caps will be replaced after rinsing and bottles stored upright. Products are never mixed, the spray operator is also responsible for preparing the equipment, and carries all documentation and a spill kit with them in the vehicles.

Regarding disposal of liquids, CDA equipment is cleaned with a bio-degradable material and disposed of on a designated site. For knapsacks, any diluted product is applied on site and spray washings on a designated site. Empty containers used for knapsack sprayers are brought back to the depot and disposed, along with glyphosate containers for the turtle packs, and these are collected by a department of the local authority which is registered to handle hazardous waste.



Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA8 stated that there are some situations, including a very small percentage that are Green Flag, where it is not possible to spray and only hand-weeding will suffice. Probing further whether selective herbicides might be the answer, LocalA8 replied “…we’ve got some beds with some Hebe in and bindweed so I asked the guys to put it on with a sponge and unfortunately they got it on the Hebe as well”. LocalA8’s organisation has also found that wicks gave poor results, “We tried burning the weeds that didn’t really work either. Spot spraying was the best here” using a hood.

Prompted, identifying the problem is definitely a key factor. Glyphosate is mainly used within the organisation as a management aid around posts and benches to reduce the need to strim. The preference is to leave green sites looking natural, unless “…we got a noxious weed in there like Hogweed or Japanese Knotweed”. So whilst aesthetics are a factor in some situations, for example bedding areas and the walled garden, financial constraints dictate the use of chemicals on pavements where there isn’t the labour to hand weed.

Looking at the use of residuals and their impact on future management options, LocalA8 is of the opinion that of those that remain are not “…as effective either and they’re quite expensive as well for what you’re getting”. For example, as current moss-killers are perceived to be generally ineffectual LocalA8’s organisation has invested in a machine with wire brushes for use in housing drying areas where the moss is particularly prevalent.

Questioned if they ever used outside help to make a final decision on pesticide selection and dose rates, LocalA8 stated that they took decisions as a team. He may well also speak with their spray contractors or others he has met professionally. If working with a new product, LocalA8 will work with staff to make sure that they are competent.


• Chemical treatment more effective than alternative options – “We get paid a certain amount of money off Herts Highways for chemical applications and we also get paid a certain amount of money off housing so we’ve got to ensure that they don’t get complaints about weeds”

• Chemical treatment was the most practical method available – ibid • Chemical treatment was more environmentally friendly – “I personally think it is…” versus

expensing frequent trips to hand-weed, strim, etc., but “…obviously it would be nice to have an alternative that worked”

• Availability of alternative products or techniques – where they exist, like using ferrous sulphate in some instances for moss control, they can provide a useful alternative

Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA8 replied, <Always>, “Like I said all our beds are done by hand”.

In terms of alternative non-chemical approaches, LocalA8 uses the following approaches: hand-weeding, cutting/strimming/mowing, brushing, mulching, soil aeration, correct fertiliser application, and drainage. Of these hand-weeding of flower beds is the most frequently used, “When we’ve spent a lot of money on bedding or bulbs or whatever chemicals are not an option just because residuals aren’t as good as they were and obviously with bedding you’re probably going to damage them anyway”.


Case Study LocalA9

LocalA9 is a Grounds Maintenance Manager for a District Council with responsibility for the management, including vegetation control, of the following areas: amenity grass, sports turf, tree/shrub beds, riparian areas, gravel/ballast surfaces, pavements/kerbs, and roads (including unpaved roads). In the interview, LocalA9 was joined by their sub-contractor who has an exclusive contract for the majority of the maintenance and all the spraying work with the authority. Although the following responses are a blend from both respondents, those of the contractor alone are clearly referenced directly or abbreviated as (SC).



• Protection of infrastructure – “If we’ve got vegetation that potentially could damage one or our own buildings or damage a private building that’s owned by somebody else, that is a very high priority to deal with that because we don’t want expensive claims…we get a bit of fly tipping, if you don’t get on top of Japanese knotweed quickly it spreads and it becomes an absolutely nightmare to get rid of, so our policy on Japanese knotweed is to eliminate it wherever it’s found, as quickly as possible”

• Protection of nature conservation areas/Conservation of native plant or animal species – “One of our council themes is clean and green, so it’s high up on the council’s agenda, that the biodiversity, the protection of wildlife and habitats is open to us. In fact 80% of the district are areas of outstanding natural beauty…we actually own a site of special scientific interest for example, it’s an area of lowland heath, which is an extremely rare habitat in itself, so when it comes to these very sensitive sites then we’ve got management plans to protect plants in there”

• Public safety/health of domestic animals/protection of fisheries – Legal requirements is at the forefront, “The last thing the Council wants is bad press over some poor practice that’s taken place that’s damaged an aquatic environment or killed somebody’s dog”

• Quality of grass/turf and survival/growth of trees/shrubs – “Quality of grass and turf is a very, very important thing for us… shrubs and the bedding that we have, have to be kept to a high standard, of course, it’s a legal requirement, it’s set in that way”

Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA9(SC) rated their knowledge as <Good>. “The contracts manager has the ultimate responsibility for issuing and the use of chemicals. I am very selective on the chemicals that I use…..and I need to be up to date with the current legislation(SC)”

LocalA9’s organisation is not a member per se of any of the listed associations but the sub-contractor’s organisation has accreditation with BACCS and some of its employees are BASIS registered but not the (SC) respondent, for now. The sub-contractor’s association is also a member of NRoSO.

Within the contractor’s depot of the 28 FTE staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0 (not storing any more than 30-40 litres and therefore claim exemption), BETA – 0, NPTC – 12 (all PA1and PA6), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 12, trained in 2006 Codes of Practice – 12.

Although LocalA9’s contractor does not have a BASIS qualification, their organisation has BASIS qualified personnel that advise on policy development and the making and checking of recommendations.


Unprompted to the question about protecting human health, LocalA9’s contactor replied “Personal protection equipment, all my staff are issued and required to wear at all times when working… If we’re using chemicals the guys are all issued with overalls, paper overalls, wellington boots, rubber gloves”.

Probing further, LocalA9’s contractor also holds monthly ‘toolbox’ talks where staff are briefed on current issues, health and safety, etc.


Prompted about the use of COSHH assessments, LocalA9’s contractor can print from a central register of these and copies are kept in all the vans, housed in a black box along with “…all the relevant paperwork that they will require to carry out their job on a daily basis”. Asked about health surveillance, LocalA9’s contractor has strict policies in place to record and monitor the results of incidents but nothing specifically relating to the application of PPPs.

Turning to protecting the general public, LocalA9 replied “We wouldn’t be spraying when it’s very windy...to prevent drift”. Asked if they used notices of spray operations, LocalA9’s contractor stated that although signs were erected for hedge or grass cutting, these were not deployed when spraying.

Asked in what situations it was necessary to be more vigilant with regards workers or the public, LocalA9 replied “When it’s hot weather, where the guys may be a bit reluctant to use the personal protection…I'm vigilant”. The contractor respondent added that he aimed to spray outside of term-time, “If little Timmy or little Jemma have asthma they immediately think that that chemical is going to impact on that. That’s not true but (try) explaining that to somebody”.

Looking at steps to protect the environment, unprompted LocalA9 stated “We won't use chemicals within 10 metres of water courses”. The contractor added, “I remember doing my accreditation PA1 and PA6, whenever there is a water course it’s just a known, it’s just an absolute no, no spraying near any type of water”.

