REGULATORY IMPACT ANALYSIS
OF WORKER PROTECTION STANDARD
FOR AGRICULTURAL PESTICIDES
OFFICE OF PESTICIDE PROGRAMS
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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REGULATORY IMPACT ANALYSIS OF
WORKER PROTECTION STANDARD
FOR AGRICULTURAL PESTICIDES
Prepared by:
Biological and Economic Analysis Division
Office of Pesticide Programs
U.S. Environmental Protection Agency
Washington, D.C. 20460
with support from:
DPRA Incorporated
EPA Contract No.: 68-D1-0134
Work Assignment No.: 1-3
August 11, 1992
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REGULATORY IMPACT ANALYSIS OF
WORKER PROTECTION STANDARD
FOR AGRICULTURAL PESTICIDES
Prepared by:
Biological and Economic Analysis Division
Office of Pesticide Programs
U.S. Environmental Protection Agency
. Washington, D.C. 20460
with support from:
DPRA Incorporated
EPA Contract No.: 68-D1-0134
Work Assignment No.: 1-3
August 11, 1992
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PREFACE
This revised regulatory impact analysis represents a major update to a draft RIA completed in
March of 1991. This revised RIA incorporates new cost analysis and an expanded benefits
analysis reflecting revisions to the rule, review comments on the draft RIA and rule, new
findings and data on farm workers and pesticide use and revised methodology. Louis True,
Special Assistant to the Office Director, Office of Pesticide Programs (OPP), EPA, directed
the preparation of the overall mlemaking package of which this report is a part. This RIA
was prepared under the direction of Joseph Hogue, Biological and Economic Analysis
Division (BEAD), OPP, EPA. Key EPA contributors to the report were:
Sally McDonald, OPP, EPA;
Joseph Reinert, Office of Policy, Planning and Evaluation (OPPE), EPA;
Jerome Blondell, Health Effects Division (HED), OPP, EPA; and
James Boland, Field Operations Divisions (FOD), OPP, EPA.
Economic and cost analysis support was also provided by DPRA Incorporated with key staff
being Joanne Blair and Daniel W. Francke.
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TABLE OF CONTENTS
Page
I. INTRODUCTION 1-1
A. Purpose of Analysis 1-1
B. Description of the Regulation 1-2
C. Requirements for Analysis 1-3
D. Methodology . . 1-4
D. SUMMARY OF FINDINGS H-l
ffl. NEED FOR REGULATION AND ALTERNATIVE APPROACHES m-1
A. Overview of Pesticide Usage and Agricultural Worker Exposure H[-l
B. Overview of Adverse Health Effects IH-12
C. Alternative Approaches to Reducing Worker Exposure to Pesticides HI-15
IV. COMPLIANCE COSTS AND ECONOMIC IMPACT ANALYSIS TV-1
A. Total and Incremental Costs by Cost Factor IV-1
B. Economic Impacts by Agricultural Sector ; IV-4
C. Economic Impacts: Annualized Costs by Agricultural Sector IV-12
D. Economic Impacts on Agricultural Workers IV-19
E. Economic Impacts on Registrants IV-21
F. Economic Impacts on States, Tribes, and Territories IV-22
V. BENEFITS ASSESSMENT V-l
A. Benefits to Agricultural Workers and Pesticide Handlers V-2
1. Acute (and Allergic) Effects V-3
a. Hospitalized acute poisoning incidents V-3
b. Nonhospitalized physician-diagnosed acute
poisoning incidents V-4
(1) Use of California data to estimate national
physician-diagnosed incidents V-5
(2) Extrapolation method for this analysis V-8
(3) Estimate of national physician-diagnosed incidents V-10
c. Concerns about pesticide-incident reporting systems V-ll
(1) Workers must perceive that they have
treatable symptoms V-12
(2) Workers must seek medical attention V-12
(3) The physician must diagnose the symptoms
as being pesticide related V-13
(4) The incident must be reported to the correct
recordkeeping system and be recorded as being
pesticide-related V-15
d. Nonphysician-diagnosed acute poisoning incidents V-17
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TABLE OF CONTENTS (Cont'd)
Page
2. Delayed effects V-20
a. Carcinogenic (cancer) effects V-21
b. Developmental and reproductive effects V-24
c. Persistent neurotoxic effects V-24
3. Cost comparison to estimated cases avoided V-29
4. Support for regulation V-34
B. Benefits to Users V-36
C. Benefits to Registrants V-38
D. Benefits to States, Tribes, and Territories V-39
REFERENCES V-41
VI. IMPACTS ON SMALL ENTITIES VI-1
A. Impacts on Family-Operated Establishments ". VI-2
B. Impacts on Hired-Labor Establishments According
to Number of Hired Employees VI-3
C. Impacts on Other Small Entities VI-7
VE. LIMITS OF THE ANALYSIS '. VD-1
A. Need for Additional Data VII-1
B. Potentially Overestimated Compliance Costs VII-3
1. Restricted-Entry Interval (REI) VH-3
2. Personal Protective Equipment (PPE) VH-4
3. Notification VII-4
4. Training VII-5
5. Decontamination VII-5
6. Emergency Assistance VI3-6
7. Forestry VII-6
8. Pesticide Labeling changes VH-6
BIBLIOGRAPHY
APPENDIX A - Compliance Cost Calculations and Documentation by Cost Factor
APPENDIX B - Compliance Costs to Forestry
APPENDIX C - High and Low Options
APPENDIX D - Small Entities Cost Data
111
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LIST OF TABLES AND FIGURES
TABLES
Page
Table m-1 Number of agricultural establishments with and without
hired labor, acres grown, and size of establishment, 1990 . . . m-3
Table 1H-2 Hired labor activities on agricultural establishments
with hired labor, 1990 HI-4
Table EQ-3 Establishments with family or hired labor that use pesticides,
by crop or crop grouping, 1990 IH-5
Table IH-4 Unpaid workers and agricultural operators handling pesticides
or potentially entering treated fields, by crop or
crop grouping, 1987 ffl-6
Table 113-5 Estimated number of commercial handlers of agricultural
pesticides by category, 1990 ni-8
Table D3-6 Annual average days of agricultural work, days performing
fieldwork, and days handling pesticides for agricultural
workers, commercial handlers, and hired and
family-member handlers ni-10
Table HI-7 Expected probability that agricultural workers are within
1/4 mile of fields after applications of pesticides
with 48/24/12 hour restricted-entry intervals . . m-13
Table IH-8 Acre-treatments of pesticides: 1989 numbers and percentages
by pesticide restricted-entry intervals IH-14
Table ffl-9 Baseline, revised rule, and high and low options
considered in the WPS development DI-17
Table IV-1 Summary of total first year user compliance costs for the
revised final rule, high option, and low option IV-2
Table IV-2 Summary of incremental first and out year user compliance costs ....... IV-5
Table IV-3 First year incremental WPS compliance costs by cost
factor and agricultural sector FV-6
Table IV-4 Out year incremental WPS compliance costs by cost factor
and agricultural sector FV-8
IV
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LIST OF TABLES AND FIGURES (cont'd)
Table IV-5 Number of establishments, acres planted, market value,
compliance costs, and compliance costs as a percentage
of market value by agricultural crop sector . . IV-10
Table FV-6 Annualized WPS incremental compliance costs by industry,
constant 1991 dollars, discounted at 10% for 10 years . IV-15
Table FV-7 Annualized WPS incremental compliance costs by industry,
constant 1991 dollars, discounted at 6% for 10 years IV-16
Table IV-8 Annualized WPS incremental compliance costs by industry,
constant 1991 dollars, discounted at 3% for 10 years FV-17
Table FV-9 Annualized WPS incremental compliance costs by industry,
constant 1991 dollars, discounted at 0% for 10 years IV-18
Table VI-1 Worker Protection Standard costs for small (without hired
employees) versus large (with hired employees) crop production
establishments, 1991 dollars VI-4
Table Vl-2 Incremental costs of compliance per year, for representative
establishments with different levels of hired employees VI-8
FIGURES
Figure IV-1 Incremental first year WPS compliance costs and percent of
total incremental costs by agricultural sector IV-7
Figure IV-2 Incremental out year WPS compliance costs and percent of
. total incremental costs by agricultural sector FV-9
Figure VI-1 Incremental costs of compliance for different establishment
sizes and number of employees VI-9
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REGULATORY IMPACT ANALYSIS OF WORKER
PROTECTION STANDARD FOR AGRICULTURAL PESTICIDES
I. INTRODUCTION
A. Purpose of Analysis
The Environmental Protection Agency (EPA or Agency) is responsible for regulating the use
of pesticides in the United States. The legal authority for this regulation is found in the
Federal Insecticide, Fungicide and Rodenticide Act (FTFRA), as amended. FIFRA requires,
among other things, that pesticides may only be used to the extent that their usage does not
cause unreasonable adverse effects on the environment. Unreasonable adverse effects on the
environment are defined to Include "any reasonable risk to man or the environment, taking
into account the economic, social, and environmental cost and benefits of the use of any
pesticide."
The Agency has recognized that risks to humans from pesticides may result from occupational
exposure to pesticides and their residues during fieldworker activities that involve contact
with treated surfaces and pesticide handling (mixing, loading, applying, etc.) activities. The
Agency is revising Parts 170 and 156 (40 CFR) to afford agricultural workers and pesticide
handlers better protection from risks resulting from occupational exposure to pesticides.
Agricultural workers are persons who are occupational^ exposed to agricultural-plant
pesticides either indirectly through contact with residues on treated plants, soil, or water, or
directly through accidental contact mainly with drift or misdirected application. Pesticide
handlers are persons who mix, load, apply, or otherwise come into direct contact with
pesticides through related pesticide-use activities. This report presents the results of a
regulatory impact analysis to support the final regulation.
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B. Description of the Regulation
The current 40 CFR 170 entitled, Worker Protection Standard (WPS) for Agricultural
Pesticides, was promulgated in 1974. The regulation deals with the occupational health and
safety of farmworkers performing hand-labor operations in fields during and after application
of pesticides. The regulation currently in effect consists of four requirements: 1) a
prohibition against exposing field workers to pesticides either directly or through drift during
application; 2) the establishment of certain reentry intervals; 3) specification of the protective
clothing that must be worn by a worker entering a field before the end of a reentry interval;
and 4) warnings to workers about prior or future pesticide applications to fields. The Agency
believes that the current 40 CFR 170 is now inadequate with respect to its scope of coverage
and specific requirements.
The revisions to Part 170 include substantial changes in the following areas:
1) change in the scope of current regulations to include non-hand-labor crops on
farms and to include nurseries, greenhouses, and forests;
2) change in scope to include persons who handle pesticides;
3) expansion of the requirements regarding restricted-entry intervals, including the
establishment of interim restricted-entry intervals based on the acute toxicity of
the component active ingredients of the pesticides;
4) standard requirements for personal protective equipment to be worn during the
handling of pesticides and during entry (when such entry is permitted) into
treated areas before restricted-entry intervals have expired;
5) more extensive requirements to provide information about pesticides hazards to
workers and handlers, including mandatory pesticide safety training;
6) new requirements for the posting of treated areas and oral notification about
pesticide treatments on agricultural establishments and for posting pesticide
specific treatment information in a central location;
7) new decontamination requirements; and
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8) new requirements to provide transportation for emergency medical treatment
and to provide labeling information in cases of suspected poisoning or injury
from pesticides.
The final rule also addresses selected labeling issues, expanding upon the current 40 CFR,
Part 156 entitled, Labeling Requirements For Pesticides and Devices. This regulation first
appeared in 40 FR 28268, July 3, 1975. General aspects related to labeling contents,
legibility, language, labeling placement, misleading statements, and final printing requirements
are covered in the current rule. Current labeling requirements also cover 'aspects related to
product quality and content, hazard warning statements, first aid, directions for use, and use
classification.
The revision to Part 156 will add a new Subpart K entitled,'Worker Protection Statements.
This new Subpart will address labeling improvements related to restricted-entry statements,
notification statements, personal protective equipment statements, application restriction
statements, certain product identification statements, Spanish-language statements, and WPS
reference statements.
C. Requirements for Analysis
This report is intended to meet the requirements for regulatory analysis as established by
Executive Order No. 12291, the Regulatory Flexibility Act and Section 25 of FIFRA, This
document also provides input for preparation of any analysis which might be required under
the Paperwork Reduction Act of 1980.
