^Uplied States * t "
^Environmental Protection
».Agency
EPA300-B-02-001
March 2002 ~
. Enforcement And Compliance Assurance (2225A)
Worker Protection
JField Inf pectipn
Pocket Guide
-------
DISCLAIMER
While unlikely, if any discrepancies are
noted between this document and 40 CFR
Part 156, subpart K or 40 CFR Part 170, 40
CFR Parts 156 and 170 shall be controlling.
Please notify Amar G. Singh at (202) 564-
4161 if any discrepancies are found.
TABLE OF CONTENTS
I. Background on the Worker Protection Standard . 1
The Revised Worker Protection Standard 1
Legal Authority 3
Pesticide Labeling Requirements;
40 CFR part 156, subpart K 4
The Worker Protection Standard;
40 CFR part 170 . 4
Exceptions: WPS 4
II. Summary of Effective Dates 7
Registrants' Implementation Schedule 7
Table 2.1 7
WPS Complying Labeling .9
Labeling to comply with PRN 93-11 10
Products Bearing labeling Per PRN 95-5 12
Pesticide Users' Compliance Schedule 14
' III. Section 1. Specifics of the Inspection Process . 15
i
Registrant/Producer Establishment &
Marketplace/Dealer Inspections 15
Requirements based on 40 CFR part 156, ..".... 15
Labeling Statements 15
Application Statements .15
Reference Statements 16
Product-Type Identification Statements 17
State Restrictions 17
Table of Contents-
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[ TABLE OF CONTENTS
Spanish Warning Statements 18
Table 3.1 18
Product-Specific Statements 19
Table 3.2 ^19
Restricted-Entry Statements .19
Exceptions/Variations: Restricted-Entry .. 20
Notification-to-Worker 21
Personal Protective Equipment 21
Min. PPE Requirements & Work Clothing for
Handling Activities Table 3.3 22
ChemicaKresistant gloves 23
Respiratory requirement 23
Existing respirator requirement for Handlers On
product labeling .24
New respirator requirement for handler 24
Additional PPE Requirements for Handlers 24
PPE for early entry workers 25
III. Section 2. Use Inspections , 27
Requirements based on 40 CFR part 170 27
1. Notification/Posting of Application 28
Table 3.4 Requirements for Posted Warning Sign 30
Worker Protection Warning Signs 31
7"x8" Size Sign requirements 34
4 1/2"x5" Size Sign requirements 34
Table 3.5 Requirements for Oral Warnings 35
2. Application/Entry Restrictions 37
Farms and Forests Provisions 37
Nursery Provisions 37
Table 3.6 Entry-Restricted Areas in Nurseries 38
Greenhouse Provisions 33
Table 3.7 Entry-Restricted Areas'in Greennouses40
Exceptions: Early Entry Worker 42
New Regulatory Amendments 42
Requirements for Pesticide Handlers 44
3. PPE for Handlers and Early Entry Workers 45
EXCEPTIONS To PPE REQUIREMENTS ' ' 47
1. A Closed System " 47
2. An Enclosed Cab ... 49
3. Cockpits .... :" 50
SPECIFIC REQUIREMENTS FOR HANDLERS51
4. Pesticide Safety Training 52
Basic Pesticide Safety Training ......... 53
General Requirements For Workers/Handlers 54
Specific Training for. Workers 54
Training Requirements for Handlers 55
EXCEPTIONS: To Training 58
5. Posted Pesticide Safety Information ... 53
Pesticide Safety Poster 59
Emergency Medical Care Information '..'.'..'...60
Pesticide Application Information .... 61
6. Decontamination 61
NOTE: EPA Amendment.................'' 62
Exceptions: Decontamination 64
7. Emergency Assistance '.'.'.'.'.'.'.'" 65
Exception ' 66
8. Retaliation ...............' 66
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BACKGROUND ON THE
WORKER PROTECTION STANDARD
The Worker Protection Standard
o
Standard (WPS) issued underthe Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) for
agnculture pesticides in August 1992 to reduce risks of illness
or injury resulting from worker pesticide exposure in
nnt"nn uUra' p/°ducti°n- ^ scope of tne regulation includes
not only workers performing hand labor operations in fields
and artWih »**"* ^ &lS° W°rkerS in fores"s 3U,
and greenhouses, and employees who handle (mix, load
apply, etc.) pesticides in these locations. The Standard '
requires warnings about applications, use of personal
Protective equipment (PPE), and restrictions on entry to treated
areas. There are also provisions for decontamination
emergency assistance, maintaining contact with handlers of
highly toxic pesticides, and pesticide safety training.
Iatbelin9 regulations (40 CFR Part 156, subpart K)
required that certain statements be placed on the la
pesticide products that bear directions for use in the
ReaK?C "«' W °" 3ny ^cultural establishment
Registrants of affected pesticides were required to revise the
product labeling by April 21, 1994, in accordance wlfh
wfth WPq?l9^ tl0n (P-R) N°tiCe 93'7 and 93-11- to Comply
with WPS labeling requirements. Products sold or distributed
by reglstrants after April 21, 1994, were required to have WPS
labelmg (except for a limited number that were included in the
Chapter I
.Page 1
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I BACKGROUND |
"released for shipment" option in PR-Notice 93-11). The WPS
also required that any agricultural pesticides sold or distributed
by any person (including pesticide retailers and distributors)
after October 23,1995, must bear labeling that complies with
the WPS. To meet this deadline the EPA issued PR Notice 95-
5 to retailers and distributors of agricultural pesticides to
provide guidance on : 1) how to recognize pesticide products
in their possession that do not comply with the WPS
requirements, and 2) how to bring all applicable product labels
into compliance with WPS requirements, so that such
products could be legally sold and distributed after October 23,
1995.
In response to farm workers groups and grower groups, on
May 3,1995, EPA issued the following five regulatory actions
in the Federal Register, Vol. 60, No. 85 to revise elements of
the 1992 WPS. These actions (1) shorten the time periods
before which employers must train workers in pesticide safety;
(2) exempt qualified crop advisors from certain requirements;
(3) allow early entry to pesticide treated areas to perform time
sensitive irrigation activities; (4) allow early entry to pesticide
treated areas to perform certain time sensitive activities
resulting in "limited contact" with pesticide-treated surfaces;
and (5) allow registrants to amend the labels to reduce the
restricted entry intervals (REIs) from 12 hours to 4 hours for
certain low risk pesticides.
On June 26,1996, the EPA issued two amendments in Federal
Register, Vol. 61, No. 124 to the WPS to allow substitution of
an alternate language commonly spoken and read by workers
I BACKGROUND |
for the Spanish portion of the warning sign. This amendment
also allows use of smaller warning signs (two sizes) in
greenhouses and nurseries.
This WPS rule applies to all agricultural establishment owners,
even if they, or members of their family, do all the work. In
such a situation, the owners have to comply with some
requirements such as restricted-entry intervals, PPE, and all
specific requirements listed on the pesticide labeling although
they are exempt from some WPS requirements, such as
posting information at a central location, pesticide safety
training, decontamination supplies, emergency assistance, and
notice about applications. The WPS does not allow any
exemptions for owners of commercial pesticide handling
establishments, or persons who operate or manage, but do not
own, an agricultural establishment.
