Investigating and Resolving Fly Complaints04 June 2013
An eight-step process of resolving complaints is outlined by the UK's Environment Agency in its publication 'Fly management: how to comply with your environmental permit'.
To demonstrate that a particular site is likely to be responsible for the flies at complainant’s premises, officers need to show that:
- The alleged source is a breeding site for significant numbers of the same species of flies as those found at the complainants’ premises. Simply showing that the adult flies at the alleged source are the same species as the flies at the complainant’s premises is not enough. The flies at the two locations could have come from another unknown site. Breeding has to be established at the source to make a clear link.
- There are no other significant sources of the same species of flies nearby, eliminating the possibility that the complainants’ flies come from elsewhere. Not all houseflies come from mass breeding sites; small quantities of waste can generate enough flies to cause a local nuisance.
- Changes in fly numbers at the source (for example due to manure removal from poultry houses, or using an inert cover on landfill sites) are mirrored in the complainants’ premises.
The following is an outline procedure to identify, investigate and resolve fly problems reported by complainants. This is neither a prescriptive approach, nor the only approach and the detail and the sequence may vary depending on the site.
Step 1. Fly complaint received
Discuss the issue with the complainant to ascertain the history of the problem, likely species, fly numbers, their habits and impact on the residents. If necessary, ask them to submit samples to the investigating officer for identification. Is the complaint associated with or close to a permitted site?
If there are a number of residents affected or the issue is contentious, you may need to prepare an engagement plan – your local communications team can help with this.
Step 2. Complainant visit
If the problem is persistent and appears to be related to a site we regulate, or involves several residents or businesses and concerns significant numbers of houseflies, consider visiting the complainant’s premises to collect samples and take photos as evidence. Offer advice on control measures they can use within their properties. Consider contacting the local environmental health department to see if they are aware of problems or can offer any advice.
Step 3. Complainant fly monitoring
Ask the complainants to hang adhesive papers in agreed locations in the property and change them every week until asked to stop. The investigating officer should take a photo of the fly paper in-situ before collecting the papers to identify and count the flies.
The sticky papers are then fixed to white paper and a label attached with details of location, dates, flies and numbers, and the officer takes another photo. Premises that have a significant fly problem are those with 20 or more flies within a room at one time, or more than 50 flies collected on a sticky fly paper over one week. Remember, there is no absolute number.
If the number of flies caught is going to be used in evidence, the complainants will need to give a statement about whether they have moved or done anything to the papers during the monitoring period.
Step 4. Identify potential fly sources
If the complaint concerns significant numbers of houseflies, identify potential fly breeding sites, initially within a 1 km radius of the complainant(s). Contact the LA to discuss any issues they may be investigating in the area.
Step 5. Investigate potential fly sources
Contact the identified sites and ask about any recent fly issues. Visit the sites where the fly breeding may be occurring. Site visits should include:
- Discussion with the operator to understand the systems and processes on their site, such as age of stock on farm, manure storage and removal procedures, ventilation systems, incoming waste streams, waste processing procedures and times, good housekeeping including waste rotation, cleaning and washing down buildings etc. Establish if there have been any recent incidents (e.g. water leaks, or equipment breakdown), or changes in procedures (e.g. new incoming waste streams) that may have increased the risk of fly infestation.
- Checking the site for the presence of adult flies, fly breeding, and conditions conducive to fly breeding. Take dated photographs of key issues seen. On farms this investigation is likely to involve examining manure from various locations within livestock sheds for moisture levels, and for the presence of fly larvae. At waste sites this may involve examining waste for fly larvae. Additionally, any adhesive fly papers and electronic fly killers present should be checked for fly numbers and species. Are the fly species present the same as those at the complainants’ premises? Is the farmer or operator already monitoring fly numbers? Are fly records available?
- Is the site already using fly control measures? Do they have a fly management plan? What has been identified in their management system? What techniques are used (both non-chemical and chemical), and for how long? Is there a fly control contract? Is the contract or contractor appropriate? Are records of pesticide use available?
- Repeat this process for each potential fly source. Beware of becoming fixated on one potential source at an early stage.
- Discuss with the operator what they need to tell the local community and what part they need to play in any engagement plan.
Step 6. Resolve fly problems
At sites where a clear fly problem has been identified, it is likely that the operator has breached their permit.
You need to establish the root causes of the fly problem, such as wet manure, poor ventilation, over-flowing drinkers, insufficient use of cover, allowing unprocessed waste to remain on site for extended periods, inadequate composting process, inappropriate pesticide use etc.
Provide the operator with relevant advice on good practice for fly management, especially on fly prevention. Ask the operator to write or amend and implement a Fly Management Plan, which addresses the root causes to solve the issue and prevents recurrence. Advise the operator clearly of the level of nuisance being experienced in nearby residences.
Step 7. Feedback to residents
Discuss the action taken with the affected residents. Advise them that treatment is likely to take several weeks to be fully effective, and they should continue to monitor until otherwise advised or they are confident the problem has been resolved.
Step 8. Follow-up visits to site
For sites where action was required, revisit the site within two weeks to assess the implementation of agreed actions and their effectiveness.
If the action taken by the operator is inadequate or ineffective continue to work to address the problems. Ask yourself the following questions:
- Are there issues that were missed at the initial visit?
- Are there fly breeding areas that were overlooked, for example, lesser housefly larvae can be very difficult to locate?
- Does there appear to be resistance to the insecticide products used?
- Are there other significant fly-breeding sites nearby which have not yet been investigated?
Step 9. Conclusion
Once the problem is resolved, advise all parties of the outcome of the investigation, action taken and proposals to avoid a recurrence. Advise complainants to contact the Environment Agency again if problems recur.
Go to the previous article in this series by clicking here.