Prompted about their approach to the SSSI, LocalA9 replied “This isn't just SSSIs, this is across the board really, we would prefer to use mechanical means of controlling vegetation as opposed to chemical…The idea is to maintain the heath heather, so we will remove scrub to retain the openness, but that’s all done by hand or using machines…your risk assessment is there an alternative”. Probing further, the contractor stated “There's an element of work that has to use chemicals…we actually use very little. The main chemical we use is Roundup and that is to treat slabs, gravel areas and hard surfaces”.

Asked how they manage public drainage areas, such as ditches and verges, LocalA9 replied “I would view that as a water course”. As a matter of policy, PPPs are also not applied in open parkland, the contractor stating “We’d use an alternative means of controlling that vegetation… from a member of public’s point of view, like spraying, they just think you're killing everything and people have become a lot more aware of what's happening. LocalA9 added “We’ve got some pitches, very occasionally we’ll do a selective herbicide to get rid of the weed…we only do it if we think that the grass is being outcompeted”.

Asked where the respondents would look for information where the PPP may have restricted use or the risk of use was greatest, LocalA9’s contractor replied “I’d go to my health and safety committee and I hope they’d give me the information”. Prompted about the CRD website, the contractor replied, “I wouldn’t say I'm knowledgeable on exactly all the information that’s obtained there” but did admit to having visited the EA’s ‘What’s in your backyard?’ Probing further, the contractor uses a few accredited PPP supplier companies for advice. He had also heard of but not used the Amenity Forum website, “To be honest I don’t get a lot of time to surf the net. It’s just 100 miles an hour”.


LocalA9’s contractor uses a variety of different-sized knapsack sprayers. These get tested annually, with maintenance during the year if nozzles or lances need replacing. Operators are required to fill out a check list before each job to confirm their equipment is in good working order, and “With knapsacks I never ever really try and repair them, I just buy another one. It’s just so much more cost effective (SC)”.

Questioned how operators calibrate in terms of application rates, the contractor replied, “They have the system for calibration so they have a sheet where they can work it out, so they know exactly how much chemical goes with the water to put into the knapsack”. On nozzle types and size, the contractor remarked “It would be a flat fan or whatever type of nozzle that requires that, we’ve got all that information at the depot… PA6 trained so they know exactly what nozzles they have to use on that certain type of spray. It goes back as well to we never spray during high wind because of drift”.

On the topic of chemical stores, LocalA9’s contractor has one bunded chemical store on site. Asked what other properties are required of a chemical safe, the contractor stated that it should be weather proof, capable of retaining more than the volume of PPP stored, which noted earlier ranges from 15-40 litres for this respondent. This particular chemical safe was situated inside a metal barn and was secured from unauthorised access. The respondent was proud of their recent ISO14001 accreditation, and “…when the external auditors come, he’s been perfectly happy with the way we store our chemicals”.


Questioned what precautions are used as standard when filling, unprompted LocalA9’s contractor replied “Everybody has a measuring jug, so that means that they can decant their chemical into the measuring jug so they have the correct amount of chemical, which obviously cuts down the risk of spillage of any type. The knapsack is already filled with the water first”. Prompted, the contractor prefers to purchase five litre containers, “…because you can control it then and of course it’s easy to transfer and store“. Asked if the spray operators are given any direction in terms of approach when pouring, the contractor replied “Not a direction I would give them because they're all PA1, PA6 accredited so they know exactly what they should be doing anyway. All I do is provide them with the infrastructure to carry out the spraying discipline. So they have the PPE to do the job, they have a calibrated knapsack, they have the correct chemical and they have a water source as well”.

Prompted about rinsing frequency, the contractor replied “There's not allowed to be any chemical left in them obviously, the caps are taken off, they're rinsed out inside in a sterile area. I can’t tell off the top of my head how many times each chemical container has to be rinsed”.

Turning to the management of diluted product, the contractor was asked about the protocol used if the weather stopped spraying or someone fell ill; “We’ve got some like water containers, old water containers that the residue is poured into, so it doesn't go down a drain or put onto the ground”. Questioned what happens to this, the contractor stated that the containers are removed by a specialist “…waste transfer company”. This is also the process for managing water after rinsing the knapsacks.

Asked about the management of spillages, the contractor replied “We have spill kits for chemical and spill kits for oil or hydraulic oil, all the vans carry them on there. The bund is in it to stop is spreading across the playground or what have you. What we do is put down the bund, then put down granules, then go back and collect the granules, make that clear and then the granules are brought back to the depot and then obviously the spoil has to be removed by the waste transfer company. We also have a form as well that we fill in, an environmental spill form, which we would fill out and then send that to our compliance department”.

Regarding the disposal of empty PPP containers, these are stored inside large bags in a bin provided by the waste disposal contractor, and removed periodically. Outsourcing is common for the contractor’s organisation and has proven here to be a practical option.


Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA9 stepped in and stated “This is where I come in” the contractor replying “He directs me”. Repeating the question, LocalA9 replied “If there is not a viable alternative we will use a chemical. If it’s a fence line and you’ve got a lot of weed all entangled through it, it may be the quickest and easiest may be to run a knapsack along the bottom of the fence line to kill the weed. Similarly if we’re treating a football pitch, weed and feed. If for example we’re doing some rhododendron bashing or you’re doing scrub control, you do that mechanically. If we’re treating Japanese knotweed we can’t really get rid of it by mechanical means very easily, so again we would spray”.

Continuing on the same theme, LocalA8 added “It’s the last resort effectively, if you can use a machine to cut back vegetation or mow grass you use a machine, but if there's not a viable alternative then you resort to chemicals”. The contractor responded, “We do very little spraying on this contract to be honest with you. I would say the places we do the most spraying are probably in the schools because the schools are obsessed by weeds, they are, they usually have three sprays were season”. Further discussion reveals that for school work this is along kerb lines. Another situation where herbicides may be used is along gravel paths that steadily narrow with weed encroachment. Churchyards were cited as an example.

Asked where the decision lies between LocalA9 and the contractor, it was clear from the response that this was a partnership, LocalA9 summarising “I’d be advised by X on certain things because I might ask him to do something and he’ll say there's a better way of doing this Y and I’ll listen to his advice and vice versa”.

Turning to factors which have influenced the organisation’s decisions to use chemicals rather than non-chemicals, LocalA9 identified weakly with most of the factors listed. It is clear from earlier responses that LocalA9 is keen on finding a mechanical solution to vegetation management, and would only go the chemical route as a last resort.


Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA9 stated, <Always>; the contractor replying “I think from my point of view as a contractor that in years to come it’s going to become more and more difficult to use chemicals so we need to start looking and we have looked at alternative methods”. He then went on to discuss a trial where weeds are jet washed at temperature with soapy water (Soapstream?). LocalA9 retorted, “The trouble is we’ve looked at that in the high street and I know about this, we’ve got cobbles and people don’t like the weeds, the trouble is if you do that with a jet all the grout goes, so we have to spray it”.