Legal Authority
EPA's authority to implement the Worker Protection Standard
is authorized by section 25(a) of the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. 136 w(a).
FIFRA requires that all pesticide products be registered with
the EPA (unless specifically exempt) and makes it "unlawful
for any person to use any registered pesticide in a manner
inconsistent with its product labeling." EPA promulgated the
following WPS rules on August 21, 1992. They became
effective October 20, 1992.
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Chapter I
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Labeling Requirements for Pesticides and Devices 40 CFR
Part 156, SubpartK.
The Worker Protection Standard, 40 CFR Part 170.
Pesticide Labeling Requirements; 40 CFR part 156
subpartK
These requirements are discussed in Chapter III, Section 1 -
Registrant/Producer Establishment and Marketplace/Dealer
Inspections (Page 15).
The Worker Protection Standard (WPS); 40 CFR part 170
In addition to covering agricultural workers/the WPS includes
persons who handle pesticides for use on agricultural
establishments. The Standard covers all pesticides used in
the production of agricultural plants on farms, forests,
nurseries, and greenhouses. These requirements are
discussed in Chapter III, Section 2 - Use Inspections (Page
27), and the exceptions to the WPS are listed below.
[(Reference EPA's How To Comply Manual (HTC), dated July
1993, pps. 9-11)] y
EXCEPTIONS: [(170.102{b)(1) and 170.202(b)(1)]
Some pesticide uses are not covered by the WPS. Even
when the Agricultural Use Requirements section is on the label
if product is to be applied to rights-6f-way, such a use is not
covered by the WPS. The WPS does not cover pesticides
applied:
for mosquito abatement, Mediterranean fruit fly eradication
or similar wide-area public pest control sponsored bv
governmental entities.
NOTE: The exception at 170.102(b)(1) and 170 202(b)(1)
does not extend to those cooperative programs in which the
SH8,. I make °r arr*nge for Pesticide applications
to their crops. Examples of such applications are boll-weevil or
gypsy moth applications which the growers arrange for or
(See 7.16 Q & A in WPS Q & A Document ).
on livestock or other animals, or in or about animal premises.
on plants not grown for commercial or research purposes.
on ornamental plants in gardens, parks, lawns, etc.
for uses not directly related to agricultural plant production
(e.g pastures, rangelands, structures, right-of-way areas,
SlC.y.
for control of vertebrate pests.
as attractants or repellents in traps.
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Chapter I
Chapter I
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BACKGROUND
on the harvested portions of agricultural plants or on
harvested timber.
for research uses of unregistered pesticides.
In addition, the Standard does not apply to employers of
workers when the pesticide is applied on an agricultural
establishment by injection directly into agricultural plants.
However, people who handle pesticides that are to be applied
by direct injection ARE covered by the WPS and must receive
handler protections. Chemigation, soil-incorporation, soil
injection, hack and squirt or frill and spray are covered by
WPS.
(Reference: EPA's HTC, p. 17)
SUMMARY OF EFFECTIVE DATES *
Registrants' Implementation Schedule
Table 2.1 is a schedule established by EPA for registrants to make
the WPS-required alterations to pesticide product labels.
* NOTE: The April 21, 1994 date applies to bulk pesticides
repackaged by dealers or others under the Bulk Repackaging
Policy. All registrant labeling requirements apply.
Table 2.1 Registrants' Compliance Schedule *
Before
April 21,
1993
No products bearing the WPS-
required statements may be
sold or distributed.
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Chapter I Chapter II
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COMPLIANCE DATES
COMPLIANCE DATES
8ate
After
April 21,
1994
All affected products sold or
distributed by registrants must
bear revised labeling with the
WPS^-required statements.
' NOTE: Registrants selecting
released for shipment option
before Jan. 1, 1994, may sell or
distribute products without
bearing labeling that complies
with WPS if registrant agreed to
recall and relabel the product
after Oct. 23,1995.
During producer establishment
inspections and at warehouses
owned/operated/leased by the
registrant, inspectors should
verify that product labels are in
compliance.
After
Oct. 23,
1995
After
Oct. 23,
1996
All affected products sold or
distributed by anyone must
bear or be accompanied by
WPS labeling with the WPS-
required statements or under
very limited circumstances,
with generic WPS labeling.
During marketplace
inspections, inspectors
should verify that product
bears WPS labeling.
Product bearing 95-5
stickering may not be sold or
distributed.
WPS COMPLYING LABELING
During marketplace inspections, inspectors must verify that the
label, labeling or replacement labeling for the pesticide contains the
following worker protection statements:
* Application Statements
+ Reference Statements (which requires users to comply with the
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COMPLIANCE DATES
* Product-Type Identification Statements e g
organophosphate
* State Restriction
+ Spanish Warning Statements,
* Cn«fiUCrSPtd^ S,tatements- e-9- RH'8. PPE Statements and
Notification to Worker Statements.
(Please reference EPA's PR Notice 93-11.)
Inspectors may find one of the following WPS Complying labeling
products in the channels of trade:
Final product-specific replacement labeling submitted by the
registrant to comply with PR Notice 93-7, 93-11 or through
certification. May be sold after 10/23/96.
Registrant verified labeling with deviations pre-approved bv EPA
May be sold after 10/23/96. uuynr-M.
- Revised EPA accepted labeling or registrant-verified labeling as
either final or interim labeling (sticker plus replacement labeHng)
to comply with PRN 93-11. Acceptable interim labeling must
consist of:
a) a sticker affixed onto product package of an existing label
and must include required text with title, "REPLACEMENT
LABELING" (crucial for identifying 93-11 product!)
"Stop! The label on this pesticide is no longer in effect
Follow replacement labeling received at sale....", and
b) product-specific replacement labeling referenced by the
sticker need not be attached to container and must contain
COMPLIANCE DATES
the final PRN 93-11 complying labeling (as EPA-accepted
or registrant-verified). It is the registrant's responsibility to
ensure that the replacement labeling accompanies the
product at the time of sale to any end users
May be sold after 10/23/96.
H8'0*5 Sti
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COMPLIANCE DATES
WPS scope, cannot be sold after Oct. 23,1995 unless
relabeled with the non-WPS label.
PR Notice 95-5 applied to stocks of registered products subject to
the WPS, which do not have required WPS labeling and are under
custody or control of wholesalers or retailers and could not be sold
or distributed after October 23, 1995. Any relabeling of non-
complying products with WPS labels was to be done in cooperation
with, and under the written authorization of the registrant. WPS-
related relabeling under PR Notice 95-5 could occur at any site
without registration of the site as a pesticide producing
establishment by the registrant or a retailer or wholesaler could be
authorized to relabel the product. Products could be relabeled by
replacing existing labeling with final printed WPS-complying
replacement labeling supplied by the registrant of the product.
Such labeling must be affixed to the product package
(May be sold after 10/23/96).
Alternatively, products could be relabeled by using supplemental
product speciifc labeling that was provided with each product when
offered for sale to the end user (Cannot be sold after 10/23/96).
