SEPA
United States
Environmental Protection
Agency
Prevention, Pesticides
And Toxic Substances
(H7506C)
                                                      735-F-93-011
                                                      March 1993
                The Worker  Protection
                Standard  for
                Agricultural  Pesticides

               How Soon Do You Need to Comply?
           You probably need to read this bulletin, if

           4   You own or manage a farm, forest, nursery, or greenhouse
               where pesticides are used in the production of agricultural
               plants.

           4   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.

           ^   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.

           4   You operate a business in which you (or people you employ)
               perform tasks as a crop advisor on any farm, forest, nursery, or
               greenhouse.
                                  Bulletin for Users of Agricultural Pesticides

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This Bulletin
explains when you
need to comply with
the new and
expanded
provisions of
the EPA Worker
Protection
Standard (WPS).
The WPS will be
phased into effect,
to allow time for
employers to learn
about the changes
and make plans to
comply.
The EPA is
preparing a
complete manual
on the WPS for
agricultural
employers: "The
Worker Protection
Standard for
Agricultural
Pesticides --
How To Comply."
The manual will be
available in April
1993. Call the
EPA Occupational
Safety Branch for
ordering information.
{703} 305-7666.
                        Revised  Worker Protection Standard
In August 1992, the Environmental Protection Agency (EPA)
revised its Worker Protection Standard (WPS) for Agricultural
Pesticides.

Not All Provisions Take Effect Right Away

     You need not comply with many parts of the WPS until
      April 15, 1994.  (Page 4.)

     You must comply with some parts of the revised WPS
      as soon as you use a pesticide that refers to the WPS in
      the Agricultural Use Requirements box on its label.
      (Page 3 and  pages 5-8.)

Labels of agricultural pesticides will require compliance with the
WPS. These labels will begin to appear after April 1993 as
pesticide companies modify their labels to include WPS
requirements.  These labels will contain statements referring to
the revised WPS.

Expanded WPS Scope and Requirements

The revised WPS expands the scope of the regulation to include
not only # Workers performing hand labor operations in fields
treated with pesticides but also  Workers in forests, nurseries,
and greenhouses and  Employees who handle (mix, load, apply,
etc.) pesticides for use in these locations.

The WPS extends requirements for  * Warnings about applications
* Use of personal protective equipment and  Restrictions on
entry to treated areas.

New WPS Provisions

The revised Worker Protection Standard adds new provisions for
* Decontamination    Emergency assistance * Pesticide safety
training  Maintaining contact with  handlers of highly toxic
pesticides
                                   Bulletin for Users of Agricultural Pesticides   Page 2

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This Quick
Reference Guide
does not include
exceptions that
may permit you to
do less or options
that may involve
different require-
ments.  These
exceptions are
described in
pages 5-8 of this
Bulletin.  For more
information, see the
EPA manual
"The Worker
Protection Standard
for Agricultural
Pesticides -
How To Comply."
Key words in the
WPS have specific
meanings.  The
definitions here
are abbreviated.
For complete
definitions, see
"The Worker
Protection Standard
for Agricultural
Pesticides --
How To Comply."
 Quick Reference  Guide To WPS Requirements
              April 21, 1993 - April 15, 1994

This page presents the maximum Federal requirements for the
parts of the 1992 Worker Protection Standard (WPS) that you
must comply with between April 21,  1993,  and April 15, 1994.
These provisions are referred to as the WPS "accelerated
provisions."  On and after April 15, 1994, you must comply  with
ALL the 1992 WPS requirements.

You will be in compliance with the accelerated provisions of the
1992 WPS if you  make sure the requirements listed below are
met. You must comply with all other directions and require-
ments specified on the pesticide labeling.