In terms of alternative non-chemical approaches, LocalA9 uses the following approaches: hand-weeding, cutting/strimming/mowing, brushing, grazing, mulching – “I’ve actually got a system at my depot where when we go out and we cut shrubs. I then bring the shrubbery back to my depot and I’ve got a tractor mounted shredder which I then chip into bark chip and then put them back onto the beds. I don’t believe people are really aware how much of a weed retardant mulch is, it’s fantastic (SC)” – use of disease resistant trees and historically a biological control agent

Probing further, the respondents were asked to recall any biological control products, LocalA9 recalled “We’ve used – I can't remember the name of the thing, but it’s a bacteria – it’s a biological based thing. In fact the Forestry Commission are moving towards that, they’d rather treat twice a year with a biological agent than once a year with a pesticide. We have used that biological, but we haven’t used anything for weeds”. Asked whether they had used a biological for Japanese knotweed, LocalA9 replied “I didn’t even know there was a biological control for it”.

Of the alternatives listed, cutting is the most popular, followed by mulching and then hand-weeding. LocalA9 added, “On hard surfaces on the other hand spraying is probably the highest” hand-weeding here being deemed too time consuming.

Case Study LocalA10

LocalA10 is a Parks Department Head for a Welsh Unitary Council with responsibility for the management, including vegetation control, of the following areas: amenity grass, sports turf, tree/shrub beds, riparian areas, gravel/ballast surfaces, and housing areas (wash lines and communal paths).

Regular outsourcing of spraying work – broadleaf weeds on sports pitches for example – is done due to “our ever diminishing workforce and our workloads”. The council spray operators focus on weed control for hard areas, mowed margins, isolated patched of knotweed control, insecticides on rose beds, herbaceous gardens and treatment of fungicides on the fine turf facilities.



• Control of invasive (non-native) plant species – “It’s been prompted because we’ve got so much leisure land, which isn’t currently maintained, and obviously in recent years there’s problems with people trying to get mortgages when there is Japanese knotweed close to the property and we’ve had to throw a lot of resources at that”

• Public safety and/or possible litigation – “We’re aware obviously of the legal onuses of Local Authority, you know make sure we apply things in the right and proper manner and obviously because of the claims culture we live in today we need to be very mindful of that” claims that “My dog’s dead, that’s a common one”

• Health of domestic animals/livestock – “We don’t spray anywhere where there would be grazing livestock. It would only be in parks where there’s a potential for domestic animals likes pets to come into contact, but again, we follow legislation and user instructions basically. The products we are using are far, far, far safer than the stuff we were using twenty years ago”

• Legal requirements – “…our legal obligation to make sure we are doing it within the laws”. Probing for who checks the work, LocalA10 has internal H&S staff and in-house monitors, but also “We get observations or complaints from members of the public but a lot of the time a little knowledge is dangerous. They see someone with a knapsack and they think you are spraying something horribly toxic. It’s about educating people as well isn’t it? The days of throwing paraquat around are obviously long gone! Thank God in a way. In relation to criticism litigation, we get very little. It’s normally about not doing something rather than doing something”

• Public concerns – “Public concern does seem to becoming more of an issue. I think people are more aware of the environment these days”


Regarding knowledge of the 2006 Code of Practice for using PPP, LocalA10 rated their knowledge as <Good>; “Certainly couldn’t quote it verbatim”.

Aside from individual memberships of the IOG, LocalA10’s organisation is not a member any of the listed associations, but knows that the contractors they use are members of Amenity Assured, BASIS, and BACCS. LocalA10 had not heard of NRoSO or NASOR.

Within LocalA10’s organisation of the approx. 100 FTE staff the number trained/qualified were as follows: BASIS – 0, BASIS register – 0, BASIS Power – 0, BASIS storekeeper – 0 (due to finances the volumes of PPP stored are very low), BETA – 0, NPTC – 20 (all PA1and PA6 and 2 with PA2), NRoSO – 0, NASOR – 0, access to 2006 Codes of Practice – 20, trained in 2006 Codes of Practice – 20. A further six are to take PA1 and PA6 with a local college next year.

LocalA10 commented, “Years ago there used to be the adage when we were using CDA that someone could work alongside them without the certificate. They could observe them, but we don’t even tolerate that now. If you’re not certificated you don’t spray”.

Prompted about sprayer training, “The training, apart from the fact they are already certificated, is when we meet with suppliers, especially if it’s a new product or a new system of application. There’s induction and training then specifically not only for the use of the kit, it’s dilution rates, storage and the recycling of the product”.

Within LocalA10’s organisation no BASIS qualified personnel are involved in the development of policies for pesticide use and the making/checking of recommendations. Information from suppliers, interactions with contractors and personal experience are the basis for informing decisions. LocalA10 remarked that it is easier now “The range of products has shrunk”.


Unprompted to the question about protecting human health, LocalA10’s contactor replied “The individual applying the product is trained and competent. That individual is then provided with the correct PPE. Then there are guidelines in relation to when and the timing of the application of the herbicide, based on the prevailing weather conditions. In relation to the public, with the product we use, apart from the odd litigious claim that someone’s pet poodle has keeled over because they’ve eaten grass, it isn’t really an issue. The days of someone thrown clouds of noxious stuff around have really gone. It’s CDA droplet, it’s pretty much inert. This coffee is probably more noxious than a CDA product these days”. Prompted about the use of COSHH assessments, LocalA10 replied “We’ve got risk and COSSH assessments and NOPs for every particular part of the spraying treatment, from storage through to application and through to return of said product” and every one of the area supervisors has a risk assessment ‘bundle’ covering every operation, “updated yearly, unless needs dictate that it’s reviewed for another reason. Perhaps a new lance or something might prompt us to review it”. Turning to health surveillance, “All our spraying operatives go through our internal occupational health department for hand, skin and lung function tests. Obviously any concerns then they are referred not only to their own GP but also our own works doctor… but I can’t remember of a single issue with anyone using herbicides or chemicals being a problem”. Notice of spray operations is used, depending on where the spraying is being done. Asked in what situations it was necessary to be more vigilant with regards workers or the public, LocalA10 stated that spraying near schools tends to be done at weekends or evenings to avoid the pupils, and “When we’re putting fungicides or herbicides down on our fine turf facilities like bowls, we liaise closely with the user groups so they’re aware of it. We try and avoid applying it on match days for example, but as you can appreciate, if you are mowing three times a week your window of opportunity for putting stuff down is limited anyway. Again, we email our lettings department, make them aware of it, and we leave a message with the club themselves so they are aware of it. It’s normally nothing more sinister than if you are playing in the afternoon make sure you wash your hands afterwards. Again it’s about communicating”

Looking at steps to protect the environment, unprompted LocalA10 believed that this didn’t really affect them as they were not dealing with sensitive areas or SSSIs, “We are applying normally in formal grass areas and shrub beds, fine turf, so I can’t think of an incidence when there’s been an issue like that”.


Prompted about water ways, “There are occasions. Primarily that is an issue with Polygonum and on the whole, where we’ve had issues like that, we’ve used stem cell injections. We do notify, and we always insist in the specification of the contractor, that they inform the Environment Agency”. Prompted about spraying near drains, LocalA10 replied “It isn’t an issue with me because we’re using a CDA product, so you’re not sloshing stuff around anyway. I suppose you’re referring more to storm drains and such like on the highways really. We’ve just got our chamber pots on park paths”

Turning to open parkland, only football pitches tend to treated and then infrequently, outside the season and advisory signage is used before and during the spraying treatment. Surface type and slope are not considered an issue using CDA sprayers, and mentioned previously the organisation will not spray for fear of drift.

