&EFA
United States
Environmental Protection
Agency
How To Com ply
With the Worker Protection Standard
For Agricultural Pesticides

What Employers Need To Know
Revised September 2005
Reprinted June 2006

-------

-------
THE                       OF THIS

Regulatory agencies will enforce the requirements of the federal Worker Protection
Standard (Code of Federal Regulations, Title 40, Part 170) when you use a pesticide
product with labeling that refers to the Worker Protection Standard. If you do not comply
with the Worker Protection Standard requirements, you will be in violation of federal law,
since it is illegal to use a pesticide product in a manner inconsistent with its labeling.
This manual provides information to help you comply with the requirements of the
federal Worker Protection Standard (WPS) for agricultural pesticides, 40 CFR part 170,
as published in 1992 and as amended in 1995. 1996, and 2004. EPA may issue additional
guidance about the Worker Protection Standard and the Worker Protection Standard may
be amended in the future. Check with your state or tribal agency responsible for
pesticides for further information and updates.

This 2005 updated Worker Protection Standard for Agricultural Pesticides — How To
Comply Manual  EPA 735-B-05-002 supersedes the 1993 version, EPA 735-B-93-001.
Changes to the Worker Protection Standard have made the 1993 version obsolete and its
continued use may lead an employer to be out of compliance with this regulation.

Additional Worker Protection  Requirements in Your Area
Some states, tribes, or local governments with jurisdiction over pesticide enforcement
may have additional worker protection requirements beyond the requirements described
in the federal manual.  Check with these agencies to obtain the information you need to
comply with all applicable state, tribal, or local requirements.

Reproduction of the Manual
This manual may be reproduced, but if this manual is altered it may no longer provide the
information to help employers comply with the requirements of the federal Worker
Protection Standard.

Material Appended to the Manual
States, tribes, or local governments with jurisdiction over pesticide enforcement may
elect to append additional worker protection requirements to the federal manual. These
additions may only be appended at the end of the federal manual, after the index. Any
additional material should be clearly identified as state, tribal, or local requirements.
                                                           WPS - How To Comply Manual as Revised 2005 i

-------
                                              TO           THIS

                        You probably need to comply with the WPS if you are a:
                             «   Manager or owner of a farm, forest, nursery, or greenhouse, or
                             «   Labor contractor for a farm, forest, nursery, or greenhouse, or
                             «   Custom (for-hire) pesticide applicator or independent crop consultant hired
                                by a farm, forest, nursery, or greenhouse operator.
                        Most WPS provisions are protections that you as an employer must provide to your own
                        employees and, in some instances, to yourself.  The WPS covers two types of employers,
                        which it defines according to the type of work their employees do:
                        Worker employer — If you hire or contract for people to do agricultural worker tasks.
                        or if you do them yourself, the WPS considers you a worker employer. In general.
                        agricultural workers are persons who (1) do hand labor tasks, such as weeding, planting,
                        cultivating, and harvesting, or (2) do other tasks involved in the production of agricultural
                        plants, such as moving or operating irrigation equipment (see p. 10 for complete
                        definition). Units 3 and 4 of this manual describe the WPS protections you must provide
                        to the agricultural workers you employ.
                        Handler employer — If you hire people to do pesticide handling tasks, or if you do them
                        yourself, the WPS considers you a handler employer.  In general, pesticide handlers are
                        persons who mix, load, apply, or do other tasks that bring them into direct contact with
                        pesticides (see p. 10 for complete definition). You must provide WPS protections to all
                        your pesticide handler employees, whether or not they are certified as applicators of
                        restricted-use pesticides. Units 3 and 5 of this manual describe the WPS protections you
                        must provide to the pesticide handlers you employ.
                             •   The same employee may be a worker at some times and a handler at other times,
                                depending on the type of task being performed.
                             •   You may be both a handler employer and a worker employer, depending on the
                                tasks that you and your employees do.
                             «   Both general-use pesticides and restricted-use pesticides are covered by the
                                WPS.
11

-------
ABOUT THIS MANUAL

This "How To Comply" manual will:
    «  Help you determine whether you are covered by the WPS.
    «  Give you detailed information on how to comply with the WPS requirements,
       including exceptions, restrictions, exemptions, options, and examples, and
    «  Provide you with a "Quick Reference Guide" — a simplified route to compliance
       that focuses on maximum requirements.
Important definitions and other special explanations are enclosed in shaded boxes.
Reading them will help you better understand the WPS requirements and how they apply
to you.

                            WPS
    If the pesticide product labeling contains specific instructions or
    that conflict with the requirements of the Worker Protection         follow
    the instructions or             on the labeling. For
                   may:
       «   Prohibit any early-entry activity, including          and
           tasks,
       «   Allow an early-entry activity that the WPS     not allow.
       •   Require the use of personal protective equipment even if closed systems
           are used for           loading.
                  TO                                                             Entry during a
    The WPS allows certain           to three specific pesticide labeling                  restricted-entry interval
    requirements:                              (p. 62),                               is permitted only in a
            (p, 36),                     (p. 33)     requirement on                  .      ,  ,
    i t. 1-   r  i- *i    i      •      j        *   4. j     \  -n  Time * *     *          Jew strictly limited
    labeling tor                            treated areas).  Hie WPs statements
    in the Agricultural Use             box on the               will tell you           circumstances; see
           WPS             exceptions.                                            Early Entry, p. 47
                                                          WPS - How To Comply Manual as Revised      ill

-------
                             For more information about the Worker Protection Standard, or if you have questions or
                             concerns about pesticides, contact the agency responsible for regulating pesticides in
                             your area or the EPA Regional Office nearest you.
                             EPA Headquarters
                             EPA Office of Pesticide Programs
                             U.S. Environmental Protection Agency
                             Ariel Rios Building
                             1200 Pennsylvania Ave., N.W.
                             Washington, D.C. 20460
                             www.epa.gov/pesticides

                             EPA National Agriculture Compliance
                             Assistance Center
                             901 North 5th Street
                             Kansas City,  KS 66101
                             (888)663-2155
                             www.epa.gov/agriculture

                             EPA Office of Compliance
                             U.S. Environmental Protection Agency
                             Ariel Rios Building
                             1200 Pennsylvania Ave., N.W.
                             Washington, D.C. 20460
                             (202) 564-2280
                             www.epa.gov/compliance

                             EPA Regions
                                    1 (MA, CT, Rl, NH, VT, ME)
                             U.S. Environmental Protection Agency, Region 1
                             Pesticides Program (CRT)
                             Office of Ecosystem Protection
                             1 Congress St., Suite 1100
                             Boston, MA 02114-2023
                             (888) 372-7341
                             www.epa.gov/NE/eco/pest/

                             Region 2 (NY, NJ, PR, V!)
                             U.S. Environmental Protection Agency, Region 2
                             Pesticide Team
                             MS-500
                             2890 Woodbridge Ave., Building K
                             Edison,  NJ 08837
                             (908) 321-6769
                             www.epa.gov/pesticides/local/region2/index.htm

                             Region 3 (PA, MD, VA, WV, DE)
                             U.S. Environmental Protection Agency, Region 3
                             Waste and Chemicals Management Division
                             Mail Code 3WCOO
                             1650 Arch St.
                             Philadelphia, PA 19103-2029
                             (800) 438-2474
                             www.epa.gov/reg3wcmd/pesticides.htm

                                    4 (GA, NC, SC, AL, MS, KY, FL, TN)
                             U.S. Environmental Protection Agency, Region 4
                             Pesticides Section
                             Sam Nunn Atlanta Federal Center
                             61 Forsyth St, SW
                             Atlanta, GA  30303-3104
                             (404) 562-8968
                             www.epa.gov/pesticides/local/region4/index.htm
Region 5 (!L, Ml, MN, IN, OH, W!)
U.S. Environmental Protection Agency, Region 5
Pesticide Program Section (DT-8J)
77 West Jackson Blvd.
Chicago, IL 60604
(312)353-2192
www.epa.gov/reg5rcra/ptb/pest/

Region 6 (TX, OK, AR, LA,  NM)
U.S. Environmental Protection Agency, Region 6
Pesticides Program
6PD-P
1445 Ross Ave.,  Suite 1200
Dallas, TX 75202-2733
(800) 887-6063
www.epa.gov/earth1 r6/6pd/pd p/pest.htm

Region 7 (MO, KS, lA, NE)
U.S. Environmental Protection Agency, Region 7
Pesticide Branch (PEST)
501 N. 5th St.
Kansas City, KS66101
(913) 551-7033
www.epa.gov/Region7/pesticides/index.htm

Region 8 (CO, MT, ND, SD, UT, WY)
U.S. Environmental Protection Agency, Region 8
Pesticide Program (8P-P3T)
999 18*51., Suite  300
Denver, CO 80202-2466
(800) 227-8917
www.epa.gov/Region8/toxics_pesticides/pests/
pesthome.html

       9 (CA, NV, AZ, HI, GU)
U.S. Environmental Protection Agency, Region 9
Pesticides Section (CED-5)
75 Hawthorne St.
San Francisco, CA  94105
(415) 947-8704
www.epa.gov/pesticides/local/region9/index.htm

Region 10 (WA,  OR,  ID, AK)
U.S. Environmental Protection Agency, Region 10
Pesticides Unit  (ECO-084)
1200 Sixth Ave.
Seattle, WA 98101-1128
(206) 553-1918
yosemite.epa.gov/R10/ECOCOMM.NSF/webpage/
Pesticides
IV

-------
Helpful Web Sites

EPA Office of Pesticide Programs Worker Protection Standard page:
www.epa.gov/oppfeadl/safety/workers/workers.htni
EPA Office of Pesticide Programs Agricultural Worker Protection Standard 40
CFR Parts 156 & 170 Interpretive Policy Questions and Answers
www.epa.gov/pesticides/safety/workers/wpsinterpolicy.htm
EPAAg Center Worker Protection Standard page:
www.epa.gov/agriculture/twor.html
EPAAg Center Worker Protection Standard publications page:
wwiv.epa.gov/agriculture/awor.html
Director}? of State Regulators
aapco.ceris.purdue.edu/htm/directories.htiii
State Pesticide Educators Directory
www.ipmcenters.org/contacts/PSEPdirectory.cfin
                                                            WPS - How To Comply Manual as Revised 2005  V

-------
VI

-------

United
Environmental Protection
Agency
      To
      the


                                 To

•
«
•


-------
Vlll

-------

Unit 1 — Quick Reference Guide ............................................. 1
Unit 2 —An Introduction to the Worker Protection Standard ........... 5
  What Is The Worker Protection Standard? ......................................... 7
  Does the Worker Protection Standard Apply to You? .............................. 9
  Who Does the WPS Protect? [[[ 10
  Which Pesticide Uses Are Covered?............................................... 12
  Which Pesticide Uses Are Not Covered?	 13
  Who Must Protect Workers and Handlers? ....................................... 14
Unit 3 — What Employers Must Do for      Workers and Handlers...  17
  Information at a Central Location ................................................ 19
  Pesticide Safety Training[[[ 21
  Decontamination Supplies[[[ 24
  Employer Information Exchange .................................................. 26
  Emergency Assistance[[[ 27
Unit 4 — Further Requirements for Employers of Workers ............  29
  Part A - Protections for All Agricultural Workers ................................ 31
     Notice About Applications  [[[ 33
     Restrictions During and After Applications ................................... 36
  Part B - Special Application Restrictions in Nurseries and Greenhouses	39
     Special Application Restrictions in Nurseries ................................ 41
     Special Application Restrictions in Greenhouses ............................ 43
  Part C-Early Entry [[[ 45
     Early-Entry Work  Situations[[[ 47
     General Protections for Early-Entry Workers ................................ 52
     Training and Instructions for Early-Entry Workers........................... 53

-------
   Equipment Safety [[[ 61
   Personal Protective Equipment (PPE) ............................................ 62
   Exceptions to PPE Requirements 	66
Unit 6 — Owner Exemptions and Crop Advisors.......................... 69
   Agricultural Owner Exemptions[[[ 71
   Protections for Crop Advisors [[[ 74
APPENDIXA-Criteria for WPS Materials ................................. 81
APPENDIX B -         Forms, Fact        and Checklists  ............. 91

-------
UNIT1
QUICK REFERENCE  GUIDE
Tliis 2-page Quick Reference Guide to the Worker Protection Standard lists the maximum
WPS requirements. Fulfilling these maximum requirements help you comply, but it may
cause you to do more than is required in some situations. If you want to look at
exceptions or want more information or examples for certain provisions, refer to the page
numbers listed in the Quick Reference Guide.
The Guide in this unit is presented on 2 pages to allow you to view all the requirements
together. For a large-print version of the same text, see Appendix C.

-------

-------
            QUICK REFERENCE GUIDE
UNIT 1








>•
II


1
™=
I
1


m
™










ll
Q
mm,.
GL
































TO THE
t
C.
1
to.
c
1
a-
_C
V
OJ
*C
g
_c
w
C
"c
1
k
e
£
c
'c
SI
C
*sC

ir
T-
_C











C
c
5
1
Q
'•C
C
<



c
a
«3
c
1
z
c
c
y.
fe
a
a
c
1
•e
o c
S
fe
=2
.2
&
&
Z
c
i, 0
" S
g
'S
i
1
r under an REI.
. In areas being treated, put d(
nclosed containers.
O t^ 
i_
 u '?
111
1 1
VI rf
o3  c
S.H ^
^H §

J 3
»ii
§w g
S 3
mployer Information Exch
. Before any application, com
ure the operator of the agricult
UJ ^ tn

^
fj
•£
3
3

0
'&
rt
^
rt
,
u S3 s
an easily seen
ay close togeth
EPAWPSsaf,
s •&•
^
— ; ^3



_O
'+-*
2004
The WPS is a federal regula




1

E
if area to
on,
e applied is aware of:
• location and description c
• time and date of applicati
•£>


o' r;
a "S
O C3
CJ 3}
"J r-
ra S
"-* £
S i!
1 s
"s, i
._ CJ
£!
J ^ 1 ijf -s s S B-S^
JD s *-i ^~! J— o .,, o "^r s ??
5fi Trt (DOiO--"1- i* "^ -S O3^
g ^ S&s^^ S « ^5 ^"'^5
a fH HQH^P 5^ > ra -rt~™
| § | s 111 S ^ | §||
^ rj^H.C
>- ^ -^gCa'^ o E? e S£^
I 1 1 1 ! ill
1 1 IHll Hi | |l!
Ill llljljlll 1 111
lil^liiiiii ji 1 iii
3l S5 H'g Sl = ss g &S3U a"§S
rt^S-sS-felg-S^SJ! a,«3S^6fe,-3
• • og. . yi*!*..
(NO UJ^&^«
g ^ (N|S^ J^J^.O3 (S
1 1 a-is H!i 1
1 1 ! |i Ifl'la

S- rf | | 1 1 1 1 1 s |
j3 -5 i""^ £ o H ' ' "^ T^ """""i . u -2

S os'-aG § "w-^S^^—^G
1 !§!s 1 -2 2§lll = sl
1 ill 1 1 111 ill II
'§> § .1 f l§ c ^ S '? '§ -| o S 3
i 'S- S1 E t§ 'Snnwu>;r!"n*5;1cs'
g 'C§-o3 ^ §c"3-^3jio^§C —
a S^^ o1 E'E"3fT>d:2-i;?'^"c
WOC C O't^S^So^rtTS-
° ^-% w3 ^ ^ '^cs'^^JI^'cOiy
« 1 1 1 1 1 1 1 1 1 1 s i i 1 f 1 1
..*•§?•* '-5 ^aj ^SS^3 o^>*C
f^^F-H^L^'i/j^'rtHHHH ^
cs|^l^o!5§ C

,-x S-H
*§ +•* -4-> °
oriMn^^toI)"w-£2'^5-H 4U'So25"
W ^4j QQ 1^3 .vMfHM^ O -H 	 i S £
p^.S +3'?^"gH3^^ ^-S^.oc
S-K Q^ ^ y ^^ ^ J-H & '""H F-H QQ top g O ^
"^^ &DO'™H OO^X rH O S C^
qj .S ^ ^ ^ ^ PH P P S '3 "** ^ -2 "r
•p-< ,2 Sj &o ^ -^ ^ -^ fl ^ ^ ^ > o .c
T3 'g 'i 1 '-s ^ s s ^-B ^ '-g g § |
q'SwgCJfl§O§ PH-tn O g X> r
TO C Q* • S &< O ^ *°^3 S O *°^3 M H C%j C




~d'
"J
M
M "j
W !-H
& g
11
w ^
• description of how the pe
• information about victim'

•o
p
M
o3 '?5
tt 1
-• O ;>
•o "2
s •?

Is "|f
"On'0 O1
OH ^ C
^ (D &D
c =3 S
ill
- 1

M 2 " .13
ill
CM CM 
-------















Ufa"'
n
a
•
ffl
•s
1
1

n
I
fl
p
h
i!
1
i
n
•
*i
m
|i
E
I
•i

t;'
11

1

^
^
c^




















I
I

<^

o
ir

r
^








i
^ S OJ «"
00 O "^ *O
L | s :s d ^
" ^ a> 2 M " — ' w
1 8 3 |3 & S
TO "-^ "^ S "5
^ .> M £j O -g
"S M & "^ ^ [5
"§ S w ° ^ "^

fe ° ^ S fr rt •§

•g -^ *C 0 ^ § g
g J3 ^ qj 00 &Q -7"
o|^^§^ ^ ^
S liri ^-3 E^'5
1 llljfl 1 111
PL] (DCM-^^WO Jt''S^°
& "". ^ 2" 'S =s ^ ^sls1!!
"O "u-SS"^-^* ^W^S —
| 3g-S"cgS SSc'^S
^ *^£ +HP*^ SS^.^H^

Sgfa'^^"|QS| "EdnHHIl

rfJ3(N^J2Sm^-S a -H
__ ^ . ^ „ ^ >
, "^ ^ O o ^ o
) ° ^ W rn »O -S ^
. g T3 CM g < ^ ^
b "^ TO W "S ^" S fij -^H §
"" •> J3 fi wrt° ^~^C3^S -5
tj*^^ im.S— ^ §^ ^
o-^1^ . &1 'S M s M ' ^ -*-r
.tt §f"^ 1 ^°^ J= d1 ^ "^ §
^pL]^^^3^,S -§^ |
•o U^ S-g^ga £^"^1 .§>
§ §"J | 'S | •> 'g I § 3 | |
c*jSSwS°'". .O^SM &>
.22w8T3J8g> ^Sg..S §
?i|l!H^llfl i
« 2 § £ J '§ •§ -2 .3 tj2'o^ 2
5t«tfSl^|^| E|^| .1
|lpl|3|||||l||
«lfif jl|| ||| Ifl
fsisllll! fcassis
_t, • S-H .TO • C t^-" "• • ^ .TO
•^ >— iO(NJ3mCODrt l/l •— i o (N J3 m



(J

^
#'
TO
o

g
o -
,0 Jj
^ "M
-§ '1 13"
-?*- 2 u •£

^ J -S -^
Vi S § "
^"Z | 1
<4H ' -3
^_ "O 0 &H ^
• cS •

(N
„
23
1>
§ O

"^ .2
t^ &
 TO
In c
O (D


g j§
"S
"i •§
.y o
i 'S
& PH
o g
JD
Cti r^
S -3'
rf "~~H

• •



V


~^J
& ^~
S
^
0^

>
'5b
S
|
Is
• restrictions on entering those ar
(The agricultural establishment opera
Eauinment Safetv 	
— —
*o *o
Q.^ "S Q.
• — ' " S (_ "5 " — ' wT
TO O rjj J&
•° Pi & i§
2 S ^ s
rt (^j o $
'S Z c1 S"
"S , £"* 3 f=-3 g
1 °S| §s * S | § a 8
1 1 1 1 s ! s 1 i « ^ a
S — J3 0 0 71 .C = +- P"
fe .2 3 13 S 8 8 ^ > 2 S ^

1 gl|§|| «?J^|
S- Q i ^ £ S ££••••
£ . § £ . i £ "a
Q -H 0 :; (NO .£ fl
». , — , , — . 
cc
(D
*"
§
^>-,
Post signs so the;
(N
S
o>
00
_c
"B
treated areas, inc]
£


• — -
S
d.
&>
*E
, 1
OH 	 ,
S 2
S o
(D
g
•^-H
3
Before each appl
^
B
rf
JH
^
the establishmen
c
o




derstand):
c
s
c
&
'£
CJ

J2
fe
Workers who ent
(N
>
'S
o
!^
3
O
0
'S
OH
"^
O
>
plication starts m
the start of theirs
&H
TO
"S

-------
UNIT 2
AN INTRODUCTION TO
THE WORKER PROTECTION
STANDARD

                          ............................7
   the                   Apply to You?................ 9
Who Does the WPS Protect?........................................... 10
Which            Covered?.................................. 12
Which Pesticide Uses Are Not Covered?............................. 13
Who Must Protect Workers and Handlers?.......................... 14

-------

-------
                                      AN INTRODUCTION TO THE WORKER PROTECTION STANDARD
           IS THE
STANDARD?