Executive Order 12291 requires that adequate information concerning the need for, and
consequences of a proposed regulatory action be presented. The order requires a finding that
potential benefits to society from a regulation would outweigh its potential costs; and that, of
all alternative approaches for achieving a regulatory objective, the proposed action will
maximize net benefits to society. In effect, a rigorous cost/benefit analysis should be
prepared to the extent that data permit. This analysis is to show that reasonable alternative
approaches were adequately considered. Finally, Executive Order 12291 recognizes that legal
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constraints may play a role in selecting among alternative approaches to achieving regulatory
objectives.
The Regulatory Flexibility Act requires agencies issuing regulations to pay special attention to
the impact of proposed regulations on small entities, and attempt to minimize these impacts.
The analytical requirements of the Regulatory Flexibility Act are to be combined with the
analysis required under Executive Order 12291.
FIFRA, in Section 25, requires that the Administrator of EPA consider such factors as the
effects of regulation on production and prices of agricultural commodities, retail food prices
and otherwise on the agricultural economy, when issuing regulations affecting the sale and
use of agricultural pesticides.
D. Methodology
Cost estimates for the final WPS rule were derived on a unit-by-unit basis for eight major site
categories: feed and grain crops, cotton, tobacco, other field crops, vegetable/fruit/nut crops,
nursery/greenhouse crops, forestry crops, and commercial pesticide handling establishments.
Cost estimates for commercial pesticide handling establishments include costs applicable to
commercial ground applicators, commercial aerial applicators, and commercial support
personnel. Seven R1A cost factors are detailed under each category if applicable: restricted-
entry, personal protective equipment, notification, training, decontamination, emergency
assistance, and rule familiarization. One additional RIA cost-factor was estimated for the
+
high cost option only: cholinesterase monitoring.
Cost factors for the seven major categories were derived by multiplying the cost of the factor
by a unit measurement. Costs for restricted-entry were estimated by multiplying the base
acreage of affected crops by the per-acre income (or yield/quality) loss that would occur if the
new restrictions on routine entry to pesticide-treated areas to perform hand labor tasks during
the restricted-entry interval were enacted. In addition, restricted-entry costs were added for
providing personal protective equipment, labeling-specific information, and decontamination
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to early entry workers to perform tasks on cut flowers and cut ferns provided this exception is
granted. Personal protective equipment costs were derived on a per handler basis and then
multiplied by the total number of commercial, hired, and family member handlers
respectively. Costs due to notification were calculated by multiplying average per
establishment costs by the total number of affected establishments. Training costs were
derived on a per handler/per worker basis (like personal protective equipment) and then
multiplied by the total number of hired (including commercial) handlers, and hired workers.
Costs for commercial handlers' decontamination were estimated on a per handling site basis
.and then multiplied by the total number of sites (1.5 handlers per site). Decontamination
costs for noncommercial hired handlers and for hired workers were calculated on a per person
basis and then multiplied by the total number of hired handlers and hired workers.
Emergency assistance costs were derived through multiplying the estimated number of
physician-attended hired worker and hired handler poisoning incidents by the per-person per-
incident cost of transportation to a medical facility and the per-person per-incident cost of
conveying information to medical personnel. Finally, the cost to agricultural establishment
owner/operators of becoming familiar with the WPS was calculated through multiplying the
estimated time it would take for an owner/operator on each establishment to become familiar
with the WPS by the owner/operator wage rate. This per-establishment cost of familiarization
was then multiplied by the total number of establishments.
The sum of all cost factors for all site categories is the total estimated cost of the final rule to
the pesticide user community. Incremental costs were derived by subtracting costs which are
currently being incurred by the pesticide user community from total compliance costs. The
one-time cost of labeling changes estimated for registrants is not subdivided or included in
other cost factors. This cost to registrants is presented separately and added to user costs to
get estimated total costs of the final rule.
1-5
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H. SUMMARY OF FINDINGS
1. The Environmental Protection Agency (EPA) under the authority of the Federal
Insecticide, Fungicide and Rodenticide Act (F1FRA) has responsibility for regulating the
sale and use of pesticides. Included in its mandate, EPA has the responsibility for
protecting agricultural workers from risks resulting from exposure to pesticides.
2. EPA is revising Parts 170 and 156 of CFR 40 to specify requirements that would
mitigate the risks to pesticide handlers and agricultural workers from occupational
exposure to agricultural pesticides and their residues.
3. EPA is issuing a regulation with additions or changes in the following areas: restricted-
entry intervals, personal protective equipment, training, notification, decontamination,
emergency assistance, and labeling changes. The regulatory development process,
including a formal negotiation mechanism under the Federal Advisory Committee Act,
has developed, considered, analyzed and chosen from among many approaches for
achieving the desired regulatory goals. This RIA summarizes the costs and benefits of
the regulation and the significant options that were considered.
4. U.S. agricultural pesticide usage in 1989 is estimated at 806 million pounds a.i. While
the following table includes usage on livestock establishment sites that are not covered
by the regulation, the majority of the pesticide use is on food, feed, and fiber crops, and
commercial tree species, ornamentals, and turf, all of which are covered by the
regulation.
n-i
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U.S. Pesticide Usage-Agriculture
Herbicides
Insecticides
Fungicides
Other
TOTAL
Million Ibs.
a.i.
520
151
65
J70
806
Percent of
Total
65
19
8
_£
100
Source: EPA/BEAD. 1991 (July). Pesticide Industry Sales and Usage: 1989
Market Estimates. Washington, DC.
5. The estimated hired labor force of 1.5 million persons occupationally exposed to
pesticides on agricultural-plant establishments, either directly or indirectly, includes 1.4
million hired workers/handlers on farms, 92,000 hired workers/handlers in
nursery/greenhouses, 10,000 hired workers/handlers in forestry, and 38,000 commercial
pesticide handlers.
6. Of the 1.4 million hired workers/handlers on farms, it is estimated that nearly 581,000
are pesticide handlers; of the 92,000 hired nursery/greenhouse workers/handlers, 37,000
are estimated to handle pesticides; and of the 10,000 hired forestry workers/handlers,
nearly 7,300 are estimated to handle pesticides. By definition, all of the 38,000
commercial pesticide handlers handle pesticides. In total, it is estimated that 663,000
hired employees handle pesticides for use on agricultural plants.
7. There are an estimated 2.4 million unpaid or family-member agricultural
workers/handlers occupationally exposed to pesticides. Of these, nearly 1.0 million are
farm operators, all of which are assumed to handle pesticides. The remaining 1.4
million unpaid/family-member employees are assumed to be agricultural workers who
never handle pesticides.
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First year incremental costs, may be estimated from total costs, given existing regulations
at the state and federal level, and voluntary compliance. Since all costs are not incurred
every year, an "out" year incremental cost, or annual cost after the first year, can be
projected. Estimated costs, by cost factor, are presented below:
> * *
Werker
'First year
, te&l«K*
COST FACTOR - TO AGRICULTURAL
ESTABLISHMENTS
Restricted-Entry Interval
Personal Protective Equipment
Notification
Training
Decontamination
Emergency Assistance
Rule Familiarization
Total
COST TO COMMERCIAL HANDLER
Personal Protective Equipment,
Training, Decontamination,
Emergency Assistance, and Rule
Familiarization
COST TO REGISTRANTS
Labeling Changes
TOTAL
39.4
78.7
16.8
11.1
30.2
.04
6.1
$182.3
FIRMS
7.8
12.0
$202.1
Protection Sta
1 €>«iyfc«r
.. total cost
udard «BB|>&a
Brstyear
jtacranefttsif
•cost
ace costs
Out ysar
incremental
cost
(Million $)—
39.3 21.1 21.1
37.4
6.1
3.8
23.2
.04
1.0
$110.8
4.8
0.0
$115.6
17.9
15.7
6.9
12.4
.01
6.0
$80.0
2.3
12.0
$94.3
9.5
5.0
2.3
8.9
.01
1.0
$47.8
1.6
0.0
$49.4
While significant numbers in themselves, the above totals are relatively small when
compared to user expenditures for all agricultural pesticides in the U.S. The total user
expenditure for all conventional agricultural pesticides in 1988 is estimated at $5.11
billion (U.S. EPA, 1990). The Worker Protection Standard incremental out year costs
represent less than one percent of 1988 total agricultural pesticide expenditures.
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9.
Another way to view the relative impacts of the WPS is to compare compliance costs
with the value of the crops affected. With total incremental out year compliance costs
estimated to be approximately $49 million and the total value of the affected crops
estimated at nearly $51 billion, WPS incremental out year compliance costs account for
less than one-tenth of one percent of the total value of the affected crops.
Costs associated with the regulation would affect sectors of the agricultural economy
according to the intensity and type of pesticides used in each sector. The estimated
incremental compliance costs to the user community of the regulation by sector, per
establishment, is as follows:
Fer «stsb!l$htiwfiit Worker f^oKsdloft
Standard. <# wHanee costs
l&er .sector
Incremental first
year cost
Incremental out \
year -cost ;
/£ /CffoViliriViT-n^r^
Feed and Grain Crops
Cotton
Tobacco
Other Field Crops
Vegetable/Fruit Crops
Nursery/Greenhouses
Commercial Handler Firms
70 30
135 63
1.16 49
118 43
440 357
190 105
247 176
Source: Table IV-5.
Note: The cost to forestry is relatively insignificant and is not applicable on a per
establishment basis. (See Appendix B for total sector cost calculation.)
10. The revised WPS will produce a wide range of benefits for various sectors associated
with the sale, oversight, or use of agricultural-plant pesticides. Agricultural workers and
pesticide handlers will derive the most substantial benefits. By lowering their
occupational exposures to such pesticides, the WPS will enable them to have improved
health and a better quality of life. Pesticide users, registrants, states, tribes, and
territories should also receive direct and indirect benefits from the WPS.
H-4
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m. NEED FOR REGULATION AND ALTERNATIVE APPROACHES
" A. Overview of Pesticide Usage and Agricultural Worker Exposure
Annual usage of pesticides in the United States in 1989 was estimated to be about 1.07 billion
pounds active ingredient (a.i.) (U.S. EPA, 1991). This total does not include about 1.6 billion
pounds annual use of disinfectants and wood preservative chemicals, which FIFRA also
defines as pesticides. Nor does it include about 200 million pounds of sulfur which has
pesticidal properties in many uses. The revised Worker Protection Standard contains
requirements to protect workers and handlers who may be occupationally exposed to
agricultural pesticides or their residues. Pesticide use on food, feed, fiber, commercial tree
species, ornamental and turf plants (on farms or in nurseries),•commercial forests, or
greenhouses, and related structures is the targeted exposure. Other uses of pesticides are not
covered by the final rule. The following is a breakdown of the 1989 total annual usage of
agricultural pesticides:
Type of pesticide
Herbicides
Insecticides
Fungicides
Other
TOTAL
. Total
MiHron
J$W* A. 3 D
BWS*. Rrfk air
655
226
111
78
1,070
P0&
kaiieUsaee '
>
" - "
, , ' Agriculture
eitsaat
61
21
10
7
100
Million
i&$. *A. :
520
151
65
70
806
• ' *^
Peroeet
65
19
8
9
100
irtsewt of total
ia agrlfioltn
79
67
59
90
75
usage
rt
Source: EPA/BEAD, 1991 (July). Pesticide Industry Sales and Usage: 1989 Maritet Estimates.
Washington, DC.
Another way to view pesticide usage and potential exposure involves the concept of "acre-
treatments," which is one acre of crop receiving one application of a pesticide. This term
allows for the identification of multiple applications on the same crop-acre throughout the
growing season. The Worker Protection Standard is triggered, in some instances, by the
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toxicity category of the active ingredients contained in pesticides as well as the frequency
with which pesticides are applied. In 1989, out of a total annual 562 million acre-treatments
of agricultural-plant pesticides, about 31 percent were toxicity category I applications (highest
toxicity), 18 percent were toxicity category II applications, and 51 percent were toxicity
category ffl-IV applications. Approximately 67 percent of total 1989 U.S. agricultural-plant
pesticide acre-treatments were on feed and grain crops, primarily because of the large acreage
involved.
One focus of the Worker Protection Standard is the health and safety of the hired labor force
employed to work in the production of agricultural plants. Table ni-1 provides estimates of
the number and size of agricultural establishments with and without hired labor. According
to USDA, nearly half of the 688,000 U.S. crop-producing farms, nurseries, and greenhouses
hire employees. However, the agricultural establishments that do hire employees account for
over 123 million acres of crops or 72 percent of the total crop acreage. Moreover, an average
farm with hired labor averages 362 acres compared to a crop farm with family labor only,
which averages 136 acres. As shown in Table IH-2, there are approximately 1.6 million hired
employees on agricultural-plant establishments (Oliveira and Cox, 1989). Some hired
employees work on agricultural establishments that do not use pesticides and, after such an
adjustment, nearly 1.5 million hired agricultural employees are potentially occupationally
exposed to pesticides as pesticide handlers, agricultural workers, or both.