Asked where they would look for information where the PPP may have restricted use or the risk of use was greatest, LocalA10 replied “I use the HSE site quite a lot and the Amenity Assured as well”. LocalA10 also defers to suppliers who “are always very much up-to-date on changes in legislation and obviously because of that products are ever-evolving”. Prompted on the use of the EA site, “I use the Environment Agency site, particularly for knotweed, because they put regular updates on it”, but they were not aware of ‘What’s in my backyard?’ specifically.

Probing again about measures to protect water, LocalA10 repeated, “It’s not something we have to contend with on a regular basis”.


LocalA10 organisation uses primarily CDA lances but does have some knapsack sprayers. Questioned about when these are tested and calibrated, LocalA10 replied “We have a number of CDA lances. They are serviced yearly by the supplier. In relation to calibration every member of staff has their own calibration pack and it’s their responsibility then to ensure that the product is calibrated correctly before they start every particular spraying operation”. As product usage is recorded daily, and the treatment area is known, anyone that was under- or overdosing would quickly become ‘red-flagged’, “You can pretty much look at something physically to know if there’s too much chemical droplet coming out. If the droplet is too big or whether the coverage is too thick”. Stocks of spinnerets are held.

Prompted about the calibration of knapsacks, LocalA10 replied “To be honest, the knapsack, it’s easier to mix the glyphosate with the water than it probably is to faffle about calibrating a CDA lance”. Probing again, LocalA10 stated “It’s not so much calibrating it’s just to make sure when you put the glyphosate in with the water that the mix is correct. That’s done every time they fill the knapsack”. The respondent was either unable or reluctant to answer how frequently knapsacks were calibrated and under what scenarios (e.g. periodicity, change of location or product, after repair/maintenance) perhaps because in this organisation they have a use limited to fine turf.

On the topic of chemical stores, LocalA10’s organisation has a number of these across the territory, “They’ve either got their own specific chemical storage room, which basically is a small lockable room with nothing but chemicals stored in it, or we’ve got chemical vaults; steel containers which are locked and with the various hazard warning signs on them”. Around 80% of the 15 areas have steel cabinets, the remaining ones are brick construction with steel doors. Probing further about inspections, these are spot checks done on by internal H&S staff for a range of issues; for chemical storage they monitor, “…is the data sheet on the wall, does that tally in with what’s actually there, what’s been brought in, what’s been taken out, etc.?”

Prompting from the list, these stores are not bunded, and being steel they are fire resistant, and locked.

Asked to consider what precautions are used as standard when filling knapsacks, unprompted LocalA10 replied “Obviously the person is trained and competent to use the said product. The correct personal protective equipment. The mixing is done obviously in a yard normally, away from the general public, because obviously we need a water supply”.

Prompted about what precautions are taken around labelled instructions, LocalA10 stated “Any instructions are adhered too, obviously, be it under the actual instructions for the chemicals itself or COSSH”. Probing about the risk of contaminating water, LocalA10 said the SOP was to fill the sprayer in a secure yard away from water. The organisation tends to avoid issues of spillages by purchasing 5 litre packs of glyphosate, one of which might needs the one team for the summer. Pouring involves the use of PPE and funnels, and all done on the ground. There is no mixing of products. Spill kits (granular


products) are available in the depots at the point of filling but not whilst on a job, “I just don’t think it would be workable, whether or not I feel there is a need anyway, given the quantities of the product involved”. Questioned what would happen if the knapsack fell over or a hose broke, LocalA10 replied “I can honestly say it’s never happened”.

Prompted about rinsing, “Again, done back at the depot and what we would normally do is, when they refill the tank to flush out is to find a bit of gash land around the site and spray off underneath a hedge base or something like that. It’s not a case of anything is poured down a drain”.

Staying on the theme of disposal any unwanted concentrated PPP, including products that are no longer approved, goes back to the distributor. Empty bottles and their outers are also collected by the distributor. Questioned why this option was selected, LocalA10 replied “Best practice. It’s something now we tend to stipulate with a supplier when we agree a contract with them, that they include any costs for removing said product afterwards, empty container and such like”.


Asked what criteria they would use in deciding whether or not to use a pesticide, LocalA10 replied “There are two options. It’s either manual, or it’s herbicide. I supposed the overriding factor must be cost… if you had to do everything manually it would be horrendous”.

Prompting, LocalA10 agreed that presented with a new situation identification of the problem was the first step. Asking whether they ever consider next using an alternative approach rather than a pesticide, LocalA10 replied “We have trialed the use of nematodes (Nemaslug) rather than pesticides in some of our shrub beds. The Hostas, where we’ve had problems with slugs and especially in relation to green flag parks”. Over two seasons the results were very disappointing and the organisation had gone back to using pesticides again. That said, whereas in the past wetting agents and fungicides would have been tank-mixed for use on fine turf, “We put the wetting agent down pre-season and then we apply a fungicide only when it’s needed really. We don’t throw it around because it’s so expensive”.

Questioned whether an evaluation of other factors like financial loss, damage or visual effects ever outweighed the need to use of a pesticide, triggered LocalA10 to reply “There is no alternative when you are dealing with fine turf, other than use an approved fungicide, if you don’t you will lose that playing surface. Certainly with the varying degrees of the weather, this summer hasn’t been so bad, but the three years before that when it’s been particularly wet we’ve struggled”.

Probing whether there are ever any concerns whether a dose rate may cause damage to fine turf LocalA10 replied that they only ever use manufacturer’s rates, “One of my colleagues is a member of BIGGA, he’s got a degree in sports turf science, he’s got a raft of contacts within the herbicide/pesticide industry. He will ring a number of them and seek their advice. They’ll recommend a product and we’ll adhere to the application rates contained on the product labels”.


• Chemical treatment more effective than alternative options – Linked to the Hosta example earlier and the observation, “The manual method of hand weeding shrub beds or mulching, isn’t cost effective in the long term”

• Lower cost of chemical treatments – “As I say, with the proviso that price isn’t’ always the most important factor when we buy a product. If something is £5 a litre less doesn’t necessarily mean it’s any cheaper if, based on application, it doesn’t work”

• Chemical treatment gives longer lasting effect than alternatives – “Not as good as it did a few years ago, obviously with diuron it was superior”

• Always done that way – But, “We’ve moved on considerably from where we were in the industry 25-30 years ago when I was an apprentice, the stuff we used to chuck around. With the lances now and the way they are calibrated and the volume of stuff we use now certainly far tighter than we used to be. We’re certainly using far less than we were as well”

• Did not consider non-chemical control – “We do mulch the shrub beds to reduce on herbicide application”

Lack of information on alternative products or techniques scored 1, LocalA10 added “Because I don’t think there is anything out there which could replace chemicals” least that is cost effective.


