HSE clarification of the term "treated areas" in relation to worker exposure to PPPs

Read the response from the Heath and Safety Executive (HSE) regarding a request to clarify the phrasing of ‘treated areas’ in relation to worker re-entry into part-treated, protected environments following Plant Protection Product application. This clarification was sought by AHDB following a query from ornamental crop growers.

The following worker protection phrase can be specified as a condition of authorisation of a Plant Protection Product (PPP) used in protected situations to mitigate exposure to workers. Workers must wear suitable protective clothing in which arms, body and legs are fully covered when re-entering treated areas or handling the treated crop(s) or contaminated surfaces. The phrase ‘when re-entering treated areas’ refers to entry of the area inside a glasshouse/greenhouse or polytunnel that has been treated with a PPP and therefore the worker protection applies to this area. The phrase ‘contaminated surfaces’ refers to surfaces within the treated area e.g. containers containing the treated crop or shelves, which may be invertedly contaminated with residues of the PPP.

‘Workers must wear suitable protective clothing in which arms, body and legs are fully covered when re-entering treated areas or handling treated x crops or contaminated surfaces within y days or z weeks after treatment.’

Depending on the application method of the PPP, the nature of the structure and the layout of crops grown within the structure, there could be the potential for spray drift into adjacent areas of the structure not being treated. Spraying activities should therefore be designed to minimise drift into adjacent areas. Under the COSHH regulations, before a PPP is used an employer or self-employed person must carry out a suitable and sufficient assessment of the likely risks to health. Should there be a risk that crops or surfaces adjacent to the treated area being contaminated with residues during treatment then measures should be put in place to prevent people working in these areas being exposed to PPP residues. This may include worker re-entry restrictions and/or the requirement for full length clothing and Splash Resistant Single Use (SRSU) gloves to be worn whilst working in these areas. It is the responsibility of the employer or self-employed person to complete the assessment and ensure that necessary restrictions are followed and/or protective clothing are worn.