Annual Compliance Review

Title Page

Site conducted
Conducted on
Prepared by
Location

Health and Safety at Work Act 2015

Part 2, Reg 44-46 (duties of personnel)

Due Diligence Framework Worker Responsibilities – induction process, ongoing consultation/meetings Other persons – visitor induction

Part 3, Reg 58 -61 (worker engagement, participation, representation)

Compliance with Regulations Meetings/Memos (2x weekly all staff, weekly project, daily snr team, agvisory, safety rep meeting, quality internal audit team, safety stand downs quarterly) Acknowledgement forms AgCarm Reviews Research Weekly Meetings Research Monthly Safety Meetings Document Control Register – all changes email and discussed, feedback requested Management of Change process Health Monitoring process (agreed to) Safety Rep Election Process Safety Rep Meetings Team Building events

Part 3, Reg 62-68 (worker engagement, participation, representation)

Safety Rep Election Process Safety Rep Meetings

Part 3, Reg 83

Inductions – right to halt unsafe work Safety Policy
General Comments

HSWA (General Risk and Workplace Management) Regulations 2016

Reg 5-8, 21, 24-25

Risk Register, Risk Register review, PHAs, PHA Schedule

Reg 9

Job Descriptions/Pre-requisites Hiring process Inductions Training Plan / Competency Framework SOPs/Work instructions/Batch Logs

Reg 10-11

Event Management Notifiable Events factsheet

Reg 13

Training Matrix Internal VoCs (Production) Product Specific Sign Offs

Reg 14

Emergency Management Plan Drill Schedule / Debrief form

Reg 15-20

Inductions (workers/visitors) PPE Framework / induction process FIT Tests Training Sessions (new PPE) Respirator Care factsheet

Reg 26 – 42

Hazardous Substance Register Batch Logs – safety requirements Air Monitoring (3yr or when changes occur) Health Monitoring (annually) / Pre-employment health checks.
General Comments

HSWA (Major Hazard Facilities) Regulations 2016

HSWA (Major Hazard Facilities) Regulations 2016
If applicable, a full review of this section is to be completed to include relevant regulations
General Comments

HSWA (Worker Engagement, Participation, and Representation) Regulations 2016

Reg 12-19

Safety Rep election process

Reg 20

List of safety reps in smoko room

Reg 21-26

Safety Rep Training / Training Matrix

Reg 29

2-monthly meetings
General Comments

HSWA (Hazardous Substances) Regulations 2016

Part 2, Reg 2.1 – 2.4 (labelling) 18.11 (lab)

In house printing Batch Logs Hazardous Waste labels Label Register

Part 2, Reg 2.5-2.6, 2.10 (signage)

Front gate signage Signage into sheds Hazardous substance register (determines thresholds)

Part 2, Reg 2.11 (SDS)

SDS are located on Production drive, and UI

Part 2, Reg 2.13 (Packing)

Formulation process (storage/stability tests) Registration Process Product Label register Registration review process

Part 3, Reg 3.1 -3.3

Hazardous Substance Register Inventory management through SAP Batch Logs PHAs Management of Change (new materials) New Raw Material / Supplier Process Project Management Tool / Process

Part 4, Reg 4.1 – 4.4

6.1A and 6.1B – Training Matrix Certified Handler (production) Growsafe/application (research)

Part 4, Reg 4.5 -4.6

Job Descriptions/Pre-requisites Inductions Training Plan / Competency Framework SOPs/Work instructions/Batch Logs

Part 5, Reg 5.3-5.12

Emergency Management Plan Emergency Equipment Layout Drawings Emergency Drills (as per schedule) Emergency Debrief Form Inspection of equipment (3rd party)

Part 10, Reg 10.3 – 10.20, 10.26, 10.34-10.35

Compliance certification for LPG & applicable controls associated. Hot Work Permits /Gas Detection

Part 11, Reg 11.5-11.17, 11.20 (class 2-4-LPG)

Compliance certification for LPG & applicable controls associated. Hot Work Permits /Gas Detection Flammable cabinets Hazardous Substance Register to determine thresholds for Reg 11.24 – 11.40

Part 12, Reg 12.2-12.12, 12.17-12.19, 12.21-12.31 (Class 5 – Sodium Nitrate Tech)

Compliance certification for Sodium Nitrate & applicable controls associated.

Part 12, Reg 13.3 (Class 6s & 8s – Majority of materials)

Hazardous Substance Register to determine thresholds Spray Logs (research) Data Packs Certified Handler / Growsafe Training

Part 12, Reg 13.7-13.10

Certified Handler / Growsafe Training PPE Induction Process Training Plans

Part 12, Reg 13.15

Formulation process (storage/stability tests) Registration Process Product Label register Registration review process Use of third party transport providers

Part 12, Reg 13.17 -13.18

Air Monitoring (3 yearly or after changes)

Part 12, Reg 13.24

Registration Process Formulation / Field Research Data

Part 12, Reg 13.29

Designated Storage Shed / Layout Plans

Part 12, Reg 13.30 -13.33

Secondary Contained Sheds Spill contingency plan Adequate storage within secondary contained areas

Part 12, Reg 13.34 (class 6.1a,b,c and class 8.2a,b)

Hazardous Substance Location Certificate (due 1st dec 2019) – working with envirohaz Tracked Substances – SAP Inventory/Sales Management

