1 Worker Protection Standard (WPS) Pesticide Inspector Training Helena, Montana November 30, 2011...

Worker Protection Standard (WPS)Pesticide Inspector Training

Helena, MontanaNovember 30, 2011

Richard PontU.S. Environmental Protection Agency

Office of Pesticide ProgramsCertification & Worker Protection Branch

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance

Introduction - Why are we here?

Training Objectives:• Learn WPS Requirements• Understand WPS Program Goals• ANSWER YOUR QUESTIONS!• Meet your expectations

WPS Overview

Background/History Regulatory Goals WPS Framework Summary of Key Definitions/Provisions

WPS Overview - Background

Basis for Current WPS Regulation• Court case involving 40 CFR Part 170• OSHA Hazard Communication Standard• Legislative and regulatory actions

* 7/08/88 - EPA Issued Notice of Proposed Rulemaking to Revise 40 CFR part 170 (53 FR 25970)

* 8/21/92 - Worker Protection Standard Final Rule Issued (57 FR 38102)

* 4/06/94 - Pesticide Safety Act (Public Law 103-231) [S. 1913]

* 4/10/95 - Guidance on Issuance of WPS Enforcement Actions (60 FR 18100)

* 5/03/95 - Agency Granted Exceptions to Early Entry (60 FR 21954)

* 5/03/95 - Requirements for Crop Advisors (60 FR 21948)

* 5/03/95 - Grace Period for Providing Safety Training (60 FR 21943)

* 12/14/95 - Labeling Revisions Required for Pesticide Products Within the Scope of the WPS: Policy Statement/Final Rule (60 FR 64281)

* 6/26/96 - Language and Size Requirement for Warning Sign (61 FR 33201)

* 6/26/96 - Decontamination Requirements (61 FR 33207)

* 5/07/98 - Labeling Requirements for Pesticides: Respirator Compliance Policy (63 FR 25168)

* 9/01/2004 - Glove Requirements: Final Rule (69 FR 53341)

WPS Overview - Regulatory Goals

Protect agricultural workers and pesticide handlers from occupational exposure to pesticides and prevent pesticide incidents and illnesses.

WPS strategy relies on 3 main components:• Information• Protection• Mitigation

Information• Pesticide safety training• Safety poster• Access to pesticide application and

hazard information (with notable exception)

Protection• Protections during applications• Restricted-entry intervals (REIs)• Early entry protections• Handler protections (PPE, etc.)

Mitigation• Decontamination supplies• Emergency Assistance

WPS Overview - WPS Framework

WPS implemented through labeling• Labeling requirements contained in 40 CFR part 156,

subpart K (Labeling Requirements for Pesticides and Devices/Worker Protection Statements)

• 40 CFR Part 170 reference statement serves to incorporate full WPS requirements by reference so that full 40 CFR Part 170 text of WPS provisions did not need to be included on every label

Agricultural Use Requirements

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. This Standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE), notification-to-workers, and restricted-entry intervals. The requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard.

WPS Label Requirements

40 CFR Part 170 (WPS) incorporation by reference established concept of “off-label” requirements:• Training requirements• Decontamination requirements• Additional notification and pesticide

safety information display requirements• Emergency assistance requirements

“On-label” WPS requirements:• Restricted entry statements (156.208)• Notification-to-workers statements

(156.210)• Personal protective equipment (PPE)

statements (156.212)• Includes handler PPE and early entry PPE• Note that handler PPE is not contained in "Ag Use

General Statements (156.206)• Application restrictions statement• 40 CFR Part 170 reference statement• Product-type identification (for

organophosphates, N-methyl carbamates and fumigants)

• State restrictions• Spanish warning statements

* Generic approach versus product-specific approach for WPS label requirements– Part 156 and original PR Notices based on

generic approach of establishing general WPS label requirements based on broader toxicity groupings and tables, etc.