Also on WPS-covered agricultural establishments are many family and unpaid laborers who
also may be exposed to pesticides and for whom many of the provisions of the final rule are
intended. Unpaid workers are found on approximately 309,000 agricultural establishments
using pesticides that also have hired labor, and on about 250,000 agricultural establishments
using pesticides with only family or unpaid labor (Table DI-3). In 1987, agricultural
establishments using pesticides were estimated to include nearly 2.4 million owner/operators,
family members, and other unpaid workers either handling pesticides or potentially exposed to
pesticides in treated areas (Table ni-4). Of the approximately 2.4 million unpaid (family)
owner/operators and workers, nearly 1.0 million are estimated to handle pesticides (handlers),
while almost 1.4 million are estimated to never handle pesticides (workers). Of the total
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able 111-1. Number of agricultural estabishmerrts with and withoirt hired labor, acres grown, and size of establishment, 1990.
RQTOKDP ~
ROUPING
EED & GRAIN
OTTON
OBACCO
TTHER FIELD
EG/FRUIT/NUT
URSERY/G.H.
OTAL
CD
—NUMBER Of* ESTABy$HMENTS—
TOTAL , WITHOUT WTTK
338,000
22,000
76,000
123,000
92,000
37,000
688,000
196,000
6,000
21,000
76,000
31,000
17,000
347,000
142,000
16,000
55,000
47,000
61,000
20,000
341,000
TOTAL
128,000,000
13,700,000
4,200,000
16,000,000
7,900,000
800,000
170,600,000
(2}
•uwmomow
HIRED LABCm
41,800,000
800,000
400,000
3,600,000
500,000
100,000
47,200,000
wrm
HtREDlABOR
86,200,000
12,900,000
3,800,000
12,400,000
7,400,000
700,000
123,400,000
ttL VS/ltHOUT WflfB
- „ HIRED lABOFt HIRED IABOR
379
623
55
130
86
22
248
213
133
19
47
16
6
136
607
806
69
264
121
35
362
OURCES:
;),(2); USDA. 1990 Farm Costs and Returns Survey.
)); Calculated from (1) and (2).
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TABLE 111-2. Hired labor activities on agricultural establishments with hired labor, 1990.
WTH HIRED
iOTABUSHMBRTS IA80R '
m
WTAt 1STAB,
m m
(10}
WORKERS
m...
FEED & GRAIN
COTTON
TOBACCO
OTHER HELD .
VEG/FRUIT/NUTS
NURSERY/G.H.
TOTAL
338,000
22,000
75,000
123,000
93,000
37,000
142,000
16,000
55,000
47,000
61,000
20,000
11% '
6%
24%
42%
15%
15%
37,180
1,320
18,000
51,660
13,950
5,550
25%
25%
25%
25%
25%
25%
9,295
330
4,500
12,915
3,488
1,388 .
132,705
15,670
50,500
34,085
57,513
18,613
558.000
105,000
136.000
317.000
418,000
99,000
3.9
6.6
2.5
6.7
6.9
5.0
265,410
31,340
101,000
68,170
115,025
37,225
256.065
71.494
23,873
161.722
279.077
~ 54,907
688,000
341,000
19%
127,660
25%
31,915
309,085
1,633,000
4.8
618,170
847,138
SOURCES:
(1 ),(2); U.S. Department of Agriculture. 1990 Farm Costs and Returns Survey (rounded to the nearest 1.000).
(3); U.S. Department of Commerce. 1987 Census of Agriculture (establishments reported as not buying pesticides in 1987).
(4); Calculated, (1)X{3).
(5); Estimated by DPRA Inc. and EPA based on general knowledge.
(6); Calculated, (4)X(5).
(7); Calculated, (2)-(6).
(8); Oiveira, Victor J. and E. Jane Cox. (1989, May). The Agricultural Work Force Survey. U.S. Department of Agriculture.
(9); Calculated. (8V(2).
(10); Estimated assuming two handlers per establishment whh hired labor that use pesticides, 2 X (7).
(11); Calculated; ((9)-2)X(7). These are considered nonhandters.
-------
TABLE II1-3. Establishments with family or hired labor that use pesticides, by crop or crop grouping, 1990.
OROUPNO
FEED & GRAIN
COTTON
TOBACCO
OTHER FIELD
VEG/FRUnVNUTS
NURSERY/G.H.
Comm. Handlers
TOTAL
NUI
Ml'
m
338,000
22,000
75,000
123,000
93,000
37,000
8,500
696,500
^HOFESTASt^
W^H^'iABCKS
142,000
16,000
55,000
47,000
61,000
20,000
341,000
.aj^ms
^jSJutviiTOft
ONLY
m
196,000
6,000
21,000
76,000
31,000
17,000
347,000
no-riot ._,
*
37,180
1,320
18,000
51,660
13,950
5,550
127,660
•ftaewsNOTus
m
9,295
330
4,500
12,915
3,488
1,388
31,915
^#A&&y)Ws88
<*ILY
27,885
990
13,500
38,745
10,463
4,163
95,745
esr
m
300,820
20,680
57.000
71,340
79,050
31,450
8,500
568,840
ftsusiwgwsi
iTO^KtHMOH
132,705
15,670
50,500
34,085
57,513
18,613
309,085
38N&PESTiCIOiS
ONLY
168,115
5,010
7,500
37,255
20,538
12,838
251,255
SOURCES:
(1),(2),(3); U.S. Dept. of Agriculture. 1990 Farm Costs and Returns Survey (rounded to nearest 1,000). Commercial handling establishments from Table III-5.
(4) U.S. Dept of Commerce (1989). 1987 Census of Agriculture (establishments reported as not buying pesticides in 1987).
(5) Calculated, 25% X (4) assuming establishments with hired labor are more likely to use pesticides than establishments with only family labor,
or establishments not using pesticides are less likely to hire labor.
(6) Calculated, (4)-(5). See footnote (5).
(7) Difference between all establishments and those not using pesticides.
-------
Table 111-4. Unpaid workers and agricultural operators handing pesticides or potentially entering treated fields, by crop or crop grouping. 1987.
*******
FEED & GRAIN
COTTON
TOBACCO
OTHER FIELD
VEOVFRUnVNUTS
NURSERYA3.H.
TOTAL
NUMBEROF WUMBEROF
UNPAID UNPA10VVORKERB
V¥OfiK£R$ PER FARM -
675,000 2.0
21,000 1.0
159,000 2.1
478,000 3.9
354,000 3.8
46,000 1.5
1,733,000 2.4
NUMBBROFUNPAID NUMBEROF NUMBgRQF N
WCJRr^RSPOISNTlAliY FARM OPERATORS 1
GXPOSE-OtOpfiSTlCfDES OPERATORS P£RpARM
#} m m
600,710 578,000 1.7
19,759 43,000 2.0
120,840 159,000 2.1
277,085 139,000 . 1.1
300,710 207.000 2.2
46,000 68,000 1.8
1,365,103 1,194,000 1.8
KJMBetOF OPERATOR
^TeNflALiYexposec
m
514.386
40.459
120,840
80,575
175,839
57.892
989.990
TOTAtNUWS
8 AfSUWWOP
) exposeo1
m
514,386
40,459
120,840
80,575
175.839
57,892
989,990
3?<3P UNPAID WORKERS
ERATOmPQTJEaffiAUY
W$wN$ TOW
|^- ^^
600.710 1,115,096
19,759 60.218
120.840 241,680
277,085 ' 357,659
300,710 476,548
46.000 103.892
1.365,103 2,355,094
SOURCES:
(1),(4) U.S. Depsrtment of Agriculture. 1989.1987 Agriculture Wcifc Force Survey.
(2) Calculated. (1) divided by "All establishments- (Table III 3. column (1)). Does not include operators.
(3) Calculated. (2) X Establishments Using Pestkxtes (Table III-3, column 7). None of these unpaid workers handle pesticides (EPA estimate).
(5) Calculated, (4) divided by "AH establishments" (Table III-3, column (1)).
(6) Calculated, (5) X Establishments Using Pesticides (Table III-3, column 7). All of these operators handle pesticides (EPA estimate).
(7) Repeat of (6).
(8) Repeat of (3).
(9) Calculated (7)+{8).
-------
unpaid handlers and workers on agricultural-plant establishments which use pesticides, over
1.1 million (47 percent) were on feed and grain crop farms; about 0.48 million (20 percent)
were on vegetable/fruit/nut farms; and about 0.36 million (15 percent) were on farms with
primarily other field crops (peanuts, dry beans, sugarbeets, potatoes, etc.).
The revised final rule will also provide protection to handlers employed by commercial firms
that apply agricultural pesticides. Growers often contract with commercial firms to apply
pesticides on their property in contrast to application by the grower, the grower's family, or
hired workers, which is commonly termed "private" application. It is estimated that about 60
percent of all agricultural-plant pesticide applications are made by commercial applicators.
However, private application is still widespread on agricultural establishments and many
establishments combine both commercial and private applications. The commercial handler
segment of the agricultural-plant pesticide industry is estimated to comprise about 8,500
commercial pesticide handling establishments including dealer applicators, independent
applicators, and aerial applicators (Table IH-5). Commercial pesticide handling
establishments employ about 38,000 people, all of whom would be considered handlers.
Thus, in total, the population of agricultural workers occupational^ exposed to pesticides is
estimated to be about 3,868,000 annually. The distribution by crop group and type of
exposure is summarized below.
•. •. f
Of-OprCyOft vJ'Qttp
Feed & Grain
Cotton
Tobacco
Other Field
Veg./Fruit/Nuts
Nursery /Greenhouse
Forestry
Commercial Applicators
TOTAL
Hlri
265
31
101
68
115
37
7
38
662
^Handlers!/
>d . Vftpafd/Family
514
40
121
81
176
58
3/
990
fl
Wrcd__,
i 000
256
71
24 .
162
279
55
3
850
forlfe*?* -'"
IktW&fW
601
20
121
211
301
46
1,366
,-.
ty. -T«f»i2/
1,637
163
367
588
871
196
10
38
3,868
Source: Tables HI-2 and III-4; Appendix B for forestry; Table in-5 for commercial handlers.
\j Handlers of pesticides may also work in fields but workers never handle pesticides.
2/ Totals may not add due to rounding.
3/ Includes operators and/or unpaid/family (not farmers).
m-7
-------
TABLE 111-5. Estimated number of commercial handlers of agricultural pesticides by category, 1990.
=1
X3
f '
TYPEQFHANOUER
Ag Chemical Dealer
Independent Appl.
Aerial Applicator
TOTAL
- , OF- , PER - 'PER
E$TA& E$FAE E$TA&
(D m m
5,500 7.6 4
1,000 4 4
2,000 6 6
8,500
, OF .
HANDLERS
; (4)
22,000
4,000
12,000
38,000
""Swit^01^^1
App ^3p
(5) ®
11,000
2,000
6,000
13,000 6,000
'EilO3^*^--**
Support
m :
11,000
2,000
6,000
19,000
Uncertified/Need Training —
Ag Chemical Dealer
Independent Appl.
Aerial Applicator
TOTAL
9,500
0 0
5,500
1,000
3,000
9,500
SOURCES:
(1) DPRA estimate based on conversations with experts within the industry.
(2) For ag chemical dealers, U.S. Dept. of Commerce, Bureau of the Census. 1988 COUNTY BUSINESS
PATTERNS (December 1990). For other categories, DPRA estimate.
(3) DPRA estimate.
(4)Calculated,(1)X(3).
-------
In developing the estimates in the RIA, the question arose as to whether to include livestock
establishments and workers. The Agency is aware that feed is sometimes grown on livestock
establishments and that some of these establishments might be included in the scope of the
Worker Protection Standard due to these feed-production activities. However, the Agency
also recognized that many feed and grain establishments also produce livestock. In neither
case were any data available to indicate how many of these livestock or feed and grain
establishments use pesticides in the production of the feed crops and hire labor to perform
activities associated with those crops within 30 days of the application and restricted-entry
interval. Since hand labor activities are relatively rare in feed crops and pesticides are only
sparsely used on many of these crops, the impact of the WPS on these establishments is
slight. In this analysis, EPA has chosen to include feed and grain establishments and exclude
livestock establishments. The establishments were categorized based on whether crops or
livestock contributed most to the gross sales on the farm. EPA believes there is an over-
estimation due to the inclusion of all establishments and workers on feed and grain farms and
an under-estimation due to the exclusion of all establishments and workers on livestock farms.