Asked how often the possibility of using non-chemical methods for vegetation control is considered, LocalA10 replied, <Sometimes>, “Thinking about our treatment on highway verges we used to spray round out trees and obstructions but since diuron has been withdrawn we’re finding that the effectiveness of the glyphosate isn’t as long as it should be. What we’ve actually done now is remove that operation and just instructed operatives to strim mower margins again instead. It worked out there wasn’t any saving in using the chemical if it was only going to last for four or five weeks it was cheaper to say go back to cultural methods and strim”. LocalA10 also added, “It was compulsory tendering that really brought weed spraying into the fore. Whereas before there would have been two or three gardeners in every park with their long handled shears. Instead of four men in a park there is (now) probably five spread across an area ten times the size”.

In terms of alternative non-chemical approaches, LocalA10 uses the following approaches: hand-weeding, cutting/strimming/mowing, brushing, mulching, soil aeration (for fungal diseases, “but it doesn’t guarantee that there’s not going to be a need to use chemicals).

Burning was trialed by LocalA10’s organisation a few years ago, but it was not considered successful “Probably enlarged the ozone hole about three times the size amount of propane we punched out at the time. That was meant to be the new big thing wasn’t it but, no, mixed results”.


• Strimming – around trees to assist with mowing • Hand-weeding – shrub beds, flower beds herbaceous borders. Due to the human cost, has

started to be replaced by mulching • Mulching – “Certainly with shrub areas we are but obviously with our annual bedding schemes

and such like, that’s still done manually. Any of the new schemes we’ve done with shrub beds we tend to put a terram down first then mulch over the top. I think if you get it right at the start that’s a big help”.


APPENDIX 2 CONSOLIDATED REPLIES TO CLOSED QUESTIONS

Unless stated, all responses are based on ten interviews per respondent type - Contractors, Green-keepers or Local Authority.

Section 1 – Amenity Use and Training

Q1. Please indicate ALL surface types that your or ganisation is responsible for treating with plant protection products

Number of respondents~ Surface types CONTRA GREENK LOCALA

Amenity grass 6 7 9 Sports turf 5 9 10 Forestry/ Woodland 4 1 2 Tree/ Shrub beds 6 4 10 Riparian areas 9 5 7 Open water/ aquatic areas 2 2 1 Gravel/ ballast surfaces 9 7 10 Pavements/ kerbs 9 8 8 Roads 7 3 7 Other - Car parks 5 3 1 Other - Communal paths 0 0 1 Other - Domestic gardens 3 0 0 Other - Equestrian areas 1 0 0 Other - Garage areas 0 0 1 Other - Patios 1 0 0 Other - Playgrounds 0 0 1 Other - Railways 1 0 0 Others - Drying areas 0 0 3

Q2. Please indicate the degree to which the factors lis ted below have influenced your

organisation's current priorities for the control o f vegetation

Factors CONTRA GREENK LOCALA MEAN~ Protection of infrastructure 3.6 1.9 2.9 2.8

Financial pressures 3.1 2.3 3.7 3.0

Control of invasive (non-native) plant species 4.1 2.8 4.5 3.8

Protection of nature conservation areas/ wildlife habitat 3.8 4.1 3.5 3.8

Conservation of native plant or animal species 3.8 4.0 3.8 3.9

Local authority policy 2.9 2.3 3.5 2.9

Government policy/ targets 2.8 2.7 3.2 2.9

Financial constraints 3.3 2.6 3.6 3.2

Public safety and/ or possible litigation 4.5 4.2 4.4 4.4

Health of domestic animals/ livestock 3.4 2.0 4.0 3.1

Protection of fisheries/ angling interests 3.5 2.5 3.0 3.0

Drainage/ flood control 3.8 2.9 3.0 3.2

Quality of grass/ turf 2.8 5.0 4.0 3.9

Survival/ growth of trees/ shrubs/ bedding 3.0 3.9 3.4 3.4

Disease control/prevention (e.g. Rhododendron removal to prevent Sudden Oak Death spread) 2.7 2.8 2.6 2.7

Legal requirements (e.g. Weeds Act) 4.1 3.3 4.8 4.1

Public concerns 4.5 3.3 4.0 3.9

Other - Safety of rail staff 1.3 0.0 0.0 0.4 ~ Mean score maximum = 5


Q3. How would you rate your personal knowledge of the 2 006 Pesticides Code of Practice for

using PPP?

Respondent type 1 2 3 4 5 6

Mean score~ Non-

existent Very poor Poor Fair Good Very

good CONTRA

4 2 4 5.00

GREENK 1 2 7 3.60

LOCALA 1 4 5 4.20

Q4. Is your organisation, or any individuals working in your organisation, a member of any

industry associations or schemes?

Organisations/ schemes

Contractor Green-keeper Local Authority~

Yes No Don’t know Yes No Don’t

know Yes No Don’t know

Amenity Assured 4 4 2 10 1 9

BASIS Advanced Contractor Certification Scheme 6 3 1 10 2 8

British Agrochemical Standards Inspection Scheme 6 3 1 10 9 1

National Register of Spray Operators 4 5 1 10 2 7 1

National Amenity Sprayer Operators Register 1 8 1 10 9 1

Other - NAAC 3 7 Other - Property Care Association 2 8 Other - CHAS 2 8 Other - INNSAP 2 7 Other - BALI 1 9 Other - Local Green-keeper Assoc. 10 1 Other - Institute of Groundsmen 10 1

~ Includes the responses of a contractor present in one local authority interview Q5. Please indicate the training, qualifications and re sources of your staff

Training, qualifications, resources

Contractor Green-keeper Local Authority

# staff with qual

# staff total

% Staff

# staff with qual

# staff total

% Staff

# staff with qual

# staff total

% Staff

BASIS qualified 13 128 10.2 0 39 0.0 1 357 0.3

Members of the BASIS Professional register 10 128 7.8 0 39 0.0 0 357 0.0

BASIS POWER training course graduates 0 128 0.0 0 39 0.0 0 357 0.0

BASIS Nominated Storekeeper certificate 31 128 24.2 0 39 0.0 1 357 0.3

Biodiversity and Environmental Training for Advisors (beta) Amenity Horticulture course graduates? 2 128 1.6 0 39 0.0 1 357 0.3

Holders of NPTC certificates for the jobs undertaken? 62 128 48.4 25 39 64.1 192 357 53.8

NRoSO Members 60 128 46.9 0 39 0.0 0 357 0.0

National Amenity Sprayer Operators Register 12 128 9.4 0 39 0.0 0 357 0.0

Easily able to access a copy of the 2006 Codes of Practice? 120 128 93.8 24 39 61.5 192 357 53.8

Trained in the requirements of the 2006 Codes of Practice? 96 128 75.0 21 39 53.8 192 357 53.8

Other - CSCS 40 128 31.3 0 39 0.0 0 357 0.0

NB Based on interviews with 30 respondents, the inf ormation above is indicative rather than definitive


Q6. For which of the following activities are BASIS qua lified personnel used?

Activities Contractor Green-keeper Local Authority


BASIS qualified personnel are not used 2 8 5 5 5 5

Development of organisation's policies for pesticide use 8 2 3 7 2 8

Making and/or checking recommendations 8 2 4 6 2 8

Tender preparation~ 7 1 2 4

Tender evaluation~ 2 1 2 4

Other – supporting new employees pre-basis training 5 5 0 10 1 10

~ Indicate numbers of affirmative responses as tenders are not issued in all circumstances. For GreenK/LocalA with one exception, BASIS qualified personnel reside outside the organisation

Section 2 – Protecting Human Health and the Environ ment

Q7. Considering first human health, what steps does you r organisation take to protect workers and the public?