– Reregistration is resulting in product specific label requirements based on product specific data (longer REIs, special PPE and/or special posting and notification requirements, etc.)

WPS Overview - Key Definitions

Agricultural establishment - means any farm, forest, nursery, or greenhouse

Agricultural plant - means any plant grown or maintained for commercial or research purposes and includes, but is not limited to, food, feed, fiber plants, trees, turf-grass, flowers, shrubs, ornamentals, and seedlings

Agricultural employer - means any person who hires workers, for any type of compensation, to perform activities related to the production of agricultural plants - or is responsible for the management of an agricultural establishment that uses such workers

Owner – means any person who has a present possessory interest in an agricultural establishment covered by the WPS

Immediate family - includes only spouse, children, stepchildren, foster children, parents, stepparents, foster parents, brothers, and sisters

Handler - means any person, including a self-employed person, who is employed for any type of compensation by a covered agricultural establishment or commercial handling establishment and who is doing any of the following tasks:

Handler tasks:• Mixing, loading, transferring, or applying

pesticides• Disposing of pesticides or pesticide

containers• Handling opened containers of pesticides• Flagging

Handler tasks: (continued) • Cleaning, adjusting, handling, or repairing any

part of pesticide equipment that may contain pesticide residues

• Assisting with the application of pesticides• Entering a greenhouse or other enclosed area…• Assisting with soil fumigation• Performing tasks as crop advisor

Worker - means any person, including a self-employed person, who is employed for any type of compensation and is performing activities relating to the production of agricultural plants (such as harvesting, weeding, watering, suckering, etc.) on a covered establishment

Hand labor - means any agricultural activity performed by hand or with hand tools that causes a worker to have substantial contact with surfaces (such as plants, plant parts, or soil) that may contain pesticide residues

Hand labor activities include, but are not limited to, harvesting, detasseling, thinning, weeding, topping, planting, sucker removal, pruning, disbudding, roguing, and packing produce into containers in the field

Hand labor DOES NOT include operating, moving, or repairing irrigation or watering equipment or performing the tasks of crop advisors

Treated area - means any area to which a pesticide is being directed or has been directed

Restricted Entry Interval (REI) - means the time after the end of a pesticide application during which entry into the treated area is restricted

WPS Overview - Key Provisions

General Duties and Prohibited Actions (170.7)• Establishes primary responsibility of

agricultural and/or handler employer for compliance and prohibits retaliation by employers

Violations (170.9) • For the purposes of 40 CFR part 170, EPA interprets

the term “use” to include:– Pre-application activities (storage, mixing and loading,

training, preparation for application, etc.)– Application of the pesticide– Post-application activities (training, notification,

decontamination, etc.)

Applicability (170.102 & 170.202)• The WPS applies when any covered

pesticide product is used on an agricultural establishment in the production of agricultural plants

Exceptions (170.103 & 170.203)• Pasture applications• Livestock applications• Rodent pest control• Post-harvest uses• Mosquito abatement, government sponsored “wide-area” public pest

control programs• Home gardens and greenhouses• Landscaping of ornamental plants• Non-cropland uses (right of way, wood preservation)• Research uses of unregistered uses

Exemptions (170.104 & 170.204)

• Exemption for Owner & Immediate Family

• Crop Advisor Exemption

WPS Requirements Applicable for Worker Employers

Restrictions During Application Restricted-Entry Intervals (REIs) Notice About Applications

• Providing oral warnings and/or posting WPS warning signs

WPS Requirements Applicable for Both Worker and Handler Employers

Anti-Retaliation Information at a Central Location Pesticide Safety Training Decontamination Supplies Emergency Assistance Employer Information Exchange

WPS Requirements Applicable for Handler Employers

Application Restrictions and Monitoring Specific Instructions for Handlers Equipment Safety Duties Related to PPE

Restrictions During Applications (170.110)

• During the application of any pesticide on an ag establishment, the ag employer shall not allow or direct ANY PERSON, other than an appropriately trained and equipped handler, to enter or to remain in the treated area