Data are unavailable to assess the degree to which these two estimates offset one another.
Under the final rule, hired workers are required to have decontamination materials available
within 1/4 mile of the work site while performing activities or tasks related to the production
of agricultural plants in treated areas within the 30 day period following a pesticide's
application or restricted-entry interval. Hired handlers are required to have decontamination
materials available during all handling activities. Table ni-6 gives the estimated annual
average days of work spent in such a treated area for agricultural workers and days handling
pesticides for commercial and hired handlers.
Data are not available on the frequency of exposure to pesticides of various toxicities by the
agricultural workers identified in Table ni-6. By definition, handlers would always be
exposed. In lieu of pesticide exposure data for agricultural workers, DPRA Incorporated,
along with EPA staff, developed general probabilities that workers would (1) be within 1/4
mile of treated areas during a pesticide application or during the restricted-entry interval
m-9
-------
Table 111-6. Annual average days of agricultural work, days performing fieldwork, and days handling
pesticides for agricultural workers, commercial handlers, and hired and family-member handlers.
AVERAGE DAYSQF WORK
TOTAL
m
DAYS
JHAMXJNQ
(4)
T0TAL
-OAYSHANDUNG-
, (Days)
B
FEED & GRAIN 84 10% 8
COTTON 84 10% 8
TOBACCO 48 50% 24
OTHER FIELD 60 10% 6
VEG/FRUIT/NUT 105 80% 84
NURSERY 137 80% 110
GREENHOUSE 137 100% 137
33
33
33
33
33
33
0
84
84
48
60
105
137
137
6
21
1
3
3
8
50
7%
25%
2%
5%
3%
6%
36%
10%
10%
50%
10%
80%
80%
100%
8
6
24
6
82
103
87
SOURCES:
(1),(5); Ofveira, Victor J. and E. Jane Cox. 1989 (May). The Agricultural Work Force Survey". U.S. Department of Agriculture.
(2),(8); Estimated by DPRA Inc. and EPA based on general knowledge. Reflects time in fields that are within
the 30-day period following a pesticide's restricted-entry interval.
(3); Calculated, (1)X (2).
(4); Commercial handlers based on the following:
-Total number of acre treatments of pesticides per year = 562,400,000 (Table III-8).
-60% of all acre-treatments are appied by commercial handlers (estimated by DPRA and Chris Myrick, National
Agri-Chemicals Retailers Association).
562,400,000 totaF applications X 60% = 337,440.000 applied by commercial handlers.
-Ground applicators can cover 75-80 acres per day (Ohio State University).
-Aerial applicators can cover about 1,000 acres per day (Rick Hardcastte, Texas Ag Aviation Assoc.).
Average acres treated per day = (77.5 +1,000)/2 = 540 acres per day.
-The number of treatment-days per year = 337,440,000/540 = 624,889.
-There are 19,000 commercial ground and aerial applicators (Table III-5).
-The average number of days per year that one commercial applicator applies pesticides:
624,889/19,000 = 32.9
*Note: It is assumed that only hired or family member handlers apply pesticides in greenhouses.
Footnotes continued ...
-------
Footnotes continued from Table 111-6
(6); Hired and family member handlers based on the following:
-Total number of acre-treatments of pesticides per year = 562,400,000 (Table 111-8).
-40% of all acre treatments are applied by hired and family-member handlers (100% - 60% applied by commercial handlers).
562,400,000 total applications X 40% - 224,960,000 applied by hired and family member handlers.
-Hired and family-member handlers only apply pesticides by ground and can cover 77.5 acres per day (See source above).
-The average number of days ft takes to apply one pesticide treatment = acres per establishment per crop (Table 111-1)
divided by the average number of acres treated per day (77.5).
Feed & Grain: 379/77.5 - 4.89 or 5 days.
Cotton: 623/77.5 - 8.03 or 8 days.
Tobacco: 55/77.5 - .710 or 1 day.
Other field crops: 130/77.5 -1.68 or 2 days.
Vegytruh: 86/77.5 »1.11 or 1 day.
Nursery/greenhouse: 22/77.5 - .284 or 1 day.
-The average number of days per year that one hired or family-member handler applies pesticides - the number of days to
apply one pesticide treatment X the average number of treatments applied non-commercially (Appendix A, Table NP-3, column (7)-{8)).
Feed & Grain: 5 days per treatment X1.2 treatments - 6.0.
Cotton: 8 days per treatment X 2.6 treatments - 20.8.
Tobacco: 1 day per treatment X 0.3 treatments - 0.3.
Other field crops: 2 days per treatment X1.2 treatments - 2.4.
Veglruit: 1 day per treatment X 2.8 treatments - 2.8,
Nursery: 1 day per treatment X 7.7 treatments « 7.7.
Greenhouse: 1 day per treatment X 50 treatments = 50.
(7); Calculated, (6)/(5).
(9); Calculated, [(5)-(6)] X 8.
-------
(0-48 hours) (Table ffl-7), or (2) be in treated areas after the expiration of the REI, but within
30 days of the REI (0-30 days) for various categories of pesticides (Table m-6).
This final rule establishes REIs for all agricultural pesticides. In general, highly toxic a.i.s
(toxicity class I) require a 48-hour restricted-entry interval (REI); moderately toxic a.i.s
require a 24-hour REI; and all other a.i.s require a 12-hour REI. Agricultural workers on feed
and grain establishments would seldom have need to be near fields within 48-hours after a
pesticide application, hence the low (5 percent) probability that workers would be present
(Table III-7). However, the likelihood that agricultural workers would be near fields (within
1/4 mile) within 48 hours after a pesticide application on tobacco, vegetable/fruit/nut, and
nursery/greenhouse crops is quite high—80 to 90 percent.
Finally, Table ni-8 shows the estimated acre-treatments of pesticides by restricted-entry
interval and crop grouping. In 1989, a total of 562 million acre-treatments were applied to
the seven1 agricultural crop groupings addressed by this rule. Of the total treatments, 31
percent were pesticides expected to have 48 hour restricted-entry intervals, 18 percent had 24
hour restricted-entry intervals and 51 percent had 12 hour restricted-entry intervals.
B. Overview of Adverse Health Effects
The widespread use of pesticides on agricultural plants, the large number of people working,
and limited worker protection in these areas sets the stage for significant potential
occupational exposure of workers to pesticides and resulting harmful health effects. It is
undisputed that workers and handlers in the agricultural workforce are occupationally exposed
to pesticides and pesticide residues and that such exposures can pose significant short-term
and long-term health risks. The difficulty is in quantifying a specific level of risk and
projecting the risk reduction that will result from this rule. There is, however, strong general
evidence that such
'Pesticide use in forests is very limited. According to a 1991 U.S. Department of
Agriculture publication, less than one percent of the total acreage of national forests and
grasslands were treated with pesticides in 1990.
m-12
-------
Table 111-7. Expected probability that agricultural workers are within 1/4 mile of fields after applications
of pesticides with 48/24/12 hour restricted-entry intervals
Expected Prpba&ityth;at_
* . Workers are VWj #4 Mite
oJFfekfe During a f*esticJde
dW&RQP ApplfcatlonanCtA^NrREf
FEED & GRAIN
COTTON
TOBACCO
OTHER FIELD
VEG/FRUIT/NUTS
NURSERY
GREENHOUSE 21
5%
10%
80%
5%
90%
90%
90%
SqaedeclProtiabllitylhal , _ jBspeetedf^QlKtJilytJat
of Flefcfe During a Pesfekte of Fiekfe Ou^ng a Pesicfc&
^pfic^ortafKiai^4»nrRHt Appjksa8or>and^12%^ '
5%
10% '
50%
5%
50%
50%
50%
0%
5%
10%
0%
25%
25%
25%
&
SOURCES:
(1); Estimated by DPRA, Inc. and EPA based on general knowledge.
21 Greenhouse establishments are based on the expected probability that workers would enter the greenhouse itself.
-------
TABLE II1-8. Acre-treatmerts of pesticides: 1989 numbers and percentages by pesticide restricted-entry intervals
GROUPING
m
FEED & GRAIN
COTTON
TOBACCO
OTHER FIELD
VEG/FRUIT/NUTS
NURSEFIY@
GREENHOUSE®
FORESTRY 3
TOTAL
100.9
31.1
0.6
16.4
17.4
2.5
2.5
171.4
58.9%
18.1%
0.4%
9.6%
10.2%
1.0%
1.0%
100%
27.0%
36.5%
19.4%
43.3%
33.8%
45.0%
45.0%
30.5%
18.6%
58.0%
61.4%
31.2%
45.0%
5.0%
5.0%
502
25.6
0.4
7,6
12.3
2.5
2.5
101.1
49.7%
25.3%
0.4%
7.5%
12.2%
1.0%
1.0%
100%
13.4%
30.1%
12.9%
20.1%
23.9%
45.0%
45.0%
18.0%
221.0
27.1
1.6
13.7
21.5
0.5
0.5
296
77.3%
9.5%
0.6%
4.8%
7.5%
1.0%
1.0%
100%
59.1%
31.8%
51.6%
36.1%
41.7%
10.0%
10.0%
50.8%
373.8 66.5%
85.1 15.1%
3.1 0.6%
373 6.7%
51.5 9.2%
5.5 1.0%
5.5 1.0%
562.4 100.0%
' Includes most of the active ingredients with REI's longer than 48 hours.
@ 1987 Agricultural Census. Horticultural specialties producers represent about 2% ol the expenditures by all users for al agricultural
chemicals. This is assumed to be split evenly between nurseries and greenhouses.
SOURCES:
(1); EPA proprietary data.
(2);CateUatedfrom(1).
(3); (1) divided by al acre treatments of pesticides.
(4); EPA proprietary data. Represents trie percentage of all 48-hr REI pesticide acre-treatments that are toxidty category I due to dermal
toxidty or skin irritation potential.
(5); Pesticide use in forests is very limited. In 1990, less than one percent ol the total acreage of national forests and grasslands were
treated with pesticides (USDA. Report of the Forest Service Fiscal Year 1990).
-------
risks are pervasive and that they can be substantially reduced through simple exposure-
mitigation measures.
Adverse health effects to agricultural workers from occupational exposures to agricultural-
plant pesticides include:
• acute effects,
• allergic or sensitization effects, and
• delayed effects.
The view that farmworkers suffer significant adverse health effects from pesticides is shared
by other institutions. EPA's Science Advisory Board concluded in 1990 that agricultural
workers are exposed to many toxic substances and such exposure can cause cancer and a
wide range of non-cancer health effects. In 1992, the U.S. General Accounting Office
concluded that farmworkers and their children are routinely exposed to pesticides and that
their health and well-being is not adequately protected by Federal laws and regulations.
Finally, the Council of Scientific Affairs of the American Medical Association (AMA) has
identified the health of agricultural workers who are exposed to pesticides as in need of
strong EPA and state regulatory support of occupational health.
C. Alternative Approaches to Reducing Worker Exposure to Pesticides
The Agency intends to promulgate a rule that, as a whole, will reduce agricultural workers'
occupational exposure to pesticides, and hence, will reduce the incidence of adverse acute and
delayed-onset health effects. Except for the cost of labeling changes to registrants, the costs
of the requirements being promulgated in this final rule are in the following categories:
• Restricted-Entry Intervals;
• Personal Protective Equipment;
• Training;
• Notification;
m-is
-------
• Decontamination;
• Emergency Assistance; and
• Rule Familiarization.
For each of these categories there have been a wide range of specific proposals identified by
the Agency and by informed, interested outside groups who participated in this rulemaking
effort. Table ni-9 summarizes the specific requirements of the three major options
considered during the development of the regulation. Labeling changes required of registrants
and rule familiarization are not included in Table IH-9 since the options do not differ
significantly.
Requirements under this Rule were established after extensive evaluation of the risk/benefit
tradeoff between requirement cost and protection provided. For example, a posting
requirement every 100 feet for all areas treated with any pesticide may be considered ideal for
maximum notification safety. This requirement, however, would be expensive for most
growers and may seem unnecessary for large rural producers, such as wheat farms with vast
acreage and no hired workers. Estimated costs for each of the three major options are
presented in the next chapter.
m-16
-------
Table III-9. Baseline, revised rule, and high VK| low options considered ix -VPS development
MA tort factor
0asdid« (torrent practice)
Higb
option
Restricted-Entry Intervals
(REI)
Product-specific REIs on some
pesticides—24 or 48 hours on
most Toxicity I
organophbsphates and n-methyl
carbamates; Sprays have dried,
or dusts have settled, on all
other pesticides used on hand
labor crops.
Short-term tasks, emergencies,
and special exceptions granted
by EPA.
