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Pesticide Labels May Contain Worker Protection Regulations
ANDY ANDREWS
Lancaster Fanning Staff
GUTHRIESVILLE (Chester
Co.) Applicators beware: pesti
cide labels are being rewritten with
intent to place some aspects of the
Environmental Protection Agency
(EPA) .Worker Protection Stan
dard (WPS) in them. Those regula
tions, such as wearing protective
clothing and imposing restricted
re-entry times, could affect your
operation in a big way.
Now is the time to fully read and
understand WPS regulations
because they may soon be made
legal and enforceable, according to
Kerry Hoffman, Penn State pesti
cide education coordinator.
Hoffman spoke to about 12S
industry representatives—includ
ing private and commercial appli
cators on Monday morning at
the Chester County Crops Day.
According to Hoffman, many of
the regulations exempt private
applicators and their immediate
family (that includes brothers, sis
ters, mothers, fathers, children,
even foster children and foster
parents) except in-laws. The
Environmental Protection Agen
cy, under whose auspices the WPS
regulations are written, “felt inhe
rently that you have provided those
kinds of things for your family and
you would take care of your fami
ly,” according to Hoffman.
But if you employ workers to
dispense pesticides, and your busi
ness commercially provides pesti
cide applications, take heed. Soon
unless commodity groups and
other organizations can make
necessary changes to the law
the WPS could become
enforceable.
For private applicators, if cited,
the fine is $l,OOO per incident For
commercial applicators, fines are
$3,000 per incident according to
Hoffman.
The bottom line, according to
the pesticide education coordina
tor, is worker protection.
“This is a law that forces you to
do what yo have been doing for a
lot of years protecting yourself
and the people that work for you
from the potential to be exposed to
pesticide residues in fields," she
said.
Hoffman reviewed a checklist
of WPS requirements for agricul
ture workers as defined by EPA.
The following rules may soon
apply:
✓ Information at a central loca
tion. The information would
include a poster (available through
your extension office) about the
dangers of being in a treated area.
Also, the poster would include the
location of emergency treatment
facilities. This central location also
needs to have an indentification of
any pesticide applications made,
when, and in what areas. The cen
tral location can be an office, cof
fee room, time clock area any
where there is free and easy access
by your employees.
✓ Training for workers. The
training is contained in the EPA
booklet, “The Worker Protection
Standard For Ag Pesticides
How To Comply.” The book is
available from most cooperative
extension offices. Workers are
required to fully read and under
stand what is described in the book
in order to meet this aspect of the
requirements. The 42-page book is
written in Spanish and English.
Also, a videotape is available on a
loan basis from cooperative exten
sion offices.
✓ Decontamination sites. If any
WPS Regulations Reviewed At Chester Crops Da'
worker is exposed to a pesticide,
make sure it is taken care of right
away, according to Hoffman. This
means that a wash-down site must
be located within 'A mile of the
application site and must be
equipped with soap, water, and
single-use paper towels. The EPA
guidelines spell out one gallon of
water per worker and three gallons
of water per handler.
✓ Emergency assistance. If
there is an exposure, the employer
must make sure the workers get
treatment for the exposure, said
Hoffman. How to obtain that assis
tance must be spelled out in the
poster at the information at central
location.
Hoffman said the first four rules
apply to private and commercial
applicators. The exemptions to the
above four rules: immediate fami
ly, as defined above, excluding in
laws.
The following regulations apply
to private and commercial applica
tors and their families:
✓ Restrictions during applica
tions. If using a labeled “skull and
crossbones” pesticide, voice con
tact must be maintained with the
applicator at two-hour intervals.
Also, protective clothing, includ
ing boots, gloves, and coveralls,
must be worn according to label
requirements.
✓ Special application restric
tions in nurseries. EPA regulations
are complex, depending on type of
operation. Consult the book for
details.
✓ Special application restric
tions in greenhouses. Again,
another EPA regulation specifical
ly for greenhouse operators, with
an array of requirements. Consult
book for details.
The following regulation “is
really the most difficult part of this
regulation to understand and to
communicate. In reality, the hard
est part with this regulation is
what’s called restricted entry
intervals (described here),” said
Hoffman.
“With every chemical now,”
she said, “it is no longer OK to
say, oh, you can go back in that
field when the sprayers have dried
or the dust is settled. That doesn’t
get it anymore. You cannot use
that as criteria to judge when
you’re allowed to go back in a
treated area.”
✓ Restrictions during
restricted-entry intervals (and lim
itations on early entry). As the reg
ulation stands now, according to
Hoffman, 12 hours is the minimum
restricted entry interval for all
chemicals. This depends on the
label. Now more than ever before
it’s important to read the label,
according to Hoffman.