The Worker Protection Standard (WPS) is a regulation issued by the U.S. Environmental
Protection Agency.  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.
If you are an agricultural pesticide user and/or an employer of agricultural workers or
pesticide handlers, the WPS requires you to provide to your employees and, in some
cases, to yourself and to others:
    »  information about exposure to pesticides.
    «  protections against exposures to pesticides, and
    «  ways to mitigate exposures to pesticides.
INFORMATION
To ensure that employees will be informed about exposure to pesticides, the WPS
requires:
    «  Pesticide safety training — for workers and handlers.
    «  Pesticide safety poster — to be displayed for workers and handlers,
    «  Access to labeling information — for pesticide handlers and early-entry
       workers, and
    «  Access to specific information — centrally located application information of
       pesticide treatments on the establishment.
PROTECTION
To ensure that employees will be protected from exposures to pesticides, the WPS
requires employers to:
    «  prohibit handlers from applying a  pesticide in a way that will expose
       workers or other persons,
    «  exclude workers from areas being treated with pesticides,
    «  exclude workers from areas that remain under a restricted-entry interval
       (REI), with narrow exceptions.
    •  protect early-entry workers who are doing permitted tasks in treated areas
       during an REI, including special instructions and duties related to correct use of
       PPE,
    •  notify workers about treated areas so they can avoid inadvertent exposures, and
    •  protect handlers during handling tasks, including monitoring while handling
       highly toxic pesticides, and duties related to correct use of PPE.
MITIGATION
To mitigate pesticide exposures that employees receive, the WPS requires:
    «  Decontamination supplies — providing handlers and workers an ample supply
       of water, soap, and towels for routine washing and emergency decontamination,
    •  Emergency assistance — making transportation available to a medical care
       facility if an agricultural worker or handler may have been poisoned or injured
       by a pesticide, and providing information about the pesticide(s) to which the
       person may have been exposed.
                                                          WPS - How To Comply Manual as Revised 2005  7

-------
These key terms have
very specific meanings
in the WPS. Note that
these definitions may be
different from
definitions found in
other state and federal
laws and regulations.
                  to
These definitions will help you determine whether you are affected by the Worker
Protection Standard,
 Agricultural plants; Plants grown or           for           or
 purposes. Examples: food, feed, and fiber plants, trees, turfgrass, flowers, shrubs,
             and
 Farms: Operations, other than          or            produce agricultural
 plants outdoors,
                   that                                  for     liber or
 timber products.

               Operations that produce agricultural plants indoors in an area that
 is enclosed with nonporous covering        is     enough to allow a person to
 enter,           polyhouses, mushroom            caves,    rhubarb houses,
 as well as traditional greenhouses. Malls, atriums, conservatories, arboretums,
     office buildings that grow or         plants primarily for          or
 environmental benefits are not included.
                                                           for:
    •  transplants to another location, or
    •  flower or fern       .

            flowering and              or trees; tree          live Christmas
                 fruit, and                      and                 for sod.
8

-------
                                      AN INTRODUCTION TO THE WORKER PROTECTION STANDARD
          THE
           TO

You need the information in this manual if:
   «  You own or manage a farm, forest, nursery, or greenhouse where pesticides
       are used in the production of agricultural plants.

     Even if you are the owner of the farm,      nursery, or              you
     or         of your family do all the work there, you are a "WPS employer."
     You must comply with     of the requirements described in this manual,
     such as restricted-entry intervals and personal protective equipment    all
     the specific requirements listed in the pesticide labeling. See Agricultural
     Owner Exemptions, pp. 71-73,

   »  You hire or contract for the services of agricultural workers to do tasks
       related to the production of agricultural plants on a farm, forest nursery, or
       greenhouse. This includes labor contractors and others who contract with
       growers to supply agricultural laborers.
   »  You operate a business in which you (or people you employ) apply pesticides
       that are used for the production of agricultural plants on any farm, forest nursery,
       or greenhouse.


     Commercial                 and              are included with
     to              even if the                     (mixing, loading,
              etc.)                              the farm.,      nursery, or
                — at the commercial                     or an
     for example.
    «  You operate a business in which you (or people you employ) perform tasks
       as a crop advisor on any farm, forest, nursery, or greenhouse.
     "Crop advisor"           person who is         pest numbers or
     pesticide distribution, or the status, condition, or            of agricultural
     plants.          include crop consultants    scouts. For a description of
     WPS provisions for crop advisors, see pp. 74-80.
If you are in any of these categories, you must comply with the Environmental
Protection Agency's Worker Protection Standard (40 CFR, part 170) including all
revisions through 2004.
UNIT 2
                                                          WPS - How To Comply Manual as Revised 2005  9

-------
Under the WPS, you
may be both a worker
and an employer of
workers.
Under the WPS, you
may be both a handler
and an employer of
handlers.
                   THE WPS

The WPS requires employers to take steps to protect two types of agricultural employees:
workers and pesticide handlers.  The terms "worker" and 'pesticide handler" are
defined very specifically in the WPS, and employers of persons who meet these
definitions must comply with the WPS. Depending on the tasks being performed, you
may need to provide the same employee with worker protections on some occasions and
pesticide handler protections on other occasions.
Owners of agricultural establishments and members of their immediate family are exempt
from many WPS requirements. See Agricultural Owner Exemptions  pp. 71-73.

  WORKERS
  A worker is        who: (1) is employed (including self-employed) for any    of
               and (2) is                as                   or watering,
         to the production of agricultural      on a farm, forest, nursery, or
             TMs          not               who are          by a
               to             as                           for Crop Advisors,
  pp. 74-80),



  A                 is       who: (1) is employed (including self-employed) for any-
  type                 by an                        or a
                       that              in the           of agricultural      on a
  farm.      nursery, or           and (2) is      any of the following
    •   mixing, loading,            or         pesticides,
    •                           of pesticides,
    •        as a
    •   cleaning, handling, adjusting, or         the parts of mixing, loading, or
        application equipment that may contain pesticide residues,
    •           with the application of pesticides, including             the pesticide
        into the soil                  has occurred,
    •   entering a greenhouse or other                  application    before the
        inhalation         level listed on the product labeling has been        or
        of the WPS ventilation criteria have been     to:
        -         ventilation
        -  adjust or remove coverings, such as tarps, used in fumigation, or
        -        air            levels,
    »          a           outdoors               of any soil          to      or
        remove soil coverings,      as
    »                  as a     advisor:
        -         any
        -         any                  level or ventilation       listed in the
                  has             or one of the WPS ventilation        has
          met.
        -         any              interval,
    »           of pesticides or                  ,
10

-------
                                        AN INTRODUCTION TO THE WORKER PROTECTION STANDARD
           UNIT 2
A person is not a handler if he or she only handles pesticide containers that have been
emptied or cleaned according to instructions on pesticide product labeling or, if the
labeling has no such instructions, have been triple-rinsed or cleaned by an equivalent
method, such as pressure rinsing.
A person is not a handler if he or she (1) is only handling pesticide containers that are
unopened and (2) is not, at the same time, also doing any handling task (such as mixing
or loading).

Examples:
    «  You are a handler if you are loading unopened water-soluble packets into a
       mixing tank (because  you are mixing and loading the pesticide).
    «  You are not a handler if you:
        -  purchase pesticides and transport them unopened to an establishment.
        -  earn' unopened containers into a pesticide storage facility.
        -  transport unopened containers to the site where they are to be mixed, loaded.
           or applied.
Handlers who are
currently certified as
applicators of
restricted-use pesticides
must be given all of the
WPS handler
protections, except that
they need not receive
WPS training.
                                                           WPS - How To Comply Manual as Revised 2005  11

-------
                                                                ARE

                        Most pesticide uses involved in the production of agricultural plants on a farm, forest,
                        nursery, or greenhouse are covered by the WPS. This includes pesticides used on plants,
                        and pesticides used on the soil or planting medium the plants are (or will be) grown in.
                        Both general-use and restricted-use pesticides arc covered by the WPS. You will know
                        that the product is covered by the WPS if you see the following statement in the
                        Directions for Use section of the pesticide labeling:

                           "AGRICULTURAL USE
                           Use this product only in accordance with its labeling and with the Worker
                           Protection Standard, 40 CFR 170. This standard contains requirements for the
                           protection of agricultural workers on farms, forests, nurseries, and greenhouses,
                           and handlers of agricultural pesticides. It contains requirements for training,
                           decontamination, notification, and emergency assistance. It also contains specific
                           instructions and exceptions pertaining to the statements on this label about
                           personal protective equipment, notification of workers, and restricted-entry
                           intervals."
                        If you are using a pesticide product with labeling that refers to the Worker Protection
                        Standard, you must comply with the WPS.  Otherwise, you will be in violation of federal
                        law,  since it is illegal to use a pesticide product in a manner inconsistent with its labeling.
12

-------
                                       AN INTRODUCTION TO THE WORKER PROTECTION STANDARD
UNIT 2
                               USES ARE  NOT

Some pesticide uses are not covered by the WPS, even when the "Agricultural Use
Requirements" section is on the labeling. For example, if the pesticide labeling bears an
"Agricultural Use Requirements" section, but the product also can be applied to rights-of-
way. the rights-of-way use is not covered by the WPS. The WPS does not cover
pesticides applied:
    «  on pastures or rangelands,
    «  for control of vertebrate pests such as rodents,                                    Pesticides used on sod
    «  as attractaiits or repellents in traps,                                              farms are covered by the
    »  on the portions of agricultural plants that have been harvested, such as in            WPS.
       packing houses or on cut timber,
    «  for mosquito abatement, Mediterranean fruit fly eradication, or similar
       government-sponsored wide-area public pest control programs,
    «  on livestock or other animals, or in or around animal premises,
    «  on plants grown for other than commercial or research purposes, which may
       include plants in habitations, home fruit and vegetable gardens, and home
       greenhouses,
    «  on plants that are in ornamental gardens, parks, golf courses, and public or
       private lawns and grounds and that are intended only for decorative or
       environmental benefit.
    «  in a manner not directly related to the production of agricultural plants.
       including, for example, control  of vegetation along rights of way and in other
       noncrop  areas and structural pest control, such as termite control and wood
       preservation,
    «  for research uses of unregistered pesticides.
The WPS does not cover workers who arc working in an area where a pesticide has been
injected directly into the plants. However, people who handle pesticides that are to be        Direct injection does not
applied by direct injection are covered by the WPS and must receive handler protections.     include chemigation,
                                                                                    soil incorporation, soil
                                                                                    injection, hack and
                                                                                    squirt, or frill and spray.
                                                          WPS - How To Comply Manual as Revised 2005   13

-------
Compensation includes
pay or wages, payment
through services or
goods, or barter of
services or goods. If
only one person
receives payment for the
joint work of several
people, all are
considered to be
compensated, and are
employees under the
WPS.  For example,
under a piece-rate
payment system for
harvesting crops, even if
payment is issued to the
head of the family only,
all of the family
members who harvest
crops are considered
employees under the
WPS.
AND
Employers are responsible for making sure that workers and handlers receive the
protections required by the pesticide labeling and the WPS. The term "employer' has a
special meaning in the WPS — you are an employer even though you are self-employed
or use only members of your own family to do the work on your establishment.
The WPS has very specific definitions for two types of employers. WPS requirements
apply only to employers who meet those definitions.

    WPS
    Worker
    Worker employers are people who:
       •          or         for the        of         (including
           and          of their family) for any type of compensation to perform
                      to the           of agricultural        or
       «        or        an
                 of "owner," p, 71.)
    (See definition of "worker," p. 10.)
    If you are a worker employer, you are           for providing your agricultural
    worker          with the           that the WPS        for workers.  (In
    the WPS itself, "worker employers" are called "agricultural employers.")

                     are people who:
       •   employ         handlers (including         of'their family), for
           type of compensation, or
       •   are self-employed as pesticide handlers.
                 of'pesticide handler," p. 10.)
    If you are         employer, you are           for providing the
            you employ with the               the WPS        for
                         If You Employ Supervisors
                         You must:
                             «  require them to make sure the workers and handlers they supervise comply with
                                the WPS and receive its protections,
                             «  give them enough information and directions about the WPS requirements to
                                make sure that the workers and handlers they supervise receive the protections
                                required by the WPS, and
                             «  tell them who is responsible for all actions necessary for compliance with the
                                WPS.
                         Even if you assign an employee to carry out the duties required by the WPS,  you are
                         responsible for making sure that all those duties are performed.
 14

-------
                                       AN INTRODUCTION TO THE WORKER PROTECTION STANDARD
          UNIT 2
Retaliation Prohibited
You and your supervisors must not prevent or discourage any worker or handler from
complying or attempting to comply with the WPS, and you must not fire or otherwise
retaliate against any worker or handler who attempts to comply.

          for Noncompliance
Agricultural and handler employers can be subject to civil and criminal penalties if found
not complying with the federal Worker Protection Standard including all revisions
through 2004. Failure to comply is a pesticide misuse violation — also known as use of a
pesticide in a manner inconsistent with its labeling. Failure to comply with distinct acts of
the WPS may result in independently assessable charges, even if the violative acts
occurred during one pesticide application.
Currently, a federal civil penalty of up to $1,100 per violation may be assessed against
private applicators (owners/operators of agricultural establishments) and other persons,
and up to $6,500 per violation against commercial applicators (owners/operators of
pesticide handling establishments) and other persons. Since Congress passed the Civil
Monetary Penalty Inflation Adjustment Rule under the Debt Collection Improvement Act
of 1996, civil penalties have been increased due to inflation and Congress' intent on
creating a deterrence to noncompliance. The next civil penalty adjustment is expected to
occur in 2009.
Criminal penalties can also be assessed if the WPS is knowingly violated. Federal fines
include up to $1,000 per offense and 30 days in jail for private applicators, and up to
$25,000 and 1 year in jail for commercial applicators.


                         WPS
    If the pesticide product labeling contains specific instructions or
    that conflict with the requirements of'the Worker Protection Standard, follow the
               or             on the          For
            may:
       •  prohibit any early-entry activity,                   and
           tasks,
       •  allow an early-entry activity that the WPS    not allow,
       •  require the use of personal protective equipment even if closed systems
           are     for            loading.
Most states and tribes
enforce under their own
laws and regulations
and have their own
penalties, which may
differ from federal
penalties. Pesticide-
related ordinances and
associated penalties
may also be imposed by
local governments.
                to
    The WPS allows                 to     specific pesticide labeling
    requirements: personal protective equipment (p, 62), restricted-entry
    Intervals (p, 36),     double notification (p, 33) (the requirement on
    labeling for both oral warnings     posting        areas).  The WPS
    in the Agricultural Use              box on the product labeling will tell you
    that the WPS contains     exceptions.
                                                           WPS - How To Comply Manual as Revised 2005  15

-------
16

-------
UNIT 3
WHAT EMPLOYERS MUST
DO  FOR BOTH WORKERS
AND  HANDLERS
Some WPS protections that employers must provide are nearly the same whether the
employees are workers or handlers. This unit describes those requirements. Unit 4
describes additional requirements that employers must provide to their employees who
arc workers. Unit 5 describes additional requirements that employers must provide to
their employees who are handlers. If you employ both workers and handlers, you will
need to read all three of these units.
          at a       Location.................................... 19

                    .............................................. 21

                     ............................................ 24

                          ..................................... 26

                  ................................................. 27

-------
18

-------
                                   WHAT EMPLOYERS MUST DO FOR BOTH WORKERS AND HANDLERS
          UNIT  3
                        AT
A


      Also Specific Duties Section Below)
Worker employers must make sure that certain information,
described below, is displayed at a central location whenever (1) any
worker whom they employ is on their agricultural establishment, and
(2) a pesticide is about to be applied or has been recently applied.
When agricultural establishments employ their own handlers, handler
employers of such establishments must make sure that certain
information, described below, is displayed at a central location
whenever (1) any handler whom they employ is on their agricultural
establishment, and (2) a pesticide has been recently applied.
However, this information does not need to be displayed if only commercial (custom)
pesticide handlers will be on the agricultural establishment.


What Information Must Be Displayed?
The following three types of information must be displayed at a central location before a
pesticide is applied:
I. Pesticide-specific application information, which must include: the location and
description of the area to be treated, product name, EPA registration number, and active
ingredient(s) of the pesticide, time and date the pesticide is scheduled to be applied, and
restricted-entry interval  for the pesticide.
2. Emergency information, which must include the name, telephone number and
address of the nearest emergency medical facility.
3. A pesticide safety poster, which must be cither the WPS safety poster developed by
EPA or an equivalent poster that contains the concepts listed in Criteria for Pesticide
Safety Poster, p. 83.

Where Must the Information Be Displayed?
Display the required information together in a central location on your agricultural
establishment where it is readily accessible and can be easily seen and read by workers
and handlers.

   Exception
   If the workplace is a forest, you may display the information near the forest. It must
   be in a location where workers and handlers can easily  see and read it and where they
   are likely to gather or pass by. For example, you might  display the information with
   the decontamination supplies or at an equipment storage site.

When Must the Information Be  Displayed?
Display the information whenever any worker or handler you employ is on your
agricultural establishment and. in the past 30 days, a pesticide has been applied or a
restricted-entry interval  has been in effect. The information may be displayed
continuously.
Commercial pesticide
handler employers do
not need to display this
information on the
commercial pesticide
handling establishment.
If the pesticide is not
applied as scheduled,
you must display the
corrected time and date
before the application
takes place. If you are
unable to make the
correction before the
application takes place,
make it as soon as
possible thereafter.
                                                           WPS - How To Comply Manual as Revised 2005 19

-------
Earlier display: If you
post WPS warning signs
at treated areas, you
must display pesticide-
specific information at
the central location no
later than the time when
the warning signs are
posted.
Timing of Displaying Application Information
1.  If workers or handlers are on your establishment at the start of an application, display
the required pesticide-specific information before the application takes place.
2.  If workers or handlers are not on your establishment at the start of an application,
display pesticide-specific information no later than the beginning of their first work
period.
3.  Continue to display pesticide-specific information when workers or handlers are on
your establishment until:
    «   at least 30 days after the restricted-entry interval expires, or
    «   at least 30 days after the end of the application, if there is no restricted-entry
        interval for the pesticide.
Other Responsibilities
1.  Inform workers and handlers where the information is located.
2.  Allow workers and handlers free, unhampered access to the information.
3.  Be sure that the poster, emergency information, and application information remain
legible during the time they are posted.
4.  Promptly inform workers if there is any change in the information on emergency
medical facilities and update the emergency information listed with the poster.
20

-------
                                   WHAT EMPLOYERS MUST DO FOR BOTH WORKERS AND HANDLERS
UNIT 3
      Also Specific Duties Section Below)
Handler employers must make sure that handlers are trained, as
described below, about general pesticide safety and about correct
ways to handle pesticides.
Worker employers must make sure that workers have been trained,
as described below, about general pesticide safety. This includes
workers who enter treated areas on the farm, forest, nursery, or
greenhouse during a restricted-entry interval to perform WPS-
permitted tasks.


Providing Basic Pesticide Safety Information to  Untrained Workers
You must provide basic pesticide safety information to untrained workers before they
enter treated areas on your establ ishment where, within the past 30 days, a pesticide has
been applied or a restricted-entry interval has been in effect. You must:
    «  provide the basic pesticide safety information in a manner that the untrained
       workers can understand, such as through written materials, oral communication,
       or other means,
    «  be able to verify that you provided the workers with the required basic pesticide
       safety information,
    «  provide the workers with at least the following information:
       -   Pesticides may be on or in plants, soil, irrigation water, or drifting from
           nearby applications.
       -   To prevent pesticides from entering your body:
               Follow directions and/or signs about keeping out of treated or restricted
               areas,
           •    Wash before eating, drinking, using chewing gum or tobacco, or using
               the toilet,
               Wear work clothing that protects your body from pesticide residues,
               Wash/shower with soap and water, shampoo  hair, and put on clean
               clothes after work.
               Wash work clothes separately from other clothes before wearing them
               again,
               Wash immediately in the nearest clean water if pesticides are spilled or
               sprayed  on your body and then —as soon as possible — shower.
               shampoo, and change into clean clothes.
           *    You will receive more training within 5 days (or at least before your
               sixth day of work in pesticide-treated areas on this establishment).
Who  Must Be Trained?
Each worker and handler must be trained. This requirement is met if the worker or
handler:
1.  has been trained within the last 5 years as a WPS handler or WPS worker, even if he
or she has changed employers, or
2.  is currently a certified applicator of restricted-use pesticides, or
3.  is currently trained (as specified in EPA's certification and training regulations) as a
handler who works under the supervision of a certified pesticide applicator.


                                                          WPS - How To Comply Manual as Revised 2005 21

-------
Entry during a
restricted-entry interval
is permitted only in a
few strictly limited
circumstances. See
Early Entry, p. 47.
 Under the WPS, you
 may be both a handler
 and an employer of
 handlers.
How Soon Must They Be Trained?
1.  Handlers must be trained before they do any handling task.
2.  Early-entry workers who will contact anything that has been treated with the
pesticide which caused the restricted-entry interval must be trained before they do any
early-entry task on your establishment.
3.  Other agricultural workers, Including early-entry workers who will not contact
anything that has been treated with the pesticide which caused the restricted-entry'
interval must be trained before they accumulate more than 5 separate days of entry into
treated areas on your establishment where, within the past 30 days, a pesticide has been
applied or a restricted-entry interval has been in effect. These 5 days of entry need not be
consecutive and are not limited to a growing season or calendar year.
   Note: You must provide untrained workers with basic pesticide safety information
   before they enter into treated areas on your establishment where, within the past 30
   days, a pesticide has been applied or a restricted-entry interval has been in effect (see
   Providing Untrained Workers Basic Pesticide Safety Information, p. 21).

How Often  Must Handlers and Workers  Be Trained?
Handlers and workers must be trained at least once every 5 years, counting from the end
of the month in which the previous training was completed.