Interim REIs: 48 hours for
Toxicity I dermal toxicity or
skin or eye irritation potential;
24 hours for Toxicity II dermal
toxicity or skin or eye
irritation potential; 12 hours
for others; 72 hours for
Toxicity I organophosphates in
arid areas.
Early entry allowed with
specified PPE only for short-
term tasks or in emergencies.
Affects: All hired workers/
handlers and unpaid/family
member workers/handlers.
Interim REIs:
72 hours for Toxicity I
48 hours for Toxicity II
24 hours for others
No early entry allowed.
24 hours for Toxicity I;
sprays dried, dusts settled for
all others.
Early reentry with PPE
allowed.
Personal Protective
Equipment (PPE)
Handlers: specified on label.
Early Entry Workers: hat, long-
sleeved shirt, trousers, shoes,
and socks.
PPE and work clothing as
described in the matrices in the
Final Rule.
PPE provided, cleaned, and
maintained by employer.
Affects: All hired workers/
handlers and unpaid/family
member workers/handlers.
PPE and work clothing as
described in the matrices in
the Final Rule.
PPE and work clothing
provided, cleaned, and
maintained by employer.
PPE and work clothing
described in the matrices in
the rule.
Neither PPE nor work
clothing provided, cleaned,
or maintained by employer.
continued...
-------
Table 01-9. Continued.
RIA wet factor
Bascttn*
practfcc)
"Revised rtile
High option
Notification
Warnings may be oral and/or by
posting signs at treated areas,
and/or by posting information
on central notice boards.
Treated area posting and oral
warnings for pesticides which
are Toxicity I for dermal
toxicity or skin irritation
potential.
Mandatory posting for
greenhouse applications.
Oral warning or treated area
posting for other applications
on farms, forests, and
nurseries.
Pesticide-specific information
on a central notice board.
Affects: All hired workers/
handlers.
Treated area posting, oral
warnings, and central notice
board listing for all pesticide
applications.
Daily oral warning.
Treated area posting and oral
warnings for pesticides with
REIs > than 48 hours.
Oral warning or treated area
posting for all other
applications.
Pesticide-specific
information available upon
request.
oo
Decontamination
OSHA Field Sanitation
Standard: handwashing facilities
for workers on farm
establishments with 10 or more
workers and for all workers on
nurseries, forests, and
greenhouses.
Handlers: water, soap and
towels within 1/4 mile for
routine washing of hands and
face and emergency whole-
body washing. Emergency
change of clothing. Eyeflush
water immediately available, if
protective eyewear required.
Workers (within 30 days of
REI): water, soap, and towels
within 1/4 mile for routine
washing of hands and face.
Early Entry Workers: same as
workers plus eyeflush water
immediately available, if
protective eyewear required.
Affects: All hired workers/
handlers.
Handlers: water, soap, and
towels immediately available.
Eyeflush dispensers for each
handler required to wear
protective eyewear. Hot
water showers at site where
PPE is removed.
Workers: same as Final Rule,
except (1) provided all season
long, (2) emergency change
of clothing required, and (3)
eyeflush dispenser required.
Early Entry Workers: same as
workers above, plus (1)
eyeflush dispensers, if
required to wear protective
eyewear, and (2) hot water
showers at site where PPE
removed.
Handlers and Early Entry
Workers: same as Final
Rule.
Workers: no wash facility
required.
continued^
-------
Table III-9. Continued.
KfA t«t factor
ft&tettae
practlct)
High option
JLm*r opf tea
Training
Certification and Training for
handlers of restricted use
pesticides.
OSHA Hazard Communication
Standard: Training for
workers/handlers on agricultural
establishments with 11 or more
employees.
Training about pesticide safety
and correct handling practices
for all handlers.
Training about pesticide safety
for all early entry workers.
Training about pesticide safety
for all workers.
Safety Poster.
Affects: All hired workers/
handlers.
Certification and training for
all handlers of Toxicity
Category I pesticides.
Handler-level training for
early entry workers.
Training about pesticide
safety for workers.
Safety Poster in language(s)
spoken by workers on
establishment.
Training about pesticide
safety and correct handling
practices for handlers.
Training about pesticide
safety for early entry
workers.
No training for workers.
No safety poster.
Emergency Assistance
Nothing
Employers provide emergency
transportation to workers and
handlers.
Employers provide pesticide-
specific information to
workers, handlers, and medical
personnel in an emergency.
Affects: All hired workers/
handlers.
Same as Final Rule.
Pesticide labels, pesticide fact
sheets, or Material Safety
Data Sheets for each
pesticide are made available
to all workers and handlers.
Nothing.
Cholinesterase Monitoring Nothing
Nothing
Cholinesterase monitoring for Nothing.
all commercial handlers.
Affects: All commercial
handlers.
-------
IV. COMPLIANCE COSTS AND ECONOMIC IMPACT ANALYSIS
A. Total and Incremental Costs by Cost Factor
The regulation and optional approaches would impose a variety of direct and indirect costs on
employers of agricultural workers and employers of agricultural pesticide handlers. Direct
costs would include personal protective equipment, decontamination items, pesticide safety
posters, and treated-area notification signs, while indirect costs would include worker, handler,
and supervisor/employer wages during notification, training, emergency assistance, rule
familiarization, PPE maintenance, and decontamination-related tasks. Additionally, direct
costs will be incurred by registrants for labeling changes.
To the extent possible, the Agency has used a variety of published data from various sources
such as the U.S. Department of Agriculture, U.S. Department of Commerce, and the U.S.
Department of Labor. When necessary, published data are supplemented with proprietary
data and estimates by knowledgeable persons both in EPA and in the agricultural sector.
When compiled, these values were used to approximate the various cost factors of the
regulation and of the major alternative approaches to the different user sectors.
Total first year user compliance costs of the regulation, along with total first year high and
low option costs, are summarized in TableTV-1. The revised final rule has a total first year
cost to users of approximately $190 million, while the high and low option costs are
estimated at $365 million and $55 million, respectively. Total compliance costs assume that
no portion of the regulation, are currently being incurred, either from State or federal
regulations, or through voluntary compliance.
Some portions of these total costs are already being incurred by growers or commercial
applicator firms as a result of (1) existing regulations promulgated at the state and federal
levels, (2) existing labeling requirements, and (3) voluntary compliance.
IV-1
-------
Table IV-1. Summary of total first year user compliance costs for the
revised final rule, high option, and low option
-Cast factor
Establishments:
Restricted-Entry Interval
Personal Protective Equipment
Notification
Training
Decontamination
Emergency Assistance
Rule Familiarization
SUBTOTAL
Commercial Handler Firms:
Cholinesterase Monitoring If
Other Requirements 2/
SUBTOTAL
GRAND TOTAL
Current revised
final rule
39.4
78.8
16.8
11.1
30.2
0.04
6.0
182.3
0.0
7.8
7.8
190.1
High option
— fMillinn HI
117.5
100.4
24.0
18.7
71..0
0.08
6.0
337.7
9.5
17.7
27.2
364.9
Low option
18.6
2.2
8.2
5.0
13.5
0.0
6.0
53.5
0.0
1.8
1.8
55.3
]J Cholinesterase monitoring is only required for commercial handlers, under the high option.
2/ Other requirements for commercial handlers include the cost of PPE, training, emergency
assistance, decontamination, and rule familiarization.
Source: Appendix A for current revised final rule costs and Appendix C for high and low option
compliance costs.
IV-2
-------
The original Worker Protection Standard for agricultural hand-labor crops and the Product
Registration (PR) Notice (83-2), through which the provisions of the Standard were
incorporated onto pesticide product labeling, established the current requirement for pesticides
used on labor-intensive crops, that warnings must be given to workers who are expected to be
in a treated area or in an area about to be treated. Therefore, the costs for oral notification
requirements associated with fruit/vegetable/nut, cotton, and tobacco crops are already being
incurred.
OSHA has promulgated a national Field Sanitation Standard (FSS), requiring water, soap, and
towels for many agricultural workers, which will be sufficient for EPA's WPS
decontamination requirements for those workers. OSHA's Hazard Communication Standard
(HCS) is also expected to mitigate the cost impact of training requirements established by this
rule.
Arizona, California, Texas, Oregon, Washington, and other states have existing regulations
designed to protect agricultural workers from occupational pesticide exposures. These include
requirements that pertain to oral warnings and treated-area posting, decontamination facilities,
training, restrictions on entry, and emergency response. . .
EPA has issued Registration Standards for approximately 80 percent of the pesticide active
ingredients used in the production of agricultural plants. In addition, EPA has issued
amended labeling requirements for several such active ingredients. These labeling
requirements and Registration Standards have resulted in some of the WPS requirements, in
particular personal protective equipment requirements, being already incorporated into the
pesticide labeling.
Finally, EPA believes that many employers of agricultural workers and pesticide handlers are
already voluntarily complying with several of the WPS requirements. In particular, EPA
believes that many such employers are providing their employees with water for routine and
emergency washing and that most are providing them with transportation and pesticide-
specific information in poisoning emergencies.
IV.3
-------
Table IV-2 summarizes incremental first and out year user compliance costs of the regulation
by cost factor. Incremental first year costs of the regulation are estimated at approximately
$94 million, while incremental out year costs are estimated to be about $49 million.
B. Economic Impacts by Agricultural Sector
The Worker Protection Standard would impact the production of all significant agricultural
commodities to some extent Pesticides are a common input in the production of many
agricultural commodities. The relative significance of the costs of the regulation can be
expected to vary according to two factors; (1) the intensity and toxicity of pesticide use, and
(2) the amount of hand labor required in the production of the commodity.
Table IV-3 and Figure IV-1 show the estimated first year incremental WPS compliance costs
by agricultural sector for each of the major cost factors. Incremental first year costs range
from a low of $0.3 million for forestry, to a high of nearly $35 million for vegetable/fruit/nut
establishments. Total incremental first year costs of the regulation for all agricultural-plant
establishments is estimated at approximately $82.3 million.
Estimated incremental out-year compliance costs are given in Table IV-4 and in Figure IV-2.
Out year incremental costs to comply with the WPS to owners of agricultural establishments
are approximately $49.4 million. Several factors associated with first year costs have more
than one year's usefulness, so costs are reduced or even eliminated in out years. For
example, in out years only 20 percent of the treated area posting signs will likely need
replacement. Other examples of reduced out-year costs include certain personal protective
equipment, safety posters, and water containers for decontamination. Some first year
compliance cost items are totally eliminated in out years-for example, the cost to registrants
of changing pesticide labeling are all incurred in the first year. After the changes are made
the first year, the labeling will not change in out years due to the WPS regulation.
Table IV-5 shows various key statistics about the agricultural-plant sectors that will be
affected by the WPS. There are 688,000 agricultural establishments with 170.6 million acres
IV-4
-------
Table FV-2. Summary of incremental first and out year user compliance costs
I ,
Cost factor
Establishments:
Restricted-Entry Interval
Personal Protective Equipment
Notification
Training
Decontamination
Emergency Assistance
Rule Familiarization
SUBTOTAL
Commercial Handler Firms:
Training
Decontamination
Personal Protective Equipment
Emergency Assistance
Rule Familiarization
SUBTOTAL
Registrants:
Labeling Changes
GRAND TOTAL
Carres* Itev
laeremefital
first year
21.1
17.9
15.7
6.9
12.4
0.01
6.0
80.0
0.06
0.4
1.6
.0002
0.2
2.3
12.0
94.3
ise(i Final Rule
Incremental
Ofi*?«$r
rvri ^C^ „„ _
21.1
9.5
5.0
2.3
8.9
0.01
1.0
47.8
0.05
0.4
1.1
.0002
0.01
1.6
0
49.4
Source: Appendix A and B.
Note: Totals may not add due to rounding.
rv-5
-------
Table IV-3. First year incremental WPS compliance costs by cost factor and agricultural sector
S*dte* "
Feed & Grain
Cotton
Tobacco
Other Field
Veg/Frurt/Nut
Nursery/greenhouse
Commercial Handlers
Forestry
Agri-Plant
Establishments
SUBTOTAL
Labeling Changes
TOTAL
JfeSffcfcd
• &*y
Not Signif.
NotSignif.
Not Signif.
NotSignif.1/
20,711,251
434,837
None
NotSignif.
21,146,088
T#iMi>fl
2,624,899
436,530
773,172
968,581
1,653,331
426,424
61,275
58,870
7,003,082
DeOOrtarftra&Sn
3,785,480
587,797
1,267,690
1,247,629
4,347,143
1,058,963
421,210
88,534
12,804,446
Personal
Protac&fr
EtjufcaiBfA
---($)
8,498,202
814,424
2,535,653
1,702,249
3,244,038
1,059,045 '
1,575,908
80,102
19,509,621
NdtStertk*
3,280,806
672,216
1,287,644.