Measures Contractor Green-keeper Local Authority


COSHH assessments 6 4 1 9 3 7

Personal Protective Equipment 10 0 4 6 7 3

Health surveillance 2 4

4 2 6

Notice of spray operations 5 5 7 3 4 3

Other - CDA 2 Other - secure storage

1

Other - Spraying conditions 2 Other - training 4

NB Indicate numbers of affirmative responses; measures like health surveillance programmes are not utilised in all cases.

Q9. Looking now at the use of measures to protect the e nvironment, could you please indicate ALL areas or situations which you believe as being of high risk when considering using pesticides?

Example areas or situations Contractor Green-keeper Local Authority


Close to water 9 1 7 2 4 3

Close to drains 4 6 3 5 2 4

SSSI’s and other conservation areas 4 6 1 2 4 2

Open parkland 2 5 3 5

Surface type and slope 1 7 4 3

Impact of weather 4 5 5 3 3 4

Other - Bore holes 1

Other - Pavements/ verges 2 1 Other - Public gardens

1

Other - River banks 1

NB Indicate numbers of affirmative responses; not all situations were relevant to all respondents


Q10. Please indicate where you go to obtain information on sites where either pesticide use is

restricted or the risk of use is greatest

Sources of information Contractor Green-keeper Local Authority


Chemicals Regulation Directorate 3 3 1 2 1

Plant Protection Product - manufacturer’s sites 3 5 3 3 2 6

Environment Agency’s, ‘What’s in your backyard?’ 3 2 4

Amenity Forum 4 1 1 2

Other - BIGGA

3

Other - Client website 3 1

Other – Green-keeper Assoc. 1 Other - Pitch care

1

Other - SEPA 1 1

NB Numbers of respondents actively seeking information rather than awareness of named sources of information.

Section 3 – Application Equipment and Pesticide Sto rage

Q12. Considering application equipment, when is this tes ted and calibrated within your organisation?

When to test/calibrate



Beginning of the season 5 1 5 1 6

When moved to a different location 1 3 1 1

Change of products/rates 1 3 3 2 1 3

After repair or maintenance 1 7 1 4 2 3

Not done 2 1

Other - As required 2 3

Other - Before each spray operation 3 1 1

Other - Daily 2

Other - Monthly 1 1 1

Other - Weekly 1

NB Indicate numbers of affirmative responses from respondents using a mix of CDA, knapsack or mounted sprayers.


Q15. Do you store pesticides on your organisation’s prem ises and, if so, how is the store

constructed to prevent unwanted releases?

Key construction considerations Contractor Green-keeper Local Authority


Resistant to fire (for 30 minutes or longer) 1 5 1 6 7

Capable of retaining leakage/spillage - to a volume of 110% of total quantity of products to be stored (or 185% in an environmental sensitive area)

2 5 8 4 5


6 2 3 1 2 5

Bunding must not be compromised by exits/entrances 3 4 3 5 6

Avoid having a water supply passing through the bunded area 1 6 7 5

The store, or the area in which it stands, should be roofed

2 5 1 5 4 5

Should be secure from unauthorised access 5 3 5 5 5 5

Other - chest freezer 1

Other - converted building 1

Other - Steel walk-in store 8 1 7

Other - Vert. steel cabinet or safe 7 2

NB Indicate numbers of affirmative responses

Q16. What precautions are used as standard in your organ isation when filling application equipment?

Precautions used when filling application equipment




4 5 3 7 3 7


7 2 4 4 5 5


3 7 4 1 7


7 2 4 6 2 5


4 5 7 2 5

Empty containers – replace caps after rinsing and draining containers and store upright in an outer carton

4 6 1 7 7

Mixing more than one product – add separately, and follow label instructions with regard to order 2 3 7 1

Spray operator – if different from the person mixing and loading, make sure they have a copy and have read the label

1 8 9 2 7

Spill -kit – make sure one is available at all times, how to use it and what other action to take if required

4 5 1 6 5 4



Q17. From the list I am going to read out, please indica te which options apply to your disposal of plant protection products and their containers:

Options Contractor Green-keeper Local Authority


Not responsible for the disposal of waste 1 9 1 9 1 9

No waste to dispose of 3 7 1 9 0 10

Returned to distributor 4 6 0 10 6 4

Waste disposal contractor 4 6 9 1 4 6

Disposed of at site of application 6 4 6 4 5 5

Disposed of at depot 1 9 2 8 1 9

Disposed of down a drain 0 10 0 10 0 10

Disposed of on a designated area 3 7 2 8 4 6

Other - containers burned (special permission) 1 9 0 10 0 10

Other - disposal via general (domestic) waste 1 9 1 9 0 10

NB Questioned complicated by merging the disposal of waste liquids and containers.

Section 4 – Minimising Pesticide Use and Alternativ e Approaches

Q20. What criteria do you use in deciding whether or not to use a pesticide?

How do you decide if it is necessary to use a pesticide?



Identify the specific weed, disease or pest affecting the area 7 3 5 6 3

Do we need to use a pesticide or is there another method of control or combination of methods we could use?

6 2 3 7 5 4

Does the financial loss, damage or visual effect caused by the pest, weed, and disease outweigh the cost of using a pesticide?

3 3 4 2 3 6

Will the dose or concentration of pesticides being used damage the area being treated or the next ‘crop’ planted here?

3 4 4 5

Are you able to make these decisions yourself or whether you will need someone to help you?

3 5 2 7 3 6

If you decide to use a pesticide, what plans do you make to use it properly? For example, is it possible to reduce the amount you use or the area you apply it to?

3 4 6 1 7



Q21. From a list of factors that I am going to read to y ou, please identify which have influenced

your organisation’s decisions to use chemicals rath er than non-chemical alternatives to plant protection products.

Factors CONTRACT GREENK LOCALA MEAN~

This organisation does not use chemical plant protection products 1.00 1.20 1.20 1.13

The organisation’s policy 3.40 3.20 3.10 3.23


3.90 3.60 4.10 3.87

Lower cost of chemical treatments 4.10 3.00 2.80 3.30

Chemical treatment gives longer lasting effect than alternatives

3.10 2.60 3.30 3.00

Availability of chemical application equipment 3.70 1.80 2.90 2.80

Chemical treatment was the most practical method available 4.30 4.00 4.30 4.20

Always done that way 2.60 2.30 2.50 2.47

Did not consider non-chemical control 2.10 2.40 2.60 2.37

Chemical treatment was more environmentally friendly 2.70 1.70 2.50 2.30

Advice of consultant or contractor 3.80 3.30 3.30 3.47


3.20 3.60 4.00 3.60

Lack of information on alternative products or techniques 1.90 2.90 2.60 2.47

Other - Biodiversity Management

0.50

Other - risk and site assessment 0.50 Other - staff time and availability 0.50

~ Mean score maximum = 5

Q22. Please indicate how often the possibility of using non-chemical methods for vegetation control is considered before any decision to use pe sticides is finalised?

Frequency CONTRACT GREENK LOCALA

Always 8 6 5

Sometimes 1 3 5

Never 1 1 0

~ Numbers of respondents


Q23. From the list of alternative non-chemical approache s I am going to read to you, please indicate the options used by your organisation or by your contractor.

