^Uplied States  ™  *  t  "
^Environmental Protection
».Agency
                                    EPA300-B-02-001
                                    March 2002  ~
. Enforcement And Compliance Assurance (2225A)
Worker Protection
JField  Inf pectipn
 Pocket Guide
                 
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               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
Table of Contents-
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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.
Page 2
Chapter I
                                                               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
                                                                                                                  Page 7

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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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                          Chapter II     Chapter  II
                                                                                                                         Page 9

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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
Page 14
                                              Chapter  II     Chapter  III
                                                                                                               Page 15

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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,
Page  16
                                          .Chapter III    Chapter III
                                                                                                         Page 17

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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
Page 18
                                          .Chapter  III
Chapter III
                                                                                                           Page 19

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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.
Page 20
                                            .Chapter 111
                                                            Chapter III
                                                                                                              Page 21

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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
Page 24
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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
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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
                                                Chapter ,1,    chapter 1,1 _ ; _ .                              page

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                       USE INSPECTION
   '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.
                     USE INSPECTIONS |

 *  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 SIGN—LANGUAGES

 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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                USE INSPECTION
                                                                I USE INSPECTIONS
       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
Page 32
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                         USE INl
 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.
Page 34
                                                                                    USE INSPECTIONS |


                                                                        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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                       USE INSPECTION
                                                                                      USE INSPECTIONS
    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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                      USE INSPECTION I
                                  USE INSPECTIONS I
        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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                   I USE INSPECTION I


 Table 3.7 Greenhouse Entry Restricted Areas Associated
               With Pesticide Applications
                                USE INSPECTIONS
;
(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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                      USE INSPECTION
 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.
                                  I USE INSPECTIONS |

               • 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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                      USE INSPECTION I
 • 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)
                    I USE INSPECTIONS |
                           '
 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
Page 44
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                        USE INSPECmnM
    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
Page 46
                                                                                     USE INSPECTIONS
                                                                  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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                     I USE INSPECTION I


   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
                                   USE INSPECTIONS
                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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                   USE INSPECTION
 ••  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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                       USE INSPECTION
  •  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
                     USE INSPECTIONS |
  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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                      USE INSPECTION
                                  USE INSPECTIONS |
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
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 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
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                 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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                  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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