United States
     Environmental Protection
     Agency
Office of Enforcement
& Compliance Assurance
Washington, DC 20460
EPA305-F-01-010
August 2001
www.epa.gov
                                                               ^-rr-HT"^?
                                                  Ag Center
                                                          Helping Agriculture Comply with
                                                          Environmental Requirements
FOCUS    ON
         Information  Commercial
         Handlers  Must  Provide  to
         Growers
        The Agricultural Worker Protection Standard (WPS) is a regulation issued by the U.S.
        Environmental Protection Agency in 1992 and amended in 1995. It covers pesticides that are
        used in the production of agricultural plants on farms, forests, nurseries, and greenhouses. The
        WPS requires you to take steps to reduce the risk of pesticide-related illness and injury if you (1)
        use such pesticides, or (2) employ workers or pesticide handlers who are exposed to such
        pesticides.

        This fact sheet will help you understand how to comply with WPS requirements concerning the
        information that commercial handlers must provide to their customers about pesticide-treated
        areas. These questions were submitted to the Agency by people seeking clarification on this part
        of the regulation, and have been answered by EPA's Office of Compliance.
         Information provided by
         commercial handlers to growers
         Commercial pesticide handlers (custom
         applicators) must make sure that their
         customer -- the operator of the farm,
         forest, nursery, or greenhouse -- knows
         certain information about the pesticide
         before it is applied on the establishment.
             If the pesticide is not applied as
             scheduled, the customer must be
             informed of the corrected time and date
             of the application. Make the correction
             before the application takes place or as
             soon as practicable thereafter.

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How can commercial
handlers comply with
the requirement for
notifying growers in
advance about pesticide
applications?
Commercial pesticide handlers must
inform their customers about:
•   the specific location and description
    of the area(s) on the agricultural
    establishment that are to be treated
    with a pesticide.
•   time and date the pesticide is
    scheduled to be applied.
•   product name, EPA registration
    number, and active ingredient (s)
•   restricted-entry interval for the
    pesticide.
•   whether the pesticide labeling
    requires both treated-area posting
    and oral notification.
•   any other specific requirements on
    the pesticide labeling concerning
    protection of workers and other
    people during or after application.

 Your customers — the operators of
agricultural establishments -- must have
this information to protect their
employees as required by the WPS.
                         If the initial notification of an
                         application cannot be made
                         because of difficulty in  reaching
                         the grower (agricultural
                         employer), can notification be
                         made after application?

                         No. There are no provisions for allowing
                         notification after application because of
                         earlier difficulty in contacting the
                         grower (agricultural employer).
How soon before an application
must a commercial handler
(handler employer) provide the
information to the grower
(agricultural employer)?

The WPS requires that the information
be provided by the commercial handler
to the grower anytime before the
application takes place. [40 CFR section
170.224]

The WPS requires that, before
the application of any pesticide
on an agricultural  establishment,
a commercial handler must
provide certain information
about the pesticide and the
application, or must assure that
the customer -- the operator of
the farm, forest, nursery, or
greenhouse -- is aware of the
information. [40 CFR 170.224].
What constitutes compliance
with this requirement?

EPA recommends that the operator of
the agricultural establishment
(agricultural employer) and the
commercial pesticide handler (handler
employer) agree on a notification
process that will ensure that workers will
not be in an area while it is being
treated or under a restricted entry
interval (REI). For example, they could
                         Ag Center Fact Sheet Series
                         Agrichemicals/WPS - Commercial Handlers Must Inform Growers
                                                                          Page 2

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Agrichemicals
                         agree that without prior mutual
                         agreement, an application will never
                         occur before the scheduled time, and
                         the grower (agricultural employer) will
                         not permit workers into the area to be
                         treated until he/she receives notification
                         from the commercial handler that:
                         •   either the application will not take
                             place until a specified future time at
                             the earliest, or
                         •   the application has taken place and
                             specific information required by the
                             WPS is provided to the grower.

                         Examples of compliance:
                         1.  An oral exchange of the required
                             information between the
                             commercial handler and the grower
                             before  an application would comply
                             with WPS notification
                             requirements.
                         2.  Leaving a complete message on a
                             telephone answering machine before
                             the application would constitute
                             compliance if the message was
                             actually received by the grower
                             before the application.
                         3.  Leaving a complete message on the
                             answering machine before the
                             application would constitute
                             compliance if the commercial
                             handler and grower had agreed that
                             by leaving a complete message on
                             the answering machine, notification
                             could be accomplished. In this
                             example, the commercial handler
                             would have satisfied his/her
                             obligations under the WPS even if
                             the message was not checked by the
                             grower before the application. The
                             grower, however, would remain
                             responsible if workers were sent into
                             treated areas in violation of any
                             portion of the WPS.
For more information
To get more facts about compliance,
contact the Ag Center by phone, fax, or
mail. Call the toll-free number to ask
compliance questions or order
publications. At the Center's web site,
www.epa.gov/agriculture, you can
explore compliance information and
order or download publications. For a
complete publications list, request
document 10001, "Ag Center
Publications."
 National Agriculture Compliance
 Assistance Center
 901 N. 5th Street
 Kansas City, KS 66101
Toll-free:
Internet:
Fax:
             1-888-663-2155
             www.epa.gov/agriculture
             913-551-7270

          United States Environmental
          Protection Agency
          Washington, DC 20460
                         Ag Center Fact Sheet Series
                                 Page 3

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