PRODUCTS BEARING 95-5 COMPLYING LABELING
Final printed WPS-complying replacement labeling supplied by
the registrant of the product. Such labeling must be printed on
or affixed to the product package.
May be sold after 10/23/96.
1.
2.
Final WPS-complying replacement labeling may also be
designed to modify existing labeling by adding the required
WPS labeling statements without replacing the entire existing
3.
4.
5.
I COMPLIANCE DATES |
labeling. The replacement labeling must be affixed in such a
way so that it must not alter or obscure the other portions of the
label text that remain unchanged.
May be sold after 10/23/96.
Products with "STOP sticker" affixed to the label with the text,
" STOP! Use this product only in accordance with the Worker
Protection Standard, 40 CFR Part 170, and the Supplemental
Labeling with Worker Protection Requirements," which must
be provided when the product is offered for sale. Two types of
supplemental product-specific labeling are:
A) single product supplement or
B) multi-product supplement.
Cannot be sold after 10/23/96.
NOTE: For "Stop stickers", ACPA members used a 95-5 specific
color combination, an orange background with black lettering.
The Agency did not require a specific color scheme for the
stickers, so it is NOT possible to rely on sticker colors for
identification of 95-5 products for all registrants.
Orphaned or canceled products may bear "Stop sticker" and
generic supplemental labeling that is provided when the
product is offered for sale to the end-user. Canceled products
without WPS complying labeling may be sold after 10/23/96 if
in compliance with cancellation order.
May be sold after 10/23/96.
Dormant product labeling must be amended to include the '
WPS requirements or amend the product registration to delete
any WPS uses. May be sold after 10/23/96
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Chapter II
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I COMPLIANCE DATES I
6. Buy-out or transferred products with final WPS-complying
replacement labeling. , May be sold after 10/23/96.
7. Buy-out or transferred products with "Stop sticker" and
supplemental product-specific replacement labeling that meets
PR 95-5 requirements. Cannot be sold after 10/23/96.
8. Deleted-Use products with the final printed replacement
labeling or marking/blocking out all WPS uses and references
to WPS uses. May be sold after 10/23/96.
By October 23,1996, all pesticide products being sold or
distributed must bear final printed replacement labeling except for
products correctly interim-labeled per PR Notice 93-11 and a
limited number of products that were included in the "release for
shipment" option in PR Notice 93-11. Supplemental product-
specific replacement labeling will not be allowed after this date.
Pesticide Users' Compliance Schedule
All WPS requirements are in effect when a pesticide product with
the WPS reference statement is used.
SPECIFICS OF THE INSPECTION PROCESS
Section 1. REGISTRANT/PRODUCER ESTABLISHMENT &
MARKETPLACE/DEALER INSPECTIONS
(Reg./Prod. Est. & Mkt./Dealer Inspections)
For additional information on inspection activities, please refer
to the Worker Protection Inspection Guidance and EPA's
National Pesticides Inspection Manual. This Worker Protection
Field Inspection pocket guide addresses only those specific
requirements found at 40 CFR part 156, subpart K.
« Requirements Based on 40 CFR Part 156, subpart K
(For information regarding specific compliance dates, please
refer to Chapter II of this pocket guide.)
Inspectors must verify that the label or labeling for the
pesticide contains worker protection statements. These
labeling statements are described below. For more specific
. examples, please refer to the sample pesticide label in the
Worker Protection Inspection Guidance.
Labeling Statements
The statement headings are followed by their specific
reference number from 40 CFR part 156, subpart K.
APPLICATION STATEMENTS [Section 156.206(a)]
Check for the application statements under the headina
DIRECTIONS FOR USE. This statement prohibits application
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Chapter II Chapter III
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of the product in any way that will contact workers or other
persons directly or through drift.
DIRECTIONS FOR USE
Do not apply thfs product to a Way that Will
wrfer* or other persons, either
or
REFERENCF RTATEMFMTfi [fio^on 156.206(5)]
£S *?* I4? CFR Part 17° reference statements are on
the product label as required. They should appear at the
begmnmg of AGRICULTURAL USE REQUIREMENTS
under DIRECTIONS FOR USE. This statement requSs users
to comply with the Worker Protection Standard (40 CFR part
Its
Protection Standard, 4ti CFR par
The label shall state whether the product:
contains an organophosphate
contains N-methyl carbamate
is a fumigant
STATE RFRTmfmnMQ [Section 156.206(d)]
Check for statement referring to State restrictions. The State
headi"9
Each user is responsible for
Stions State-sPecific regulations in addition to Federal
DIRECTIONS FOR USE
to your State,
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.Chapter III Chapter III
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[ REG./PROD.EST. & HKT./DEALER INSPECTIONS"I
SPANISH WARNING STATEMENTS [figrfinn 156.206(e)]
Inspect label for Spanish warning statements for products
classified in toxicity category I and II. For products classified in
category I or II, the signal words "danger" and "warning" are
required on front panel in both English and Spanish. A
message in English and Spanish must be adjacent to the
signal word telling users to have all labeling explained if they
do not understand the label. The signal word and message
appear under the heading KEEP OUT OF REACH OF
CHILDREN.
(Table 3.1 provides an example of the required wording)
Table 3.1 Spanish Warning Statements
y&eitog "'-'"-
Requirements ' ,»,
Spanish Signal Word
English Signal Word
Spanish Statement
English Statement
1Bw$t%,Xfct$<&l!, *
tl
Aviso
Warning
Si Usted no entiende la
etiqueta, busque a alguien para
que se la explique a Usted en
detalle.
If you do not understand the
label, find someone to explain it
to you in detail.
REG./PROD.EST. & MKT./DEALER INSPECTIONS
PRODUCT-SPECIFIC STATEMFMTS
156.206(c)]
The signal word and message appear under the heading
KEEP OUT OF REACH OF CHILDREN.
RESTRICTED-ENTRY STATEMENTS (Section 156.208)
Check for restricted-entry statements on product label or
labeling under the heading AGRICULTURAL USE
REQUIREMENTS which is under DIRECTIONS FOR USE. All
agricultural pesticide labels must have a restricted-entry
statement, although the statement will vary depending on the
toxicity of the product.
Table 3.2 Restricted-Entry Interval for Products
Containing One Active Ingredient
/,, "'fttXifcfty ,
Category :
1
II
III
IV
- f> f .. V,
***
48 hours
24 hours
4 or 12 hours
4 or 12 hours
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REG./PROD.EST. & MKT./DEALER INSPECTIONS
EXCEPTIONS/VARIATIONS: Restricted-Entry
If the active ingredient is an organophosphate or an N-
methyl carbamate that inhibits cholinesterase and which is
applied outdoors in an area where the average annual
rainfall for the application site is less than 25 inches per
year, then the REI is 72 hours. [Section 156.208(c)(2)]
Entry restrictions for fumigants are based on a case-by-case
basis at the time of registration, or other Agency review
process.