Who Can Conduct Training?
1.  The person who conducts handler training must:
    »   currently be a certified applicator of restricted-use pesticides (in any category of
        certification).
        or
    «   currently 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 a state,
        federal, or tribal agency having jurisdiction.
2.  The person who conducts worker training must:
    •   currently be qualified to present handler training, as described immediately
        above,
        or
    »   currently be trained as a WPS handler.
        or
    «   have completed a pesticide safety train-the-trainer program approved by a state,
        federal, or tribal agency having jurisdiction.
How To Conduct Training
1.  Anyone who conducts worker or handler training must:
    «   use written and/or audiovisual materials,
    «   present the training orally or audiovisually,
    «   present the information in a manner that the trainees can understand, using a
        translator, if necessary.
    «   respond to trainees' questions.
2.  Anyone who conducts worker training must use non-technical terms.
22

-------
                                   WHAT EMPLOYERS MUST DO FOR BOTH WORKERS AND HANDLERS
UNIT 3
Content of Training
The pesticide safety training materials for workers and handlers must be either:            Handlers who are
    _  llrnc,4.  •  -     *  • i j    1    ju  T-T»A                                       currently certified as
    «  WPS training materials developed by hPA,
                                       "                                            applicators of
    •  equivalent material that contains at least the concepts listed in Criteria for           restricted-use pesticides
       Worker and Handler Training, p. 87, 89.                                         must be given all of the
Verification of Training                                                           WPShandler
If you make sure that a handler has an EPA-approved WPS handler training card or that      protections, except that
a worker has an EPA-approved WPS worker or handler training card, the person does not     they need not receive
have to be retrained unless you are aware, or have reason to know, that the card is invalid.     WPS training.
A WPS training card is Invalid if you, the employer:
    «  are aware, or have reason to know, that the card was not issued according to the
       criteria in the WPS.  For example, you know that the person who gave the
       training was not qualified to conduct WPS training, or that the content of the
       training did not meet the WPS criteria, or the trainee could not understand the
       training when it was given.
       or
    «  are aware, or have reason to know, that the card was not issued to the person who
       has the card.
       or
    «  know that the training for which the card was issued took place more than 5 years
       before the beginning of the current month (the card has expired).
Avoiding Discrimination in Hiring
Even if you do not normally provide training in the particular language of a job applicant,
or if a translator is not readily available, you are not exempted from your training
responsibilities under the WPS.


            to hire an          who                 the         or
    in which you usually               may                       on the
    of national origin. Such discrimination is          under Title VII of the Civil
          Act of 1964 or the                   and Control Act of 1986 (IRCA).
    If you want information     your               under Title ¥11 of the Civil
    Rights Act of 1964,        the U.S. Equal Employment Opportunity
    Commission. For       about IRCA anti-discrimination provisions,       the
          Counsel for Immigration-Related Unfair Employment Practices, U.S.
    Department of Justice,
                                                          WPS - How To Comply Manual as Revised 2005  23

-------

The WPS requires that
decontamination
supplies be provided
regardless of the
number of employees.
There is no exemption
for employers with only
a few employees.
Note: For early-entry
workers who will
contact anything that
has been treated with
the pesticide, the
decontamination supply
requirements are
different. See
Decontamination
Supplies for Early-
Entry Workers, p. 54.
 Decontamination and
 emergency eyeflush
 water must, at all times
 when it is available to
 workers or handlers, be
 of a quality and
 temperature that will
 not cause illness or
 injury when it contacts
 the skin or eyes or if it is
 swallowed.
      Also Specific Duties Section Below)
Handler employers must make sure that
decontamination supplies (described below) for
washing off pesticides and pesticide residues
are provided to handlers while they are doing
handling tasks.
Worker employers must make sure that
decontamination supplies (described below)
for washing off pesticide residues are
provided to workers who are working in a
pesticide-treated area and are doing tasks that involve contact with anything that has been
treated with the pesticide, including soil, water, or surfaces of plants.

When Must the           Be Provided?
For handlers, for the duration of the handling task.
For workers, until 30 days after the end of any restricted-entry interval for that area. If
there is no restricted-entry' interval, until 30 days after the end of any application in that
area.
   Exception
   When the only pesticides used in the treated area are products with a restricted-entry
   interval of 4 hours or less, the decontamination supplies must be provided until 7 days
   after the end of the restricted-entry interval. Note: When products have no restricted-
   entry interval listed on the label, the decontamination supplies must be provided until
   30 days after the end of any application in that area.
For early-entry workers who will contact anything that has been treated with the
pesticide, the decontamination supply requirements are different.  See Decontamination
Supplies for Early-Entry Workers, p. 54.
Supplies
Provide workers and handlers with:
1.  Water — enough for:
    «   routine washing, and
    »   emergency eyeflush i ng.
        If the water is stored in a tank, the water must not be used for mixing pesticides,
        unless the tank is equipped with correctly functioning anti-backsiphoning or
        check valves or other mechanisms (such as air gaps) that prevent pesticides from
        moving into the tank.
2.  Soap and single use towels — enough for workers' or handlers" needs.
3.  For handlers, also provide:
    »   enough water for washing the entire body in case of emergency, and
    «   clean change of clothes, such as one-size-fits-all coveralls, to put on if the
        handlers' garments  are contaminated and need to be removed right away.
 24

-------
                                                                                              UNIT 3
WHAT EMPLOYERS MUST DO FOR BOTH WORKERS AND HANDLERS
                                                  Be
    Obviously, running           the requirement.  However, if it is not available,
    use the following guidelines,
       •  Workers: At least 1 gallon of water is recommended for
                the supplies. If you find that 1 gallon per worker is inadequate to
           last forme     work period., provide           or
           as        during the work period.
       «           : At     3        of     is             for
                the supplies. If you find that 3       per        is           to
           last forme     work period, provide           or
           as        during the work period.

Location
1.  All decontamination supplies for workers must be located together and all
decontamination supplies for handlers must be located together. Decontamination
supplies must be reasonably accessible to the workers and handlers. Handlers mixing
pesticides must have decontamination supplies at the mixing area.

   Exceptions:
    «  For a pilot who is applying pesticides aerially, the decontamination supplies must
       be at the aircraft's loading site or in the aircraft.
    «  For tasks performed more than 1/4 mile from the nearest point reachable by
       vehicles (cars, trucks, or tractors), the decontamination supplies may be at the
       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 access point.
2.  Worker decontamination supplies must not be in an area being treated with
pesticides or in an area under a restricted-entry interval.
3.  Handler decontamination supplies may be located in an area being treated with
pesticides (or an area that has a restricted-entry interval in effect), only if:
    «  They are in the area where the handler is doing handling tasks.
       and
    «  The soap, single-use towels, and clean change of clothing are in closed
       containers,
       and
    «  The water is running tap water or is in a closed container.
Emergency Eyeflushing
Provide each handler with  at least 1 pint of emergency eyeflush water when the pesticide
labeling requires protective eyewear for the handling task being performed. The
emergency eyeflush water must be Immediately accessible. For example, it could be
carried by the handler or be on a vehicle the handler is using. The water that is supplied
for general decontamination may also be used as eyeflush water, if it is immediately
accessible.

Decontamination After Handling Tasks
At the site where handlers remove their personal protective equipment (PPE), provide:
    «  soap,
    «  clean towels, and
    «  enough water to allow handlers to wash thoroughly after removing PPE.
                                                           WPS - How To Comply Manual as Revised 2005 25

-------
If the pesticide is not
applied as scheduled,
you must display the
corrected time and date
before the application
takes place. If you are
unable to make the
correction before the
application takes place,
make it as soon as
possible thereafter.
      Also Specific Duties Section
Below)
Employers of commercial pesticide handlers
must make sure that their customer — the
operator of the farm, forest, nursery, or
greenhouse — knows certain information,
described below, about the pesticide before it is
applied on the establishment.
Operators of farms, forests, nurseries, and
greenhouses (agricultural employers) must make sure that, whenever a commercial
handler will be doing pesticide handling tasks (including tasks as a crop advisor) on their
establishment, the commercial handler's employer knows specific information,
described below, concerning treated areas on the agricultural establishment.


Information for Establishment Operators
Commercial handler employers must inform their customer — the operator of the farm,
forest, nursery, or greenhouse — about:
    «   the specific location and description of the arca(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, and
    «   any other  specific requirements on the pesticide labeling concerning protection
        of workers and other persons during or after application.
Operators of agricultural establishments must have this information to protect their
employees. See Information at a Central Location, pp. 19-20 and Notice about
Applications, pp. 33-35.

Information for Commercial  Handler Employers
Operators of agricultural establishments must provide the following information to the
commercial pesticide handler employer that they hire:
    «   Specific location and description of any  areas on the agricultural establishment:
        -  that may be treated with a pesticide or be under a restricted-entry interval
           while the commercial handler will be there, and
        -  that the commercial handlers may be in (or walk within 1/4 mile of).
    «   Restrictions on entering those areas.
Operators of commercial pesticide handling establishments must have this information to
protect their employees.  See Specific Instructions  for Handlers, p. 60.
26

-------
                                   WHAT EMPLOYERS MUST DO FOR BOTH WORKERS AND HANDLERS
          UNIT 3

      Also Specific Duties Section Below)
Worker employers must provide emergency assistance, described below,
to anyone who is or has been employed as a worker on their farm, forest.
nursery, or greenhouse if there is reason to believe that the worker has
been poisoned or injured by a pesticide used on the agricultural
establishment — for example, through application, spills, splashes, drift,
or contact with pesticide residues.
Pesticide handler employers must provide emergency assistance, described below, to
anyone who is or has been employed as a handler on their farm, forest nursery, or
greenhouse or on their commercial pesticide handling establishment, if there is reason to
believe mat the handler has been poisoned or injured by a pesticide as a result of that
employment — for example, through application, spills, splashes, drift, handling tasks, or
contact with pesticide residues.


Emergency  Transportation
1. Promptly make emergency transportation available to take the worker to an
emergency medical facility able to provide treatment:
    »  from the agricultural establishment, or
    «  from a labor camp located on the establishment.
2. Promptly make emergency transportation available to take the handler to an
emergency medical facility able to provide treatment:
    »  from the agricultural establishment, or
    m  from another handling site, such as a commercial handling establishment or an
       airport hangar.
Emergency  Information
 Provide to the worker or handler or to treating medical personnel, promptly upon
request, any obtainable information on:
    «  product name, EPA registration number, and active ingredients for any product(s)
       to which the person may have been exposed,
    «  antidote, first aid, statement of practical treatment and other medical or
       emergency information from the product labeling,
    «  description of the way the pesticide was being used, and
    «  circumstances of the worker's or handler's exposure to the pesticide.
Employer-scan "make
transportation
available " by:
•  taking the employee
   to the emergency
   medical facility, or
•  calling an
   emergency vehicle,
   such as an
   ambulance, or
•  making sure the
   employee has a ride
   to the medical
  facility with someone
   else.
                                                          WPS - How To Comply Manual as Revised 2005 27

-------
28

-------
UNIT 4
FURTHER  REQUIREMENTS
FOR  EMPLOYERS OF
WORKERS
Unit 3 described the WPS protections that employers must provide to both worker and
handler employees. This unit describes the additional protections that employers arc
required to provide to their worker employees.


PART A -         for All              .................. 31

PART B - Special Application Restrictions in
                  ............................................ 39


-------
30

-------
                                      FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS



PART A
                      FOR ALL


The requirements described in this part are In addition to the protections employers must
provide to both workers and handlers (Unit 3).


                            ............................................. 33

              During and After Applications ......................... 36
UNIT 4
                                                    WPS - How To Comply Manual as Revised 2005 31

-------
32

-------
                                         FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
                     UNIT 4
     Also Specific Duties Section Below)
Under most circumstances, worker employers must make sure that
workers are notified about areas where pesticide applications are talcing
place or where restricted-entry intervals are in effect.


Both Oral Warnings      Posted Signs
Some pesticide labels require you to notify workers both orally and with
signs posted at entrances to the treated area. If both types of notification
are required, the following statement will be in the "'Directions for Use"
section of the pesticide labeling under the heading •'Agricultural Use
Requirements'":
   "Notify workers of the application by warning them orally and by
   posting warning signs at entrances to treated areas."

Notification on Farms, Forests,      Nurseries
Unless the pesticide labeling requires both types of notification, notify' workers either
orally or by the posting of warning signs at entrances to treated areas. You must inform
workers which method of notification is being used.

Notification in Greenhouses
In greenhouses, you must post all treated areas, except as described below. If the
pesticide labeling requires both types of notification, you must also notify workers orally.

Exceptions to Worker Notification
1.  Oral warnings need not be given to:
    «   any worker on your farm, forest, or nursery who will not be in the treated area, or
       walk within 1/4 mile of a treated area, during the pesticide application or while
       the restricted-entry interval is in effect,
    «   any worker who will not be in your greenhouse during a pesticide application or
       while a restricted-entry interval is in effect there, or
    «   any worker who applied (or supervised the application of) the pesticide and is
       aware of all of the information required to be given in the oral warning.
2.  Treated area posting is not required if:
    «   no workers on your farm, forest, or nursery will be in the treated area, or walk
       within 1/4 mile of the treated area, during the pesticide application or while the
       restricted-entry interval is in effect,
    «   no workers will be in the greenhouse during the pesticide application or while
       the restricted-entry interval is in effect there, or
    •   the only workers for whom you need to post applied (or supervised the
       application of) the pesticide and are aware of all of the information required to be
       given in the oral warning.
DANGER  PELIGRO
PESTICIDES  PESTICIDAS
     KEEP OUT
     NO ENTRE
                                                        WPS - How To Comply Manual as Revised 2005 33

-------
Signs meeting these
requirements should be
available commercially.
For a detailed
description, see
Requirements for
Warning Signs, p. 85.
Posted Warning Signs
 Use WPS-design signs when you post warnings at entrances to treated areas. For a
detailed description, see Requirements for Warning Signs, p. 85.
1. Location:
    «   On farms, forests, and nurseries, post the signs so they can be seen from all
        points where workers usually enter the treated area, including at least:
        - each access road,
        - each border with any labor camp adjacent to the treated area, and
        - each established walking route that enters the treated area.
          When there are no usual points of worker entry, post the signs in the corners
          of the treated area or in places where they will be most easily seen.
    «   In greenhouses, post the signs so they can be seen  from all points where workers
        usually enter the treated area, including doorways, aisles, and other walking
        routes. When there are no usual points of worker entry to the  treated area, post
        the signs in the comers of the treated area or in places where they will be easily
        seen.
2. Timing and Visibility of Warning Signs:
    «   Post signs 24 hours or less before the scheduled application of the pesticide.
    «   Keep signs posted during application and throughout the restricted-entry interval
        (if any),
    «   Remove the signs within  3 days after the end of the restricted-entry interval.  If
        there is no restricted-entry interval for that application, remove the signs within 3
        days after the end of the application.
    «   Keep workers out during  the entire time the signs are posted, (except for trained
        and equipped early-entry  workers entering as permitted under WPS).
    «   Keep signs visible and legible while they are posted.
3. Posting Adjoining Areas
When several adjoining areas are to be treated with pesticides on a rotating or sequential
basis, you may post the entire area at the same time. Worker entry, except for early entry
permitted by the WPS, is prohibited for the entire area while the signs are posted.
4. Design and Size
    «   Each warning sign must look
        like this:
                                                                  Red-
   Exception:
   As an option, you may use warning
   signs that replace the Spanish
   words with the same words in
   another language (other than
   English) that is read by the largest
   number of your workers who do
   not read English. The replacement
   sign must meet all other
   requirements for the WPS warning
   sign.
    «   You may put additional information on the warning sign, such as the name of
        the pesticide or the date of application, if it does not lessen the impact of the sign
        or change the meaning of the required information. If you add the required
        information in other languages, the words must be translated correctly.

                                                                                 KEEP OUT
                                                                                 NO
34

-------
                                           FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
          UNIT 4
    «  The signs must be at least 14 inches by 16 inches, and the letters must be at least
       1 inch high.
   Exception:
   On farms and forests, you may use smaller signs if the treated area is too small to
   accommodate  14- by 16-inch signs. For example, when a single plant needs to be
   posted, a smaller sign would be appropriate. In nurseries and greenhouses, you may,
   at any time, use a sign smaller than the standard size. Whenever a small sign is used,
   there are specific posting distances depending on the size of the lettering and symbol
   on the sign (see table below).

7" x8"
(approx.)
4 1 /2" x 5"
(approx.)
Required in Inches
Circle Graphic
3"
1 1/2"
Lettering for
Words
a
"PELIGRO"
7/8"
7/16"
Lettering for
1/2"
1/4"
Maximum
Distance
Between
Signs*
50 feet
25 feet
   *  This distance requirement is for places where multiple signs are used to post a
   single treated area, such as a field or a greenhouse section. It does not apply where
   individual signs arc used for separate small treatment areas (such as single potted
   plants in a greenhouse).
Oral Warnings to Workers
1.  Content:
Oral warnings must include:
    «  the location and description of the treated area,
    «  the time during which entry is restricted, and
    «  instructions not to enter the treated area until the restricted-entry interval has
       expired.
2.  Communication:
Provide oral warnings to workers in a manner that they can understand.
3.  Timing:
    «  Workers who are on your establishment at the start of an application must be
       orally warned before the application takes place.
    «  Workers who are not on your establishment at the start of an application must be
       orally warned at the beginning of their first work period if (1) the application
       is still talcing place or (2) the restricted-entry interval for the pesticide is in effect.
Signs with the words
"DANGER" and
"PELIGRO "in letters
less than 7/16 inch in
height or with any words
in letters less than 1/4
inch in height or with
the circle graphic
containing an upraised
hand and a stern face
less than 1 '/2 inches in
diameter do not meet
WPS sign requirements.
                                                           WPS - How To Comply Manual as Revised 2005 35

-------
Entering either
enclosed or outdoor
fumigated areas to
ventilate, remove tarps
or other coverings used
in the fumigation,  or to
measure air
concentration levels are
handling tasks, not
early entry. Only
appropriately trained
and equipped handlers
can do these tasks.
      Also Specific Duties Section Below)
Worker employers must take actions, described below, to
protect workers and other persons during pesticide
applications on agricultural establishments. Worker
employers also must take actions, described below, to protect
workers during restricted-entry intervals.


During Applications
1.  Keep everyone except appropriately trained and equipped handlers out of areas being
treated with pesticides.
2.  In nurseries and greenhouses, during some applications, also keep workers and other
persons out of the area Immediately around the area being treated. The size of this
"keep-out zone" depends on the pesticide used and the application method. In some
greenhouse situations, the greenhouse must be adequately ventilated before workers are
allowed to enter (see Special Application Restrictions in Nurseries and Greenhouses,
pp. 41 and 43).

During Restricted-Entry Intervals
In general, keep workers out of a treated area during the restricted-entry interval. This
restriction has only two types of exceptions: (1) early entry with no contact, described
below, and (2) early entry with contact for short-term, emergency, or specially excepted
tasks (all described in Early Entry, p. 47). Note, however, that entry into treated areas
during a restricted-entry interval is also allowed to perform handling (including crop
advisor) tasks as long as the persons entering such areas are trained and equipped as
pesticide handlers and receive all other applicable WPS handler protections.

                                       (REI)
    The               interval is the
    when,      into the           is limited.                     one REI,
    as 12 hours, for all      arid      Other
    on the     or method of application. When, two (or more)           are
              time, and             REIs, you     follow the        interval.

              of      on
    The restricted-entry interval is listed on the pesticide labeling;
        •   under the         "Agricultural Use Requirements" in the "Directions
           for Use" section of the pesticide labeling, or
        «        to the      or                  to which it

                                a         REI for          Labeling
    say, for        "72 hows in outdoor      where average annual rainfall is less
        25      a year." You can get information on                      for
    your     from any nearby weather bureau, such as one located at a local airport
    or            with the National Oceanographic and Atmospheric
    Administration.
36

-------
                                           FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
           UNIT 4
NO-CONTACT
If workers will have no contact with anything that has been treated with the pesticide
to which the restricted-entry interval applies, you may permit them to enter pesticide-
treated areas when the application is finished.
1. After any inhalation exposure level listed on the product labeling has been reached or
any WPS ventilation criteria have been met. you may permit workers into a treated area
during an REI if they will not touch or be touched by any pesticide residues, including:
    «   on plants, including both agricultural plants and weeds,
    »   on or In soil or planting medium,
    «   in water, such as irrigation water or water standing in drainage ditches or
        puddles,
    «   in air, if pesticide remains suspended after application, such as after fumigation
        or after a smoke, mist, fog, or aerosol application.

    No-contact                     do not     to be provided the
                      in Early Entry, p. 47,  However, they     be provided the
    following                 to                 workers: information at a
           location,                      for workers, notification,
                      and        restricted-entity intervals, and
                                       however,     not be provided to no-
           early-entry workers.
Avoiding contact by
using personal
protective equipment
does not qualify as no-
contact early entry.
2. The following are examples of situations where a worker would not be expected to
contact pesticide residues in a treated area after sprays, dusts, and vapors have settled out
of the air:
    «  The worker is wearing footwear and is walking in aisles or on roads, footpaths,
       or oilier pathways through the treated area where the plants or other treated
       surfaces cannot brush against the worker and cannot drop or drip pesticides onto
       the worker.
    «  The worker is in an open-cab vehicle in a treated area where the plants cannot
       brush against the worker and cannot drop or drip pesticide onto the worker.
    «  After a pesticide application that is incorporated or injected into the soil, the
       worker is doing tasks that do not involve touching or disrupting the soil
       subsurface.
    «  The worker is in an enclosed cab on a truck, tractor, or other vehicle.
                                                           WPS - How To Comply Manual as Revised 2005  37

-------
38

-------
                                       FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS


PARTB
                                                         IN
                 AND
The WPS requires additional restrictions during some pesticide applications in nurseries
and greenhouses. This part describes those restrictions.

                                  in            ...................... 41
                                  in               .................. 43
UNIT 4
                                                     WPS - How To Comply Manual as Revised 2005  39

-------
40

-------
                                          FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
                         IN


      Also Specific Duties Section  Below)
Worker employers must make sure that, during certain nursery applications,
workers and other persons do not enter treated areas on the nursery or, in
some circumstances, do not enter areas that are near the treated area.