Part 12, Reg 13.35

Site Security / Gates locked Alarms 2 means of access in sheds/labs Change management (new build requirements) Air Extraction for sheds Fume cupboards / Extrractions for research/pilot plant/Wood Natural ventilation for hot box/prep shed 4 Air Monitoring Secondary Containment Design – floors made of material capable of containing spill Racking Load capacities clearly displayed Emergency Response equipment (showers, water for hand washing, eye wash stations)

Part 12, Reg 13.36 (class 6)

Less than 25kg/L of 6.1As stored in cabinet Less than 50kg/50L of 6.1B stored in cabinet Less than 250kg/L stored in total in cabinet

Part 12, Reg 13.37 (class 8)

Less than 50kg/L of 8.2A stored in cabinet Less than 50kg/50L of 8.2B stored in cabinet Less than 1000kg/L stored in total in cabinet

Part 12, Reg 13.38

Compliance Certs for (a) 50 kg or 50 L of class 6.1A: (b) 250 kg or 250 L of class 6.1B: (c) 1 000 kg or 1 000 L of class 6.1C: (d) 50 kg or 50 L of class 8.2A: (e) 250 kg or 250 L of class 8.2B: Compliance certs renewed at least every 3 years Compliance cert issued for Reg 13.39

Part 12, Reg 13.45

Spill Kits Spill Contingency Plans Absorbent Material DCOIT Neutraliser solution

Part 18, Reg 18.2

Part 18 applies to our Labs

Part 18, Reg 18.3

Non pervious materials on benches/wall/surfaces in labs Fume Cupboards and Servicing Discharge to Air Consent (Hudson road)

Part 18, Reg 18.5

Security Fobs Site Alarms/Fences/Gates/Locks

Part 18, Reg 18.6

Hazardous substance register

Part 18, Reg 18.9-18.10

Product Safety Card – research Drive Certified Handlers (where required) Organophosphate testing (where required) FIT Testing (where required)

Part 18, Reg 18.12 -18.13

Lab Managers – Corbett Road and QC Manager

Part 18, Reg 18.14-18.15

SOPs / Methods Product Safety Card Formulation Manual Project Management Tool – new formulations, including waste management Emergency Management /Drills

Part 19 (tracking)

SAP Inventory Management Sales Management / Material Movements
General Comments

Workplace Exposure Standards 2018

Engagement of WaterCare NZ Air Monitoring of all sheds completed in 2018 Air monitoring conducted after changes or 3 yearly intervals (change management process) Substances highlighted in WES of what is applicable New Products/Formulation Changes – project management tool
General Comments

EPA Hazardous Substances (Classification) Notice 2017

Guidance Doc regarding classifications EPA / Self-assessment Process Registered/Approved products Used in Formulation as a reference doc for non-approved substances
General Comments

EPA Hazardous Substances (Disposal) Notice 2017

NP-QA-GL-005_Waste Disposal Guideline Use of approved 3rd party providers
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EPA Hazardous Substances (Hazardous Property Controls) Notice 2017

Part 2, Clause 13

NP-SF-CM-004 Product Manual Triggers for Controls New Products: project management process

Clauses 14-54

Processes/Procedures covered under HSWA Regulations

Clause 55

Rampage is completely covered with soil once applied or birds are prevented or deterred from foraging where it has been applied

Clauses 60 - 66

NP-SF-CM-004 Product Manual Triggers for Controls Product Label instructions Label development/review process
General Comments

EPA Hazardous Substances (Labelling) Notice 2017

Overlap with HSWA (Hazardous Substance) Regulations Part 2, Reg 2.1 – 2.4 (labelling) 18.11 (lab): In house printing Batch Logs Hazardous Waste labels Label Register

Clauses 6 – 8

Product Label register NP-QA-GL-004_Label Creation Guideline

Clauses 9 – 13, 15-28

NP-QA-GL-004_Label Creation Guideline (detail requirements clauses)

Clause 29

Cartons/outer packing includes correct labels, including DG requirements and pictograms, signal words, hazard statements as in clause 13 or 14. Trained personnel in Dangerous Goods

Clause 30

Product label register – carton requirements Box End creator in UI New Products: Project Management Tool

Clause 33

Dedicated Business Manager/Marketing Department Engagement of 3rd party marketing medium Any advertising to members of public through any medium of class 6.1, 8.2 or 3A substances must convey easily that it is toxic or corrosive and child should be restricted from accessing the substance, if the public is not provided with product label before purchase.
General Comments

EPA Hazardous Substances (Packaging) Notice 2017

Clause 8

Storage and Stability of formulations Product filling procedures Torque wrenches that can be set to newton readings Heat sealed products can retain its contents if part of the contents is removed and the packaging is resealed

Clause 12

≤5L containers of the following substance have child restraint lids 6.1A, 6.1B, 6.1C, 6.1D: 6.1E (aspiration hazard): 6.6A: 6.7A: 6.8A: 6.9A: 8.2A, 8.2B, 8.2C: 8.3A.

Clause 16

All containers are plain white in design and is not likely to attract or arouse the active curiosity of children

Clause 17

Requirement contained within NP-QA-GL-004_Label Creation Guideline
General Comments

EPA Hazardous Substances (Safety Data Sheets) Notice 2017

NP-QA-GL-003_SDS Compliance Guideline Chemwatch
General Comments