If the product contains more than one active ingredient, the
REI is based on the active ingredient that requires the
longest restricted-entry interval. [Section 156.208(c)(3)
Existing product-specific entry intervals based on data
collected in accordance with other EPA regulations in 40
CFR part 158.390 should override any general REI. [Section
156.208(e)]
Interim product-specific entry intervals should continue to
apply unless a longer REI is required based on the
requirements in the Rule (i.e., see Table 3.2). [Section
156.208(f)
In some product-specific cases, the REI may be longer than
the active ingredient toxicity category REI.
REG./PROD.EST. & MKT./DEALER INSPECTIONS
NOTIFICA TION-TO-WORKER STATEMENTS [Section
156.210(a)(b)]
Check for notification-to-workers of pesticide applications
statements under AGRICULTURAL USE REQUIREMENTS
DIRECTIONS FOR USE. If a product is highly toxic for acute
dermal toxicity or skin irritation potential, the label must require
both an oral warning and the posting of warning signs. For
any fumigant that may be used in a greenhouse, a statement
on the label requires users to notify workers by warning them
orally and by posting warning signs outside all entrances to the
greenhouse.
PERSONAL PROTECTIVE EQUIPMENT STATEMENTS
[Section 156.212)(c)(1)(2)]
Check for personal protective equipment (PPE) statements for
pesticide handlers in the HAZARDS TO HUMANS (&
DOMESTIC ANIMALS) section of the labeling. PPE
statement for early-entry workers is placed in the
DIRECTIONS FOR USE section. A statement which specifies
the minimum requirements for PPE based on the acute toxicity
of the end-use product must appear on the label.
A summary of PPE requirements is shown in Table 3.3.
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& MKT./DEAIER INSPECTION
Dermal Toxicity
or Skin Irritation
Potential*
Coveralls worn
over long-sleeved
shirt and long
pants
Socks
Chemical-resistant
footwear
Chemical-resistant
loves
Coveralls worn
over short-sleeved
shirt and short
pants
Socks
Chemical-resistant
footwear
Chemical-resistant
gloves
Inhalation
Toxicity
Eye Irritation
Potential
Protective eyewear
Protective eyewear
Dermal Toxicity
or Skin Irritation
Potential*
Long-sleeved shirt
and long pants
Socks
Shoes
Chemical-resistant
loves
Long-sleeved shirt
and long pants
Socks
Shoes
No minimum
loves
Inhalation
Toxici
Eye Irritation
Potential
& HKT./DEALER INSPECTIONS
Other PPE that may be required include
headgear
apron
chemical resistant suit
. These are described below.
Chernical-rasiRtRntqlfwp;:. [Section 156.212(f)l If chemical
resistant gloves are required, the registrant must specTf^ me
glove type. For more specific information on glove types
please refer to the Worker Protection Inspection GuEB
Worker Protec«°" '"spection Gufdance',
Pespirator reqiiirprnpnt. [Section 156.212(g)] If a
inhalati°"
exposure situation - the iabel wi., specify a dus'mTst fittering
Chapter III Chapter III
Page 23
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respirator, an organic-vapor-removing respirator with a
are as follows ' ^ *" ail"-supp|yin9 Aspirator. Guidelines
n[Srf cti°nJ56-210-(9) 'f « is beforTthe eSve date of
part and the product labeling already indicates that
rXined0ry Pr°teCtion is re(*uired. that requirement shall be
'esP|rato':tyPe is already specified, the label shall be
mo* S ^ th! MSHA/NI°SH approval number. For
more information on the types of and criteria for identifying
respirators, refer to the WPS Inspection Guide aemnyinB
roQniroi J a lespiraiory requirement, b
respiratory devise is required under the revised WPS the
registrant shall add a statement that specifies a "dustS
filtering respirator with MSHA/NIOSH approval number^reflx
n r^uiretmenfs fnr "*«^ In addition to the
personal protective equipment required in Table 33
the following instructions may apply: '
If the product is not ready-to-use and no requirement exists
for a chemical-resistant suit, the following statement must
. appear: "Mixers/Loaders: add a chemicll-rSant apron.--
If the apphcation may result in overhead exposure to any
handler, the following statement must appear; "Overhead
Exposure: wear chemical-resistant headgear."
If any type of equipment other than the product container
may be used to mix, load, or apply the product, and there is
no requirement for a chemical-resistant protective suit the
following statement shall appear; "For Cleaning Equipment:
add a chemical-resistant apron."
(Reference EPA's HTC, pps. 82-83)
PPE for early entry workers. [Section 156.212(0] Specific
requirements for early entry workers are as follows?
For all pesticide products, the following statement shall
und^S, w' tar'yDentry to treated areas that is permitted
Sh^h^S9! ^rot?ction Standard and involves contact
with anything that has been treated, such as plants soil or
water, wear (list the body protection, glove, footwear
protective eyewear, and protective headgear, if applicable
for applicators and handlers, but omit any respiratory
protection statement)." ^iidiory
If the body protection statement in the PPE statement for
handlers specifies a long-sleeved shirt and long pants
coveralls'' must be specified in the PPE statement for'early
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KC.WKKOD.EST. &MKI./UbALER INSPECTIONS
(Reference EPA's HTC, pps. 69-70)]
Page 26
Chapter III
SPECIFICS OF THE INSPECTION PROCESS
Section 2. USE INSPECTIONS
' '
rererence statement appears on the labeling.
Requirements based on 40 CFR part 170
ChapterllL
Page 27
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USE INSPECTION!
USE INSPECTIONS
the 1992 WPS. restricted-entry interval before agricultural-worker entry is
permitted (refer to Table 3.4 on page 30) and
The inspector must check the following eight major compliance
areas covered by the WPS: Verify that oral notification of the pesticide application was
9'ven to all workers at the site, if required. (Refer to Table
1. Notification and Posting of Pesticide Application 3.5 on page 35)
2. Application and Entry Restrictions
3. Personal Protective Equipment (PPE) and pesticide
handling equipment
4. Pesticide Safety Training
5. Pesticide Safety Information *
6. Decontamination Supplies for Handlers and Workers
7. Emergency Assistance Procedures
8. Retaliation
Each of these are discussed below. After each heading is the
specific cite from 40 CFR 170 for Workers and/or Handlers.
1. NOTIFICATION AND POSTING OF PESTICIDF
. APPLICATION (For Workers, see Sections 1 70. 1 20 &
170.124; for Handlers, see Section 170.224)
To ensure that notification and posting requirements for
pesticide applications complies with the WPS label, the
inspector, through interviews and observations, must:
Check that the treated area is/was posted with warning
signs in the required format and manner if required by the
labeling and removed within 3 days after the end of
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'able 3.4 Requirements for Posted Warning Signs
Required Words: (legible)
Use alternative language for Spanish portion of the
warning sign with translations of "Danger", "Pesticides"
and "Keep Out" in ten different languages
Required Design:
Bears the WPS warning-sign symbol [stern face (on
right) and raised hand (on left) within a circle near the
center of sign)].
Color requirements - background contrasts with inside
of circle; hand and face contrast with inside of circle
and remainder of circle is red.
Size Requirements - 14" x 16" except if treated area is
too small to accommodate 14" x 16" sign. Letters must
be at least 1" high.