Application Restrictions on Nurseries
During any application described in column A of Table I, do not allow or direct any
person, other than an appropriately trained and equipped handler, to be in the areas on
the nursery specified in column B.  After the application is finished and during the
restricted-entry interval:
    «  keep workers out of the treated area (the area to which the pesticide was
       directed).
    «  you may allow workers in the areas just outside the treated area that were off-
       limits during the application.
UNIT 4
                                                         WPS - How To Comply Manual as Revised 2005 41

-------
                                                            Table I
                                        Special Application Restrictions in Nurseries
                                      COLUMN A
                                 While a Pesticide Is
                                    Being Applied:
            COLUMN B
 Workers and Other Persons Are
          Prohibited in:
                          1.  (a)  Applied:
                             •  Aerially, or
                             "  In an upward direction, or
                             "  Using a spray pressure greater
                                 than 150 pounds per square inch.
Pesticide-treated area plus 100 feet in all
directions on the nursery.
                          or
                             (b)  Applied as a:
                             «  Fumigant, or
                             "  Smoke, or
                             "  Mist, or
                             "  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
                                 pounds per square inch and less
                                 than 150 pounds per square inch.
Pesticide-treated area plus 25 feet in all
directions on the nursery.
                          or
                             (b) Under circumstances other than
                             (l)(a) or (l)(b) or (2)(a) above but
                             for which the pesticide labeling
                             requires the applicator to wear a
                             respirator.
                          3.  In any other manner.
 Pesticide-treated area.
42

-------
                                          FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
                         IN


      Also Specific Duties Section Below)
Worker employers must make sure that workers and other persons do
not enter specific areas within the greenhouse during — and, in some
instances, after — certain greenhouse applications.


Application Restrictions In Greenhouses
During any application described in column A of Table II, do not allow or dir
person, other than an appropriately trained and equipped handler, to be in the
specified in column B.

Ventilation Criteria for Greenhouses
1.  After some types of pesticide applications listed in column A of Table II, you must
make sure that adequate ventilation has occurred before you allow workers to enter the
areas specified in column B. If column C indicates that ventilation restrictions apply.
make sure that one of the following ventilation criteria is met:
    «  The  concentration of the pesticide in the air is measured to be less than or equal
       to any inhalation exposure level required on the labeling.
    »  If no inhalation exposure level is listed on the labeling, keep workers out until
       after:
       -  10 air exchanges, or
       -  2 hours of ventilation using fans or other mechanical ventilating systems, or
       -  4 hours of ventilation using vents, windows or other passive ventilation, or
       -   11 hours with no ventilation followed by 1 hour of mechanical ventilation, or
       -  11 hours with no ventilation followed by 2 hours of passive ventilation, or
       -  24 hours with no ventilation.
2.  After ventilation criteria are met and until the restricted entry interval expires:
    «  do not allow workers into the treated area (see Column D on Table II),
    «  you may allow workers to enter the areas just outside the treated area that were
       off-limits during the application.
UNIT 4
                                                          WPS - How To Comply Manual as Revised 2005 43

-------

^^
o

c
,0

is
o *
o •&
.
1





o
is
35
o
o






j_
0*

4-1
to O
Z °O
•f c.
COLUJ
Workers ai




 °-
_J 10
O c
U 0>
f
^



— in
*•* J>«  c 4J JW
U ui «r<
C TJ gf TJ
l|l|
0 C UJ C
^ w -5 w
sp™ ^& ^ •*•
?! —
t~
O
L.
Persons Are P





ii
.2
"5.
a,
<
w



.s
B
'C
o
a>
4n
C
o
'•g
"C
n
^— )
d>
o
?:
CD
^ r"
C
o
c^
'C
.-§
"
O
'•3
^
c
CD




c'*
^

S
"3.
m
Entire greenhous<






SO
's
e.
<

— '






re met.
0
P
"o
o
gq




Cu>
s
1
1>
K?
OH
1
[>
H
CD
43
'S
c
TO
o
ts
42

adjacent structure



































d
1
T3
CD
-fr"j
g
•i-1
CD
sealedoff from th










-o
Is
£2
+-*
O
+J
T3
O
JO
O
rH
.g .
"fH Q
t3 S
CD
C
O
c3
'C o
.£ s
« 1
O 0
'•3 §P
rS OH
11
CD *•**"
fS a







d

Entire enclosed a






o
^ I-H 1— H
^ O co
S iS o 2
^ C/3 2; PH <
w
< = = = =


cf

,0
^>
£
a.














CJ
J
,— H

5
-s





































CD
^
CO
.s

o

CO
a





































VH*
1
QH
00
2
c3
S
p
|
0
S
o
• T"H
"&I







d
1
H—
'o
00
£


O

"On
8
• S
a
o
1
"&
OH
g CD

>/•) 'S
(N CD
CO OJ
p~* 4—
*"o ^™*
C^ • -"j
OJ 42
& -M

Pesticide-treated
in all directions \\
enclosed area.


o
^~* "p"l
-0 2 0 0
en t^-S g- g
O ,j *™^ 3 J>-,
g f~t r~H • ^°j ^""^
1 "

*•'






d
e
CD
1
4— i
CD
'o
°+3
CO
CX


•
4™»
"a
o
o
_co
C
o
.1
OH
OH






d

cS
Pesticide-treated
in
O
O OT
H T3
S fl
So 3
0 0
G QI
K, 2 ^
pi., Ct! Q rf
OT -fi .s S
^3 ^ ^«
^j o f* D
fl et! ^ '-M
'^ S a- °
h— ' 51) OO K*^
§

,n
44

-------
PARTC

The WPS allows entry into a treated area that remains under a restricted-entry interval
only in a few narrow work situations.  When early entry is permitted under the WPS,
special protections must be given to the early-entry workers. This subsection describes
those work situations and protections.
Early-Entry Work Situations........................................... 47
          Protections for Early-Entry            ...................... 52
Training and              for Early-Entry           ................ 53
                              for Early-Entry           ............... 54
                                   for Early-Entry          ......... 56
                                                      WPS - How To Comply Manual as Revised 2005  45

-------
46

-------
                                           FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
          UNIT 4
      Also Specific Duties Section Below)
Worker employers must not allow their workers to enter treated areas
where they will contact treated surfaces, except in a few very limited work
situations.
Worker employers must provide special protections to any of their workers
who do early-entry tasks involving contact with anything that has been treated
with a pesticide, including soil, water, air, and surfaces of plants.


Early entry involving contact with treated surfaces is permitted in only four work situations:
    «  short-term tasks that last less than 1 hour and do not involve hand labor,
    «  limited-contact tasks that could not have been foreseen, cannot be delayed, and
       do not involve hand labor,
    «  emergency tasks that take place because of an agricultural emergency, and
    «  specific tasks approved by EPA through a formal exception process.
Short-term Tasks With No Hand Labor
Workers may enter treated areas before the restricted-entry interval is over to do
short-term jobs that do not involve hand labor, if provided with the protections and
PPE required for early entry.  Each worker must:
    «  Wait at least 4 hours after the pesticide application is completed before entering
       the treated area, and
    «  Wait at least until any inhalation exposure level listed on the product labeling has
       been reached or any WPS ventilation criteria have been met, and
    «  Spend no more than 1 hour in a 24-hour period on short-term early-entry tasks.


    Any            activity          by hand, or with     tools,    might
    a  worker to                      with         (such as                  or
    soil)     may contain         residues.
    Examples of hand labor tasks include: harvesting,            thinning,
    weeding, topping, planting, girdling, caning,       removal, pruning,
    disbudding, roguing, and packing produce into containers in the field.
Employers should make
every effort to schedule
pesticide applications
and worker tasks in a
way that will avoid the
necessity of early entry
of workers into treated
areas.
For additional
protections that must be
provided to workers
who do short-term
early-entry tasks, see
pages 52-56.
    Limited-Contact
               early-entry workers' only       with              —         soil,
    water,        of plants, crops,    irrigation equipment— is minimal     is limited
    to tiieir    lower     hands, and forearms. Hand labor     are not limited-
    contact tasks.
                                                   moving, or
             or watering equipment;          or                           and
                                                        air conditioning, and

       moving
    Only appropriately trained and equipped pesticide handlers may operate, move.
    or repair the      of chemigation               may contain         residues.
    Chemigation          is equipment used to apply pesticides with irrigation
For additional
protections that must be
provided to workers
who do limited-contact
early-entry tasks, see
pages 52-56.
                                                           WPS - How To Comply Manual as Revised 2005  47

-------
Could not have been
foreseen means that
when you made the
pesticide application,
you could not have
anticipated the
circumstances that led
to the need to perform
limited-contact tasks.
For example, you do not
qualify if you knew that
you would need to enter
the treated area to
perform routine
watering during the
restricted-entry interval.
Limited-Contact Tasks That Could Not Have        Foreseen, Cannot Be
Delayed,      Involve No Hand Labor
Early-entry workers may enter treated areas to do limited-contact tasks before the
restricted-entry interval is over, provided all the following conditions are met:
    «   the early-entry tasks do not involve hand labor (see definition in the shaded box
        on p. 47), and
    »   the early-entry tasks will not cause workers to have more than m inimal contact
        with treated surfaces, and
    »   contact with treated surfaces will be 1 imited to the workers' feet, lower legs.
        hands, and forearms, and
    »   the need for the early-entry could not have been foreseen, and
    »   if the early-entry tasks are delayed, the delay would cause significant economic
        loss, and there are no alternative practices that would prevent the loss, and
    «   the pesticide product's Agricultural Use Requirement box does not contain the
        following "double notification" statement: "Notify workers of the application by
        warning them orally and by posting warning  signs at entrances to treated area,"
        and
    «   the pesticide product does not contain a restriction prohibiting any person, other
        than an appropriately trained and equipped handler, from entering during the
        restricted-entry interval.
You must provide each limited-contact early-entry worker with:
    «   either the personal protective equipment required on the pesticide labeling for
        early entry into treated areas or a standard  set of PPE consisting of coveralls,
        chemical-resistant gloves, chemical-resistant footwear, and protective eyewear
        (and make sure the worker wears socks) and
   Note: You may eliminate the protective eyewear from the standard set of PPE in any
   treated area where the pesticide label does not require it for early entry.
    «   all the protections required for early-entry workers (see p. 56). and
    «   oral or written notification, in a language that the workers can understand, that:
        -  the establishment is relying on this exception to allow workers to enter
           treated areas to complete limited-contact  tasks,
        -  no entry is allowed for the first 4 hours after an application, and until
           applicable ventilation criteria have been met. and until any label-specified
           inhalation exposure level has been reached.
        -  the time the worker spends in any treated area where a restricted-entry
           interval is in effect cannot exceed 8 hours in any 24-hour period.
You must make sure that each limited-contact early-entry worker:
    »   waits at least 4 hours after the pesticide application is completed before entering
        the treated area, and
    «   waits at least until any inhalation exposure level listed  on the product labeling
        has  been reached or any WPS ventilation criteria have  been met, and
    «   spends no more than 8 hours in a 24-hour period on limited-contact early-entry
        tasks.
48

-------
                                           FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
Tasks During An Agricultural Emergency
Early-entry workers may enter treated areas before the restricted-entry interval is over to
do tasks that are necessary because of an agricultural emergency, if provided with the
protections and PPE required for early entry. Each worker must:
    «   do only those tasks relating to mitigating the emergency, and
    «   wait at least 4 hours after the pesticide application is completed before entering
        the treated area, and
    «   wait at least until any inhalation exposure level listed on the product labeling has
        been reached or any WPS ventilation criteria have been met.
For additional protections that must be provided to early-entry workers, see pp. 52-56.
1.  Declaring a Potential Agricultural Emergency
A state, tribal, or federal agency having jurisdiction must declare that circumstances exist,
have occurred, or are forecast that might cause an agricultural emergency where your
establishment is located.  Such circumstances may include, for example, flooding, hail,
high winds, hurricane, tornado, freeze, or frost.
2.  Agricultural Emergency on Your Establishment
Once such an agency has declared that circumstances might cause (or might already have
caused)  an agricultural emergency in your area, you must decide if an agricultural
emergency actually exists for any treated areas on your establishment that remain under a
restricted-entry interval. All of the following conditions must be met before you may let
workers go into a treated area where a restricted-entry interval is in effect:
    «   You could not have anticipated the circumstances that led to the emergency when
        you made the pesticide application. For example, you do not qualify if weather
        forecasts before the application warned you that the emergency was imminent.
    «   You had no control over the circumstances that led to the emergency. For
        example, you do not qualify if you forgot to heat your greenhouse or over-
        watered with an irrigation system.
    »   Early entry is the only practice that will prevent or reduce a substantial economic
        loss involving the crop in that treated area. For example, you do not qualify if
        you have access to mechanical harvesting equipment that could harvest your
        crop in lieu of hand-harvesting.
    »   If early entry does not occur, the loss of profit will be greater than the loss that
        would be expected on the basis of experience and the variation in crop yields in
        previous years. The contribution of mismanagement cannot be considered in
        determining the loss.

EPA-Approved Exceptions
EPA has established a formal regulator}7 process for considering additional exceptions to
the restrictions on entering treated areas during an REI. If any such exceptions are
approved, EPA will publish them in the Federal Register and intends to inform state and
tribal pesticide agencies, the Cooperative Extension Sendee, affected commodity,
industry, and worker associations, and other interested parties. Check with them or the
EPA office in your region for an updated list of approved exceptions and for information
about the requirements and limitations of those exceptions.
UNIT 4
                                                          WPS - How To Comply Manual as Revised 2005  49

-------
Summary of Early Entry Requirements
WPS Provision
or Requirement
Entry during application
(entry by workers during
application is never
acceptable)
Entry before inhalation
exposure level or
ventilation criteria have
been met
Entry during first
4 hours after application
is complete
Need for early entry
could have been
anticipated
Need for early entry
could not have been
anticipated
Entry is not an
economic necessity
Entry is an economic
necessity-
Hours of entry
permitted per day
Hand labor tasks
permitted?
Pesticide safety training
(worker) provided?
Information at central
location provided?
Emergency assistance
provided?
Notice about
applications provided?
Restrictions during
applications in effect?
Instructions related to
personal protective
equipment provided?
Type of Early Entry
No Contact
(see p. 37)
no entry
no entry


entry permitted
entry permitted

entry permitted
entry permitted

entry permitted
no limit

yes

yes
yes

yes
yes
yes
no

Short-Term
(see p. 47)
no entry
no entry


no entry
entry permitted

entry permitted
entry permitted

entry permitted
1 hour

no

yes
(no 5 -day-
grace period)
yes

yes
yes
yes
yes

Limited Contact
(see p. 48)
no entry
no entry-


no entry
no entry

entry permitted
(if other triggers
are met see p. 48)
no entry

entry permitted
(if other triggers
are met, see p. 48)
8 hours

no

yes
(no 5 -day
grace period)
yes

yes
yes
yes
yes

Agricultural
Emergency
(see p. 49)
no entry
no entry-


no entry
no entry

entry permitted
(if other triggers
are met, see p. 49)
no entry

entry permitted
(if other triggers
are met, see p. 49)
no limit

yes

yes
(no 5 -day-
grace period)
yes

yes
yes
yes
yes

50

-------
FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
UNIT 4
Summary of Early Entry Requirements (Cont.)
WPS Provision
or Requirement
Labeling information
and instructions
provided?
Early entry
decontamination
supplies provided?
Personal protective
equipment provided,
cleaned, and maintained'.
Type of Early Entry
No Contact
(see p. 37)
no

no


no
Short-Term
(see p. 47)
yes

yes


yes
Limited Contact
(see p. 48)
yes

yes


yes
Agricultural
Emergency
(see p. 49)
yes

yes


yes
             WPS - How To Comply Manual as Revised 2005  51

-------
These requirements are
described in detail in
the next several pages.
                         FOR
                              Also Specific Duties Section
                         Below)
                         Worker employers must provide several
                         types of protections, described below, to
                         their early-entry workers who contact
                         anything that has been treated with a
                         pesticide, including soil, water, air, and
                         surfaces of plants.
Protections Required By the Pesticide
Provide any protections required by the pesticide labeling for early-entry tasks.

Required Protections That Are the       As For Other Workers
Provide protections that are required for all agricultural workers:
    «  Information at a central location (p. 19),
    »  Emergency assistance (p. 27),
    «  Restrictions during applications (p. 36), and
    «  Notice about applications (p. 33).
Special Protections For Early-entry Workers
A few WPS requirements for early-entry workers differ from those for other agricultural
workers. Provide special protections to early-entry workers in the following areas:
    »  Training and instructions,
    »  Decontamination supplies, and
    «  Personal protective equipment.
52

-------
                                          FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
UNIT 4
FOR


      Also Specific Duties Section Below)
Worker employers must make sure that each of their early-entry workers is currently
trained as a WPS worker and, in addition, receives specific information and instructions,
described below.


Training
Make sure that each early-entry worker is currently trained as a WPS worker (see
requirements on p. 21) before entering a treated area on the agricultural establishment
during a restricted-entry interval.
   The 5-day grace period for training that applies to other agricultural workers
   does not apply to early-entry workers.

Instructions Related to Personal Protective Equipment (PPE)
Instruct early-entry workers, in a manner they can understand:                             F°r definitions of PPE,
    «  how to put on, use, and take off early-entry PPE correctly,                          seepage
    «  about the importance of washing thoroughly after removing PPE, and
    «  how to prevent, recognize, and give correct first aid for heat illness (too much
       heat stress).  For more information on heat stress, see chart in Appendix B, p 115.
Labeling Information and Instructions
Inform early-entry workers, in a manner they can understand, about the safely                Option: You may allow
information and instructions on the labeling of the pesticide(s) to which the RET applies,       workers who will do
including:                                                                          early-entry tasks to
       human hazard statements and precautions,                                       rea^ ^e labeling
       first aid,                                                                    themselves, if they are
       signs and symptoms of poisoning,                                              able to read and
       PPE required for early entry, and                                                understand it.
       any other precautions or instructions related to safe use or early entry.
                                                         WPS - How To Comply Manual as Revised 2005  53

-------
Decontamination and
emergency eyeflush
water must, at all times
when it is available to
early-entry workers, be
of a quality and
temperature that will
not cause illness or
injury when it contacts
the skin or eyes or if it is
swallowed.
                                                  FOR




      Also Specific Duties Section  Below)
Worker employers must provide their early-entry
workers with decontamination supplies for washing off
pesticides and pesticide residues.


Supplies
Provide early-entry workers with:
1. Water — enough for:
    «  routine washing, and
    «  emergency eyeflushing.
       If the water is stored in a tank, the water must not be used for mixing pesticides,
       unless the tank is equipped with correctly functioning antibacksiphoning or
       check valves or other mechanisms (such as air gaps) that prevent pesticides from
       moving into the tank.
2. Soap and single use towels — enough for the needs of early-entry workers.


                        How Much               Be Provided?
    Obviously, running            the requirement. However, if it is not available,
    use the following guidelines.
       «   Early-Entry Workers: At     1       of water is              for
                early-entry worker      the supplies. If you find     1       per
           early-entry        is           to last for the      work period,
           provide           or         the water as              the work
           period.
                         Location
                         Make sure:
                         1.  The decontamination supplies are not in an area being treated with pesticides.
                         2.  The decontamination supplies are not in an area under a restricted-entry interval,
                         unless that location is necessary for the supplies to be reasonably accessible to early-
                         entry workers.
                         3.  The decontamination supplies are reasonably accessible to and not more than 1/4 mile
                         from early-entry workers.

                            Exception
                            For tasks performed more than 1/4 mile from the nearest point reachable by vehicle
                            (car, truck, or tractor), the decontamination supplies may be at the access point. In
                            mis 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
                            access point.
54

-------
                                         FURTHER REQUIREMENTS FOR EMPLOYERS OF WORKERS
Emergency Eyeflushing
Provide each early-entry worker with at least 1 pint of emergency eyeflush water when
the pesticide labeling requires protective eyewear for early entry. The emergency
eyeflush water must be immediately accessible. For example, it could be carried by the
handler or be on a vehicle the early-entry worker is using. The water that is supplied for
general decontamination may also be used as eyeflush water, if it is immediately-
accessible.

Decontamination at the End of Exposure  Period
At the site where early-entry' workers take off their PPE. provide :
    «  soap,
    «  clean towels, and
    «  enough water to allow early-entry workers to wash thoroughly after removing
       their PPE.
UNIT 4
                                                        WPS - How To Comply Manual as Revised 2005  55

-------
                         FOR
PPEfor early-entry
activities is listed on the
pesticide label in the
"Directionsfor Use "
section under the
heading "Agricultural
Use Requirements."
See PPE definitions,
p. 64.
For an example of what
to tell people who clean
PPE, see pp. 95-96.
      Also Specific Duties Section  Below)
Worker employers must provide their early-entry workers with the early-entry PPE
required by the pesticide labeling, make sure they wear the PPE, and make sure they use
the PPE correctly.


Duties         to Personal Protective Equipment
1.  Provide the appropriate PPE in clean and operating condition to each early-entry worker.
2.   Make sure early-entry workers wear PPE correctly for its intended purpose and use it
according to the manufacturer's instructions.
3.  Inspect all PPE before each day of use for leaks, holes, tears, or worn places. Repair
or discard any damaged equipment.
4.  Provide early-entry workers clean places away from pesticide storage and pesticide
use areas to:
    «  store personal clothing not in use,
    «  put on PPE at the start of any exposure period, and
    «  take off PPE at the end of any exposure period.
5.  Take necessary' steps to prevent heat illness (too much heat stress) while PPE is being
worn.
6.  Do not allow early-entry workers to wear home or take home PPE contaminated with
pesticides.

Cleaning     Maintaining PPE
1.   Keep pesticide-contaminated PPE separate from other clothing or laundry,  and wash
it separately.
2.  If PPE will be reused, clean it before each day of reuse according to the instructions
from the PPE manufacturer, unless the pesticide labeling specifies different requirements.
If there are no such instructions or requirements, wash the PPE thoroughly in detergent
and hot water.
3.  Thoroughly dry the clean PPE before it is stored, or put it in a well-ventilated place to dry.
4.  Store clean PPE separately from personal clothing and away from pesticide-
contaminated areas.