Non-chemical approaches CONTRACT GREENK LOCALA

Hand weeding 7 10 10

Cutting, strimming, flailing and/or mowing 8 9 10

Brushing 5 9 10

Steam treatment 1 0 1

Burning 4 0 1

Grazing 1 0 3

Mulching 2 5 10

Soil aeration 3 10 6

Correct fertiliser application 5 10 6

Drainage 4 7 7

Biological control 4 3 2

Use of disease resistant stock 2 6 6

Other - Use of Harpins# 1 Biological control products (name) Nemasys J 1 Psyllid aphid (under trial from CABI) 1 Symbio (endo mycorrhizae)

1

Nemaslug 1

Respondent cannot recall names 2 2 1

~ Numbers of respondents

# proteins from certain bacterial plant pathogens applied to trigger plant defensive and growth responses

149

APPENDIX 3

UK AMENITY PESTICIDE SURVEY Topic Guide, October 2013

Topic guide plan

SECTION MINUTES

1 Introduction 5

2 Amenity Use and Training 15

3 Protecting Human Health and the Environment 10

4 Application Equipment and Pesticide Storage 15

5 Minimising Pesticide Use and Alternative Approaches 15

Total 60

Objectives (Moderator guidance notes only)

To explore the following topics with all respondent types: Local authorities, contractors and green- keepers

� Training – extent of certification and participation in recognised national schemes � Protection of human health – measures employed � Testing/calibration of Application Equipment – frequency, timing, elements tested � Protection of water – awareness and impact of variables and protection measures taken � Minimising usage – steps taken to meet legal requirements � Storage, handling and disposal – nature of stores, use of PPE, disposal of concentrates,

dilute waste and containers � Alternatives approaches to pest, weed and disease control – including use of biologicals


Background

Thank you for agreeing to participate in this research program.

The purpose of this survey is to gain a deeper understanding of your working practises in the use of pesticides in the amenity sector.

We would like to discuss the situations where you use pesticides, the types of training and membership of national schemes, and methods of testing and calibrating application equipment. Additionally, we also wish to understand what steps are taken to protect human health and the environment. To conclude, we would like to explore what alternative approaches you may use to minimise the use of pesticide. The results from this study will be used to inform policy developments both within the UK and the wider EU.

Anything you tell us will be treated with the strictest confidentiality. We follow the ESOMAR code of conduct which means that the information you give will be combined with the information from other respondents participating in this study and your individual comments will not be directly attributable to you. We will not reveal your name or contact details to our client.

I would like to record our conversation in case I need to check back any of the details. Is that okay with you? This discussion should take around 60 minutes.

Moderator: please ensure that you have completed th is table before the end of the interview

Organisation name

Name of contact person

Position in organisation

Address 1

Address 2

County

Post code

Telephone number

Email address

* For local authority respondents please indicate w hich of the options best describes their authority

Unitary council (Scotland) County Council (England)

Unitary council (Wales) District Council (England)

District council (Northern Ireland) Unitary Metropolitan borough (England)

City of London borough (England) Unitary non-Metropolitan borough (England)


Section 1: Amenity Use and Training

Each organisation has its own priorities and constraints when it comes to the use of plant protection products. Your answers to the following few questions will help us to better understand your priorities, and those of organisations like yours.

1 Please indicate ALL surface types that your organ isation is responsible for treating with plant protection products (INTERVIEWER: CHECK ALL RELEVANT BOXES)

Amenity grass Open water/ aquatic areas Sports turf Gravel/ ballast surfaces Forestry/ Woodland Pavements/ kerbs Tree/shrub beds Roads Riparian areas/ areas beside water Other hard surfaces Other (please specify) 2 Please indicate the degree to which the factors l isted below have influenced your

organisation’s current priorities for the control o f vegetation. (INTERVIEWER: You may wish to hand this list directly to the respondent and ask them to complete rather than read out).

Factors 1

(Little influence)

2 3 4 5

(Strong influence)

Protection of infrastructure

Financial pressures

Control of invasive (non-native) plant species

Protection of nature conservation areas/ wildlife habitat

Conservation of native plant or animal species

Local authority policy

Government policy/ targets

Financial constraints

Public safety and/ or possible litigation

Health of domestic animals/ livestock

Protection of fisheries/ angling interests

Drainage/ flood control

Quality of grass/ turf

Survival/ growth of trees/ shrubs/ bedding

Disease control/prevention (e.g. Rhododendron removal to prevent Sudden Oak Death spread)

Legal requirements (e.g. Weeds Act)

Public concerns

Other (please specify)

Please explain your choice of ‘other’

INTERVIEWER: For factors identified above with a score of 5 (Strong influence), please enquire and record ALL verbatim reasons, why…?


INTERVIEWER: PLEASE READ OUT THE FOLLOWING STATEMENT…

“Pesticides, Code of Practice for Using Plant Prote ction Products” (England and Wales) and “Code of Practice for using Plant Protection Produc ts” (Scotland) provide authoritative guidance on the use of plant protection products, i ncluding amenity use across the UK.

3 How would you rate your personal knowledge of the 2 006 Pesticides Code of Practice for using Plant Protection Products?

Non-existent Very poor Poor Fair Good Very Good

(INTERVIEWER: For all replies less than <Good> explore reasons why not better. For respondents answering <Non-existent> probe to see if there is someone else that we should be interviewing in their place?)

4 Is your organisation, or any individuals working in your organisation, a member of any industry associations or schemes? (TOP-OF MIND FIRST, THEN PROMPT WITH THE FOLLOWING)

Organisations/ schemes Yes No Don’t know

Amenity Assured BASIS Advanced Contractor Certification Scheme (BACCS)

British Agrochemical Standards Inspection Scheme (BASIS)

National Register of Spray Operators (NRoSO)

National Amenity Sprayer Operators Register (NASOR)

Other (Specify)…

Other (Specify)…


5 Please indicate the training, qualifications and resources of your staff. (INTERVIEWER: For respondents that also use a contractor please ask respondent to complete this column)

Training, qualifications, resources Proportion

of your staff (e.g.

3/6)

Contractor’s staff

BASIS qualified

Members of the BASIS Professional register

BASIS POWER training course graduates

BASIS Nominated Storekeeper certificate Biodiversity and Environmental Training for Advisors (BETA) Amenity Horticulture course graduates?

Holders of NPTC certificates for the jobs undertaken?

NRoSO Members

National Amenity Sprayer Operators Register

Easily able to access a copy of the 2006 Codes of Practice?

Trained in the requirements of the 2006 Codes of Practice?


6 For which of the following activities are BASIS q ualified personnel used?

BASIS qualified personnel are not used Tender preparation

Development of organisation’s policies for pesticide use Tender evaluation

Making and/or checking recommendations



Section 2: Protecting Human Health and the Environm ent

The information provided here will help us to understand what measures are taken by your organisation to protect employees, the general public and the environment, particularly water.