Greenhouses and nurseries may use two smaller
signs, provided minimum letter size and posting
distances are observed.
Signs must:
Be visible from all usual points of worker entry to the
treated area.
Be posted no sooner than 24 hours before the
scheduled application.
Remain posted throughout the application and REI e)
Be removed within 3 days after the application and the
REI expires, and before allowing workers to enter the
treated area.
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* The warning sign may contain additional information ONLY if it
does not alter the meaning of the required information or
otherwise detract from the appearance.
WORKER PROTECTION WARNING SIGNLANGUAGES
On June 26, 1996. EPA issued two final amendments to WPS to
allow substitution of an alternate language commonly spoken
and read by workers for the Spanish portion of the warning sign
The sign must be visible, legible, and in the required format. Use
of alternate languages is optional and would not preclude the
continued use of the English/Spanish sign. EPA has developed
warning signs in 10 languages. To facilitate inspector some
translations are provided below.
DANGER PEGGAD
PESTICIDES SABIDONG
KEEP OUT
AWAN ITI SUMREK
ILOCANO (Hawaii)
KOREAN
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KEEP OUT
NO ENTRE
SPANISH
DANGER
PESTICIDES
KEEP OUT
^ A
CHINESE (Traditional)
DANGER
PESTICIDES
KEEP OUT
CAMBODIAN
DANGER DANJE
PESTICIDES PESTISID
KEEP OUT
RETE DENQR
LAOTIAN
DANGER
PESTICIDES
KEEP OUT
HAITIAN CREOLE
THAI
DANGER PANGANIB
PESTICIDES MGA PESTICIDE
KEEP OUT
HUWAG PAPASOK
TAGALOG (Philippines)
DANGER
PESTICIDES
KEEP OUT
vlo
VIETNAMESE
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greenhouse^ nurserief*-?^0 smaller^rning signs in
posting distances SSS^dTS^nT11 'f * *" and
include a requirement forTSSniS sS 2f °1S? d°6S not
that the criteria established S S^M ' * estimates
m sign sizes of approximated T s»«L u Slzes would result
inches by 5 inches V inche8'lV 8 inches and 41/2
T« u nif _
7" x 8" size sign requires:
4 1/2" x 5" sign requires:
upraised hand semfac r C°nanin9
the signs shali be no further than 25 feet apart.
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Table 3.5 Requirements for Oral Warnings
Or^l Warafags.
Oral^warnings must be provided in a manner that the
"""" ' understand (e.g., translation may be
If a worker will be on the premises during the
application, the warning shall be given before the
application takes place; otherwise, the warning shall be
given at the beginning of the first work period during the
time of application or REI.
Warning must give location and description of the
treated area.
Warning must state the time during which the REi is in
STTGCt.
rnth
area until the REI is over or until signs are removed.
that specific information about the location and nature
pesticide application is/was displayed.
Verify that the employer assured that, from the start of the
application until the end of the restricted-entry interval a
S6^ "Ot e,nter> Work in' remain in- or Pass through a
treated area on foot on a farm, nursery, greenhouse o? Forest.
S/ "H?the fo!lowin9 specific information was provided by
the handler employer to the the agricultural employer about
scheduled pesticide applications on the agricultural
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establishment before the application has taken place, (refer to
IGWQ&A11.14.1)
specific location and description of the pesticide-treated
area,
time and date of application,
product name, EPA registration number, and active
ingredient(s),
restricted-entry intervals),
» whetherposting and/or oral notification are required,
any other product-specific requirements on the product
labeling concerning the protection of workers or other
persons during or after the application.
Verify that all product-specific requirements on the pesticide
label and in the labeling concerning protection of workers and
pesticide handlers or other persons during or after the
application were followed.
(Reference EPA's HTC, p. 41, pps. 113-115)
2. APPLICATION AND ENTRY RESTRICTIONS
(For Workers see Sections 170.112 & 170.110; For Handlers
see Section 170.210)
To ensure that the user is in compliance with application and
entry restrictions, the inspector must:
Verify that during application of any pesticide, the agricultural
employer did not allow or direct any person other than an
appropriately trained and equipped handler to enter or to
remain in a treated area.
Confirm that on farms, forests, greenhouses and nurseries,
the handler employer and handler assured that no pesticide
was applied so as to contact, either directly or through drift,
any worker or other person.
Verify that workers were prohibited from entering the treated
area and any required border areas.
Nurseries. [Section 170.110(b)] Also verify that the
application-specific entry restrictions and restricted areas for
nurseries were followed as specified in Table 3.6 on page 38.
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Table 3.6 Entry-Restricted Areas in Nurseries
During Pesticide Applications
; % "
\ Itoittf Application^* $><*sfteiite
(1)(a) Applied: aerially, in an
upward direction, or using a spray
pressure greater than 150 psi, or
(b) Applied as a fumigant, smoke,
mist, fog, or aerosol.
(2)(a) Applied downward using: a
height of greater than 12 inches
from the planting medium, or a fine
spray, or a' spray pressure greater
than 40 psi and less than 150 psi.
(b) Not as in 1 or 2(a) above, but for
which a respiratory protection
device is required for application by
the product labeling.
(3) Applied otherwise.
WadterSare Pfohiirfted ..
fefi
Treated area plus 100 feet
in all directions on the
nursery.
Treated area plus 25 feet
in all directions on the
nursery.
Treated area.
(Reference EPA's HTC, pps. 51-52)
Greenhouses [See Sections 170.110(c) and 170.210(c)(1)(2)]
Verify that greenhouse specific entry restrictions and restricted
areas for greenhouse were followed as specified in Table 3.7 on
Page 40.
Verify that the ventilation criteria for pesticide applications
in greenhouses were followed.
Confirm compliance with the restricted-entry interval on
the product labeling.
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Table 3.7 Greenhouse Entry Restricted Areas Associated
With Pesticide Applications
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;
(1)
(2)
(3)
(4)
(5)
-.WNJJjg**.' '-
As a fumigant.
As a smoke, mist, fog, or
aerosol.
Not in 1 or 2 above, and a
respiratory protection device
is required for application by
the product labeling.
Not in 1, 2, or 3 above, and
from a height of greater than
12 inches from the planting
medium, a fine spray, or a
spray pressure greater than
40 psi and less than 150 psi.
Otherwise
i S*W&t'H0r$$r$
Prohibited: m>.
Entire greenhouse plus any
adjacent structure that
cannot be sealed off from
the treated area.
Entire enclosed area.
Entire enclosed area.
Treated area plus 25 feet in
all directions in the
enclosed area.
Treated area.
V.
(1)
(2)
(3)
(4)
(5)
'"- - ' eCttattfs " ',
, -. ' -f
Ventilation shall continue until
the air concentration is
measured to be equal to or
less than the inhalation
exposure level the labeling
requires to be achieved If no
inhalation exposure level is
listed on the labeling,
ventilation shall continue after
10 air exchanges are
completed; or 2 hours of
ventilation using fans or other
mechanical ventilating
systems; or 4 hours of
ventilation using vents,
ventilation; or 1 1 hours with
no ventilation followed by 1
hour of mechanical
ventilation; or 1 1 hours of no
ventilation followed by 2
.hours of passive ventilation;
or24hourswith'no
ventilation.