Disposal of PPE
Comply with any applicable federal, state, tribal, and local regulations when you dispose
of PPE that cannot be cleaned correctly.

Instructions for Persons Who Clean  PPE
Inform anyone who cleans or launders PPE:
    «  that PPE may be contaminated with pesticides,
    «  of the potentially harmful effects of pesticides,
    «  how to protect themselves when handling contaminated PPE, and
    «  how to clean PPE correctly.
For more information about laundering pesticide-contaminated clothing, please visit the
Worker Protection Standard topic page on the Ag Center's Web site at: http://
www.epa.gov/agriculture/twor.litml
56

-------
UNITS
FURTHER REQUIREMENTS
FOR EMPLOYERS OF
HANDLERS
Unit 3 described the WPS protections that employers must provide to both worker and
handler employees. This unit describes the additional WPS protections that employers
are required to provide only to their handler employees.


                       and         Handlers....... 59

Specific Instructions for Handlers.................................... 60

Equipment     [[[ 61

Personal Protective Equipment ...................................... 62


-------
58

-------
                                         FURTHER REQUIREMENTS FOR EMPLOYERS OF HANDLERS
UNITS
AND



     Also Specific Duties Section Below)
Handler employers must make sure that:
    «  pesticides do not touch people, other than appropriately trained
       and equipped handlers, during pesticide applications, and
    »  pesticide handlers are monitored, as described below, when
       handling certain types of pesticides.
Pesticide handlers must make sure that pesticides do not touch people.
other than appropriately trained and equipped handlers, during pesticide
applications.


Restrictions During Applications
Both handler employers and pesticide handlers must make sure that each pesticide is
applied so that it does not contact, either directly or through drift, anyone except
appropriately trained and equipped handlers.

Monitoring Handlers
1.  Pesticides with skull and crossbones
At least once even' 2 hours, someone must check on — by sight or by voice
communication — any handler who is handling a pesticide that has a skull and
crossbones symbol on its label. (For monitoring the handling of fumigants in
greenhouses, see immediately below.)
2.  Fumigants handled in greenhouses
Someone must maintain constant visual or voice contact with any handler who is
applying or otherwise handling a fumigant in a greenhouse. This includes handlers who
enter the greenhouse during fumigation to operate ventilation systems, adjust tarps or
other coverings used in the fumigation, or check air concentration levels. The person
monitoring the fumigant handler must:
    «  be trained as a pesticide handler, and
    «  have immediate access to the PPE that the fumigant labeling requires for
       applicators.
    Fumigant
    Any         product that is a vapor or    or forms a vapor or gas on
    application,    whose method of pesticidal action is through the        state.
                                                         WPS - How To Comply Manual as Revised 2005  59

-------
Option: You may allow
handlers to read the
labeling themselves, if
they are able to read
and understand it.
Operators of
agricultural
establishments are
required to make sure
that commercial
handler employers have
this information (p. 26).
FOR


      Also Specific Duties Section
Below)
Handler employers must make sure that, before
handlers do any handling task, the handlers:
    «   are given information from the pesticide
        labeling and have access to the labeling
        itself, and
    «   are instructed in the safe operation of the equipment they will be using.
Commercial (custom) handler employers must make sure that, whenever one of their
handlers will be doing pesticide handling tasks (including tasks as a crop advisor) on an
agricultural establishment, he or she is aware of specific information, described below,
concerning pesticide-treated areas on the agricultural establishment.


Labeling Access and Information
1.  Inform handlers, in a manner they can understand, about all labeling requirements
related to safe use of the pesticide, including at least:
    «   the signal word,
    »   human hazard statements and precautions,
    «   personal protective equipment requirements,
    »   first aid instructions,
    »   environmental precautions, and
    »   any additional precautions about the handling task to be performed.
2.  Provide handlers access to the pesticide labeling information during handling tasks.

Safe  Operation of Equipment
Make sure that handlers know how to safely and correctly use all equipment they are
assigned to use for handling pesticides, including, if applicable, how to avoid drift and
how to use chcmigation equipment safely.

Instructions for Commercial Pesticide Handlers
Commercial (custom) pesticide handler employers must make  sure that their handler
employees are informed about:
1.  Specific location and description of any areas on the agricultural establishment:
    «   that may be treated with a pesticide or be under a restricted-entry interval while
        the commercial handler will be there, and
    «   that the commercial handler may be in (or walk within 1/4 mile of).
2.  Restrictions on entering those areas.
For example, if custom applicators are scheduled to use ground equipment to apply a
pesticide on a farm, they need to be informed of any nearby areas on the farm that they
should stay out of because the area has an REI in effect. Or if commercial crop advisors
are scheduled to scout in an area on a farm that remains under an REI, they need to be
told what personal protective equipment they must wear while  in that area.
60

-------
                                        FURTHER REQUIREMENTS FOR EMPLOYERS OF HANDLERS
UNITS

     Also Specific Duties Section Below)
Handler employers must make sure that equipment used for mixing,
loading, transferring, or applying pesticides (pesticide handling
equipment) is inspected and repaired and that persons repairing,
cleaning, or adjusting such equipment are protected or informed, as
described below.


Equipment Inspection
Inspect pesticide handling equipment before each day of use for leaks, clogging, and
worn or damaged parts. Repair or replace any damaged equipment.

Protections for Persons Maintaining Equipment
Remove pesticide residues from pesticide handling equipment before anyone other than
an appropriately trained and equipped handler is allowed to repair, clean, or adjust it.

   Exception
   If it is not feasible to remove pesticide residues from pesticide handling equipment,
   and the people who will be repairing, cleaning, or adjusting the equipment arc not
   your employees (and, therefore, are not handlers for whom you are responsible under
   the WPS), you must inform them:

    «   that the equipment may be contaminated with pesticides,
    «   of the potentially harmful effects of exposure to pesticides, and
    «   how to correctly handle such equipment.
For an example of what information to give those who clean and maintain equipment for
you. see page 97.
                                                        WPS - How To Comply Manual as Revised 2005  61

-------

In the pesticide
labeling, PPE for
handling activities is
listed in the "Hazards to
Humans " section.
PPE is coveralls,
respirators, protective
eyewear, and chemical-
resistant suits, gloves,
footwear, aprons and
headgear.  See
definitions, p. 64.
A chemical-resistance
chart is provided in
Appendix B, p. 113.
Exceptions to PPE:
Handler employers may
allow handlers to omit
some of the PPE listed
on the pesticide labeling
for a handling activity if
the handlers are using a
closed system or are
working in a cockpit or
in an enclosed cab. See
pages 66-67.
      Also Specific Duties Section Below)
Handler employers must make sure that pesticide handlers:
    «   are provided with the PPE the pesticide labeling requires for the task.
    «   wear the PPE  for the entire handling task, and
    «   use the PPE correctly.
Each pesticide handler is responsible for wearing the required personal protective
equipment during the entire handling task.

Duties         to Personal Protective Equipment
Employers must:
1.  Provide handlers with the appropriate PPE in clean and operating condition.
2.  Make sure the handlers wear the PPE correctly and use it according to the
manufacturer's instructions. If a handler wears a respirator, make sure that it fits the
wearer correctly.
3.  Inspect all PPE before each day of use for leaks, holes, tears, or worn places, and
repair or discard any damaged equipment.
4.  Provide handlers with clean places away from pesticide storage and pesticide use
areas to:
    «   store personal clothing not in use,
    «   put on PPE at  the start of any exposure period,
    «   take off PPE at the end of any exposure period.
5.  Take any necessary steps to prevent heat illness (too much heat stress) while PPE is
being worn.
6.  Do not allow any handler to wear home or take home PPE contaminated with
pesticides.
Cleaning    Maintaining PPE
Employers must do the following:
1.  Keep pesticide-contaminated PPE away from other clothing or laundry, and wash it
separately.
2.  If PPE will be reused, clean it before each day of reuse according to the instructions
from the PPE manufacturer unless the pesticide labeling specifies other requirements. If
there are no such instructions or requirements, wash PPE thoroughly in detergent and hot
water.
3.  Thoroughly dry the  clean PPE before it is stored, or put it in a well-ventilated place to dry.
4.  Store clean PPE separately from personal clothing and away from pesticide-
contaminated areas.
62

-------
                                          FURTHER REQUIREMENTS FOR EMPLOYERS OF HANDLERS
Replacing Respirator Filters, Cartridges, or Canisters
Employers must:
1.  Replace dust/mist respirator filters:
    «  when breathing resistance becomes excessive,
    «  if the filter is damaged or torn,
    «  whenever the respirator manufacturer or pesticide labeling says to replace them
       (if the instructions differ, change the filter at the shorter interval),
    «  at the end of each day's work period, if no other instructions or indications of
       sendee life are available.
2.  Replace gas- and vapor-removing respirator cartridges or canisters:
    «  at the first indication of odor, taste, or irritation,
    «  when the respirator manufacturer or pesticide labeling says to replace them (if
       instructions differ, change the cartridge or canisters at the shorter interval),
    «  at the end of each day's work period, if no other instruction or indications of
       sendee life are available.
Disposal  of PPE
Employers must:
1.  Discard coveralls or other absorbent materials that have been drenched or heavily
contaminated with an undiluted pesticide that has the signal word '"DANGER" or
'"WARNING" on the labeling. They must not be reused.
2.  Comply with any applicable Federal, State, Tribal, and local regulations when
disposing of PPE that cannot be cleaned correctly.

Instructions for Persons Who Clean PPE
Employers must inform people who clean or launder PPE:
    «  that the PPE may be contaminated with pesticides,
    «  of the potentially harmful effects of exposure to pesticides,
    «  how to protect themselves when handling contaminated PPE, and
    «  how to clean PPE correctly.
For more information about laundering pesticide-contaminated clothing, please visit the
Worker Protection Standard topic page on the Ag Center's Web site at:
http://www.epa.gov/agriculture/twor.htnil
For an example of what to tell people who clean PPE, see page 95.
UNITS
                                                          WPS - How To Comply Manual as Revised 2005  63

-------
                                                            (PPE)


                             Apparel and       worn to protect the body from       with          or
                                              including: coveralls,                       gloves, footwear,
                                    and         protective eyewear, and           While the following
                             attire is not defined as PPE, the labeling may require pesticide handlers or early-
                             entty workers to wear it for some tasks:  long- and short-sleeved shirts, long and
                             short pants, shoes and socks, other items of regular work clothing. If such non-
                             PPE attire is required, the employer must make     that it is worn.
                             Chemical-resistant:
                             Allows no measurable amount of the pesticide being     to move through the
                             material during use.

                             Waterproof:
                             Allows no measurable movement of water (or water-based solutions) through the
                             material during use,


                                                                     boots; or
                             coverings worn over      or boots. Substitution: Leather     may be worn in
                                  terrain,                   footwear with         durability and
                                       for wear in            is not


                             Goggles, a    shield, or              with front, brow,    temple protection,
                             Substitution: A full-face respirator may be worn       of protective eyewear,

                                                 suit:
                             A loose-fitting, one- or two-piece.                            covers, at a
                             minimum, the entire body except head, hands,    feet.
                             Coverall:
                             A loose-fitting one- or two-piece            covers, at a minimum, the
                             body      head.       and feet. Coveralls are      of fabric such as      or a
                             cotton-polyester blend, and are not                 The                may
                             specify that the coveralls be worn over a layer of clothing. Substitution: A
                                              suit    be worn       of coveralls and any        inner
                                  of clothing.


                             An          is made of chemical-resistant material and that covers the front of the
                             body from mid-chest to the knees. Substitution: If a chemical-resistant suit is
                             worn, no apron is required.

                             Respirator:
                             A           protects the respirator)7 system. It must be the type listed on the
                             pesticide label (or       is more protective) and must be appropriate for the
                             pesticide product      used    for the  activity being performed. Substitutions: A
                             respirator with a canister approved for          or with an organic-vapor
                                     equipped with a pesticide prefilter    be worn        of a dust/mist
                             filtering
64

-------
                                      FURTHER REQUIREMENTS FOR EMPLOYERS OF HANDLERS
                               (PPE)


A                      or a                 hat with a wide brim.
Gloves:
Hand-coverings that are the type listed on the pesticide label.
 •  Gloves      of leather, cotton, or                            not be
    worn for        or early-entry activities                    are      on
    the                 as           for     use,
 «                          with
    not be worn            or early-entry activities, A
    is provided in         B, p, 113.
 •  Substitution: Leather      may be worn over chemical-resistant liners, if
                     gloves with.          durability and           are not
    obtainable. However,      leather gloves have been worn for protection from
    pesticide exposure, they may only be worn with chemical-resistant liners
    may not be worn for any other use,

         glove      are        glove-like      coverings,      of lightweight
        with or without

 •  Work gloves made from lightweight cotton or poly-type material are
    considered to be glove liners, if worn         chemical-resistant gloves.
 •  Unless the pesticide product labeling specifically prohibits their use, separable
    glove liners may be worn                         gloves, provided tfa&
    liners do not extend outside the chemical-resistant gloves that are worn over
    them,
 «  Once     for        or early-entry activities,         glove
    be                            a     of 10      of use or within 24
    of first    whichever      first. Hie           be
                 if they               contact with          Pesticide-
                           be        of in           with any
    or
UNITS
                                                       WPS - How To Comply Manual as Revised 2005  65

-------
These exceptions to
PPE are allowed unless
expressly prohibited by
product labeling.
Even when reduced
PPE is permitted to be
worn during a task,
handlers must be
provided all PPE
required by the
pesticide labeling for
that task and have it
immediately available
for use in an emergency.
                      TO PPE




      Also Specific Duties Section
Below)
Handler employers may allow handlers to omit
some of the PPE listed on the pesticide labeling for
a handling task if the handlers are:
    «  using a closed system, or
    »   in an enclosed cab, or
    «  in a cockpit.


Closed Systems
Closed systems are systems designed by the manufacturer to enclose the pesticide to
prevent it from contacting handlers or other people while it is being handled. Such
systems must function properly and be used and maintained in accordance with the
manufacturer's written operating instructions.
1.  When using a closed system to mix or load pesticides with the signal word
"DANGER" or 'WARNING," handlers need not wear all the PPE listed on the pesticide
labeling, but must wear at least:
    »  long-sleeved shirt and long pants,
    «  shoes and socks,
    »  a chemical-resistant apron, and
    «  protective gloves specified on the pesticide labeling for mixing, loading, and
       other handling tasks.
2.  When using a closed system to mix or load pesticides with the signal w7ord
"CAUTION," handlers need not wear all the PPE listed on the pesticide labeling, but
must wear at least:
    «  long-sleeved shirt and long pants, and
    «  shoes and socks.
3.  When using a closed system to do handling tasks other than mixing and loading with
any pesticide, handlers need not wear all of the PPE listed on the pesticide labeling, but
must wear at least:
    «  long-sleeved shirt and long pants, and
    «  shoes and socks.
   Such closed systems might include closed application systems designed to
   incorporate pesticides into soil, hut only if the system does not allow any pesticide
   contact with the air throughout the entire application process.

4.  When using a closed system that operates under pressure, handlers may wear the
reduced PPE specified above, but must add protective eyewear.

Enclosed
Enclosed cabs must have a nonporous barrier that totally surrounds the occupants and
prevents contact with pesticides outside of the cab.
Enclosed cabs that provide respiratory protection must have a properly functioning
ventilation system that is used and maintained according to the manufacturer's written
operating instructions. The cab must be declared in writing by the manufacturer or by a
66

-------
                                           FURTHER REQUIREMENTS FOR EMPLOYERS OF HANDLERS
UNITS
governmental agency to provide at least as much respiratory protection as the type of
respirator listed on the pesticide labeling.

   Examples:
   Some enclosed-cab systems provide respiratory protection equivalent to a dust/mist
   filtering respirator and could, therefore, be used as a substitute when that type of
   respirator is specified on the product labeling. Other enclosed-cab systems are
   equipped to remove organic vapors as well as dusts and mists and could be used as a
   substitute when either the dust/mist filtering respirator or an organic-vapor-removing
   respirator is specified on the product labeling.
1.  Enclosed cabs that do not provide respiratory protection — In an enclosed cab
that does not provide respiratory protection, handlers need not wear all the  PPE listed on
the pesticide labeling, but must wear at least:
    «   long-sleeved shirt and long pants,
    «   shoes and socks, and
    «   any respirator required for the handling task.
2.  Enclosed cabs that provide respiratory protection — In an enclosed cab that
provides respirator}' protection equal to the labeling-required  respirator, handlers need
not wear all the PPE listed on the pesticide labeling, but must wear at least:
    «   long-sleeved shirt and long pants, and
    «   shoes and socks.
3.  In any enclosed cab where reduced PPE Is worn — Handlers must:
    «   keep immediately available all PPE listed on the labeling for the type of task
        being performed,
    «   store the PPE in a chemical resistant container (such as a plastic bag),
    «   wear the PPE if it is necessary to leave the cab and contact pesticide-treated
        surfaces in the treated area, and
    «   take off PPE mat was worn in the treated area before  reentering the cab in order
        to prevent contamination of the inside of the cab.
   Note: If the PPE that was worn in the treated area needs to be stored inside the
   enclosed cab, it must be stored in such a way that will prevent contaminating the
   inside of the cab. One way to achieve this would be to store the contaminated PPE in
   a chemical-resistant container, such as a plastic bag.

Cockpits
1.  Gloves when entering or leaving an aircraft — Handlers have the option of
whether to wear chemical-resistant gloves when entering or leaving an aircraft used to
apply pesticides, unless the pesticide product labeling requires chemical-resistant gloves
to be worn for these activities. If gloves are worn for such a use, then if they are brought
inside the cockpit, handlers must store the used gloves in a enclosed container, such as a
plastic bag, to prevent contamination of the inside of the cockpit.
2.  Open cockpits — In an open cockpit, handlers must wear any gloves, respirator, and body
protection listed on the pesticide labeling for application tasks. However, they may wear:
    «   shoes and socks instead of chemical-resistant footwear,
    »   a helmet instead of a chemical-resistant hat or hood, and
    «   a visor instead of protective eyewear.
3.  Enclosed cockpits — In an enclosed cockpit, handlers need not wear all the PPE
listed on the pesticide labeling, but must wear at least:
    «   long-sleeved shirt and long pants, and
    «   shoes and socks.

                                                            WPS - How To Comply Manual as Revised 2005 67

-------
68

-------
UNIT 6
OWNER EXEMPTIONS AND
CROP ADVISORS
The WPS exempts owners of agricultural establishments from many WPS requirements,
and it contains specific protections for crop advisors. This unit describes these owner
exemptions and crop advisor provisions.


Agricultural Owner         ...................................... 71

Protections for Crop Advisors......................................... 74

-------
70

-------
                                                      OWNER EXEMPTIONS AND CROP ADVISORS
          UNIT 6
EXEMPTIONS

Owners of agricultural establishments and members of their immediate
family are exempt from many WPS requirements. However. EPA
encourages owners to provide themselves and their families with all
WPS protections.
 Owner: Any       who has a present possessory       (fee, leasehold,
 rental, or other) in an agricultural establishment covered by the WPS. A person
 who has both      such agricultural establishment to another person and
 granted that      person the right    full authority to           govern the
 use of such                       is not an owner under the WPS.

     Examples:
    You do not qualify for the           owner           if:
     1,  you have rented out or      out your farm, forest nursery, or
    to  another          you have no part in the             or profit/loss from
    it.  The person to whom you have rented or       your property is the
     "owner" for the purposes of the WPS.
    2.  you are hired to       a farm, forest, nursery-, or           but the
    person who owns the property makes some of the decisions as to the
    management of it or      in the profit/loss from it.
Immediate family
includes only spouse,
children, stepchildren,
foster children, parents,
stepparents, foster
parents, brothers, and
sisters.
The WPS does not allow any exemptions for owners of commercial pesticide handling
establishments or for persons who operate or manage, but do not own. an agricultural
establishment.
Agricultural owners must provide all protections required by the WPS to persons who are
not members of their immediate family. These persons include:
    «  workers or handlers who are their employees, and
    «  persons who clean PPE or repair, clean, or maintain contaminated pesticide
       handling equipment.
                                                        WPS - How To Comply Manual as Revised 2005  71

-------
                                           AGRICULTURAL           MUST           WITH
                         The following requirements and provisions do apply to owners of agricultural
                         establishments and to members of their immediate family:
                         1.  Employer information exchange, (p. 26)
                         2.  Restrictions during handling tasks:
                             «  Use the personal protective equipment and other work attire listed on the
                                pesticide labeling for the task being performed, (pp. 64-65)
                             «  Exceptions to personal protective equipment,  (pp. 66-67)
                         3.  Restrictions during applications:
                             »  Make sure that each pesticide is applied so that it does not contact, either directly
                                or through drift, anyone  (including you and members of your immediate family),
                                except appropriately trained and equipped handlers,  (p. 59)
                             »  Make sure that you, your family members, and all other persons, except correctly
                                trained and equipped handlers, are kept out of areas being treated with pesticides.
                                (pp. 36-37)
                             »  Make sure that you. your family members, and all other persons, except correctly-
                                trained and equipped handlers, are kept out of areas immediately around the area
                                being treated during certain pesticide applications in nurseries and greenhouses.
                                (p. 39-44)
                         4.  Restrictions during restricted-entry intervals: (p. 36-37)
                             «  When two (or more) pesticides are applied at the same time, and have different
                                REIs, make sure that you and your family members follow the longer restricted-
                                entry interval,  (p. 36)
                             «  No-contact early entry, (p. 37)
                             «  Short-term, limited-contact, agricultural emergency, or specially excepted early
                                entry (see explanation below),  (p. 47)
                            If agricultural        or         of their           family     a
                            and                             a              interval, they must:
                                •   Wait at least 4 hours after the pesticide application is completed before
                                           the treated     and
                                •   Wait at least until any                  level listed on the product
                                    labeling has             or    WPS ventilation
                                    met, and
                                •   Obey the time limitation of 1 hour in 24 hours, if short-term (non-hand-
                                    labor) early-entry      are being performed or 8 hours in 24 hours, if
                                    limited-contact early-entry     are      performed,
                                «   Wear the                                     on the
                                           for early-entry      and
                                «   Follow any                        in any                under
                                    which the      entry
                                «   Follow any                        in the                 for early
                                    entry.
72

-------
                                                      OWNER EXEMPTIONS AND CROP ADVISORS
UNIT 6
               FOR AGRICULTURAL
Agricultural owners arc not required to provide themselves or members of their
immediate family with the following protections of the WPS:
1.  Information at a central location (p. 19)
2.  Pesticide safety training (pp. 21-23)
3.  Decontamination supplies  (pp. 24-25)
4.  Emergency assistance  (p. 27)
5.  Notice about applications (pp. 33-35)
6.  Monitoring handlers (p. 59)
7.  Specific handling instructions (p. 60)
8.  Equipment safety (p. 61)
9.  All the specific duties related to the care of PPE and management of its use.
(p. 62-63)
10. The following duties related to early entry: (p. 53-56)
    «  Training and instructions,
    «  Decontamination supplies,
    «  Specific duties related to the care of PPE and management of its use.
                                                         WPS - How To Comply Manual as Revised 2005  73

-------
                                                  FOR


                         The WPS requires employers to provide certain protections to their employees who are
                         working as crop advisors.