✓ Notice about applications
(oral warnings and treated area
posting). Employers can orally
instruct workers about what areas
that pesticides have been applied.
But, according to EPA regulations,
a sign must be posted that clearly
indicates “keep out.” This warn
ing sign is available through
cooperative extension offices.
Asa result of these WPS regula
tions, labels continue to change
dramatically. Commodity organi
zations and farm bureaus are
mounting drives to petition EPA to
have the regulations altered, speci
fically the re-entry times, to con
form more realistically to farm
operations. Hoffman said that two
weeks ago, 39 national commodity
organizations joined to petition for
another delay in the enforcement
of the WPS.
The 1994 Innovative Farmer of the Year Award went to Seven Stars Farm, Inc., Klm
berton, operated by David Griffith, left. At right is district manager, Dan Greig.
At the banquet, the county conservation district honored DH Lone Hill Farm, Honey
Brook, as 1994 Conservation Farmer of the Year, operated by David Homing, right. At
left Is Dan Greig, Chester County Conservation District manager.
‘ ‘lf you feel strongly about parts
of this regulation that need to be
changed, now is the time to
speak,” said Hoffman.
She said that the theory behind
the regulations is good, ‘‘but the
practicality needs a little work.”
But for many businesses, it is
better to make efforts to try to con
form to WPS regulations to protect
the health of the workers and vit
ality of the business in the long
run. “It’sbettertoerronthesideof
caution than to not do it at all,” she
said.
“I truly believe that we in Pen
nsylvania have really tried very
hard to be progressive and to get
this information out to you and to
listen to your comments and to try
and make this regulation work in
every industry that it's been meant
to address. It’s hard to take a reg
ulation and make it work for dairy
farmers and flower growers all at
the same time. But basically that’s
what they’re doing.. . .
“I think that, for the most part,
you are already doing the things
you need to do to protect the peo
ple that you have out there from
exposures,” she said.
Also at the Crops Day. Alan
S track, Chester County farm man
agement agent, reviewed some of
the changes made to basic govern
ment programs and how they will
affect fanning.
One agency, the former USDA
ASCS, is now the consolidated
USDA Farm Service Agency
(FSA). The SCS is now called the
Natural Resources Conservation
Service, or NRCS.
One thing that has become
important to securing government
assistance, particularly in times of
disaster, is the new catastrophic
coverage (CAT), the new federal
crop insurance program, that is
available from the USDA FSA.
The annual fee is $5O per crop per
county, not to exceed $2OO per
county or $6OO per producer.
To qualify for other programs,
according to Shock, farmers must
purchase CAT. Applications must
be made by March IS fra all crops.
Additional coverage is available.
Fra other programs, of which
Strock described, it is important
that farmers ‘‘stay informed and
stay in contact with local offices,”
he said.
Also at the Crops Day, Lynn
Hoffman, Penn State agronomy
extension specialist, provided
information on new herbicides and
spoke about conservation tillage.
Dennis Calvin, Penn State ento
mology extension specialist, pro
vided information on effective
integrated pest management (IPM)
programs available to farmers
right now. He also provided an
insect management update.
At the banquet, the county con
servation district honored DH
Lone Hill Farm, Honey Brook, as
1994 Conservation Farmer of the
Year. Operated by David Homing,
DH Lone Hill Farm milks about 70
cows and farms 133 acres. The
crop rotation is two-year com with
a rye cover crop and a three- to
four-year alfalfa stand. The farm
follows a nutrient management
and conservation plan that consists
of conservation cropping, contour
fanning, contour stripcropping,
cover cropping, manure storage,
and pasture management.
The 1994 Innovative Farmer of
the Year Award went to Seven
Stars Farm, Inc., Kimberton, oper
ated by David Griffith. Seven Stars
Farm milks about 65 cows and
farms 282 acres. The crop rotation
is one-year com, one-year soy
bean, one-year small grain, and a
four-year alfalfa stand. The farm
follows a nutrient management
and conservation plan that consists
of conservation cropping, contour
fanning, crop residue use, com
posting pad, conservation tillage,
cover cropping, waste storage
pond, pasture management, water
ways, and wildlife management.
According to the district, the
farm recently installed a compost
ing pad with a waste storage pond
'to better utilize manure. The farm
uses leaves and manure to make
compost in order to retain the
nutrients for later use in field appli
cation. All runoff water is col
lected in the waste storage pond
and reapplied to either the compost
or an adjacent field. Griffith also
uses municipal leaves in his com
posting operation, according to the
district.