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#1 Posted : 30 September 2003 09:58:00(UTC)
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Posted By Benedict Thierry I'm interested to know what you think or if there is a body of opinion on the use of any kind of pre-filled in record sheet to help staff who are qualified to do the job but get a bit nervous about filling in forms due to poor literacy/ numeracy/ language skills. What I'm looking at is the information on the product label that tells the spray operator the dose rate, water volume, application rate, pressure setting and nozzle type. Or - Do you give a worked example for each product used so that it can be used to copy the information by the spray operator onto the daily record sheet? Or - Do you feel this raises questions about competence, quality of training, the reliability of the national competency scheme for spray operators and/ or any other issues or questions/ interpretations and how they may relate to health, safety, welfare and environment at work?- especially if your systems were under scrutiny of investigation - would this stand as acceptable practice or would it viewed as doubtful practice in good faith or as dubious practice or just plain bad practice or malpractice? I'm on a deadline for this of Monday next 6.10.03. Thanks in anticipation Benedict
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#2 Posted : 30 September 2003 10:28:00(UTC)
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Posted By Jane Blunt It would be really helpful to have a bit more information - what is being sprayed, for what purpose? There is a world of difference between paint and pesticide, for instance. What are the forms for - are they for quality control purposes? or for other reasons? Has someone done the risk assessment and devised safe systems of work? Where does the risk assessment fit into your query? Sorry to ask so many questions. Jane
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#3 Posted : 30 September 2003 10:46:00(UTC)
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Posted By Sean Fraser Wow! Some question! There is no right answer to this one (haven't we heard all that before) but it does add to the debate of to what extent a Safe System of Work provides to the employee and to what extent competence plays its part. The term competence has been debated numerous times on this forum and we have all contributed towards it at some point, but I would say that there is agreement that qualification, knowledge and experience forms the basis of a competent person. Unfortunately there is no fixed criterion that one can apply that satisfies everyone at every stage - the level of competence is balanced by the level of risk and specialist function. My personal definition is "knowing when to ask". When I did my initial foray into this field I was told to dumb it down - aim for the lowest common denominator and you can't go wrong. As a general philosophy this is OK, but there is the danger of patronising the workforce by pitching it too low, while there remains the danger that one cannot assume prior knowledge either and giving incomplete instructions and advice as a result. Again, it depends on the message and more importantly, the intended recipients. At all times the KISS principle should be applied though, so the crux of the matter is at the forefront and not obscured by screeds of relevant but inappropriate information. There is an additional point here - standardisation of information. In the example quoted I would expect that the harmonisation of labelling and safety data sheets across Europe goes a long way towards helping make use of chemicals safer. If everyone recognises the symbology used, if everyone can read a MSDS without worrying that information might be missing or is presented in a different and hence confusing manner, then we have general recognition as the central plank to our training programme. This helps in teaching people how to read the info, as there is a basic assurance that they aren't going to have to interpret the way it was presented before they ever get around to interpreting the information contained within! The question lies in how much of the information is a record, and how much is an instruction. I would suggest that any information that is pre-filled is not a record - it is an instruction. Only the bits that are variables (i.e. location, date, time, quantities, personnel names etc.) are the actual records. The issue of competence is not on the completion of the record, but in correctly interpreting / following the instructions and performing the work to the required standard. The record only notes that the work was done. Obviously this is different if the personnel are being required to make comments, recommendations or assessments as a result of the work performed. Now the competence lies not only in performing the work, but in correctly reporting it in an adequate manner that ensures that the critical points are covered effectively. Now the individuals need to be good report writers as well. The issue of competence is complicated, but my opinion would be to start with what you expect of people. If they are practical people doing a practical job, then spending a significant period of time writing reports that essentially provides the same information time after time is a waste of resources - they are paid to do, not to write. The more you can reduce this requirement and then assist with what remains the better (i.e. do we need the report? If so, what do we need to record? How can we reduce the completion time to ensure only the pertinent facts are recorded?). On the other hand, if you are requiring written opinions and judgements then the form cannot be pre-filled - that is what the personnel are there to do. But in both cases, you will be using their individual competencies to their best effect.