                               Crop
                               Any       who is                     or                 distribution.
                               or the       condition, or             of agricultural        The
                               not include any       who is                               as
                                       cultivating, or harvesting.          of crop        are
                                                 and                          monitors.
                                             or
                               Any person who is working as a crop advisor    is employed (including
                               self-employed) by anyone other than, the agricultural establishment on which
                               the work is being done. Such a person may be either certified/licensed or
                               uncertified/unlicensed.

                               Any       who is working as a crop advisor    is employed directly by the
                               agricultural establishment on which the work is being done. Such a person
                               may be either certified/licensed or uncertified/unlicensed.
                               Certified or          crop
                               Any       who is        or licensed as a      advisor by
                                             in writing, as           by EPA or a    or tribal
                                                              The            or
                                                                that        at     all the information
                                        for WPS                            p. 21).


                               A person is considered to be under a certified/licensed crop advisor's direct
                               supervision (and therefore eligible for crop advisor           only      the
                                    advisor has informed the             all of the following:

                                       the appropriate personal protective equipment,
                                       the appropriate decontamination supplies,
                                       how to conduct the crop advising      safely,
                                       the pesticide products    active ingredients) applied,
                                       the method of application,
                                       the time of application,
                                       the restricted-entry interval,
                                       which crop advisor tasks to undertake, and
                                       how to contact the certified/licensed crop advisor.
                               Direct supervision     not require that the crop advisor be physically present
                               at all times, but the crop advisor must be readily accessible to the employees
                               at all times.
74

-------
                                                        OWNER EXEMPTIONS AND CROP ADVISORS
UNIT 6
         FOR

   Exemption
   Certified/licensed crop advisors and persons performing crop advising tasks under
   their direct supervision are exempt from certain WPS duties and requirements when
   specific conditions are met.  See Certified/Licensed Crop Advisor Exemption on p. 77.

Required Protections During or Soon After a           Application
1. Same Protections as Pesticide Handlers
Employers must provide their crop advisors with the WPS protections required for
pesticide handlers //the crop advisor enters an area on an agricultural establishment:
    «  while a pesticide is being applied.
    «  before any inhalation exposure level listed in the pesticide labeling has been
       reached or before one of the ventilation criteria in the WPS or in the pesticide
       labeling has been reached,
    «  while a restricted-entry interval is in effect
2. No Time Limits
Crop advisors may enter an area during a pesticide application or during a restricted-entry
interval as long as they arc trained as pesticide handlers, arc given other pesticide-handler
protections (listed below), and are wearing the appropriate personal protective
equipment. The restrictions on entry, such as waiting for 4 hours after application is
completed or limiting the time spent in the entry-restricted area to 1 hour or any oilier
period, do not apply to crop advisors.
3. Required Protections
    «  Information at a central location (p. 19)
       Exception
       Employers of independent (commercial) crop advisors do not have to provide
       their crop advisors with information at a central location.
    «  Pesticide safety training for handlers (p. 21)
    «  Decontamination supplies (p. 24)
    «  Emergency assistance (p. 27)
    «  Monitoring handlers  (p. 59)
       Note: After the application is complete, crop advisors entering a treated area
       during a restricted-entry interval need not be monitored.
    «  Special instructions for handlers (p. 60)
    «  Duties related to PPE (p. 62)
4. Personal Protective Equipment During REIs
Early-Entry PPE for Early  Entry "With Contact": Crop advisors who enter a treated
area during a restricted-entry  interval, and whose crop advisor activities involve contact
with anything that has been treated with a pesticide, including soil, water, and surfaces of
plants, may wear the PPE listed on the pesticide labeling for early-entry tasks (instead
of the PPE listed for handling tasks), if:
    «  Application has been completed for at least 4 hours, and
    »  Any inhalation exposure level listed in the labeling has been reached or any
       ventilation requirements established by the WPS or pesticide labeling have been
       met.
                                                           WPS - How To Comply Manual as Revised 2005  75

-------
Crop advisors may
enter treated areas
during an application
or during a restricted-
entry interval if they
receive handler-type
protections.
Seep. 74for definition
of certified/licensed
crop advisor.
No PPE for "No Contact" Early Entry: Crop advisors who enter a treated area during
a restricted-entry interval and whose crop advisor activities do not involve contact with
anything that has been treated with the pesticide to which the restricted-entry interval
applies arc not required to wear personal protective equipment.

Required Protections After the REI
1. Independent (Commercial) Crop Advisors
When independent (commercial) crop advisors enter any area on an agricultural
establishment where no application is underway and no restricted-entry interval is in
effect, their employers need not provide them with any WPS protections.
2. Noncommercial Crop Advisors
When noncommercial crop advisors (employees of the farm, forest, nursery, or
greenhouse) enter any area on the agricultural establishment where no application is
underway and no restricted-entry interval is in effect, their employer must provide them
with the WPS protections required for agricultural  workers. For specific information
about each of these protections, see the pages referenced below. The protections include:
    »   Information at a central location (p. 19)
        -  certain information (pesticide safety poster, application information, location
           of emergency facility) must be displayed at a central location whenever (1)
           the crop advisor is on the agricultural establishment, and (2) a pesticide has
           recently been applied.
    «   Pesticide safety training for workers  (p. 21)
        -  crop advisors must be trained about general pesticide safety before they
           accumulate 5 days of entry into treated areas on the establishment where.
           within the past 30 days, a pesticide has been applied or a restricted-entry
           interval has been in effect.
    «   Decontamination supplies (p. 24)
        -  decontamination supplies for washing off pesticide residues must be provided
           to any crop advisor who is working an area where a pesticide has recently
           been applied and who  is doing tasks that involve contact with anything that
           has been treated with the pesticide, including soil, water, or surfaces of
           plants.
    »   Emergency assistance (p. 27)
        -  Emergency assistance  must be provided to the  crop advisor if there is reason
           to believe that the employee has been  poisoned or injured by a pesticide used
           on the agricultural establishment — for example, through application, spills,
           splashes, drift, or contact with pesticide  residues.
    «   Notice about applications (p. 33)
        -  with a few exceptions, the crop advisor must be notified about areas on the
           agricultural establishment where pesticide applications are taking place  or
           where restricted-entry  intervals are in effect.
    «   Restrictions during and after applications (p. 36)
        -  the crop advisor must be protected during pesticide applications and during
           restricted-entry intervals on the agricultural establishment.
76

-------
                                                        OWNER EXEMPTIONS AND CROP ADVISORS
         FOR

Certified/licensed crop advisors and persons performing crop advising tasks under their
direct supervision arc exempt from certain WPS duties and requirements, provided the
certified/licensed crop advisors:
    «   do not enter, or allow persons under their supervision to enter, treated areas until
        after application is completed, and
    »   perform, and make sure that persons under their supervision perform, crop
        advisor tasks only, including assessing pest numbers or damage, checking
        pesticide distribution, or determining the status, condition, or requirements of
        agricultural plants, and
    «   specifically determine the appropriate personal protective equipment, and the
        appropriate decontamination supplies and how to conduct the crop advising tasks
        safely, and
    »   inform each person under their direct supervision - in a language that the person
        can understand — about the appropriate personal protective equipment, the
        appropriate decontamination supplies, and how to conduct the crop advising
        tasks safely, and
    «   using an established practice of communication, inform each person under their
        direct supervision about all the following:
        - the pesticide product(s) and active ingredient(s) applied,
        - the method of application,
        - the time of application,
        - the restricted entry interval.
        - which crop advisor tasks to undertake,
        - how to contact the certified/licensed crop advisor.
Requirements for Entry During an Application
The certified/licensed crop advisor exemption does not apply when crop advisors or
persons under their direct supervision enter an area before application is completed.

Required Protections  for Entry During an REI
When crop advisors enter  into treated areas while a restricted-entry interval is in effect,
they are defined in the WPS as pesticide handlers. When all the conditions of the
certified/licensed crop advisor exemption are met, certified/licensed crop advisors and
persons under their direct supervision are exempt from the following WPS handler
requirements:
    «   Decontamination  supplies (p. 24)
    »   Emergency assistance (p. 27)
    «   Special instructions for handlers (p. 60)
        Note:  Despite this exemption, the WPS does require that any agricultural
        establishment owner or operator who hires a commercial crop advisor must
        inform the employer of that advisor about the specific location and description of
        any areas on the agricultural establishment (1) that may be treated with a
        pesticide or be under a restricted-entry interval while the commercial crop
        advisor will be there, and (2) that the commercial crop advisor may be in (or
        walk within 1/4 mile of). The operator must also provide information about
        restrictions on entering those areas.
    «   Duties related to PPE  (p. 62)
UNIT 6
                                                          WPS - How To Comply Manual as Revised 2005  77

-------
For specific information
about each of these
protections, see the
pages referenced.
However, while a restricted-entry interval is in effect, employers must provide the
following WPS protections to certified/licensed crop advisors and persons under
such crop advisors' direct supervision:
    »   Information at a central location (p. 19)
        -  certain information (pesticide safety poster, application information, location
           of emergency facility) must be displayed at a central location whenever
           (1) the crop advisor is on the agricultural establishment, and (2) a pesticide
           has recently been applied.
        Exception
        The requirement above applies only to noncommercial certified/licensed crop
        advisors (employees of the establishment where they are working). Employers
        who hire independent (commercial) crop advisors do not have to provide those
        crop advisors with information at a central location.
    «   Pesticide handler training  (p. 21)
        Exception
        As a requirement of any approved certification or licensing program, certified/
        licensed crop advisors have received pesticide safety' training equivalent to WPS
        pesticide handler training. Employers do not need to retrain either commercial or
        noncommercial certified/licensed crop advisors. However. WPS pesticide
        handler training IS required for any unlicensed/uncertified crop advisors working
        under the direct supervision of certified/licensed crop advisors, and they must be
        retrained at least once every 5 years.

            PROTECTIONS AFTER THE REI
1. Independent (Commercial) Crop Advisors
When certified/licensed independent (commercial) crop advisors enter any area on an
agricultural establishment where no application is underway and no restricted-entry
interval is in effect, their employers need not provide them with any WPS protections.
2. Noncommercial Crop Advisors
When noncommercial crop advisors (employees of the farm, forest, nursery, or
greenhouse) enter any area on the agricultural establishment where no application is
underway and no restricted-entry interval is in effect, they are defined in the WPS as
agricultural workers. When all the conditions of the certified/licensed crop advisor
exemption are met. certified/licensed crop advisors or persons under thei r di rect
supervision are exempt  from the  following WPS agricultural worker requirements:
    «   Decontamination supplies   (p. 24)
    »   Emergency assistance (p. 27)
However, agricultural employers must provide the following WPS protections  to their
employees who arc certified/licensed crop advisors, or who arc persons under such crop
advisors' direct supervision, when the  employees enter treated areas on the agricultural
establishment where no application is underway and when no restricted-entry interval is
in effect:
    •   Information at a central location  (p. 19)
        -  certain information (pesticide safety poster, application information, location
           of emergency facility) must be displayed at a central location whenever
           (1) the crop advisor is on the agricultural establishment, and (2) a pesticide
           has recently been applied.
78

-------
                                                 OWNER EXEMPTIONS AND CROP ADVISORS
UNIT 6
Pesticide safety training and safety information for workers  (p. 21)
Exception
As a requirement of any approved certification or licensing program, certified/
licensed crop advisors have received pesticide safety training equivalent to WPS
pesticide handler training. They need not be retrained. However, uncertified/
unlicensed crop advisors working under the direct supervision of a certified/
licensed crop advisor must receive pesticide safety training and safety
information for workers and must be retrained within 5 years.
Notice about applications,  (p. 33)
-  with a few exceptions, the crop advisor must be notified about areas on the
   agricultural establishment where pesticide applications are taking place or
   where restricted-entry intervals are in effect.
Restrictions during and after applications  (p. 36)
-  the crop advisor must be protected during pesticide applications and during
   restricted-entry intervals on the agricultural establishment.
                                                    WPS - How To Comply Manual as Revised 2005  79

-------
                                           c.
                                           o
                                           y
                                           •a
                                           HH1
                                           HI
                                           O
                                           •a
                                           .-
                                           c.
                                           2
                                           y
                                           e

                                           •a
                                           cs
                                           a.
80
[3
V
g
S
O
y,

B
•a
a
B.
a;
•a
B
HH


S ^
1 s
o £
— J-
CH w
II
C, S
"3 ^
bd
S M
a; •<;
S S*>
S -°
o
g

o
z


/—>
•S
1
y,
^
B
•a
§•
•a
a
HH

f

HH ^
"S S
II
& 22
1 1
3 w
'3 BE
C2 •:*,
g *
0
a
o
Z
|'H
 ^
>J ^



^^
M ^
^^


M 1
^ I


>-j
Pesticide Safel
Training &
Information
i


o




u
3

^ 3^
OH
03
i




o



u
2
~n rt
^ 3n
OH
03


O


^fl ' — 1
W "^
^ c3
^s

^
I]
^^
w f

^


^_^
M J2
W "g
^^


c/^ i — i
W "^
^ ^
*" x
B
o
Deconlaminali
Supplies
i


o




u
3

^ 3^
OH
03
i




o



u
2
"n rt
3n
OH



O


S-i
L-Ll ^
C] C
K^ Cj
^s

^
w ^
K^ Cj

w f

^


^_^
11
^-^ '


S-i
yl ' — 1
W "^
^ I



Emergency
Assislance
i


o




u
3

^ 3^
OH
03
i




o



u
2
"n rt
3n
OH



O


o
^



Vl
w

o





i



VI
w




Moniloring
Handlers
i


o




u
3

^ 3^
OH
03
i




o



u
2
"n rt
3n
OH
03


O


VI
W
^



w

o





!/J
w



w



HI
Special
Inslruclions fo
Handlers
i


o




u
3

^ 3^
OH
03
i




o



u
2
"n rt
^ 3n
OH
03


O


VI
W
r^



Vl
W

O





Vl
w



VI
w



rvi
Duties
Related lo PPI
i


o




u
3

^ 3^
OH
03
Vl
w




o



u
2
~n rt
3n
OH
03


O


o
^



i

VI
w





i



o
^



NoliceAboul
Applications
i


o




u
3

£ ^
OH
03
W




O



u
2
"n rt
3n
OH
03


O


o
^



i

w





i



o
^

^
-S
Reslriclions
During and Af
Applications

-------
APPENDIX A
CRITERIA FOR WPS
AAATERIALS
The WPS contains specific criteria for the design of the sign required for treated-area
posting and for the content of the safety poster, worker training materials, and handler
training materials. This appendix lists those criteria.
EPA has developed a safety poster, warning sign, and worker and handler training
programs to meet the requirements of the WPS. You may use these materials, or you may
use alternative materials that meet the criteria as listed in this appendix.


Criteria for Pesticide Safety Poster  .................................. 83

Requirements for Warning      ..................................... 85

Criteria for Worker Training........................................... 87

Criteria for Handler Training.......................................... 89

-------
82

-------
                                                            CRITERIA FOR WPS MATERIALS
                 FOR

Each WPS safety poster must convey to workers and handlers:
1.  That there are federal rales to protect them, including a requirement for safety
training.
2.  How to help keep pesticides from getting on or into their bodies. The poster must
include the following instructions:
    «  Avoid getting 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, and put on clean
       clothes after work.
    «  Wash work clothes separately from other clothes before wearing them again.
    «  Wash immediately in the nearest clean water if pesticides are spilled 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.
APPENDIX A
                                                          WPS - How To Comply Manual as Revised 2005  83

-------
84

-------
                                                          CRITERIA FOR WPS MATERIALS
                           FOR

1.  Required Words:
    «  The words "DANGER — PELIGRO" and "PESTICIDES —- PESTICIDAS"
       must be located at the top of the sign and "KEEP OUT—NO ENTRE" at the
       bottom.
       Exception
       As ail option, you may use warning signs that replace the Spanish words with the
       same words in another language (other than English) mat is read by the largest
       number of your workers who do not read English. The replacement sign must
       meet all of the other requirements for the WPS warning sign.

    «  The words must be clearly legible.
2.  Required Design:
    «  A circle containing an upraised hand on the left and a stern face on the right must
       be near the center of the sign.
    «  The background outside the circle must contrast with the inside of the circle.
    «  The hand and a large portion of the face must contrast with the inside of the
       circle.
    «  The remainder of the inside of the circle must be red.
    «  The length of the hand must be at least twice the height of the smallest letters.
    «  The length of the face must be only slightly smaller than the hand.
3.  Additional Information:
You may put additional information on the warning sign, such as the name of the
pesticide and the date of application, if it does not detract from the appearance of the sign
or change the meaning of the required information.
4.  Size:
The signs must be at least 14 inches by 16 inches, and the letters must be at least 1 inch
high.

   Exception
   On farms and in forests, you may use smaller signs if the treated area is too small to
   accommodate 14- by 16-inch signs. For example, when a single plant needs to be
   posted, a smaller sign would be appropriate. In nurseries and greenhouses, you may
   use a sign smaller than the standard size. Whenever a small sign is used, there are
   specific posting distances depending on the size of the lettering and symbol on the
   sign (see table on the next page).
APPENDIX A
                                                         WPS - How To Comply Manual as Revised 2005 85

-------
Signs with the words
"DANGER" and
"PELIGRO "in letters
less than 7/16 inch in
height or with any
words in letters less than
1/4 inch in height or
with the circle graphic
containing an upraised
hand and a stern face
less than 1 ¥2 inches in
diameter do not meet
WPS sign requirements.

7" x 8"
(approx.)
41/2"x5"
(approx.)
Required Height in Inches
Circle Graphic
3"
1 1/2"
Lettering for
Words
a
"PELIGRO"
7/8"
7/16"
Lettering for
Words
1/2"
1/4"
Maximum
Distance
Between
Signs*
50 feet
25 feet
*  This distance requirement is for places where multiple signs are used to post a single
treated area, such as a nursery or a greenhouse section. It docs not apply where individual
signs are used for separate small treatment areas (such as single potted plants in a
greenhouse).
86

-------
                                                            CRITERIA FOR WPS MATERIALS
                FOR

1.  WPS training for workers must include at least the following information:
    »  Where and in what form pesticides may be encountered during work activities.
    «  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 types of pesticide poisoning.
    »  Emergency first aid for pesticide injuries or poisonings.
    «  How to obtain emergency medical care.
    «  Routine and emergency decontamination procedures, including emergency
       eyeflushing 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.