Application is complete.
Application is complete.
; ^ % f
I ixAfterffe&gxphsattesj;^
; ltn*ejfcCi^be,a»tS
: the nm Expires, w&
i Erttry-Resti-jcted A*ea fej
No entry restrictions after
criteria in column C are
met.
Entire enclosed area is the
treated area.
Treated area.
Treated Area. :
Treated Area.
(Reference EPA's HTC, pps. 53-55)
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EXCEPTIONS: Early Entry Workers
EPA issued five regulatory amendments to revise the 1992
WPS. Two of the actions allowed early entry into pesticide
treated areas to perform certain irrigation activities and
limited contact activities. These exceptions allow workers
to perform irrigation and limited contact tasks, during
restricted entry interval (REI) up to 8 hours per 24 hours,
that could not have been foreseen which, if delayed, would
cause significant economic loss. This exception does not
apply to double notification products.
Inspectors must verify that any early entry into a treated area
under an REI by workers was under the following exceptions:
Activities with no contact with treated surfaces.
Short-term activities (1 hour limit) that do not involve hand
labor.
Agricultural emergency declared by a State, Tribal, or
Federal Agency.
Limited contact activities and irrigation activities (8 hour
limit/worker) that could not have been foreseen and if
delayed, would cause significant economic loss.
The inspector through interviews and observations, must:
Confirm that, if early entry did occur under the exception the
worker had no contact with anything that has been treated
with the pesticide to which the REI applies including but not
limited to, soil, water, air or surfaces of plants.
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Confirm that, if early entry did occur under the exception for
short-term activities and agricultural emergencies, the
following requirements were met:,
No hand labor activities were performed under the
exception for short-term activities except for an agricultural
emergency. .
No worker remained more than 1 hour in a 24-hour period
in a treated area for short-term activities except for an
agricultural emergency.
No worker entered the treated area within 4 hours of
application, and at least until any inhalation exposure level
listed on the product labeling has been reached or any
WPS ventilation criteria have been met.
The PPE specified on the product labeling for early entry
was provided to the worker and worn by the worker.
Verify that early-entry workers were informed before entering
the treated area, in a manner they can understand, about the
safety information, first aid, symptoms of poisoning, personal
protective equipment, and any other labeling requirements
related to safe use.
Inspect for maintenance, and storage of personal protective
equipment.
Check to assure decontamination supplies were provided as
required.
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Early entry workers were trained prior to entering the treated
area.
Ensure that the agricultural employer has not allowed or
directed any handler/worker to wear or take home PPE
contaminated with pesticides.
(Reference EPA's HTC, p. 61-70)
REQUIREMENTS FOR PESTICIDE HANDLERS DURING
APPLICATION: (Section 170.210)
Confirm that the handler employer assured that the following
handler-specific provisions were met during handling activities:
Pesticide labeling was accessible to each handler during the
entire handling task.
Any handling of highly toxic pesticides or any product with the
skull and crossbones symbol on the front panel was monitored
visually, or by voice communication, by another handler at
least once every two hours.
- Any handler who handles a fumigant in a greenhouse,
including a handler who enters the greenhouse before the
acceptable exposure level or ventilation criteria has been met
maintained continuous visual/voice contact with another
equipped handler.
(Reference EPA's HTC, pps. 73-76)
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'
3. PERSONAL PROTECTIVE EQUIPMENT (PPE) FOR
HANDLERS AND EARLY ENTRY WORKERS (For Workers
see Sec. 170.112, for Handlers see Sec. 170.240)
To ensure that the user is in compliance with PPE
requirements for early entry workers and pesticide handlers,
the inspector must verify that the agricultural/handler employer
assured the following:
Early-entry workers and pesticide handlers, before entering
the treated area, have read the product labeling or have been
informed, in a manner that the workers/handlers can
understand, the labeling requirements related to human
hazards or precautions, first aid, symptoms of poisoning, and
the PPE specified for the workers/handlers.
PPE specified on the labeling was provided to and used by the
workers/handlers.
PPE conformed to the standards specified on the product
labeling.
PPE was correctly worn by workers/handlers for its intended
use.
Each worker was instructed in how to put on, use, and remove
the PPE and is informed about,the importance of washing
thoroughly after removing PPE.
Workers/handlers had clean place(s) away from pesticide
storage and pesticide-use areas to store personal clothing not
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in use, and to put on and remove PPE.
PPE was Cleaned according to the manufacturer's instructions
or pest.cide product labeling instructions before each day of
1^ and washed
Any person who cleans or launders PPE was informed by the
agricultural employer that it may be contaminated with
pes icides, of the potentially harmful effects of exposure to
pesticides, and the correct way(s) to handle and clean
contaminated PPE.
' PPE.was stored separately from personal clothing and
pesticide- contaminated areas, (refer to IGW Q & A 12.19)
* h ^E W3S inspected by the agricultural employer for leaks,
nfnaf!?arS^-WOmJ>la^Sl and any damaged equipment was
repaired or discarded before use.
PPE that cannot be cleaned is properly disposed of in
accordance with Federal, State, and local regulations.
When appropriate, the workers/handlers were instructed in
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the prevention, recognition, and first-aid treatment of heat-
related illness.
Workers/handlers were restricted from wearing or taking home
contaminated PPE. '
Dust/mist filters used in handler dust/mist masks or respirators
were replaced per Section 170.240(F)6.
Gas or vapor absorbing canisters or cartridges used
in
(Reference EPA's HTC, pps. 69-70, 79-81)
If handling tasks are performed using properly functioning
systems that enclose the pesticide to prevent it from contacting
handlers and if such systems are maintained in accordance with
DDCTniluac!grer's instructi°ns, exceptions to labeling-specified
PPE for the handling activity is allowed for the following three
systems. The handlers must be provided all PPE required by the
pesticide labeling for that task and have it immediately available
for use in an emergency.
1. A Closed System [Section 170.240(d)(4)]
The inspector must verify that the handler used a properly
functioning closed system, which was maintained in
accordance with manufacturer's operating instructions
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Persons using a closed system to mix or load pesticides with
the signal word "DANGER" or "WARNING" may substitute for
PPE specified on the labeling with:
Long-sleeved shirt and long pants.
Shoes and socks.
A chemical-resistant apron.
Protective gloves specified on the pesticide labeling for
handling tasks.
When mixing or loading pesticides with the signal word
"CAUTION," handlers may substitute for the labeling-specified
PPE with:
Long-sleeved shirt and long pants.
Shoes and socks.
When conducting handling tasks other than mixing and
loading with ANY pesticide, handlers must wear:
Long-sleeved shirt and long pants.
M Shoes and socks.
If handlers are working in a closed system which operates
under pressure, they may wear the PPE identified above, but
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add protective eyewear.
2. An Enclosed Cab [Section 170.240(d)(5)]
If the cab has a nonporous barrier which prevents contact with
the pesticides outside of the cab, exception to PPE specified
on the product labeling for that handling activity is permitted.
