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Pesticides: The Latest Buzz EPA’s Proposed Workers Protection Standard
Agenda
Overview of existing WPS
Analysis of proposed changes
Rulemaking process
Strategies for participation in rulemaking
Tips for reviewing existing programs
Suggested resources
Overview of Existing WPS
Current WPS, 40 CFR 170 Pesticide safety training
Access to labeling and specific information
Keep workers out of areas being treated and under REI
Protect early-entry workers
Notify workers
Provide PPE
Decon supplies
Emergency assistance
Who is covered
Responsible for compliance
Owners/employers
Employers of researchers
Employers at commercial establishments
Exceptions
Owners and immediate family
Certified or licensed crop advisors
Limited and narrow circumstances
Who is protected
Pesticide handlers
Agricultural workers
Some requirements – anyone doing certain tasks
Duties for Employers
Duties for ALL employers:
Do not retaliate
Provide info
Provide safety training
Provide decon supplies
Exchange info
Provide emergency assistance
Duties for Employers
Additonal Duties for employers of workers:
Restrictions
REIs
Early-entry worker protections
Notify workers
Additional Duties
For employers of handlers:
Restrictions
Monitor
Specific info
Ensure equipment safety
PPE
Analysis of Proposed Changes
Increased Training
Annual training
Restrictions on entrance
Decontamination supplies
Access to info
Use of PPE
Postings
No-entry signs posted until residues decline to safe
level.
Age Requirement
Under 16 prohibited
No-Entry Buffer Areas
Protect from exposure from overspray and fumes
Improve State Enforcement
Records
Training
Early-entry notification
PPE
Consistent with OSHA
Information
Application
Labels
SDS
Other…
Easier compliance
Exemptions still in place for family farms
Rulemaking Process
Timeline
February 20, 2014: EPA announced proposed changes
March 19, 2014: Notice of Proposed Rulemaking
August 18, 2014: Comments must be received
Strategies for Participation in
Rulemaking
Comments
The comment period has been extended to August
18, 2014.
1st – read about changes
2nd – read full explanation of changes, rationale, and
disucssion of alternatives
3rd – submit comments (English or Spanish)
Submitting Comments
Federal eRulemaking Portal
Hand Delivery
Questions
Training for Workers and Handlers
Shorten retraining interval for workers and handlers
Establish recordkeeping requirements to verify training for
workers and handlers
Require employers to provide establishment-specific info
for workers and handlers
Establish trainer qualifications
Expand the content of worker and handler pesticide
safety training
Retain AV presentations as training
Eliminate exception to handler training requirements
Questions
Notifications to workers and handlers
Posted notification timing and oral notification
Locations of warning signs
Warning sign content
Questions
Hazard Communication
Pesticide-specific hazcom materials
Pesticide application info – content and timing
Pesticide application info – location and accessibility
Pesticide application info – retention of records
Questions
Info exchange between handler employers and ag
employers
Questions
Handler restrictions
Questions
Restrictions for worker entry into treated areas
Questions
Display of basic pesticide safety info
Questions
Decontamination and emergency assistance
Questions
PPE
Questions
Monitoring handler exposure to cholinesterase
inhibiting pesticides
Questions
Exemptions and exceptions
Questions
General revisions to the WPS and implementation of
this proposal
Tips for Reviewing Your Existing Program
HTC Document
Use current HTC as a way to audit your program
Suggested Resources
Current WPS
June 2006 reprint of WPS “How to Comply” manual
Publications – Ag Center
Fact Sheets on WPS
Thank you!
Continue the conversation –
Abby Ferri, CSP
abbyferri@gmail.com
612-567-9981
@abbyferri
Abby Ferri, CSP
+AbbyFerriCSP
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