3,755,689
3,898,355
2,680,026
None
102,204
15,676,940
Emergency
Assistance
3,385
668
811
1,492
2,559
598
247
70
9,830
flub
£arfl$*tfeatiort
3,034,675
254,450
759,500
737,975
949,263
350,875
85,000
16,000
6,187,738
TOTAL
21,227,447
2,766,085
6,624,470
8,413,615
34,805,940
6,010,768
2,143,640
345,780
82,337,745
12,000,000
$94,337,745
Source: Appendix A and B.
1/ May be costs associated with seed com, but otherwise not significant.
-------
Figure IV-1. Incremental first year WPS compliance costs and percent of total
incremental costs by agricultural sector
Other Field ($8,413,
2.6%
Veg/Fruit ($34,805,940)
ommercial Handlers ($2,143,640)
Feed & Grain ($21,227,44
Tobacco ($6,624,470)
Cotton ($2,766,085)
Nursery/Greenhouse ($6,010,768)
Total Incremental First Year WPS Compliance Costs = $82.3 Million'
•Includes a $345,780 compliance cost to forestry; excludes one-time cost of label changes to registrants.
-------
Table IV-4. Out year incremental WPS compliance costs by cost factor and agricultural sector
1 ~~t ' .. ' ' S
Feed & Grain
Cotton
Tobacco
Other Field
Veg/Fruit/Nut
Nursery/greenhouse
Commercial Handlers
Forestry
Labeling Changes
TOTAL
"V
Not Signif.
Not Signif.
Not Signif.
Not Signif.1/
20,711,251
434,837
None
Not Signif.
21,146,088
" W , *
866,030
152,893
239,276
340,191
581,620
144,773
55,148
18,515
2,398,446
easntemtftaSort
2,267,375
397,155
734,481
829,460
3,714,044
864,245
366,406
50,220
9,223,386
Personal
---($)
4,444,864
441,217
1,382,541
929,080
1,732,142
564,632 '
.1.081,608
42,818
10,618,902
K*Sfe*tk*
1,007,127
236,381
310,637
843,921
1,254,487
1,273,876
None
31,363
4,957,792
Srwgsncy
Asgigteaee f
3,385
668
811
1,492
2,559
598
247
70
9,830
flute
505,779
42,408
126,583
122,996
158,211
58,479
14,167
3,000
1,031,623
' TOTAL
9,094,560
1 ,270,722
2,794,329
3,067,140
28,154,314
3,341,440
1,517,576
145,986
0
$49,386,067
CXI
Source: Appendix A and B.
1/ May be costs associated with seed com, but otherwise not significant.
-------
Figure IV-2. Incremental out year WPS compliance costs and percent of total
incremental costs by agricultural sector
Other Reid ($3,067,140)-^
3.1%
Veg/Fruit ($28,154,314
(-Commercial Handlers ($1,517,576)
Feed & Grain ($9,094,560)
Tobacco ($2,794,329)
e.8% w— Cotton ($1,270,722)
Nursery/G.H. ($3,341,440)
Total Incremental Out Year WPS Compliance Costs = $49.4 Million*
'Includes a $145,986 compliance cost to forestry.
-------
Table IV-5. Number of establishments, acres planted; market value, compliance costs, and compliance costs
as a percentage of market value by agricultural crop sector
WPS Compliance Cos!
• Crap Sector
Feed and Grain
Cotton
Tobacco
Other Field
Vegetable/Fruits/Nuts
Nursery/Greenhouse
Forestry
Commercial handler firms
TOTAL
*
A*'
BeliMtebBttats tt
— (number) —
338,000
22,000
76,000
123,000
92,000
37,000
8.500
696,500
planted j/
— (million) —
128
13.7
4.2
16
7.9
0.8
170.6
, , „ „
Market V.lue
of crop 2/
—(billion $)—
22.4
4.2
1.5
5.7
11.3
5.7
$50.8
, ,,
iacr*a«nial 3t/
— (million $) —
21.2 '
2.8
6.6
8.4
34.8
6.0
0.3
2.1
$82.3
focremeatal 4/
—(million $)—
9.1
1.3
2.8
3.1
28.2
3.3
0.1
1.5
$49.4
firtf $&t ut»f y^i# i« ^ )»«*«t or
lner«B*ateI^/ tecrtfrneataJ
-------
of planted crops, in addition to 8,500 commercial handler firms that could potentially be
affected by the regulation. The total market value of production of the six crop sectors was
approximately $50 billion in 1987 (U.S. Department of Commerce, 1989).
While the total first year incremental cost of the WPS to agricultural-plant establishments and
commercial-handler firms is estimated at $82.3 million, this total represents a small fraction
of one percent of the market value of production of the six agricultural sectors (Table FV-5).
The vegetable/fruit/nut sector incurs the single largest compliance cost from the regulation of
$34.8 million for the first year and $28.2 million in out years. However, with an annual
market value of vegetable/fruit/nut crops at slightly over $11 billion, WPS compliance costs
account for less than one-third of one percent of the sector's annual market value. In fact,
compliance costs represent far less than one percent of the total market value for each one of
he six individual crop sectors. On average, it will cost individual operators of agricultural
establishments from $70 on feed and grain farms to $440 on vegetable/fruit/nut farms to
comply with the WPS regulations in the first year. Out year incremental compliance costs are
reduced by at least half as much as first year costs on feed and grain, cotton, tobacco, and
other field crop farms. Nursery/greenhouse establishments' compliance costs are reduced by
almost one-half in out years and vegetable/fruits/nuts by nearly twenty percent. Overall first
year incremental costs of compliance with the WPS are expected to total less than two-tenth's
of one percent of the total value of the crops affected.
The somewhat wide variability in the cost per establishment across the commodity groups
analyzed, results from the variation in pesticide use practices, including the different types of
pesticides used, as well as the variation in intensity of hand labor practices. Pesticide usage
in feed/grain and other field crops tends, for the most part, to be herbicide application with
relatively less insecticide usage. Herbicides tend to have lower acute toxicity levels, and
hence, trigger less costly requirements under the WPS. Another factor is that following
herbicide application and planting, there is little need for entry into the fields of feed/grain or
other field crops to perform hand labor tasks. However, tobacco, vegetable/fruit/nut, and
nursery/greenhouse crops often require insecticide treatments throughout the growing season
and these types of pesticides tend to have higher acute toxicity values, and therefore, trigger
IV-11
-------
more requirements in the WPS. These crops also tend to require significant hand labor
during the entire cultivation cycle. Therefore, the higher potential for occupational pesticide
exposure of workers in these labor intensive crops, triggers requirements under the WPS
regulations that are more costly than for the non-labor intensive field crops.
C. Economic Impacts: Annualized Costs by Agricultural Sector
As previously mentioned, the costs of complying with the WPS will decrease after the first
year due to the fact that some costs are not incurred every year. While it is likely that
compliance costs will be reduced even further in successive out years (due to changes in
pesticide use, development of non-chemical methods of pest control, development of pest-
resistant crop varieties, etc.), they cannot be accurately estimated without further study.
Therefore, compliance costs are assumed to be the same in years two through ten.
Another way to view compliance cost streams is to calculate their equivalent, constant-level
cost per year. The equivalent value is referred to as the annual revenue stream requirement
(ARR) because the present value of such an annual revenue stream equals the present value
of the cost stream. In order to calculate an ARR for a cost stream the following three steps
are taken.
STEP 1: Prepare Cash Flow Estimates and Assumptions.
First and out year incremental compliance costs of the WPS by industry were
estimated earlier in this chapter. These are the initial year and annual cash flow
estimates, respectively. Cash flow estimates are in constant 1991 dollars and are
computed as before tax values per standard regulatory impact analysis
guidelines. Calculating present values requires that all future period streams be
IV-12
-------
discounted1 at a specified rate of return, with appropriate consideration for inflation.
STEP 2: Calculate Present Values for Each Year and the Total Present Value of the
Cost Stream
The present value of the cost stream by industry is multiplied by the discount factor
to convert the future sum to a present value. The discount factor (DF) for k percent
interest2 and n periods is calculated with the formula:
1
(1+*)"
Annual NPVs are summed by industry to obtain a total present value (TPV) of the
overall cash flow.
STEP 3: Compute the Capital Recovery Factor and Estimate Annual Revenue
Requirement
The annual revenue requirement (ARR) is obtained by converting the total NPV into
an equivalent, constant-level cash flow, i.e. the average annual revenue required to
provide an equivalent total present value. A capital recovery factor (CRF) is used to
convert the NPV into an annual stream that is equivalent given the underlying
economic assumptions. The relationship is:
'Discounting is a technical procedure by which costs of a regulation which occur over a
specified time period are set equal to current costs. Projects that have different time horizons
will have different net present values (NPV); using different discount rates also leads to
different NPVs.
social rate of discount rate is the rate at which society is willing to trade current
consumption for future consumption. The appropriate discount rate to use is the post-tax risk-
free long-run consumer rate of time preference since society is understood to be trading
present for future consumption on behalf of consumers by engaging in a public project.
Empirical observations suggest that, all other things being equal, consumers prefer
consumption in the present to that in the future, so that the discount rate obtained from the
rate that existing consumers trade across time should also be positive.
IV- .13
-------
ARR = CRF X TPV
where:
ARR ?= annual revenue requkement
CRF = capital recovery factor, and,
TPV = total present value.
The equation to calculate the CRF is:
CRF=
where:
i = the real rate of return on invested capital, excluding inflation
n = the effective operating life of the asset.
Cash flow, net present value, total present value, annual revenue requirement, and annual
revenue requkement per establishment for WPS compliance by industry are given in Tables
IV-6 through FV-9. Worker Protection Standard total ARRs for all affected agricultural
industries and registrants is estimated to range between $53.9 - $56.0 million, depending upon
the discount rate. This compares to first year cash flows (costs) of $94.3 million and out year
costs of $49.4 million. A comparison of Tables IV-6 to IV-9 show that the ARRs are
insensitive to the choice of discount rates used in this sensitivity analysis.
ARRs are quite variable by industry. The vegetable/fruit/nut sector is estimated to incur the
largest ARR, ranging between $28.8 - $29.1 million per year, while the forestry sector is
estimated at less than $200,000. Per establishment ARRs are based on the total number of
establishments in the particular industry that use pesticides. ARRs range from $369 (10%
discount rate) on vegetable/fruit/nut establishments to about $34 (not discounted) on feed and
grain farms.
IV-14
-------
Table IV-6. Annualized WPS incremental compliance costs by industry, constant 1991 dollars, discounted at 10% for 10 years
Feed & Grain
Cash
Year Flow
1 21,227
2 9,095
3 9,095
4 9,095
5 9,095
6 9,095
7 9,095
8 9,095
9 9,095
10 9,095 .
Total NPV
Annual Revenue
Requirement 1/
Total Revenue
Requirement Per
Establishment ($)
Net
Present
Value
19,295
7,512
6,830
6,212
5,648
5,130
4,666
4,247
3,856
3,511
66,908
10,889
36.20
Cotton
Cash
Flow
2,766
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,271
Net
Present
Value
2,514
1,050
955
868
789
717
652
594
539
491
9,168
1,492
72.15
Tobacco
Cash
Flow
6,624
2,794
2,794
2,794
2,794
2,794
2,794
2,794
2,794
2,794
Net
Present
Value
6,021
2,308
2,098
1,908
1,735
1,576
1,433
1,305
1,185
1,078
20,648
3,360
58.95
Other Reid
Cash
Flow
8,414
3,067
3,067
3,067
3,067
3,067
3,067
3,067
3,067
3,067
Net
Present
Value
7,648
2,533
2,303
2,095
1,905
1,730
1,573
1,432
1,300
1,184
23,704
3,858
54.08
Veg/FruiVNuts
Cash
Flow
34,806
28,154
28,154
28,154
28,154
28,154
28,154
28,154
28,154
28,154
Net
Present
Value
31,639
23,255
21,144
19,229
17,484
15,879
14,443
13,148
11,937
10,867
179,025
29,135
368.57
Nursery/Greenhouse
Cash
Flow
6,011
3,341
3,341
3,341
3,341
3,341
3,341
3,341
3,341
3,341
Net
Present -
Value
($1 000)—
5,464
2,760
2,509
2,282
2,075
1,884
1,714
1,560
1,417
1,290!