• Entry-restricted areas in greenhouses and nurseries• Entry-Restricted Area is NOT the same as an REI

Summary of Entry-Restricted Areas in Nurseries During Pesticide Applications170.110 (b)

During application of a pesticide: Workers are prohibited in:

(1) a- Applied: (i) Aerially, or (ii) In an upward direction, or (iii) Using a spray pressure > 150 psi, or(2) b- Applied as a: (i) Fumigant, or (ii) Smoke, or (iv) Mist, or (v) Fog, or (vi) Aerosol

Treated area + 100 ft in all directions on the

nursery

(2) a- Applied downward using: (i) A height > 12 in. from the plant medium, or (ii) A fine spray, or (iii) A spray pressure > 40 psi. and < 150 psi. b- Not as 1 or 2 (a) described above but for which a

respiratory protection device is required for application by the product labeling.

Treated area + 25 ft in all directions on the

nursery

(3) Applied otherwise Treated area

Entry-Restricted Areas in Nurseries

* This diagram depicts a treated area plus 100 or 25 ft. entry-restricted area in all directions on the nursery

Nursery Treated Area

100 ft

Summary of Greenhouse Entry-Restricted Areas Associated With Pesticide Applications

170.110 (C) (4)

A. When a pesticide is applied:

B. Workers are prohibited in:

C. Until: D. After the expiration of time in Column C until the Restricted-

Entry Interval Expires Area is:

(1) As a fumigant Entire greenhouse plus any adjacent structure that cannot be sealed off from the treated

The ventilation criteria of paragraph (c) (3) of this section are met

No entry restrictions after criteria in column C are met

(2) As a (i) Smoke, or (ii) Mist, or (iii) Fog, or (iv) Aerosol

Entire enclosed area The ventilation criteria of paragraph (c) (3) of this section are met

Entire enclosed area is the treated area

(3) Not in 1 or 2 above, and for which a respiratory protection device is required for application by the product labeling

Entire enclosed area The ventilation criteria of paragraph (c) (3) of this section are met

Pesticide treated area

(4) Not in 1,2, or 3 above and:

(i) From a height of > 12 in from plant medium, or

(ii) As a fine spray, or (iii )Using a spray pressure

> 40 psi.

Treated area plus 25 ft. in all directions in the enclosed area

Application is complete

(5) Otherwise Pesticide treated area Application is complete

Post-Application Entry Restrictions (REIs) (170.112)

• After the application of any pesticide on an ag establishment, the ag employer shall not allow or direct any worker to enter or to remain in the treated area before the REI specified on the pesticide labeling has expired, except as provided in the various exceptions

Exceptions to the Entry Restrictions

• Exception for activities with “no contact”• Exception for short term activities• Exception for an agricultural emergency

• Exception requiring Agency approval• Current, valid Agency granted exceptions

include:• Irrigation exception• Limited contact exception

Exceptions to the Entry Restrictions

Notice of Applications (170.120)

• The ag employer shall notify workers of any pesticide application on the establishment• Purpose is to notify workers about areas

where pesticide applications are taking place or where REI’s are in effect

• Some labels may require both oral notification and posting of treated areas with warning signs

WPS Field Posting Sign

Fumigant Treated Area Posting Sign

• Farms, Forestry Operations and Nurseries–Workers may be notified either orally or

by posting of warning signs• Greenhouses

–Must post all treated areas (and provide oral notification if both are required)

• Notice of applications need not be given if:–Worker will not enter, work in,

remain in, or pass through on foot:• the treated area • any area within 1/4 mile of the treated

area during the application

–Worker will not enter, work in, remain in, or pass through on foot (continued):• any area within 1/4 mile of the treated

area during the REIWorker applied the pesticide and is aware of information required