Persons occupying an enclosed cab that has a properly
functioning ventilation system which is used and maintained in
accordance with the manufacturer's operating instructions and
which is declared in writing by the manufacturer or by a
governmental agency to provide respiratory protection
equivalent to a dust/mist filtering respirator may substitute a
long-sleeved shirt, long pants, shoes, arid socks for the
labeling-specified PPE. (refer to IGW Q & A 12.11)
In cabs which DO NOT provide respiratory protection,
handlers may substitute for the labeling-specified PPE with:
Long-sleeved shirt and long pants.
Shoes and socks.
Any respirator required for the handling task.
In cabs which DO provide respiratory protection equal to that
listed on the label, handlers may substitute for the labeling-
specified PPE with:
Long-sleeved shirt and long pants.
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Shoes and socks
In ANY enclosed cab where reduced PPE is worn, handlers
must:
Have ALL PPE listed on the label for the task being
performed immediately available.
Wear the PPE if it is necessary to exit the cab and contact
pesticide-treated surfaces.
Remove PPE worn in the treated area before reentering
C3D.
Store all PPE in a chemical-resistant container to prevent
contamination insirifi thp_cah trefer irswn «. A -ii -IQ\
I USE INSPECTIONS I
Shoes and socks instead of chemical-resistant footwear.
A helmet instead of a chemical-resistant hat or hood.
_ In an enclosed cockpit, handlers may substitute for the>
labeling-specified PPE with:
Long-sleeved shirt and long pants.
Shoes and socks.
(Reference EPA's HTC, pps. 85-87)
SPECIFIC PPE REQUIREMENTS FOR PESTICIDE
HANDLERS: (Section 170.240)
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If pesticide removal was not feasible, the person who
repaired, cleaned, or adjusted the equipment had to be
informed that such equipment may have been contaminated
with pesticides and of the correct way to handle such
equipment.
EXCEPTION FOR CROP ADVISORS: Inspector verified that
certified or licensed crop advisors and persons under their
direct supervision entered the treated area after the pesticide
2SP Amc0!1 P rm Cr°P advisin9 tasks- (EPA has amended
the WPS to exempt qualified crop advisors from the PPE
whTnS8 3nd a"°W^d them t0 Choose aPPr°Priate protection
JulJ 17 "9 Cr°P 9 taSkS> The rule became effective
4.
SAFFTY TRAINING (For Workers, see Section
170.130; for Handlers, see Section 170.230)
Effective January 1, 1996, agricultural employers must assure
that workers receive basic pesticide safety information before
they enter a treated area on the establishment. This would
provide basic safety information to workers while they wait for
the complete WPS pesticide safety training which is required
within 5 days of entering a treated area.
To ensure that the agricultural employer is in compliance with
pesticide safety training requirements, the inspector must
verify that:
General pesticide safety information was presented to
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workers/handlers in a manner that could be understood orally
or using written or audiovisual training materials.
Verify that the basic pesticide safety information included
the following information before they entered a treated area on
the establishment:
(1) Pesticides may be orv or in plants, soil, irrigation water or
drift from nearby applications.
(2) Workers should prevent pesticides from entering their
body by:
Following directions and/or signs about keeping out of
treated area.
Washing before eating, drinking, using chewing gum or
tobacco, or using the toilet.
Wearing work clothing that protects the body from pesticide
residues.
Washing/showering with soap and water, shampoo hair and
put on clean clothes after work.
Washing work clothes separately from other clothes before
wearing them again.
Washing immediately in the nearest clean water if pesticides
are spilled or sprayed on the body. i
Additional pesticide safety training will be provided within 5
days of entry into treated areas.
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GENERAL COMPLETE WPS SAFETY TRAINING
REQUIREMENTS FOR WORKERS AND HANDLERS:
Confirm that the person who conducted the worker/handler
safety training meets one of the following criteria:
Be a certified applicator of restricted-use pesticides at the
time of training; or
Be designated as a trainer of certified pesticide
applicators or pesticide handlers by a State, Federal, or
Tribal agency having jurisdiction; or
Have completed a pesticide safety train-the-trainer
program approved by State, Federal, or Tribal agency
having jurisdiction.
Verify that the WPS pesticide safety training materials presented
to workers/handlers WITHIN 5 DAYS of entry into any areas on
the establishment included, at a minimum:
Where and in what form pesticides may be encountered
during work activities.
Hazards of pesticides resulting from toxicity and
exposure, including acute and chronic effects, delayed
effects, and sensitization.
Routes through which pesticides can enter the body.
" Signs and symptoms of common types of pesticide
poisoning.
Emergency first aid for pesticide injury or poisoning.
How to obtain emergency medical care.
Routine and emergency decontamination procedures,
including emergency eye flushing techniques.
Hazards from chemigation and drift.
Hazards from pesticide residues on clothing.
Warnings about taking pesticides or pesticide containers
home.
An explanation of the WPS requirements designed to
protect workers, including application and entry
restrictions, design of the warning sign, posting of warning
signs, oral warnings,, availability of specific information
about applications, and protection against retaliatory acts.
(Reference EPA's HTC, pps.25-28)
REQUIREMENTS FOR PESTICIDE SAFETY TRAININC5 FOR
HANDLERS: (Section 170.230)
Verify that the handler/agricultural employer assured that all
pesticide handlers received safety training as required before
performing any handling tasks.
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Confirm that the genera! pesticide safety training materials for
pesticide handlers included:
Format and meaning of information contained on
pesticide labels and in labeling, including safety
information such as human health hazard precautionary
statements.
Hazards of pesticides resulting from toxicity and
exposure, including acute effects, chronic effects, delayed
effects, and sensitization.
Routes through which pesticides can enter the body.
" Signs and symptoms of common pesticide poisoning.
- Emergency first aid for pesticide injuries or poisonings.
How to obtain emergency medical care.
Routine and emergency decontamination procedures,
including emergency eye flushing techniques.
Need for and appropriate use of PPE.
Prevention, recognition, and first-aid treatment of heat-
related illness.
Safety requirements for handling, transporting, storing,
and disposing of pesticides, including general procedures
| USE INSPECTIONS |
for spill cleanup.
Environmental concerns such as drift, runoff, and wildlife
hazards.
Warnings about taking pesticides or pesticide containers
home.
An explanation of WPS requirements that handler
employers must follow for the protection of handlers and
others, including the prohibition against applying
pesticides in a manner that will cause contact with
workers or other persons, the requirement to use PPE,
the provisions for training and decontamination, and the
protection against retaliatory acts.
Check and document that the handler read the product
labeling or had been informed, in a language the handler
could understand, of all labeling requirements related to
safe use of the pesticide, such as signal words, human
hazard precautions, PPE requirements, first-aid
instructions, environmental precautions, and any
additional precautions pertaining to the handling activity
performed.
Verify and document that the handler had access to the
product labeling during handling activities.
(Reference EPA's HTC, pps. 75-76)
Verify that the pesticide safety training materials for
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workers and handlers was either:
WPS training material developed by EPA, or
equivalent material that contains the concepts listed in
the criteria for worker and handler training.