2.  WPS worker training materials must use terms that the worker can understand.
APPENDIX A
                                                          WPS - How To Comply Manual as Revised 2005  87

-------
88

-------
                                                            CRITERIA FOR WPS MATERIALS
                 FOR

WPS training for handlers must include at least the following information:
    »   Format and meaning of information on pesticide labels and in labeling, including
        safety information such as precautionary statements about human health hazards.
    «   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 types of pesticide poisoning.
    »   Emergency first aid for pesticide injuries or poisonings.
    «   How to obtain emergency medical care.
    «   Routine and emergency decontamination procedures, including emergency
        eyeflushing techniques.
        Need for and appropriate use of personal protective equipment.
        Prevention, recognition, and first aid treatment of heat-related illness.
        Safety requirements for handling, transporting, storing, and disposing of
        pesticides, including general procedures 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 personal protective equipment, the provisions for training and
        decontamination, and the protection against retaliatory acts.
APPENDIX A
                                                           WPS - How To Comply Manual as Revised 2005  89

-------
90

-------
APPENDIX B
SAMPLE  FORMS,  FACT
SHEETS, AND CHECKLISTS
Appendix B includes a sample Pesticide Application Information form with space
for the pesticide application information the WPS requires to be listed at a
central location on each agricultural establishment. The WPS does not
specify a format for presenting the information — you may copy this form
or design another that meets your needs.
Appendix B also includes several fact sheets to help you comply with
sections of the WPS that require you to provide information to others.
Although the WPS does not require you to provide this information in written
form, you may find that using photocopies of these fact sheets is a convenient way
to make sure you convey the necessary information.
Finally. Appendix B includes some checklists and charts you can use as reminders of
your WPS duties.
                   Information.................................... 93


   Information About Cleaning PPE.................................. 95
   Working       With                    ...................... 97
                     and                       to Be
           to           of                  and
                            ....................................... 99
   Custom Applicators: Information to Be         to
   Agricultural              Owners and          .......... 101
Checklists:
   WPS             for                    ................. 103
   WPS             for          Handlers.................... 105
   WPS             for                     ................ 107
   WPS           for            Owners ..................... 109

   WPS            To Provide
   Information To Untrained Workers ............................. 111
Charts:
   EPA Chemical                   Chart..................... 113
                                            and
   First Aid Treatments.............................................. 115

-------
92

-------
                                            SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
                           APPENDIX B
The use of this form is optional, but if the information about an application is entered, it
will help you comply with the federal Worker Protection Standard including all revisions
through 2004 for information that must be displayed at a central place to inform workers
and handlers about specific pesticide applications. For complete information, see p. 19
of the EPA manual "The Worker Protection Standard for Agricultural Pesticides: How To
Comply. "
                                Application #1
Application #2
 Area Treated:
 Location & Description
 Product Name
 EPA Registration
 Number
 Active Ingredient:
 Common or
 Chemical Name
 Application:
 Month/Day/Time
 Restricted-Entry Interval
 Do Not Enter Until:
 Month/Day/Time
Similar data is required by (he Federal Recordkeeping Requirements for Certified
Applicators of Federally Restricted Use Pesticides (RUP). For more information on the
RUP recordkeeping requirements, contact Agricultural Marketing Service, USDA, 8609
SudleyRoad, Suite 203, Manassas, VA 20110, (703) 330-7826. Please consult the
 "USDA Recordkeeping Manual" at the following Web site for a complete list of all USDA
record keeping requirements: http://www.ams.usda.gov/science/prb/Prbfonns.htni
Some states, tribes, or local governments with jurisdiction over pesticide enforcement
may have additional worker protection requirements beyond these requirements. Check
with these agencies to obtain the information you need to comply with all applicable
state, tribal,  or local requirements.
                                                         WPS - How To Comply Manual as Revised 2005  93

-------
94

-------
                                           SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
Note to Employers:
This 2-page fact sheet will help you comply with the section of the WPS that requires you
to provide information to people (other than your own handlers) who clean PPEforyou.
You are not required to give them this information in written form, but you may find that
photocopying this fact sheet is an easy way to pass along the necessary information.


                                                      PPE



[J  1.  The clothing and protective equipment items you will be cleaning may have
     pesticides on them.

[]]  2.  Although you may not be able to see or smell the pesticides, they can rub off on
     you when you touch the clothing and equipment.

[J  3.  If pesticides get on you, they can hurt you.  They can:

    «   cause skin rashes or bums,
    «   go through your skin and into your body and make you ill,
    «   bum your eyes,
    »   make you ill if you breathe them or get them in your mouth.
[]]  4.  To avoid harm from the pesticide, you should:

    «   Pour the clothes from their container into the washer without touching them.
    «   Handle only the inner surfaces, such as the inside of boots, aprons, or coveralls.
    «   Do not breathe the steam from the washer and dryer.
[J  5.  Pesticides should not be allowed to stay on your hands:

    »   When you wash clothing or equipment by hand, use plenty of water and rinse
        yourhands  often.
    «   Wash your hands before eating, drinking, chewing gum, using tobacco, or using
        the toilet.
    «   Wash your hands as soon as you finish handling the clothing or equipment.
[]]  6.  You should not allow clothing and equipment with pesticides on them to be
     washed with regular laundry. The pesticides can rub off on other items.
APPENDIX B
                                                        WPS - How To Comply Manual as Revised 2005   95

-------
                                                       FOR             PPE
                         Cleaning Eyewear
                         Hand-wash reusable respirator facepieces, goggles, face shields, and shielded safety-
                         glasses, following manufacturer's instructions.  In general, use mild detergent and w7arm
                         waterto wash the items thoroughly. Rinse well. Wipe dry, or hang in a clean area to air
                         dry.

                         Cleaning Other PPE
                         Q   1. Follow the manufacturer's cleaning instructions.  If the instructions say only to
                              wash the item, or if there are no cleaning instructions, follow the procedure below.

                         Q   2. Recommended procedure for washing most PPE:

                            a.  Rinse in a washing machine or by hand.
                            b.  Wash In a washing machine, using a heavy-duty detergent and hot water for the
                                wash cycle.
                            c.  Wash only a few Items at a time to allow plenty of agitation and water for
                                dilution. Use the highest water-level setting.
                            d.  Rinse twice using two rinse cycles and warm water.
                            e.  Use two entire machine cycles to wash items that are moderately to heavily
                                contaminated.
                            f.  Run the washer through at least one more entire cycle without clothing, using
                                detergent and hot water, to clean the machine.
                         n   3. Some plastic or rubber items that are not flat, such as gloves, footwear, and
                              coveralls, must be washed twice — once to clean the outside and a second time
                              after turning the item inside out.

                         Q   4. Some items, such as heavy-duty boots and rigid hats or helmets, should be
                              washed by hand using hot water and heavy-duty detergent.

                         []   5. Hang the items to dry, if possible.  Let them hang for at least 24 hours in an area
                              with plenty of fresh air — preferably outdoors.  Do not hang items in enclosed
                              living areas.

                         Q   6. You may use a clothes dryer for fabric items if it is not possible to hang them to
                              dry.  But after repeated use, the dryer may become contaminated with pesticides.
96

-------
                                           SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
Note to Employers:
This fact sheet will help you comply with the section of the WPS that requires you to
provide information to people (other than your own handlers) who clean or maintain you
pesticide equipment. You are not required to give them this information in written form,
hut you may find that photocopying this fact sheet is an easy way to pass along the
necessary information.




n  1. The equipment you will be cleaning, adjusting, or repairing may have pesticides
     on it. Although you may not be able to see or smell the pesticides, they can rub off
     on you when you touch the equipment.

Q  2. If pesticides get on you, they can hurt you. They can:

    «   cause skin rashes or burns.
    «   go through your skin and into your body and make you ill,
    «   burn your eyes.
    «   make you ill if you get them in your mouth.
n  3. You should wear work clothing that protects your body from pesticide residues,
     such as long-sleeved shirts, long pants, shoes, and socks. If possible, avoid
     touching the parts of the equipment where the pesticide is most likely to be. Or, if
     practical for the job that you will be doing, consider wearing rubber or plastic
     gloves and an apron.

Q  4. You should not let pesticides stay on your hands:

    «   Wash your hands as soon as you finish handling the equipment.
    «   Wash your hands before eating, drinking, chewing gum, using tobacco, or using
        the toilet.
    «   Wash or shower with soap and water,  shampoo your hair, and put on clean
        clothes after work.
    «   Wash work clothes that may have pesticides on them separately from other
        clothes before wearing them again.
APPENDIX B
                                                         WPS - How To Comply Manual as Revised 2005  97

-------
98

-------
                                           SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
                           APPENDIX B
               a

Agricultural Establishment Owners and Operators:
The use of this form is optional, but if you hire custom applicators or independent crop
advisors, you must provide this information to the employers of those persons. This
information is necessary to assure that custom applicators and independent crop
advisors are protected according to the federal Worker Protection Standard including all
revisions through 2004. For complete information, see p. 26 of the EPA manual "The
Worker Protection Standard for Agricultural Pesticides: How To Comply. "

                TO BE            TO               OF
               AND
The following information refers to areas that your employees may need to enter, or come
with in 1 4 mile of on foot, while working on this agricultural establishment.
                               Application #1
Application #2
 Areas to be Treated or
 Under Restricted
 Entry Intervals:
 Location & Description
 Entry Restricted Until:
 Month/Day/Time
 PPE Required for
 Handlers*
 Early-Entry PPE Required
 for Workers*
*The only early entry allowed is that which is permitted by the federal Worker Protection
Standard including all revisions through 2004.
                                                        WPS - How To Comply Manual as Revised      99

-------
100

-------
                                           SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
APPENDIX B
Custom (for hire) Applicators:
The use of this form is optional, but you must provide this information to the agricultural
owners and operators who hire you to apply pesticides. Tills information is necessary to
assure that the grower's employees are protected according to the federal Worker Protection
Standard including all revisions through 2004. For complete information, seep. 26 of the EPA
manual "The Worker Protection Standard for Agricultural Pesticides: How To Comply. "

                TO BE            TO AGRICULTURAL
Application #1 Application #2
Area to be Treated:
Location & Description
Product Name
EPA Registration Number
Active Ingredient:
Common or Chemical Name
Application:
Month/Day/Time*
Entry Restricted Until:
Month/Day/Time
Are Both Treated Area
Posting and Oral
Notifications Required?
Other Label Requirements
to Protect Workers,
Handlers, and Others
PPE Required for Handlers**
Early-Entry PPE Required
for Workers**
Other






















*Ifthe pesticide is not applied as scheduled, the customer must be notified of the
corrected time and date before the application takes place.  If you are unable to make the
correction before the application takes place, make it as soon as possible thereafter.
**The only early entry allowed is that permitted by the federal Worker Protection
Standard including all revisions through 2004.
                                                        WPS - How To Comply Manual as Revised 2005   101

-------
102

-------
                                           SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS



CHECKLIST:
WPS                            FOR


Have you given your agricultural workers the protections required by the EPA
Worker Protection Standard? Use this list as a reminder. Remember that you
have duties to persons other than your worker employees. For complete
explanations, refer to "'The Worker Protection Standard for Agricultural
Pesticides — How To Comply."'

Q  1. Information at a central location (WPS safety poster, application information.
     location of emergency medical facility)	H-T-Cpp. 19-20

n  2. Pesticide safety training for workers	H-T-Cpp. 21-23

[J  3. Decontamination supplies (water, soap, towels, etc.) 	H-T-C pp. 24-25

[]]  4. Emergency assistance (transportation and information)	H-T-C p. 27

[]]  5. Restrictions during applications (do not allow workers
     in area)	H-T-Cpp. 36-37

Q  6. Special application restrictions in nurseries	H-T-Cpp. 41-42

[]]  7. Special application restrictions in greenhouses	H-T-C pp. 43-44

n  8. Restrictions during restricted-entry intervals (and limitations
     on early entry)	H-T-Cpp. 36-37
                                                             and 47-56

[]]  9. Notice about applications (oral warnings and treated
     area posting)	H-T-Cpp. 33-35
APPENDIX B
                                                       WPS - How To Comply Manual as Revised 2005   103

-------
104

-------
                                           SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
CHECKLIST:
WPS                            FOR


Have you given your pesticide handlers the protections required by the EPA
Worker Protection Standard? Use this list as a reminder. Remember that you
have duties to persons other than your handler employees. For complete
explanations, refer to "'The Worker Protection Standard for Agricultural
Pesticides — How To Comply."'

Q  1. Information at a central location (WPS safety poster, application
     information, location of emergency medical facility)	H-T-C pp. 19-20

n  2. Pesticide safety training for handlers	H-T-C pp. 21-23

[J  3. Decontamination supplies (water, soap, towels, change of
     clothing, etc.)	H-T-C pp. 24-25

[]]  4. Emergency assistance (transportation and information)	H-T-C p. 27

n  5. Restrictions during applications (do not allow pesticide to contact
     anyone directly or through drift)	H-T-C p. 59

n  6. Monitoring handlers (if handling skull and crossbones pesticides
     anywhere or fumigants in greenhouses)	H-T-C p. 59

n  7. Specific instructions for handlers (pesticide label information
     and how to use application equipment)	H-T-C p. 60

[J  8. Equipment safety (inspection and maintenance of application
     equipment)	H-T-C p. 61

[]]  9. Personal protective equipment (provide, clean, maintain PPE.
     and prevent heat illness) 	H-T-C pp. 62-63

[J  10.  Exceptions to personal protective equipment (closed systems,
     enclosed cabs, and open and enclosed cockpits)  	H-T-C pp .66-67
APPENDIX B
                                                       WPS - How To Comply Manual as Revised 2005  105

-------
106

-------
                                          SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
CHECKLIST:
WPS                           FOR


Have you given the handler employees of your commercial pesticide handling
establishment the protections required by the EPA Worker Protection
Standard? Use this list as a reminder. Remember that you have duties to
persons other than your handler employees. For complete explanations, refer
to "The Worker Protection Standard for Agricultural Pesticides — How To
Comply.'"

Q  1. Pesticide safety training for handlers	H-T-C pp. 21-23

n  2. Decontamination supplies (water, soap, towels, change of
     clothing, etc)	H-T-C pp. 24-25

[J  3. Emergency assistance (transportation and information)	H-T-C pp. 27

[]]  4. Restrictions during applications (do not allow pesticide to contact
     anyone directly or through drift)	H-T-C p. 59

Q  5. Monitoring handlers (if handling skull and crossbones pesticides
     anywhere or fumigants in greenhouses)	H-T-C p. 59

Q  6. Specific instructions for handlers (pesticide label information and
     how to use application equipment)	H-T-C p. 60

[[]  7. Equipment safety (inspection and maintenance of application
     equipment)	H-T-C p. 61

Q  8. Personal protective equipment (provide, clean, maintain PPE. and
     prevent heat illness)	H-T-C pp. 62-63

[]]  9. Exceptions to personal protective equipment (closed systems,
     enclosed cabs, and open and enclosed cockpits) 	H-T-C pp. 66-67
APPENDIX B
                                                      WPS - How To Comply Manual as Revised 2005  107

-------
108

-------
                                          SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
CHECKLIST:
WPS                       FOR


Although agricultural owners are encouraged to give WPS protections to
themselves and their families,* the WPS does not require them to provide
themselves or members of their immediate family with the following:

Q  1. Information at a central location (WPS safety poster, application
     information, and location of emergency medical facility)	H-T-C pp. 19-20

[]]  2. Pesticide safety-training for workers or handlers	H-T-C pp. 21-23

[J  3. Decontamination supplies (water, soap, towels, change of
     clothing, etc.)	H-T-C pp. 24-25

[]]  4. Emergency assistance (transportation and information)	H-T-C p. 27

n  5. Notice about applications (oral warnings and treated area posting). H-T-C p. 33-35

Q  6. Monitoring handlers (if handling skull and crossbones pesticides
     anywhere or fumigants in greenhouses)	H-T-C p. 59

[]]  7. Specific handling instructions (pesticide label information and
     how to use application equipment)	H-T-C p. 60

n  8. Equipment safety (inspection and maintenance of application
     equipment)	H-T-C p. 61

[]]  9. All the specific duties related to the care of PPE and management
     of its use (provide, clean, maintain PPE and prevent heat illness) .. H-T-C pp. 62-63

n  10. The following duties related to early entry:	H-T-C pp. 53-56

     •   Training and instructions
     »   Decontamination supplies
     "   Specific duties related to the care of PPE and management of its use.

     * Remember that you must provide all protections required by the WPS to persons
     who are not members of your immediate family.
APPENDIX B
                                                       WPS - How To Comply Manual as Revised 2005   109

-------
110

-------
                                           SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
CHECKLIST:
WPS                          TO
                                                       TO


You must provide basic pesticide safety information to untrained workers
before they enter treated areas on your establishment where, within the past
30 days, a pesticide has been applied or a restricted-entry interval has been in
effect. For a complete explanation, refer to "The Worker Protection Standard
for Agricultural Pesticides — How To Comply."
The following is a list of things that you must provide:

Q  1. Basic pesticide safety information in a manner that the untrained workers can
     understand, such as through written materials, oral communication, or other means.

[]]  2. Verification that you provided the workers with the required basic pesticide safety
     information.

n  3. At least the following information:

    «  Pesticides may be on or in plants, soil, irrigation water, or drifting from nearby
       applications.
    «  To prevent pesticides from entering your body:
       -  Follow directions and/or signs about keeping out of treated or restricted
          areas,
       -  Wash before eating, drinking, using chewing gum or tobacco, or using the
          toilet,
       -  Wear work clothing that protects your body from pesticide residues,
       -  Wash/shower with soap and water, shampoo hair, and put on clean clothes
          after work,
       -  Wash work clothes separately from other clothes before wearing them again,
       -  Wash immediately in the nearest clean water if pesticides are spilled or
          sprayed on your body and then — as soon as possible — shower, shampoo.
          and change into clean clothes.
    «  You will receive more training within 5 days (or at least before your sixth day of
       work in pesticide-treated areas on mis establishment).
APPENDIX B
                                                       WPS - How To Comply Manual as Revised 2005  111

-------
112

-------
                                            SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
APPENDIX B
EPA

This chart is to be used when PPE section on the pesticide label lists a chemical
resistance category. The Worker Protection Standard requires that labels of pesticides
used on farms, and in forests, nurseries and greenhouses list the type of personal
protective equipment (PPE) that must be worn with each product. Labels will refer to
chemical resistance categories (A-H) for PPE. Items in these categories are made of
materials that the pesticide cannot pass through during the times indicated below the
chart. Choose the category of resistance which best matches the handling task duration.
The categories are based on the solvents used in the pesticides, not the pesticides
themselves. Therefore, there will be instances where the same pesticide with two
different formulations (wettable powder-WP and emulsifiable concentrate-EC, for
example) will require PPE from two different chemical resistance categories.
Selection
Category
Listed on
Pesticide
Label


A (a dry and
water-based
formulation)
B
C
D
E
F
G
H

Types of Personal Protective Material

Barrier
Laminate

high

high
high
high
high
high
high
high
Butyl
Rubber
> 14 mils
high

high
high
high
slight
high
slight
slight
Nitrile
Rubber
> mils
high

slight
high
moderate
high
high
slight
slight
Neoprene
Rubber
> 14 mils
high

slight
high
moderate
high
moderate
slight
slight
Natural
Rubber
>14 mils
high

none
moderate
none
slight
slight
none
none
Poly-
ethelene

high

slight
moderate
none
none
none
none
none
Polyvinyl
Chloride
(PVC)
>14 mils
high

slight
high
none
moderate
slight
none
none
Viton
>14 mils

high

slight
high
slight
high
high
high
high
HIGH: Highly chemical-resistant. Clean or replace PPE at end of each day's work period. Rinse
off pesticides at rest breaks.

MODERATE: Moderately chemical-resistant. Clean or replace PPE within an hour or two of
contact.

SLIGHT: Slightly chemical-resistant. Clean or replace PPE within ten minutes of contact.

NONE: No chemical-resistance. Do not wear this type of material as PPE when contact is
possible.
                                                         WPS - How To Comply Manual as Revised 2005  113

-------
114

-------
                                         SAMPLE FORMS, FACT SHEETS, AND CHECKLISTS
APPENDIX B
                  AND

      TO                           IN AGRICULTURAL
Taken from EPA's "Controlling Heat Stress in Agriculture"' (EPA 750-F-95-001)

Key Elements
    «   Drinking enough water to replace body fluid lost through sweating.
    «   Gradually adjusting to working in the heat.
    «   Taking periodic breaks in a shaded or air conditioned area whenever possible.
    »   Monitoring by supervisors of environmental conditions and workers.
Basic Steps
    «   Training in how to control heat stress and to recognize, prevent, and treat heat
       illnesses.
    «   Accounting for the weather, workload, protective gear to be worn, and condition
       of the workers.
    «   Determining minimum amounts of water workers should drink.
    «   Adjusting work practices for the conditions of each day.
    «   Giving first aid when workers become ill.
                          AND          AID
Chart taken from EPA's "A Guide to Heat Stress in Agriculture" (EPA 750-B-92-001)
Illness Signs and Symptoms
Early heat illness • Mild dizziness,
fatigue, or irritability;
decreased
concentration; impaired
judgement
Heat rash • Tiny, blister-like
"prickly heat" red spots on the skin;
pricking sensations
• Commonly found
on clothed areas of the
body






Heat cramps • Painful spasms of
leg, arm, or abdominal
muscles
• Heavy sweating,
thirst

• Occurs during or
after hard work
Cause and Problem
• Reduced flow of
blood to the brain
• May lead to heat
exhaustion or heat
stroke
• Sweat glands
become plugged and
inflamed from
unrelieved exposure of
skin to heat, humidity,
and sweat






• Loss of body salt in
sweat
• May be totally
disabling



Treatment
• Loosen or remove
clothing
• Rest in shade 30
minutes or more
• Drink water
• Clean skin, apply
mild drying lotion or
cornstarch
• Wear loose clothing
• Preventable by
regular bathing and
drying the skin and by
periodic relief from
humid conditions of
work
• See physician if
rash persists
• Loosen clothing
• Drink lightly salted
O J
beverages
• Massage
• Rest


                                                     WPS - How To Comply Manual as Revised 2005   115

-------
            HEAT ILLNESS AND
Illness
Heat exhaustion






















Heat stroke



Immediate
Treatment
Required

















Signs and Symptoms
• Fatigue, headache,
dizziness, muscle
weakness, loss of
coordination, fainting,
collapse
• Profuse sweating;
pale, moist, cool skin;
excessive thirst, dry
mouth; dark yellow
urine
• Fast pulse, if
conscious

• Low or normal oral
temperature, rectal
temperature usually
99. 5-101. 3 degrees F
• May also have heat

cramps, nausea, urge to
defecate, rapid
breathing, chills,
tingling of the hands or
feet, confusion,
giddiness, slurred
speech, irritability




Life-threatening
medical emergency
• Often occurs
suddenly
• Headache,
dizziness, confusion,
irrational behavior,
coma
• Sweating may slow
down or stop
• Fast pulse, if
conscious
• Rapid breathing
• Rectal temperature
104 degrees F and over
• May also have
convulsions, nausea,
incoherent speech, very
aggressive behavior








Cause and Problem
• Dehydration, lack of
acclimatization;
reduction of blood in
circulation; strain on
circulatory system,
reduced flow of blood
to the brain
• Worker may resist
treatment
H May lead to heat
stroke















• Sustained exertion
in heat, lack of
acclimatization,
dehydration,
individual risk factors;
reduced flow of blood
to the brain and other
vital organs, body's
temperature-regulating
system fails, body can
J ' J
not cool itsell
• Risk of damage to
vital organs, including
the heart, brain,
central nervous
system, liver, and
kidney
• Worker may resist
treatment
• Brain damage and
death can result even
with prompt
treatment






Treatment
• Removal to cooler,
shaded area as quickly
as possible
• Rest lying down
• If conscious, have
worker drink as much
water as possible
• Do not give salt
• If unconscious or if
heat stroke is also
suspected, treat for heat
stroke until proven
otherwise
• Loosen or remove
clothing
• Splash cold water on
body

• Massage legs and
arms
• If worker collapsed,
get evaluation by
physician, nurse, or
EMT before worker
leaves for the day;
shower in cold water;
rest for balance of day
and overnight
• Move to a shaded
area
• Remove outer
clothing/shoes
• Immediately wrap in
wet sheet, pour water
on and fan vigorously,
avoid over-cooling
• Treat shock if
present, once
temperature is lowered
• If worker vomits,
make sure all vomit is
cleared from mouth and
nose to prevent choking
on vomit
• Transport to nearest
medical treatment
facility at once
• While awaiting or
during transport,
elevate legs, continue
pouring on water and
fanning
• If conscious, have
worker drink as much
water as possible
• Do not give salt
116

-------
APPENDIX C
QUICK REFERENCE GUIDE TO
THE WORKER PROTECTION
STANDARD
     All

-------
118

-------
                                  Quick Reference Guide to the Worker Protection Standard
                                          TO
THE
                All

The WPS is a federal regulation designed to protect agricultural workers (people
involved in the production of agricultural plants) and pesticide handlers (people mixing,
loading, or applying pesticides or doing other tasks involving direct contact with
pesticides) (see p. 10). The guide on these two pages presents the maximum WPS
requirements. It does not include exceptions that may permit you to do less or options
that may involve different requirements. Each section below lists pages in this manual
where you can find out about exceptions and options. For more information about your
responsibilities, read pp. 9-15. There are some exemptions for owners of agricultural
establishments and members of their immediate family (pp. 71-73).