22,954
3,736
118.59
Commercial Handlers
Cash
Row
2,144
1,518
1,518
1,518
1,518
1,518
1,518
1,518
1,518
1,518
Net
Present
Value
1,949
1,254
1,140
1,037
943
856
779
709
644
586
9,896
1,610
189.47
Forestry
Cash
Row
346
146
146
146
146
146
146
146
146
146
Net
Present
Value
315
121
110
100
91 4
82
75
68
62
56
1,079
176 '
- NA -
Labeling Changes
Cash
Flow
12,000
0
0
0
0
0
0
0
0
0
Net
Present
Value
10,908
0
0
0
0
0
0
0
0
0
10,908
1,775
Not Applies
Total
Net
Cash Present
Flow Value
94,338 85,753
49,386 40,793
49,386 37,089
49,386 33,731
49,386 30,669
49,386 27,854
49,386 25,335
49,386 23,063
49,386 20,940
49,386 19,063
344,289
56,031
*h[o
M Annual Revenue Requirement = Capital Recovery Factor (CRF) X Total Net Present Value (NPV).
Where: i = the real rate of return on invested capital, excluding inflation (10%)
n = the effective operating life of the asset ( 1 0 years)
-------
Table IV-7. Annualized WPS incremental compliance costs by industry, constant 1991 dollars, discounted at 6% for 10 years
Feed & Grain
Cash
Year Flow
1 21,227
2 9,095
3 9,095
4 9,095
5 9,095
6 9,095
7 9,095
8 9,095
9 9,095
10 9,095
Total NPV
Annual Revenue
Requirement 1/
Total Revenue
Requirement Per
Establishment ($)
Net
Present
Value
20,017
8,095
7,640
7,203
6,794
6,412
6,048
5,703
5,384
5,075
78,371
10,648
35.40
Cotton
Cash
Flow
2,766
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,271
Net
Present
Value
2,608
1,131
1,068
1,007
949
896
845
797
752
709
10,763
1,462
70.71
Tobacco
Cash
Flow
6,624
2,794
2,794
2,794
2,794
2,794
2,794
2,794
2,794
2,794
Net
Present
Value
6,246
2,487
2,347
2,213
2,087
1,970
1,858
1,752
1,654
1,559
24,173
3,284
57.62
Other Field
Cash
Flow
8,414
3,067
3,067
3,067
3,067
3,067
3,067
3,067
3,067
3,067
Net
Present
Value
7,934
2,730
2,576
2,429
2,291
2,162
2,040
1,923
1,816
1,711
27,612
3,752
52.59
Veg/Fruit/Nuts
Cash
Flow
34,806
28,154
28,154
28,154
28,154
28,154
28,154
28,154
28,154
28,154
Net
Present
Value
32,822
25,057
23,649
22,298
21,031
19,849
18,722
17,653
16,667
15,710
213,458
29,002
366.88
Nursery/Greenhouse
Cash
Flow
6,011
3,341
3,341
'3,341
3,341
3,341
3,341
3,341
3,341
3,341
Net
Present
Value
($1 000}—
5,668
2,973
2,806
2,646
2,496
2,355
2,222
2,095
1,978
1,864
27,104
3,683
116.91
Commercial Handlers
Cash
Flow
2,144
1,518
1,518
1,518
1,518
1,518
1,518
1,518
1,518
1,518
Net
Present
Value
2,022
1,351
1,275
1,202
1,134
1,070
1,009
952
899
847
11,761
1,598
188.00
Forestry
Cash
Flow
346
146
146
146
146
146
146
146
146
146
Net
Present
Value
326
130
123
116
109
103
97
92
86
81
1,263
172
- -NA- -
Labelinq Changes
Cash
Flow
12,000
0
0
0
0
0
0
0
0
0
Net
Present
Value
11,316
0
0
0
0
0
0
0
0
0
11,316
1,537
NotApplicabl
Total
Net
Cash Present
Flow Value
94,338 88,961
49,386 43,954
49,386 41,484
49,386 39,114
49,386 36,891
49,386 34,817
49,386 32,842
49,386 30,965
49,386 29,237
49,386 27,557
405,821
55,138
Where: i = the real rate of return on invested capital, excluding inflation (6%)
n = the effective operating life of the asset (10 years)
-------
Table IV-8. Annualized WPS incremental compliance costs by industry, constant 1991 dollars, discounted at 3% for 10 years
Feed & Grain
Cash
Year Flow
1 21,227
2 9.095
3 9,095
4 9,095
5 9,095
6 9,095
7 9,095
8 9,095
9 9,095
10 9,095
Total NPV
Annual Revenue
Requirement 1/
Total Revenue
Requirement Per
Establishment ($)
Net
Present
Value
20,611
8,577
8,322
8,076
7,849
7,613
7,394
7,176
6,967
6.767
89,351
10,475
34.82
Cotton
Cash
Flow
£766
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,271
Net
Present
Value
2,686
1,199
1,163
1,129
1,097
1,064
1,033
1,003
974
946
12,292
1,441
69.68
Tobacco
Cash
Flow
6,624
2,794
2,794
2,794
2,794
2,794
2,794
2,794
2.794
2,794
Net
Present
Value
6,432
2,635
2,557
2,481
2,411
2,339
2,272
2,204
2,140
2,079
27,549
3,230
56.66
Other Reid
Cash
Row
8,414
3,067
3,067
3,067
3,067
3,067
3,067
3,067
3,067
3,067
Net
Present
Value
8,170
2,892
2,806
2,723
2,647
2,567
2,493
2,420
2,349
2,282
31,350
3,675
51.52
Veq/Fruil/Nuts
Cash
Row
- ($1 ,000)-
34,806
28,154
28,154
28,154
28,154
28,154
28,154
28,154
28,154
28,154.
Net
Present
Value
33,797
26,549
25,761
25,001
24,297
23,565
22,889
22,214
21,566
20,947
246,585
28,907
365.68
Nurserv/Greenhouse Commercial Handlers
Cash
Row
6,011
3,341
3,341
'3,341
3,341
3,341
3,341
3,341
3,341
3,341
Net
Present
Value
5,837
3,151
3,057
2,967
2,883
2,796
2,716
2,636
2,559
2,486,
31,088
3,644
115.70
Cash
Flow
2,144
1,518
1,518
1,518
1,518
1,518'
1,518
1,518
1,518
1,518
Net
Present
Value
2,082
1,431
1,389
1,348
1,310
1,271
1,234
1,198
1,163
1,129
13,555
1,589
186.95
. Forestry
Cash
Row
346
146
146
146
146
146
146
146
146
146
Net
Present
Value
336
138
134
130
126
122
119
115
112
109
1,439
169
--NA--
Labelinq Changes Total
Cash
Flow
12,000
0
0
0
0
0
0
0
0
0
Net
Present
Value
11,652
0
0
o -
0
0
0
0
0
0
11,652
1,366.
Not Applic
Net
Cash Present
Flow Value
94,338 91,602
49,386 46,571
49,386 45,188
49,386 43,855
49,386 42,620
49,386 41,336
49,386 40,151
49,386 38,966
49,386 37,830
49,386 36,743
464,862
54,496
1/ Annual Revenue Requirement
Where: i = the real rate of return on invested capital, excluding inflation (3%)
n = the effective operating life of the asset (10 years)
-------
Table IV-9. Annualized WPS incremental compliance costs by industry, constant 1991 dollars, discounted at 0% for 10 years
Feed & Grain Cotton
Year
1
2
3
4
5
6
7
8
9
10
Annual Revenue
Requirement 1/
Total Revenue
Requirement Per
Establishment ($)
Cash
Flow
21,227
9,095
9,095
9,095
9,095
9,095
9,095
9,095
9,095
9,095
10,308
34.27
Cash
Flow
2,766
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,271
1,421
68.69
Tobacco Other Field Veg/Fruit/Nuts Nursery/Greenhouse Commercial Handlers Forestry Labeling Changes
Cash
Fbw
6,624
2,794
2,794
2,794
2,794
2,794
2,794
2,794
2,794
2,794
3,177
55.74
Cash
Flow
- /
-------
D. Economic Impacts on Agricultural Workers
With only narrow exceptions, trie revised Worker Protection Standard (WPS) prohibits entry
to treated areas during a restricted-entry interval to perform routine hand labor tasks, such as
harvesting, pruning, or tying. Should this prohibition result in workers not being employed
during the restricted-entry interval, the resulting wage loss would be a cost attributable to the
WPS. EPA believes that workers would be unemployed during the restricted-entry interval
only in rare circumstances. First, only a few crop-task combinations require the application
of a pesticide at a frequency that would cause the restricted-entry interval to interfere with
necessary and time-sensitive hand labor tasks. In most circumstances in those few crop-task
combinations, the grower can avoid either crop loss or loss of worker employment with
careful scheduling of workers and pesticide applications. Even in those situations where the
application frequency and the time-sensitivity of the hand labor task directly conflict, EPA
believes that agricultural employers' least cost method of responding would have little impact
on the demand for workers.
EPA has identified four possible ways that a grower may respond when the frequency of
pesticide application conflicts with a time-sensitive hand labor task:
1. The grower does not apply any pesticide and accepts the resultant loss in crop yield or
quality due to the pest infestation. The workers would be employed to perform the
necessary hand labor task as scheduled. Indeed, in some pest control situations such
as weed control, the use of labor might increase to provide a non-chemical alternative
to the use of pesticides.
2. The grower applies a pesticide with a shorter restricted-entry interval and accepts the
resultant loss in crop yield or quality due to incomplete control of the pest infestation.
The workers would 'be employed to perform the necessary hand labor task as
scheduled.
IV-19
-------
3. The grower applies the pesticide, reschedules the hand labor task, and accepts the loss
in crop yield or quality due to poorly timed hand labor activities. The workers would
be employed for the same number of days overall, but the timing of their employment
would be altered.
4. The grower applies the pesticide, cancels the employment of workers to perform the
necessary hand labor task, and accepts the loss in crop yield or quality due to poorly
timed hand labor activities. One or more days of hand labor activity, such as
harvesting, are skipped entirely. In locations and times where the demand for
agricultural laborers temporarily exceeds the supply, workers would usually be able to
find alternative employment on nearby agricultural establishments with no loss in
wage. In locations and times where the supply of agricultural labor temporarily
exceeds the demand, workers might be unable to find alternative employment on
nearby agricultural establishments and would incur a wage loss.
Only scenario #4 might result in a loss of income to the workers, and that loss would occur
only in locations and times with a surplus of labor. EPA believes that scenario #4 may be
the least likely scenario, because growers would most often opt to harvest a crop with poorer
yield or quality than to forgo the harvest entirely.
In those situations where the WPS would result in a wage loss to workers, the RIA has
already assumed the costs of such a loss. The lost wage would be a transfer of costs from
the grower who suffered the crop loss, but did not have to pay the workers' wage, to the
workers who suffer a wage loss.
The RIA assumed a cost impact from the WPS-imposed restricted-entry intervals due to a loss
in crop yield or quality. That loss in crop yield or quality was assessed on a per acre crop
production value basis, i.e., the gross revenue from marketing the crop. In the first three
scenarios, the loss is incurred entirely by the grower. In the last instance, the total loss is the
same, but is shared by the grower and the workers. The grower receives less income from
marketing the crop, but has less expenditure to be debited from that income due to reduced
IV-20
-------
labor costs. The worker incurs a cost due to reduced wages. In any case, the total costs are
reflected in the RIA.
E. Economic Impacts on Registrants
The final regulations would be applicable to most pesticide products registered for use on
agricultural plants including forestry and ornamental crops. A review of EPA records has
found that currently there are about 18,000 registered pesticide products. Of this total,
approximately 8,000 products are estimated to contain agricultural sites on their labeling. The
registrants of these products would be required to amend their product labeling to reflect
requirements associated with the Worker Protection Standard.
Available information indicates that such changes to labeling would require total expenditures
(labor, materials, support needs, overhead, etc.) of between $1,000 and $2,000 per product.
Thus, the total cost to registrants of agricultural-plant pesticide products is estimated to range
from $8.0 to $16.0 million with a midpoint (or expected cost) of $12.0 million. This would
be a one-time expense necessary to meet regulation requirements and would not be borne
subsequent to the first year under the final Rule.
Other impacts on registrants are less certain, and hence, cannot be addressed in any detail by
this analysis. There has been speculation that the requirements associated with restricted-
entry intervals and personal protective equipment could produce shifts in user preference
toward products that are less toxic. A shift to less toxic pesticides could also reduce the
number of pesticide-related poisonings, thus potentially increasing the general health of those
persons exposed. Assuming that users shift to less toxic products, income transfers among
registrants would likely occur, however, there is insufficient basis on which to make credible
quantitative estimates of these impacts.