7 Considering first human health, what steps does y our organisation take to protect workers and the public? (INTERVIEWER: Without prompting, establish respondent awareness and frequency of use of ALL available measures, before probing further from the list)

Measures Unprompted Prompted

COSHH assessments

Personal Protective Equipment

Health surveillance

Notice of spray operations


8 Are there situations or circumstances where you n eed to be particularly vigilant? (INTERVIEWER: PROBE in detail whether this has an impact on the measures taken)

9 Looking now at the use of measures to protect the environment could you please indicate ALL areas or situations which you believe as being of high risk when considering using pesticides? (INTERVIEWER: Ask the respondent to provide a list of situations before prompting from the list below)

Example areas or situations Unprompted Prompted

Close to water

Close to drains

SSSI’s and other conservation areas

Open parkland

Surface type and slope

Impact of weather



10 Please indicate where you go to obtain informati on on sites where either pesticide use is restricted or the risk of use is greatest (INTERVIEWER: Ask the respondent to provide a list of web-sites/sources before prompting from the list below)

Sources of information Unprompted Prompted

Chemicals Regulation Directorate

Plant Protection Product - manufacturer’s sites

Environment Agency’s, ‘What’s in your backyard?’

Amenity Forum


11 Finally, what other measures are taken by your o rganisation to protect water? (INTERVIEWER: If not elicited through earlier questions, PROBE and capture specific examples)


Section 3: Application Equipment and Pesticide Stor age

The information provided here will help us to understand what measures are taken by your organisation to calibrate application equipment and procedures for the safe storage, handling and disposal of pesticides

12 Considering application equipment, when is this tested and calibrated within your organisation? (INTERVIEWER - PROBE in detail: Guidance suggests application equipment must be tested/calibrated as listed below:

WHEN TO TEST/CALIBRATE Unprompted Prompted

Beginning of the season

When moved to a different location

Change of products/rates

After repair or maintenance

Not done


13 Do different sprayers or types of sprayer, for e xample knapsacks versus tractor-mounted sprayers, influence the frequency of calibration? ( INTERVIEWER: record examples of calibration frequency in months or numbers of times /year by sprayer type)

14 What specific training does the employee(s) resp onsible for this activity receive? (INTERVIEWER - PROBE in detail)


15 Do you store pesticides on your organisation’s prem ises and, if so, how is the store constructed to prevent unwanted releases? (INTERVIEWER: PROBE to see if the respondent knows where to get guidance on the appropriate standards for fixed and mobile stores; HSE

agriculture information sheet #16 - http://www.hse.gov.uk/pubns/ais16.pdf provides guidance on the Storage Code of Practice, important elements from which are listed below).

Key construction considerations Unprompted Prompted

Resistant to fire (for 30 minutes or longer) Capable of retaining leakage/spillage - to a volume of 110% of total quantity of products to be stored (or 185% in an environmental sensitive area)


Bunding must not be compromised by exits/entrances

Avoid having a water supply passing through the bunded area

The store, or the area in which it stands, should be roofed

Should be secure from unauthorised access

Other (Please specify)


16 What precautions are used as standard in your or ganisation when filling application equipment? (INTERVIEWER: The list is huge so suggest focusing on the major precautions that the respondent can recall top of mind, before PROBING from a shortened list below. Section 4.5.2 of the Code lists all the Do’s and Don’ts)

Precautions used when filli ng application equipment

Unprompted Prompted






Empty containers – replace caps after rinsing and draining containers and store upright in an outer carton

Mixing more than one product – add separately, and follow label instructions with regard to order

Spray operator – if different from the person mixing and loading, make sure they have a copy and have read the label

Spill -kit – make sure one is available at all times, how to use it and what other action to take if required


17 From the list I am going to read out, please ind icate which options apply to your disposal of plant protection products and their containers:

Not responsible for the disposal of waste Disposed of at site of application

No waste to dispose of Disposed of at depot

Returned to distributor Disposed of down a drain

Waste disposal contractor Disposed of on a designated area


18 Please explain why these disposal options were c hosen by your organisation. (INTERVIEWER: PROBE for details around the circumstances in which each mentioned disposal option is used. For example, what is the organisations policy for disposal of concentrates or RTU formulations which are considered hazardous waste versus disposal of dilute wastes; section 5.5 of the Code?)

19 Finally in this section, could you please explai n your organisation’s policy(ies) towards the disposal of containers? (INTERVIEWER: details can be found in section 5.6 of the Code)


Section 4: Minimising Pesticide use and Alternative approaches

The 2006 Codes of Practice encourage approaches that minimise the use of pesticides, including the use of non-chemical alternatives. Your answers to the following questions will help us understand where alternative techniques are used by you and organisations like yours. They will also help us understand why you have made these decisions. 20 What criteria do you use in deciding whether or not to use a pesticide? (INTERVIEWER:

Here we want to know whether the respondent underst ands the circumstances in which there is a legal obligation to minimise pesticide u se. Ask respondent to list the criteria and then PROBE from the list given below:

How do you decide if it is necessary to use a pesticide?

Unprompted Prompted

Identify the specific weed, disease or pest affecting the area

Do we need to use a pesticide or is there another method of control or combination of methods we could use?

Does the financial loss, damage or visual effect caused by the pest, weed, and disease outweigh the cost of using a pesticide?

Will the dose or concentration of pesticides being used damage the area being treated or the next ‘crop’ planted here?

Are you able to make these decisions yourself or whether you will need someone to help you?

If you decide to use a pesticide, what plans do you make to use it properly? For example, is it possible to reduce the amount you use or the area you apply it to?


21 From a list of factors that I am going to read t o you, please identify which have influenced your organisation’s decisions to use chemicals rath er than non-chemical alternatives to plant protection products. By alternatives, we mea n biopesticide products or alternative techniques. (INTERVIEWER: You may wish to hand this list directly to the respondent and ask them to complete rather than read out).

Factors 1

(Little influence )

2 3 4 5

(Strong influence)

This organisation does not use chemical plant protection products

The organisation’s policy


Lower cost of chemical treatments

Chemical treatment gives longer lasting effect than alternatives

Availability of chemical application equipment

Chemical treatment was the most practical method available

Always done that way

Did not consider non-chemical control

Chemical treatment was more environmentally friendly

Advice of consultant or contractor


Lack of information on alternative products or techniques


(INTERVIEWER: For factors given a score of 3 or more, PROBE to understand the drivers, for example ‘how important is advice in the decision on whether to treat or not’, or ‘how frequently is organisational policy reviewed and why’, or ‘why are non-chemical approaches not more important’)


22 Please indicate how often the possibility of usi ng non-chemical methods for vegetation control is considered before any decision to use pe sticides is finalised? Again, by alternatives, we mean products or alternative techn iques.

Always Sometimes Never

(INTERVIEWER: For respondents who answer <NEVER> to question 22, go straight to the end)

23 From the list of alternative non-chemical approa ches I am going to read to you, please indicate the options used by your organisation or b y your contractor.

Hand weeding Mulching

Cutting, strimming, flailing and/or mowing Soil aeration

Brushing Correct fertiliser application

Steam treatment Drainage

Burning Biological control

Grazing Use of disease resistant stock


Interviewer: Please record the names of any Biological Control products used, or check box:

Respondent cannot recall any names

24 Of those options you have identified, which of thes e are used most frequently?

(INTERVIEWER: PROBE respondent to list).

25 In what specific circumstances are these options us ed and why?

PESTICIDE USAGE SURVEY REPORT 254 · PESTICIDE USAGE SURVEY REPORT 254 AMENITY PESTICIDES IN THE...

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