(Reference EPA's HTC pps. 27, 38-41)
Note: EPA has prepared training material; however, employers
are not required to use these materials.
EXCEPTIONS: The following persons need not be trained:
/ A worker who is certified as an applicator of restricted-use
pesticides under part 171.
/ A worker who satisfies the training requirements of part 171.
/" A worker who satisfies the handier training requirement of
170.230(c).
/ A worker who is certified or licensed as a crop advisor by a
program approved by EPA or a State or Tribal lead agency for
pesticide enforcement and includes all the information in
170.230(c)(4).
5. POSTED PESTICIDE SAFETY INFORMATION! (For Workers
see Section 170.122,170.135; for Handlers see Section
170.235)
The inspector must verify that information described below, is
displayed at a central location on the agricultural site where it
| USE INSPECTIONS |
is readily accessible, can be seen and read by
handlers/workers, where within the last 30 days, a pesticide
covered by the WPS has been applied. In forests, information
should be displayed in or near the forest where it can be
readily seen and read by handlers and where handlers are
likely to congregate or pass by, such as at a decontamination
site or an equipment storage site.
PESTICIDE SAFETY POSTER: To ensure that the
agricultural employer complies with the WPS requirements for
a pesticide safety poster, the inspector must:
Check for a pesticide safety poster displayed in an easily
accessible, central location. If it is not the EPA approved
poster, photographing the poster is recommended.
Verify that the safety poster conveys the following basic
pesticide safety concepts to workers/handlers:
Avoid getting pesticides on your skin or into your body
any pesticides that may be on plants and soil, in irrigation
water, or drifting from nearby applications.
Wash before eating, drinking, chewing gum, using
tobacco, or using the toilet.
Wear work clothing that protects your body from pesticide
residues, such as long-sleeved shirts, long pants, shoes,
socks, and hats or scarves.
Wash or shower with soap and water, shampoo your hair,
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and put on clean clothes after work.
3s separately from other clothes before
-i,?1"?ediate|y in 'he nearest clean water if pesticides
are sp.llec I or sprayed on your body; as soon as possible
shower, shampoo, and change into clean clothes
Follow directions about keeping out of treated or
restricted areas.
hh' the WPS Safe*y Poster must tell workers/handlers
that there are Federal rules to protect them; including a
requirement for safety training.
doct;ment that wooers/handlers have been
of the location of the safety poster.
Determine if the safety poster is legible.
(Reference EPA's HTC, pps. 23-24)
INFORMATIN
Determine if the address and telephone number of the nearest
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emergency medical care facility is located on or near the
safety poster.
Confirm that the employer has promptly informed
workers/handlers of any change to the information on
emergency medical care facilities on or near the safety poster.
(Reference EPA's HTC, pps. 23-24)
PESTICIDE APPLICATION INFORMATION (Section 170.122)
Confirm that the specific application information is posted near
the safety poster before the pesticide application or at the
same time.
Verify that the information includes the location and
description of the treated area, product name,-EPA Reg No
active ingredient(s) of the pesticide, time and date the
pesticide was applied, and the restricted-entry interval for the
pesticide. Check if the information was updated, if the
treated area is moved (potted plants), (refer to IGW Q & A
(Reference EPA's HTC, pps. 23-24)
6. DECONTAMINATION (For Workers see Section 170 150- For
Handlers see Section 170.250)
To ensure that all requirements concerning the
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decontamination site are/were met, the inspector must:
forh LeniP|oyer P"°vWed decontamination supplies
for washmg off pesfade residues if an early entry worker
performed an activrty in a treated area where a restricted-entry
S '" effeCt °r had expired within th|rty days ^
the site
NOTE: On June 26, 1996, EPA amended the WPS by
reducing the length of time for which decontamination
supplies are required for workers at 7 days following the end
of REI. Th,s apphes only pesticides which are low risk and
have restncted-entry intervals of 4 hours or less The
^
forn lf «6 emPloyer-Provided decontamination supplies
for washing off pesticide residues for any activity.
Determine if the decontamination supplies are not in an area
Under a
Verify that the decontamination Supplies provided by the
employer for workers and handlers included the following:
and
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reasobly accessible to
than one quarter mile from where
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workers/handlers are working as required in the
regulation.
Water of a temperature that will not cause illness or injury
when it contacts the skin or eyes, or if it is swallowed in
adequate supply (suggested amount 3 gal/handler/day)
for washing the entire body in case of an emergency as
well as for routine washing by workers/handlers.
Water properly stored in a tank. The water must not be
used for mixing pesticides unless mechanisms are used
to prevent pesticides from moving into the tank (refer to
IGWQ&A3.21).
Soap and single-use towels in quantities sufficient to meet
workers'/handlers' needs.
An eye flush dispenser with at least one pint of water for
handlers and early entry workers required by the pesticide
labeling to wear protective eyewear. The emergency eye
flush water must be immediately accessible.
For handlers, after handling activities, and workers
engaged in early entry activities, provisions of soap, clean
towels, and sufficient clean water so that the
handlers/workers may wash thoroughly after removing
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Verify For Handlers Only:
The decontamination supplies must have one clean
change of clothes. This could be a "one size fits all"
coverall for pesticide handlers.
EXCEPTIONS: Decontamination [Section 170.250(1 )(2)(3)
For mixing activities, the decontamination site shall be at the
mixing site.
For a pilot who is applying pesticides aerially, the
decontamination site must be at the aircraft's loading site or in
the plane.
For tasks performed more than one quarter mile from the
nearest point reachable by cars or trucks, the
decontamination site may be at the nearest access point. In
this circumstance, clean water from springs, streams, lakes, or
other sources may be used for decontamination if such water
is more readily available than the water at the
decontamination site.
(Reference EPA's HTC, pps. 29-31)
EXCEPTION: No decontamination supplies are required for crop
advisors.
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7. EMERGENCY ASSISTANCE (For Workers see Section
170.160; For Handlers see Section 170.260)
The inspector should verify that the employer did the following
if a worker/handler may have been poisoned or injured by
pesticides used at the site through exposure, splash, spill,
drift, or pesticide residues:
« promptly make available transportation from the place of
employment or the handling site to an appropriate emergency
medical facility by (refer to IGW Q & A 8.12, 8.13 & 8.14):
taking the employee to the emergency medical facility, or
calling an ambulance
promptly provide on request to the worker/handler or treating
medical personnel the following information:
product name, EPA registration number, and active
ingredients in any product to which the worker/handler
might have been exposed
antidote, first aid, and any other medical information from
the product labeling
information about the circumstances of application or use
of the pesticide at the site, or about the exposure of the
worker/handler to the pesticide
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(Reference EPA's HTC, pps. 35-36)
EXCEPTION: Crop advisors are exempt from this provision.
8. RETALIATION [(For Workers and Handlers see Section
170.7[b])]
By interviewing workers, the inspector should determine that the
employer DID NOT take any action having the effect of
preventing or discouraging any worker/handler from complying
or attempting to comply with any regulations of 40 CFR Part 170.
(Reference EPA's HTC, p, 19)
NOTES
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