–Note difference for greenhouses

* Timing of Warning Signs –Must be posted 24 hours or less before

application–Remove the signs within 3 days after the

REI has expired–Keep signs legible and visible while they

are posted –Remove sign prior to entry by workers

* Timing of Oral Warnings– If workers are present they must be

warned before application takes place– If they are not present they must be

warned orally at the beginning of the next work period if the application is taking place or if the REI is still in effect

Providing Specific Information About Applications and Posting Pesticide Safety Information (170.122 and 170.135)

• If a worker whom they employ is on their establishment; and

• A covered pesticide has been applied or a REI has been in effect within the last 30 days

• List of recent pesticide applications– Location and description of treated area,

product name, EPA Reg. No., active ingredients, time and date of application, REI for the pesticide applied/to be applied

• Local emergency medical information– Name, phone number, and address

• WPS safety poster (or equivalent)

• Inform workers where information is located

• Allow access to the location• Information must remain legible• Shall be displayed until 30 days after the

expiration of the last REI

Notice of Applications to Handler Employers (170.124)

• Ag employers must provide handler employers with information about treated areas on their ag establishments if hiring commercial pesticide handlers that may be in or near treated areas– Specific location and description of any

such areas–Restrictions on entering areas

Pesticide Safety Training for Workers (170.130)

• The ag employer shall assure that each worker required to be trained has been trained according to the requirements in the WPS during the last 5 years

• Who can legally conduct worker training?• Certified applicators• Trainers of certified applicators• EPA or State-approved designated

trainers• Trained WPS handlers

• Other training criteria:–Train before 6th day (unless early entry)–Training must be presented orally from

written materials or audio-visually– In manner/language understood by

workers

• Use EPA/State approved training materials (videos, flip charts, manuals, slides) or assure coverage of points in WPS

• Respond to questions

Decontamination Supplies for Workers (170.150)

• The ag employer must provide decontamination supplies when workers will be working in an area:

–where a covered pesticide has been applied or

– an REI has been in effect within last 30 days and the worker will have contact with treated surfaces (except where products with an REI of 4 hours or less are only pesticides that were used)

• General conditions for decontamination supplies:–Soap and single-use towels in quantities

sufficient to meet worker’s needs–Enough water for routine washing/emergency

eye-flushing–Water must be of quality and temperature not

to cause illness or injury when it contacts skin or eyes or if swallowed (anti-siphon req. for mix water)

* General conditions for decontamination supplies: (continued)–Location must be reasonably accessible–Not more than 1/4 mile from work site–Cannot be in area being treated with

pesticides–Exceptions for remote sites–Additional requirements for early entry sites

Emergency Assistance (170.160)

• If there is reason to believe that a worker has been poisoned or injured by exposure to pesticides in connection with worker duties on the establishment, the employer shall provide emergency medical assistance:–Provide prompt emergency transportation

• …the employer shall provide emergency medical assistance: (continued)–Provide information:

• Product name, EPA Reg. No., active ingredients• Statement of practical treatment from labeling• Circumstances of the application• Circumstances of exposure of the

person involved

• The handler employer and the handler shall assure that no pesticide is applied so as to contact, either directly or through drift, any worker or OTHER PERSON, other than an appropriately trained and equipped handler

• Other restrictions:–The handler employer must assure that

handlers using skull & cross-bone products are monitored visually or by voice communication at least every two hours; and

–Fumigant handling/application in greenhouses must be monitored continuously• Monitor must have access to PPE

• If a handler whom they employ is on their establishment; and

• A covered pesticide has been applied or a REI has been in effect within the last 30 days

• List of recent pesticide applications–Location and description of treated area,

product name, EPA Reg. No., active ingredients, time and date of application, REI for the pesticide applied/to be applied

• Local emergency medical information–Name, phone number, and address

• WPS safety poster (or equivalent)

• Inform handlers where information is located

• Allow access to the location• Information must remain legible• Shall be displayed until 30 days after the

expiration of the last REI

Notice of Applications to Agricultural Employers (170.224)