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#4 Posted : 30 September 2003 17:57:00(UTC)
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Posted By Hilary Charlton I am not entirely sure what you are asking here? Does the operator have to fill in the information from the product label on to a separate sheet and are the categories always the same but quantities, nozzle size, etc change? Can you clarify the question please and hopefully I can give an answer. Thanks Hilary
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#5 Posted : 30 September 2003 18:05:00(UTC)
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Posted By Benedict Thierry Sorry Jane, Various herbicides. Spray record is a statutory requirement from & for each operator per location(s) per day. Yes method statements and risk assessments and COSHH assessments in place. Staff trained in appropriate |NPTC spray module. I have been an NPTC instructor and examiner and know that it is possible for individuals with poor literacy, numeracy and language skills to be coached to pass. I'm now in a situation where some of the spray operates employed by the company are in this situation. However - the aim of the NPTC certificates is some form of guarantee that the person holding a certificate can both read and interpret a product label and an MSDS etc. Sean - you hit a nail on the head precisely when you identify the difference between a record and an instruction. What is being considered here is the statutory spray record - not instruction which are found on the product label, method statement etc and form a significant part of the spray certificate test. I would agree with Sean and that pre-filled information is not a record - but is an instruction. and that competence is to do with interpreting/ following instruction correctly. Comments on weather etc are looked for on the record. My concern is that if the form is partially pre- filled as a template how do I argue they have read and understood the label, the method statement or risk assessments etc. although I can see what you are saying Sean about time and productivity and resources etc. and I can see that since we are using limited numbers of products perhaps pre- printing some of the information such as product name, application rate, water volume etc may be acceptable to help save time and reduce irritation and only require the information that changes to be filled in by staff. Somehow I feel uncomfortable with this, but I can see I may just being awkward.
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#6 Posted : 30 September 2003 18:14:00(UTC)
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Posted By Benedict Thierry Apologies Hilary, Yes,some of the information is taken directly from the product label and written on the daily spray record. Categories are always the same - but quantities, nozzle size etc may vary depending on label instructions dependent on things like target spray species, wind speed, proximity to water &/or dwellings, season and the size of area being treated amongst others - hence the statutory requirement for the record. Also on different sites different products may be being used.
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#7 Posted : 01 October 2003 08:21:00(UTC)
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Posted By Jane Blunt If your operatives are competent to make the decisions and use the correct dosage, but are unsure about writing about what they have done, how about a creative solution? Give them a blank or annotated record sheet and a tape recorder. Get them to talk through the 'boxes' on the sheet onto audio tape to record what they have used for each job, pesticides, concentrations, weather conditions etc. At the end of the day or shift get them to use the audio tape to transcribe the information onto blank forms. If they are not happy to do this, then ask someone else to transcribe the contents of the audio tape. Might this work? Jane
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#8 Posted : 01 October 2003 08:45:00(UTC)
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Posted By Sean Fraser I'm intrigued by your innovative solution Jane - it certainly seems to address Benedict's concern in demonstrating that the operators have understood and followed the instructions, apart from the obvious method in that the job was done. Example - instead of assuming that the quantity actually used was the quantity required on the sheet, they can verbally report this by repeating what is already written down i.e. "I have now set the nozzle to ....". Confirmation enough I would have thought. And the cost of the technology required to do this probably isn't excessive now either.
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#9 Posted : 01 October 2003 11:36:00(UTC)
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Posted By Hilary Charlton From what you have said a pre-printed form seems like the most obvious answer. If the categories remain the same then presumably the metrics remain the same so things will be measured in mm, litres, mph, etc. Your form could leave blank spaces for numbers to be filled in. Most people can manage numbers easier than letters so for example Nozzle Size: ...... mm Quantity per 5 litres ...... ml Wind Speed ........ mph The name of the product would have to be written down but you could get the rest of this in clever form design. Recommend also that pictorial representations are used as well as words and that training is given on these. Hilary
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#10 Posted : 01 October 2003 21:02:00(UTC)
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Posted By Benedict Thierry Jane & Hilary, Thank-you both. Jane -I have a sincere question - have you come across any equipment that can cut out or reduce background noise? Hilary - I've worked as an adult literacy/numeracy tutor and your suggestion is good. We are now looking at preparing prompt cards with all the details asked for on the spray record sheet but I think your suggestion would still be useful as a secondary measure. It is something I would have included if I'd prepared the record sheet -- I'm not thinking clearly - there is no consideration time being given to this. I have a more awkward question now - The spray record must identify the product used by name. The MD is dead set against this and is insisting on something like --- approved mix. I can't understand why he feels it is sensitive information as it has been supplied in other ways on other documents a to the client who is insisting on being provided copies of the spray record sheets. Due to the huge reduction in herbicides approved for use you can bet your bottom dollar that any other company doing similar work has little choice but to use identical products - but he has said no way will he agree to the product names being recorded. We've crossed points of view previously on risk assessments and COSHH risk assessments and I noticed today that I've not been notified of a change of product. Each similar product - say MCPA - but supplied by a different manufacturer has its own unique reference number and is viewed as different product under pecticide regs and requires its own separate risk & COSHH assessment. I think he thinks I'm being awkward when I'm just trying to stop sinking deeper into the quagmire.
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#11 Posted : 02 October 2003 10:12:00(UTC)
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Posted By Hilary Charlton I am totally in agreement with you on the names factor - the client may decide to go elsewhere if he or she does not know what product/products are being used and cannot assess them for themselves. The only way I can see of getting round this is perhaps by putting "approved mix" and the amounts and CAS numbers of those products that are classified under CHIP - however, this is a very long winded way of going about it. If this is the alternative though your MD may decide that putting the names on is the better solution. Good luck. Hilary
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