  Personal Protective Equipment (PPE):  Make sure all
   pesticide handlers wear the PPE required on the pesticide
   labeling for the handling task being performed.  (Page 5)

*  Restricted-Entry Intervals (REIs):  During any REI, do  not
   allow workers  to enter a treated area. (Page 6)

*  Notice About Applications:  Orally warn workers and post
   treated areas if required on the pesticide labeling.  (Page 5)

   *  Post warning signs at entrances to treated  areas.
     Orally warn workers of * location and description of
      treated area * REI and # not to enter during REI.

Kev WPS Definitions

Pesticide handlers, in general, mix, load, apply, or do other
tasks that bring them into direct contact with pesticides.

Restricted-entry interval is the time after the end of a pesticide
application during which entry into the treated area is limited.

Treated area is any area to which a pesticide is being directed or
has been directed.

Workers, in general, do (1) hand labor tasks, such as weeding,
planting, cultivating, and harvesting, or (2)  other tasks involved
in the production of agricultural plants, such as operating or
moving irrigation  equipment.

             Bulletin for Users of Agricultural Pesticides  Page 3

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Many of the WPS
provisions do not go
into effect until
April 15, 1994, to
allow employers
time to learn about
the requirements
and make
arrangements to
comply.
* However, prior to
 April 15, 1994,
 employers must
 assure that all
 labeling-required
 PPE is worn, even
 though they are
 not required to
 provide, clean, or
 maintain the PPE
 until April 15,
 1994.
                  WPS  Requirements
               On And After April 15, 1994

In general, the Worker Protection Standard (WPS) provisions that
go into effect on April 15, 1994, include

 Display of information  at a central location, including WPS
  safety poster, information about the location of emergency
  medical facilities, and a  list of recent pesticide applications.

* Pesticide safety training.

 Decontamination sites.

 Employer information exchange between employers of
  agricultural workers (i.e., growers) and employers of
  commercial (for-hire) pesticide handlers.

 Emergency assistance, including transportation to medical care
  and information to medical personnel or your employees.

 Notice of applications, for products that allow a choice of
  warning  workers orally or by posting treated areas.

* Monitoring of handlers who are using highly toxic pesticides.

 Specific instructions for handlers, including labeling
  information and safe operation of application equipment.

 Equipment safety, including inspection and maintenance.

* Many duties related to  personal protective equipment
  (PPE),* including providing, cleaning, and maintaining it,
  preventing heat illness, and allowing exceptions to PPE.

 Many duties related to  early entry, including training and
  instruction, decontamination sites,  and  providing,  cleaning, and
  maintaining personal protective equipment*.

 Special application restrictions in nurseries and
  greenhouses.
                                      Bulletin for Users of Agricultural Pesticides  Page 4

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WPS Accelerated Requirements: Detailed Information
LABEL REQUIREMENTS

As  soon  as  you  use,  in the  production  of
agricultural plants, a pesticide with the Worker
Protection   Standard  (WPS)   reference
statements on  the pesticide  label, you must
comply with the following requirements, if they
are listed on the pesticide label:

  Personal protective equipment (PPE).

  Double notification (a requirement  on some
   labels  to  provide  oral warnings  to your
   workers  AND  post  warning   signs   at
   entrances to treated areas).

  Restricted-entry intervals.

The Worker Protection Standard 
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WPS Accelerated Requirements:  Detailed Information
   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.

  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.
based  on the toxicity  of  the product active
ingredient.
   While warnings are encouraged for all parsons
   who may be exposed to pesticides, owners of
   farms, forests, nurseries, and greenhouses are
   NOT required  to orally warn members of their
   immediate families, They also need not post
   entrances to treated areas if the only workers
   who may come close enough to the treated
   area to cause the posting to be required  are
   members of their immediate family.  For more
   information   about   the   exemption   for
   agricultural owners  and their families,  see
   "The  Worker  'Protection   Standard   for
   Agricultural Pesticides - How To Comply,"
   Until April 15, 1994, you may use any sign
   that clearly tells workers to keep out of the
   treated; area.  By Apnf 15, 1994, signs must
   be of the design and meet the criteria required
   by the WPS,  Such signs should be available
   from the major agricultural sign producers.
RESTRICTED-ENTRY INTERVALS