• Before the application of any pesticide on or in an ag establishment, the handler employers must provide ag employers with information about pesticide applications or assure the ag employer is aware of such information

• Specific location and description of areas to be treated

• Product name, EPA Reg. No., active ingredient(s)

• Time and date of application• REI• Notification requirements• Any other restrictions

Notice of Applications to Agricultural Employers (170.224)

Pesticide Safety Training for Handlers (170.230)

• Before any handler performs any handling task, the handler employer shall assure that the handler has been trained according to the requirements in the WPS during the last 5 years

• Who can legally conduct handler training?• Certified applicators• Trainers of certified applicators• EPA or State-approved designated

trainers

• Other training criteria:• Train before any handling tasks

performed• Training must be presented orally from

written materials or audio-visually• In manner/language understood by

handlers

• Other training criteria (continued):• Use EPA/State approved training

materials (videos, flip charts, manuals, slides) or assure coverage of points in WPS

• Respond to questions

Knowledge of Labeling and Site-Specific Information (170.232)

• The handler employer shall assure that the handler:–has either read the product labeling or has

been informed in a manner the handler can understand all of the labeling requirements related to safe use of the pesticide

• The handler employer shall assure that the handler: (continued)–has access to the product labeling

information during handling activities– is aware of information about treated

areas on the ag establishment

Knowledge of Labeling and Site-Specific Information (170.232)

Safe Operation of Equipment (170.234)

• The handler employer shall assure that before the handler uses any equipment for mixing, loading, transferring, or applying pesticides, the handler is instructed in the safe operation of such equipment– Inspect and maintain equipment before each use–Remove residues before repair; or– Inform person of potential risks

PPE Requirements (170.240)

• Any person who performs tasks as a pesticide handler shall use the clothing and personal protective equipment (PPE) specified on the labeling for use of the product

PPE Requirements (170.240)

• Handler employer is responsible for:–Providing clean and properly operating PPE

to the handler–Assuring proper use of PPE by handler–Care and maintenance of PPE–Preventing heat-related illness

• Note PPE exceptions

Decontamination Supplies for Handlers (170.250)

* During any handling activity, the handler employer must provide for handlers, decontamination supplies for washing off pesticides and pesticide residues

• General conditions for decontamination supplies:–Soap and single-use towels in quantities

sufficient to meet handler’s needs (plus clean change of clothing)

–Enough water for routine washing, emergency eye-flushing and washing entire body in case of emergency

• General conditions for decontamination supplies: (continued)–Water must be of quality and temperature

not to cause illness or injury when it contacts skin or eyes or if swallowed (anti-siphon req. for mix water)

• General conditions for decontamination supplies: (continued)–Location must be reasonably accessible–Not more than 1/4 mile from work site–Exceptions for remote sites

• Additional conditions for handler decontamination supplies:–Decontamination supplies must be at

mixing/loading sites–Emergency eyeflush water must be

immediately available when label requires protective eyewear

• Additional conditions for handler decontamination supplies: (continued)–Decontamination supplies may be in

treated area (but covered)–Decontamination supplies must be at site

for removing PPE and washing thoroughly at end of exposure period

–End-of-day site may use clean towels

• If there is reason to believe that a handler has been poisoned or injured by exposure to pesticides in connection with handling duties on the establishment, the employer shall provide emergency medical assistance:

• ...the employer shall provide emergency medical assistance:– Provide prompt emergency transportation –Provide information:

• Product name, EPA Reg. No., active ingredients• Statement of practical treatment from labeling• Circumstances of the application• Circumstances of exposure of the person involved

Interpretive Guidance Workgroup

* The Interpretive Guidance Workgroup (IGW) was established to address WPS policy questions. Existing IGW policies can be found on EPA’s worker safety website:

www.epa.gov/pesticides/safety/

1 Worker Protection Standard (WPS) Pesticide Inspector Training Helena, Montana November 30, 2011...

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