TOPICS

         FOR ALL
    »  Anti-Retaliation
    •  Information at a Central Location
    «  Pesticide Safety Training
    «  Decontamination Supplies
    •  Employer Information Exchange
    »  Emergency Assistance

    «  Restrictions During Applications
    «  Restricted-Entry Intervals (REIs)
    «  Notice About Applications
       -  Posted Warn ing Signs
       -  Oral Warnings
                       FOR
    «  Application Restrictions and Monitoring
    «  Specific Instructions for Handlers
    «  Equipment Safety
    »  Personal Protective Equipment (PPE)
       -  Duties Related to PPE
       -  Care of PPE
       -  Replacing Respirator Purifying Elements
       -  Disposal of PPE
       -  Instaictions for People Who Clean PPE
APPENDIX C
                                                       WPS - How To Comply Manual as Revised 2005  119

-------
                                              [[[ (p. 15)
                         Do not retaliate against a worker or handler who attempts to comply with the WPS

                         IN FORMATION AT A CENTRAL LOCATION ........................(p. 19-20)
                         1.  In aii easily seen central location on each agricultural establishment display close
                         together:
                            »   EPA WPS safety poster,
                            »   name, address, and telephone number of the nearest emergency medical facility,
                            »   these facts about each pesticide application [from before each application begins
                                until 30 days after the restricted-entry interval (REI)]:
                                -  product name, EPA registration number, and active ingredient(s),
                                -  location and description of treated area,
                                -  time and date  of application, and REI.
                         2.  Tell workers and handlers where the information is posted, and allow them access.
                         3.  Tell them if emergency facility information changes and update the posted
                         information.
                         4.  Keep the posted information legible.

                                                          ...................................  (pp. 21-23)
                         Unless they possess a valid EPA-approved training card, train handlers and workers
                         before they begin work and at least once each 5 years:
                            «   use written and/or audiovisual materials,
                            «   use EPA WPS handler training materials for training handlers,
                            «   use EPA WPS worker training materials for training workers,
                            «   have a certified applicator conduct the training orally and/or audiovisually in a
                                manner the employees can understand, using easily understood terms, and
                                respond to questions.
                                               SUPPLIES...................................  (pp. 24-25)
                         1.  Establish accessible decontamination supplies located together within 1/4 mile of all
                         workers and handlers. Supply:
                            «   enough water for routine and emergency whole-body washing and for
                                eyeflushing,
                            «   plenty of soap and single-use towels,
                            «   a clean coverall.
                         2.  Provide water that is safe and cool enough for washing, for eyeflushing, and for
                         drinking. Do not use tank-stored water that is also used for mixing pesticides.
                         3.  Provide handlers the same supplies where personal protective equipment (PPE) is
                         removed at the end of a task.
                         4.  Provide the same supplies at each mixing and loading site.
                         5.  Make at least 1 pint of eyeflush water immediately accessible to each handler.

-------
                                   Quick Reference Guide to the Worker Protection Standard
7. In areas being treated, put decontamination supplies for handlers in enclosed
containers.

                                           ............................... (p. 26)
1. Before any application, commercial handler employers must make sure the operator
of the agricultural establishment where a pesticide will be applied is aware of:
        location and description of area to be treated,
        time and date of application,
        product name. EPA registration number, active ingredient(s), and REI,
        whether the product label requires both oral warnings and treated area posting,
        all other safety requirements on labeling for workers or other people.
2. Operators of agricultural establishments must make sure any commercial pesticide
establishment operator they hire is aware of:
    «   specific location and description of all areas on the agricultural establishment
        where pesticides will be applied or where an REI will be in effect while the
        commercial handler is on the establishment,
    «   restrictions on entering those areas.
                             .............................................. (p. 27)
When any handler or worker may have been poisoned or injured by pesticides:
1. Promptly make transportation available to an appropriate medical facility.
2. Promptly provide to the victim and to medical personnel:
    «   product name, EPA registration number, and active ingredient(s),
    «   all first aid and medical information from label,
    «   description of how the pesticide was used,
    »   information about victim's exposure.
APPENDIX C
                                                         WPS - How To Comply Manual as Revised 2005  121

-------
                                                             FOR

                                                                      .............................. (p. 36)
                         1.  In areas being treated with pesticides, allow entry only to appropriately trained and
                         equipped handlers.
                         2.  Keep nursery workers at least 100 feet away from nursery areas being treated.
                         3.  Allow only handlers to be in a greenhouse:
                             »   during a pesticide application,
                             «   until labeling-listed air concentration level is met or. if no such level, until after
                                 2 hours of ventilation with fans.
                         (Also see nursery restrictions and greenhouse restrictions) (pp 41-42, 43-45)

                                                              (REIs)............................... (p. 36)
                         During any REI, do not allow workers to enter a treated area and contact anything
                         treated with the pesticide to which the REI applies.
                         (Also see early entry by workers) (p. 36-37,47-56)

                                                             ........................................ (p. 33)
                         1.  Orally warn workers and post treated areas if the pesticide labeling requires.
                         2.  Otherwise, either orally warn workers or post entrances to treated areas. Tell workers
                         which method is in effect.
                         3.  Post all greenhouse applications.

                         Posted Warning Signs [[[  (p. 33)
                         1.  Post legible 14" X  16" WPS-design signs just before application; keep posted during
                         REI;  remove before workers enter and within 3 days after the end of the REI.
                         2.  Post signs so they can be seen at all entrances to treated areas, including entrances
                         from labor camps.

                         Oral  Warnings	  (p. 35)
                         1.  Before each application, tell workers who are on the establishment (in a manner they
                         can understand):
                             «   location and description of treated area,
                             «   REI, and not to enter during REI.
                         2.  Workers who enter the establishment after application starts must receive the same

-------
                                    Quick Reference Guide to the Worker Protection Standard
                                                       ................... (p. 59)
1.  Do not allow handlers to apply a pesticide so that it contacts, directly or through drift,
anyone other than trained and PPE-equipped handlers.
2.  Make sight or voice contact at least every 2 hours with anyone handling pesticides
labeled with a skull and crossbones.
3.  Make sure a trained handler equipped with labeling-specified PPE maintains constant
voice or visual contact with any handler in a greenhouse who is doing fumigant-related
tasks, such as application or air-level monitoring.

                             FOR             ........................... (p. 60)
1.  Before handlers do any handling task, inform them, in a manner they can understand,
of all pesticide labeling instructions for safe use.
2.  Keep pesticide labeling accessible to each handler during entire handling task.
3.  Before handlers use any assigned handling equipment, tell them how to use it safely.
4.  When commercial handlers will be on an agricultural establishment, inform them
beforehand of:
    «   areas on the establishment where pesticides will be applied or where an REI will
        be in effect
    «   restrictions on entering those areas.
(The agricultural establishment operator must give you these facts.)

EQUIPMENT SAFETY [[[ (p. 61)
1.  Inspect pesticide handling equipment before each use, and repair or replace as needed.
2.  Allow only appropriately trained  and equipped handlers to repair, clean, or adjust
pesticide equipment that contains pesticides or residues.

                                                  ..................  (pp.
(See exceptions to PPE) (pp. 66-67)

                 to PPE[[[  (p. 62)
1.  Provide handlers with the PPE the pesticide labeling requires for the task, and be sure
it is:
    «   clean and in operating condition,
    «   worn and used correctly,
    «   inspected before each day of use,
    «   repaired or replaced as needed.
2.  Be sure respirators fit correctly.
3.  Take steps to avoid heat illness.
4.  Provide handlers a pesticide-free  area for:
    «   storing personal clothing not in use,
    «   putting on PPE at start of task,
    «   taking off PPE at end of task.
5.  Do not allow used PPE to be worn home or taken home.

-------
                         Care of PPE [[[  (p. 62)
                         1.  Store and wash used PPE separately from other clothing and laundry.
                         2.  If PPE will be reused, clean it before each day of reuse, according to the instructions
                         from the PPE manufacturer unless the pesticide labeling specifies other requirements. If
                         there are no other instructions, wash in detergent and hot water.
                         3.  Dry the clean PPE before storing, or hang to dry.
                         4.  Store clean PPE away from other clothing and away from pesticide areas.

                         Replacing Respirator Purifying Elements .................................  (p. 63)
                         1.  Replace dust/mist filters:
                             «   when breathing becomes difficult,
                             «   when filter is damaged or torn,
                             «   when respirator label or pesticide label requires (whichever is shorter), or
                             «   at the end of day's work period, in the absence of any other instructions or
                                 indications.
                         2.  Replace vapor-removing cartridges/canisters:
                             »   when odor/taste/irritation is noticed,
                             »   when respirator label or pesticide label requires (whichever is shorter), or
                             «   at the end of day's work period, in the absence of any other instructions or
                                 indications.
                                   of PPE[[[  (p. 63)
                         1.  Discard coveralls and other absorbent materials that are heavily contaminated with
                         undiluted pesticide having a '"DANGER" or "'WARNING" signal word.
                         2.  Follow federal, state, and local laws when disposing of PPE that cannot be cleaned
                         correctly.

                         Instructions for People Who Clean PPE  ...................................  (p. 63)
                         Inform people who clean or launder PPE:
                             «   that PPE may be contaminated with pesticides,
                             «   of the potentially harmful effects of exposure to pesticides,

-------

agricultural emergency 47, 49, 72
agricultural employer  14,  26, 78
agricultural owner 9,  10,  69, 71-73,91,
     101, 109 See also employer
agricultural plants ii,  3, 7-9,  10, 12,  13,
     14, 37,  53 74, 77, 119
agricultural worker ii, 3,  7, 9, 12, 14, 22,
     31, 37,  52, 53, 76, 78, 91, 103, 119
  requirements checklist  29
air exchanges 43
anti-retaliation 3, 119, 120
     See also retaliation
apparel 64
application information 7, 19, 20,  76,  78,
     91, 93, 103
application restrictions 4, 29, 36,  39,  41,
     42, 43, 44, 103,  119,  123
applicator 3, 11, 15,  21,  22, 23,42,44,
     59, 60, 91, 93,  99,  103, 120
arid areas 36

B

boots 95. See also footwear
central location  3, 17, 19,  20, 26,
     37, 52, 73, 75,  78,  80, 91,  103,
     105, 109, 119, 120.
certified applicator 3,  21,  22, 93, 120
certified crop advisor  78
charts  91
checklists, See also forms
  requirements for pesticide handlers 91
  exemptions for agricultural workers
  WPS requirements for agricultural workers
     103
  WPS requirements for pesticide handlers
     105
  WPS requirements for commercial handlers
     107
  WPS exemptions for agricultural owners
     109
  WPS requirement to provide basic
     pesticide safety information  to
     untrained workers 111
chemical-resistant  48,  62,  64, 65, 66, 67
chemigation 13, 47,  60,  87
closed system  15,  62,  66,  105, 107
clothing. See also personal protective
     equipment
cockpits 67, 105,  107
commercial crop advisor 60, 74,  76,  77,  78
commercial pesticide handler 9,  19, 26
  requirements checklist  60. See also
     pesticide handler
commercial pesticide handling establishment
     10, 19, 27, 71, 107
coveralls 4, 24, 48, 62,  63, 64, 95,  96,
     124
crop advisor 9, 10,  26, 36, 60, 69,
     74-80, 91, 99
crop consultant 9, 74
custom applicator 60,91, 99,  101

D

decontamination 12, 19, 17, 24, 25, 37,
     45, 52, 54, 55, 73,  75, 76, 77, 78,
     80, 103, 105, 107, 109,  119,  120, 121
  for workers  3
  water quantity 7
direct supervision 74, 75, 77,  78,  79
discrimination  23
displaying application information  20
disposal 4, 63, 119, 124
  of personal protective equipment 9
double notification  15, 48
drift 4,  21, 27, 59, 60, 72, 76, 83,
     87, 89, 105, 107, 111,  123
early entry 22, 34, 36, 37, 45, 47-49,
    50, 51, 53, 55, 65, 72, 73, 75, 76,
    99, 101, 103,  109,  122
  with no contact  4, 29
emergency 3, 7,  17,  19, 25, 27, 49,
    50-52, 55, 73, 75-8, 80, 87,
    89, 103, 105, 107, 109, 119, 121
emergency assistance  3,7,  12,27,37,
    50, 52, 73, 75,  76,  77,  78,
    103,  105, 107, 109, 119,  121
emergency information 19,20,  27
emergency medical facility
    3, 19, 27, 103,  105,  109,  120
employers 3, 4, 10, 17, 26, 27, 47, 62
    63, 75, 78, 80,  91,  95,  97,  99, 119,
    120,  122, 123
  information exchange 14
enclosed cabs  66,  67, 105,  107
equipment 3, 4, 9, 10, 12,  15, 19, 25, 36,
    47, 53,  57, 60-62, 64, 65, 73, 75, 77,
    89,91,  95,97,105,  107,  109,  119, 123
  instructions for nonemployees 45
eyeflush water  3,  24, 25, 54, 55, 120
eyewear  25,  48, 55,  62, 64, 66, 67, 96
face shield 64, 96
farms 7, 8, 12, 13, 26, 33, 34, 35, 85, 113
flagger  10
footwear  37, 48, 62, 64,  67,  96
forests  7, 8, 12,  26,  33, 34, 35,  85,  113
  specific provisions for 8

-------
                           forms 59,  93 See also checklists
                           forms, factsheets, and checklists 91
                             application information 93
                             fact sheets:
                             information about cleaning PPE  95
                             working  safely with pesticide equipment
                               97
                             agricultural owners and operators informa-
                               tion to be provided to employers of
                               custom applicators and independent
                               crop advisors  99
                             custom applicators information to be
                               provided to agricultural establishment
                               owners and operators 101
                             checklists:
                             WPS requirements for agricultural workers
                               103
                             WPS requirements for pesticide handlers
                               105
                             WPS requirements for commercial handlers
                               107
                             WPS exemptions for Agricultural owners
                               109
                             WPS requirement to provide basic pesti-
                               cide safety information to untrained
                               workers  111
                             charts:
                             EPA chemical resistance category chart 113
                             heat stress - preventable measures,
                               illnesses, and first aid treatments  115
                             information for employers of custom
                               applicators  91
                           fumigant 4, 10, 42, 44,  59, 60, 105, 107,
                               109, 123
                           gloves 48, 62, 64-67, 96,  97
                           goggles 64, 96
                           greenhouses  7,  8,  12, 13, 26, 29, 33, 36,
                               39,  43,  44, 59, 72,  85,  103,  105,
                               107, 109, 113
                           H
                           hand labor 47, 48, 50, 74
                           handler  3,4, 5,  10,  11, 14, 17, 21, 23,
                               24, 25, 26, 57,  59, 60, 61, 62, 66, 67, 75,
                               80,  81,  89, 91, 99,  101,  105, 119, 123
                               See also pesticide handier
                           handler employee 4,29, 57, 60, 105,  107,
                               123
                           handler employer  14,  21, 24, 26,27,
                               59,  60-62, 66, 89, 119, 121
                           headgear 62, 64, 65
                           heat illness 4,  53,  62, 105, 107, 109,  115,
                               116, 123
                           heat stress  53, 62, 91
immediate family 3, 10,  71-73,  109, 119
independent crop advisor 91, 99
information exchange  3,  26,72,119, 121
integrated pest management monitor 74
irrigation  21,  37, 47, 49, 83, 111
labeling  3, 4, 7, 10-15, 25-27, 33, 36,  37,
    42, 43, 44, 47-49, 51 52, 53,  55, 59,
    60, 63-67, 72, 75,  76,  89, 121-124
  exceptions to  9
labor contractor 9
language 23, 34, 50, 48, 77, 85
licensed crop advisor 74-80

M

medical care 87, 89
  transportation to. See also emergency
    medical facility
monitoring 4, 7, 47, 59, 73, 74, 75,  80, 105,
    107, 109, 115

N

no-contact early entry. 36, 72
    See also early entry
noncommercial crop advisor  74, 76, 78
notification  12,  15, 26, 33, 37, 48, 101
  treated-area posting  33
nurseries  7, 8, 12, 26,  29,  33, 34,
    36, 39, 41, 42, 72, 85, 103, 113
  specific provisions for  8

o

oral warnings  3,4, 15,  33, 35,  87,  103,
    109,  119, 121, 122
owner  3,9, 10, 14, 15, 69, 71-73,91,
    93, 99, 101, 109, 119
    See also employer
owner exemption 9, 10,69, 71
penalties  15
personal protective equipment (PPE)  3,
    4, 7, 9,12,15,25, 36,47,  48,  49,
    53, 55, 59,  62, 63, 64,  65,  66, 67, 71,
    73, 75, 76, 77, 80, 81, 91,  95,  96, 99, 101,
    105,  107, 109,  113, 119, 120,  123,  124
  types of 4, 45
    See oiso personal protective equipment
pesticide application information. 93
    See oiso application information
126

-------
                                                                                                         INDEX
pesticide handler training 59, 60,  75,  78,
     91, 105
  See also commercial pesticide handier
     3, 7, 9, 10, 14, 19, 22, 26,
     36, 47, 59, 60, 62,  64,  74, 75, 77-79,
     105, 119
pesticide handler employer 19, 26, 27,60
pesticide uses 5,12,  13
poster 3, 7, 19, 20,  76,  78,  81,  83,  103,
     105,  109,  120 See also sign
protective eyewear 25, 48, 55, 62, 64,
     66,  67  See also personal protective
     equipment
quick reference guide 3, 117,119
  large print version 117
REI 3, 4, 7,  37,  49,  53, 60, 72, 75,
    76, 77, 78, 80, 119, 120, 121, 122,  123.
    See also restricted entry interval
respirator 4, 42,  44, 62, 64,  66, 67, 96,
    119, 123, 124
   maintenance of 63
restricted-entry interval  (REI) 3,  4,7,  9,
    10, 12, 15, 19, 20, 21, 22, 24, 25, 26, 33,
    34,  36,  37, 41, 45, 47, 48, 49, 53,
    54, 60, 72, 74, 75, 76,  77, 78,  79,  103,
    111,  119, 120, 122
restrictions during applications.
    See also application restrictions
retaliation 15, 119
   prohibition against  3
treated area posting 3,  103,  109,  121
     See also notification
u
uncertified crop advisor 78
unlicensed crop advisor 75, 79, 80
ventilation criteria  10,  37, 43, 44, 47,
     48, 49, 50, 72, 75

W

warning signs 4, 20, 33, 34, 48, 81, 85, 87
     119, 122
  criteria for 34
worker  1,  4, 5, 7, 8,  10,  12,  14,  15,  19,
     21,  22, 23,  24, 25, 27, 29, 33, 34,
     35, 36, 41, 42, 43, 44, 45, 47, 52,
     54, 63, 81, 91, 93, 99, 101, 103,
     105,  107,  111, 113, 116, 117, 119, 122
worker employer 4, 14,  19,  21,  24,  27, 33,
     36, 41, 43, 47, 52, 53, 54119, 122
Worker Protection Standard (WPS)  1,  3, 5,
     7, 8, 9, 12, 15,  63, 93, 99, 101,  103,
     105,  107,  111, 113, 117, 119
safety glasses  96.
     See also eyewear, protection
safety poster 3, 7, 19,  76, 78,  81,  83,
     103, 105,  109, 120
scout 60, 74.  See also crop advisor
separable glove liners 65
sign size 35, 87
skull and crossbones 4, 59, 105, 107,  109, 123
sod farms 13
supervisors  14, 15, 115
training 3, 7,  11,  12, 21, 22, 23, 37,  50
     53, 73, 74, 75, 76, 78, 79, 81, 83, 87, 89,
     103,  105,  107,  109, 111, 115, 119, 120
  verification of 3
translator 22, 23
treated area  3, 4, 7, 10, 15, 20, 21,  24,
     26,  33,  34, 35, 36,  37, 41,  42, 43, 44
     45, 47, 49, 53, 60, 67, 72, 75, 76, 77, 78,
     85, 86, 101, 103,  109,  111,  120,  121,
     122
                                                               WPS - How to Comply Manual as Revised 2005  127

-------
128

-------





-------