In general,  you must  keep workers out of a
treated area during the restricted-entry interval
(RED.  The  REI is the  time after the end of a
pesticide  application during which  entry into
the treated area is limited. In general, REIs are
   Some pesticide labels require a long REI for
   arid areas.  A label might say, for example;
   "72 hours  tn outdoor  areas where average
   annual rainfall is less than 25 inches a year."
   You can get  information on average annual
   rainfall for your area from any nearby weather
   bureau, such  as one located at a local airport
   or  one  affiliated with  the  National Oceano-
   graphic and Atmospheric Administration, .
In general,  an  REI has only two  types of
exceptions:  (1) early entry with no contact and
(2)  early  entry  with contact  for  short-term,
emergency,  or specially excepted  tasks.  No-
contact early entry --   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. (Note: Avoiding contact by
using personal protective equipment does NOT
qualify as "no contact.")

Early entry with no contact:  You may permit
workers into a treated area (after any inhalation
exposure  level or ventilation criteria  has been
met) during an REI if they will NOT touch or be
touched by any  pesticide residues,  including

  On plants, including both agricultural  plants
   and weeds.
  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.
                                          Bulletin for Users of Agricultural Pesticides Page 6

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WPS Accelerated Requirements: Detailed  Information
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
   other 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 performing  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.
   No-contact early-entry workers do NOT have
   to  wear the PPE required  on  the pesticide
   labeling for early entry with contact.
Early entry with  contact  --  If workers will
contact anything that has been treated with the
pesticide to which the restricted-entry interval
applies,  you   may  permit  them  to  enter
pesticide-treated areas  in  only three  work
situations:

  Short-term  tasks that last less than 1 hour
   and do not  involve hand labor.
+  Specific tasks approved by EPA through a
   formal exception process.
+  Emergency tasks that take place because of
   an agricultural emergency.
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 they wear the PPE
required  on the  pesticide labeling  for  early
entry.

Examples of short-term tasks NOT considered
hand  labor  include  operating,  moving,  or
repairing irrigation or  watering  equipment not
used to apply pesticides.

You must make sure each 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 pesticide labeling has been
   reached, AND
*  Spends no  more than  1 hour in a 24-hour
   period on short-term early-entry tasks.
   Entering either enclosed or outdoor fumigated
   dreds to ventilate, remove coverings used in
   the fumigation, such as.tarpa, or measure air
   concentration levels i$ a handling task, not
   early, entry,  Only  appropriately  equipped
   handlers can perform such tasks.
EPA-approved exceptions: EPA has established
a  formal  regulatory 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   Service,   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.
                                          Bulletin for Users of Agricultural Pesticides  Page 7

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WPS Accelerated Requirements: Detailed Information
Tasks during an agricultural emergency:  You
may allow  workers to enter treated areas
before  the restricted-entry interval is over to
perform tasks that are necessary because of an
agricultural  emergency (described below),  if
you make sure they wear the PPE required on
the pesticide labeling for early entry. You must
make sure each worker

  Performs only those tasks required by the
   emergency, AND
  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 pesticide labeling has been
   reached or any WPS ventilation criteria have
   been  met.

WHAT IS AN AGRICULTURAL EMERGENCY?

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.

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 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 failed 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.

"THE WORKER PROTECTION STANDARD FOR
AGRICULTURAL  PESTICIDES  --   HOW  TO
COMPLY"

The EPA is preparing a complete manual on the
WPS for agricultural employers: "The Worker
Protection Standard for Agricultural Pesticides
--  How  To  Comply."  The  manual will  be
available   in  April  1993.   Call   the  EPA
Occupational  Safety  Branch  for  ordering
information.  (703) 305-7666.
                                        Bulletin for Users of Agricultural Pesticides  Page 8

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