A44-Lancaster Fanning, Saturday, September 17, 1994
1994 Versus 1995 WPS Compliance
Requirements
Congress recently enacted legislation which
delays implementation of some but not all of the
WPS until January 1,1995. The new law provides
the agricultural community with more time to learn
about the WPS and to prepare for implementation.
Table (1) is a summary of the key WPS
provisions, including those that are required to be
implemented in 1994, and those that are deferred
until January 1,1995. Most of WPS requirements
appear on the labels of the pesticides used on
agricultural establishments (farms, forests,
nurseries, greenhouses). There are two types of
WPS provisions on the label; those that are fully
spelled out, and those that are referenced but
not thoroughly described on the label.
During 1994, you must comply with the WPS
requirements that are spelled out on the label.
These include the label requirements for personal
protective equipment (PPE), the restricted-entry
interval (REI), and the requirement for "double
notification," if this requirement is on the label.
Double notification requires both oral warning and
posting warning signs at entrances to treated
areas.
You need not comply with the WPS requirements
only referenced on the label until January 1,
1995. These include pesticide safety training for
agricultural workers and handlers,
decontamination sites, notification of workers
about pesticide applications (except the "double
notification" requirement described above), display
of information about pesticide applications,
emergency assistance, and display of the
pesticide safety poster.
Restricted-Entry Interval Requirements
Under the WPS, each agricultural pesticide label
will specify a restricted-entry interval (REI),
usually ranging from 12 to 72 hours. Some labels
may specify a longer REI. The REI begins
immediately after pesticide application. You must
keep workers out of a treated area during the
REI, except in the following situations.
(1) No contact early entry. After any applicable
inhalation exposure level or ventilation criteria has
been met, you may permit workers to enter a
treated area during an REI if they will not touch or
be touched by any pesticide residues on plants, in
soil, in water, or in the air. If there is no contact,
there are no PPE requirements and no time
limitations. The exception to early-entry
limitations for no contact early entry applies in
1994 and beyond.
(2) Non-hand labor early entry. You may allow
workers to enter treated areas before the REI is
over to perform non-hand labor jobs that will
involve contact with pesticide residues. These
tasks include operating, moving or repairing
irrigation or watering equipment, but does not
include such tasks as harvesting, weeding,
pruning, cultivating, etc., which are considered
hand labor tasks. You must make sure that non
hand labor early-entry workers do all of the
following:
(a) Wear the early-entry PPE specified on the
label. In 1994, you must provide the early-entry
PPE to the worker and it must be in clean and
operating condition. Starting January 1, 1995,
EPA WORKER PROTECTION STANDARD (WPS)
Jk! COUNTDOWN TO COMPLIANCE ...
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OCTOBER
NOVEMBER
DECEMBER
TABLE (1) SUMMARY OF KEY 1994/95 WORKi
Requirement Applies Applies Notes
in after
1994 1/1/95 (Pag* numlwr* Kited ratarmccEPA’* WPS How To Comply Manual)
Restricted Entiy Inteivl (REI) Yes Yet The REI Is specified on the label. (pgt 45-47)
Early Entry AcHvWet Involving Yet-no Yet-time No entry for flrtt four hourt alter application & Inhalation
contact w/lreated aurfacea timelimits IlmHa levels/ventilation criteria met. PPE required. No hand labor. Until
1/1/BS, no limit on worker time in treated area. Alter 1/1/95, one
hour/day. (pg 137)
Personal Protecßve Equipment Yes Yea PPE apadtled in Pracautlonaiy Slatemenla portion of the label
/PPE) for Handlara must be uaad. Additional employer dutiea for providing, cleaning.
maintaining PPE alter 1/1/95. (pg* 79-81,139)
PPE for Early Entry Workers Yea Yea PPE muat be provided by the employer and must be m clean and
involving contact with treated operating condition. Additional employer dutiea for providing,
surfacea cleaning, maintaining PPE after 1/1/95. (pga 65,69-70,139)
Early Entry Irrigation Workers Yes No Until 1/1/95, early entry PPE or covsralla plus chemical-realatant
Choice of PPE gloves and chemical-realatant fbotwaar if there is pesticide contact
only to the feat, lower legs, hands, arms. Alter 1/1/95, use PPE on
label tor early entry.
Notification of Agricultural No Yea Required alter 1/1/95. In moat cases, employer can choose oral
Workers about Applications notification or posting, unless both are required by the label.
Greenhouse uaeS*posting required. (pgl39)
Double Notification, Oral & Yes Yes In 1994, employer must post and warn. Alter 1/1/95, must use the
Posted Warnings, as req.d on WPS field warning sign and follow WPS specifications for posting
labels for most toxic products or for oral notification. (pg 520,33,41.139)
Protections for Crop Advisors No Yes Until 1/1/95. WPS does not apply. (pgl36)
Pesticide Safety Training for No Yes WPS requires basic safely training for workers and more detailed
Handlers and Agric. Workers training far handlers, (pg 141 A other EPA training handbooks)
Additional WPS Protections: No Yes These and other WPS requirements are delayed untH 1/1/95. This
-Display of a Safety Poster delay gives employers an opportunity to learn about the
- Pesticide Application Display requirements and integrate them into work operations?
- Decontamination Sites
- Emergency Assistance
- Monitoring Handlers
- Employer Info. Exchange _—
there are additional employer duties for providing,
cleaning, and maintaining the PPE.
(b) Wait at least four hours after the pesticide
application is completed before entering the area.
(c) Wait at least until any inhalation exposure level
listed on the label has been reached.
During 1994, there are no time limitations to non
hand labor early entry. Starting 1-1 -95, early-entry
work under this exception is limited to short-term
tasks and usually not allowed to exceed one hour
per worker each day.
"Countdown To Compliance" is a cooperative educational
effort of the PA Department of Agriculture, Penn State Office
of Pesticide Education, Penn State Cooperative Extension
Service, PA Farm Bureau, PA Farmers Union, PA State
Grange, PA Vegetable Growers Assoc., PA Christmas Tree
Growers Assoc., Adams County Fruit Growers Assoc., PA
Farmer Magazine, and Lancaster Farming Newspaper.
Copies are available by contacting PA Farm Bureau Division.
leptember Comi
Review WPS requirements for 1994 in
Table 1 above and all appropriate portions of
WPS How To Comply Manual.
Review your chemical handling/use
practices for REl's, early entry, PPE, and
double notification to determine if they meet
WPS label requirements.
Register For Pa. Plowing Contests
NEW YORK. N.Y, Ard
shiel, Inc. announced that it has
concluded the transaction for the
purchase of American Breeders
Service (ABS) and the Caribbean
Fertilizer businesses owned by
:er protection standard
iliance Checklist
W.R. Grace & Co., for a combined
purchase price of approximately
$39 million in cash, as previously
indicated in June 1994.
Ardshiel, Inc. formed a new
company to acquire the two busi-
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nesses, registered as Protein
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directors of the new company.