IV-21
-------
F. Economic Impacts on States, Tribes, and Territories
The Worker Protection Standard and other pesticide regulations, are, in general, enforced by
states3, both independently and within a framework of cooperative agreements with EPA.
Therefore, the revised WPS could be expected to add to the regulatory burden currently being
incurred by states. State inspectors will have to be trained about the requirements of the
revised WPS and to develop compliance monitoring strategies specific to the revised Rule.
There is not, however, expected to be an increased financial burden to states due to
promulgation of the WPS. Since fiscal year 1990, EPA has been providing states, tribes, and
territories with funding specifically set aside for WPS compliance. In fiscal year 1990, $1
million out of a total pesticide compliance budget of $12.8 million was set aside for WPS
compliance. In fiscal years 1991 and 1992, the amount set aside for WPS enforcement was
increased to $1.5 million. Funding for WPS compliance is expected to increase for fiscal
year 1993 to $2.6 million. In fiscal year 1994, WPS compliance funding is expected to be at
the fiscal year 1993 level or higher and, in addition, will be allocated to states based on
relative need for WPS funding.
To date, states have used the WPS monies to devise compliance monitoring strategies, hire
WPS-specific personnel, and develop agreements with other state agencies that clarify and
assign responsibilities for implementing and enforcing the WPS.
3The term "state", as used here, includes tribes and territories.
IV-22
-------
V. BENEFITS ASSESSMENT
The revised Worker Protection Standard (WPS) will produce a wide range of benefits for
various sectors associated with the sale, oversight, or use of agricultural-plant pesticides.
Agricultural workers and pesticide handlers will derive the most substantial benefits. By
lowering their occupational exposures to such pesticides, the WPS will enable them to have
improved health and a better quality of life. Pesticide users-both growers and commercial
pesticide handlers-will benefit directly from the WPS through the increased standardization
of both pesticide-use directions and pesticide-related requirements. The indirect benefits to
pesticide users through compliance with this rule will stem from having a more informed and
healthier workforce, which should lead to improved productivity, lower liability risks, reduced
legal costs, and lower insurance rates. Registrants will benefit directly through
standardization and reduction of labeling language and indirectly through having more
informed pesticide users, resulting in lower liability risks, reduced legal costs, and lower
insurance rates. States, tribes, and territories will benefit from increased standardization of
pesticide-use directions and pesticide-related requirements that will be more easily conveyed,
interpreted, and enforced. Many states, tribes, and territories may also benefit by not having
to enact their own worker protection regulations.
This section will discuss the potential benefits of the WPS to the following four entities:
• agricultural workers and pesticide handlers,
« users of agricultural-plant pesticides,
• registrants of agricultural-plant pesticides, and
• states, tribes, and territories.
In many cases, data are sparse for topics such as worker exposure, resultant health effects
(both acute and delayed), and potential amelioration attributable to this rule. However, the
weight of evidence,.combined with facts about agricultural workers' activities and risks,
indicate substantial benefits from this rule.
V-l
-------
A. Benefits to Agricultural Workers and Pesticide Handlers
The use of agricultural-plant pesticides in the United States potentially exposes about 4
million members of the agricultural workforce, including hired workers, unpaid workers
(presumably family members), and agricultural establishment owner/operators, to risks of
adverse health effects. Pesticide handlers are persons who mix, load, apply, or otherwise
come into direct contact with pesticides through related pesticide-use activities. The number
of pesticide handlers nationwide is estimated at 1.66 million. Approximately 1 million are
owner/operators of agricultural establishments, approximately 620,000 are hired to work on
agricultural establishments, and approximately 40,000 work for commercial pesticide handling
establishments. Agricultural workers do not handle pesticides directly, but they may be
exposed to agricultural-plant pesticides either indirectly (through contact with residues on
treated plants, soil, or water) or directly (through accidental contact, mainly with drift or
misdirected application). The number of agricultural workers nationwide is estimated at 2.25
million. Approximately 1.4 millixjn are unpaid (family-member) workers, and approximately
850,000 are hired workers.
By initiating several interrelated exposure-reduction measures, the revised final rule is
expected to substantially mitigate for these workers and handlers the adverse health effects
(acute, allergic, and delayed) from occupational exposures to such pesticides. These measures
include requirements intended to:
Ensure that employees are informed about the hazards of pesticides—The WPS
includes such provisions as pesticide safety training for workers and handlers,
use of a pesticide safety poster, access to labeling information, and access to
information about what pesticides have been used on the establishment.
Eliminate or reduce exposure to pesticides—For example, the WPS imposes
restrictions during applications and restricted-entry intervals and requires use of
personal protective equipment, decontamination facilities for routine washing,
and notification to workers of treated areas so they can avoid inadvertent
exposures.
V-2
-------
Mitigate the effects from exposures that occur--the WPS requires such things as
decontamination facilities for emergency washing, and prompt emergency
assistance if pesticide poisoning is suspected.
One benefit of the rule to pesticide handlers is the exceptions to personal protective
equipment requirements if engineering controls are used. For example, when enclosed cabs
are used during pesticide application, pesticide handlers have the attractive option of forgoing
the sometimes hot and cumbersome personal protective equipment. Pesticide handlers will be
both more protected and more comfortable when engineering controls are adopted.
It is undisputed that workers and handlers in the agricultural workforce are occupationally
exposed to pesticides and pesticide residues and that such exposures can pose significant
short-term and long-term health risks. The difficulty is in quantifying a specific level of risk
and projecting the risk reduction that will result from this rule. There is, however, strong
general evidence that such risks are pervasive and that they can be substantially reduced
through simple exposure-mitigation measures.
Adverse health effects to agricultural workers from occupational exposures to agricultural-
plant pesticides include:
• acute effects,
• allergic or sensitization effects, and
• delayed effects.
1. Acute (and Allergic) Effects
a. Hospitalized acute poisoning incidents
A recently released study (Keefe et al., 1990) estimated the nationwide incidence rates for
hospitalized acute pesticide poisoning cases among persons admitted to general-care hospitals
during the years 1977 to 1982 and estimated such rates for selected occupations, including
farmer, agricultural worker, and commercial applicator. The study estimated that an average
V-3
-------
.of 168 farmers, 130 agricultural workers, and 180 commercial applicators were hospitalized
annually due to occupational pesticide poisonings. Virtually all of the hospitalized cases in
the categories "farmer" and "agricultural worker" should be persons within the scope of this
final rule. The only exception would be persons who are poisoned through exposure to
pesticides used on livestock, and these are known to be relatively rare. The average annual
estimated hospitalized occupational, pesticide poisonings for the categories "farmer" and
"agricultural worker" is 298.
168 (farmer) + 130 (agricultural worker) = 298
In addition, some fraction of the hospitalized cases in the category "commercial applicator"
would be persons within the scope of this final rule because they would be applying
agricultural-plant pesticides, but the Agency is unable to ascertain from the data what that
fraction is. If all of these cases were persons within the scope of this final rule, then an
upper-bound estimate can be derived. As many as 478 annual hospitalized acute pesticide
poisoning cases could be attributed to occupational exposures to agricultural-plant pesticides.
168 (farmer) + 130 (ag worker) + 180 (commercial appl.) = 478
Therefore, for the purposes of this analysis, EPA proposes to use a range of 300 to 450 for
this value.
b. Nonhospitalized physician-diagnosed acute poisoning incidents
The population at risk of pesticide poisoning and subject to this final rule is the entire
population of agricultural workers and pesticide handlers—paid and unpaid-^who perform tasks
related to the production of agricultural plants on establishments where pesticides are used in
such production. EPA estimates there are 3.9 million agricultural workers and pesticide
handlers nationwide who perform duties related to the production of agricultural plants on
these establishments. These workers and handlers are the primary beneficiaries of this rule,
V-4
-------
which is intended principally to mitigate occupational exposure to agricultural-plant
pesticides.
(1) Use of California data to estimate national physician-diagnosed incidents. The
California Reporting System. The California reporting system receives the majority of the
reports of illness and injury potentially related to pesticide exposure through two main
methods (Calif. EPA, 1991). Physicians in California are required by law to report any
illness or injury suspected of being related to pesticide exposures. In addition, State
government or insurance programs supervised by the State compensates physicians for the
examination of any person who is injured or becomes ill as a result of circumstances within
the workplace. Other more minor mechanisms for reporting pesticide-related cases include
complaints reported to local or State government agencies and reports received from poison
control centers. Once a report is received by the California Environmental Protection Agency
(CEPA), it is sent to the local County Agricultural Commissioner (CAC) for follow-up
investigation.
Information received from the CAC investigation, the physician's report(s), toxicological data,
and any other pertinent background information is used by CEPA in the evaluation of each
incident reported. The incidents are first evaluated as to the completeness of the information
submitted. If sufficient information is- for a determination of exposure/illness relationship, no
conclusion is made about the case and it is listed as "unclassifiable." For those incident
reports determined to be "complete" or "adequate," the cases are further classified as to the
likelihood of a relationship between the reported pesticide exposure and the illness/injury
occurrence. Each case is classified as:
• Definite,
« Probable—there is close correspondence between the pattern of exposure and
the illness/injury experienced,
• Possible-there is some correspondence between the pesticide exposure
described and the illness/injury experienced,
V-5
-------
Unlikely—the signs and symptoms reported are not typical of the exposure
suspected, but the possibility that the victim is suffering the effects of pesticide
exposure cannot be discounted,
Asymptomatic-the subject was exposed to pesticides, but suffered no
illness/injury in consequence,
Indiiect--the illness/injury appears to have been caused not be pesticide
exposure, but by measures prescribed for avoiding pesticide exposure.
Both California and EPA generally use the first three classifications (definite, probable, and
possible) in assigning a number for illnesses and injuries associated with pesticide use.
Extrapolating from California data. Since California maintains the most reliable reporting
system for physician-diagnosed poisoning incidents that are related to occupational exposures
to agricultural-plant pesticides, EPA used California data to derive a reasonable estimate of
the national rate, of such incidents. When extrapolating California data to the rest of the
Nation, EPA looked for evidence that might indicate how best to extrapolate the data—directly
or with an adjustment based on the expected degree to which California data might over- or
underestimate national cases. EPA considered several factors, including handler exposures,
worker exposures, and the existence of the comprehensive California worker protection
standard. ,
Pesticide Handlers. The Agency has no reason to believe that the conditions and activities
affecting agricultural pesticide handler exposures to pesticides vary across the country.
Pesticide handler poisoning incidents do not appear to be related to climatic conditions, such
as aridity. Therefore, pesticide handler exposures in California would not be expected to
differ from those in the rest of the United States.
Agricultural Workers. The Agency believes that consideration should be given to the fact
that pesticides generally degrade much more slowly in arid regions. This persistence might
cause a greater opportunity for exposures to pesticides among agricultural workers in
California (and other states with arid agricultural regions) than would be expected in most of
V-6
-------
the Nation. Therefore, on this basis alone, agricultural-worker exposures in California could
be expected to differ from those in the United States as a whole.
California Worker Protection Standard. California has implemented the most
comprehensive agricultural worker protection regulations in the Nation. The protections for
workers and handlers include: (1) reentry intervals of as long as 90 days with no early entry
to perform hand labor tasks, (2) decontamination sites, (3) mandatory field posting under
certain conditions, (4) mandatory oral warnings for all treated areas, (5) training for and
monitoring of pesticide handlers, (6) cholinesterase monitoring for handlers of
organophosphates and N-methyl carbamates, (7) increased level of personal protective
equipment and closed-system mixing/loading for handling highly toxic pesticides, and (8)
emergency assistance. As a result, California may have already experienced reduction in
poisoning incidents. Therefore, on this basis alone, California may be expected to experience
poisoning rates below those experienced nationwide.
Integrating the Factors. Because the arid California climate might lead to an over-estimate
of agricultural worker poisoning incidents and the comprehensive California worker protection
standard might lead to an under-estimate of pesticide handler and agricultural worker
poisoning incidents, EPA sought a means of determining how these possibly conflicting
influences might be integrated.
To extrapolate the California incident rate to a national incident rate, EPA has considered
several different methods of extrapolation. These include extrapolation based on:
the percent of the total agricultural-plant workforce that is employed in
California,
the percent of the hired agricultural-plant workforce that is employed in
California,
the percent of the hired agricultural-plant workforce's workdays that are
worked in California,
the percent of national agricultural-plant pesticide expenditure that is expended
in California,
V-7
-------
the percent of total pounds of insecticide applied to agricultural plants
nationally that is applied in California,
the percent of national hospitalized acute pesticide poisoning cases due to
occupational exposures by farmers and agricultural workers that occur in
California.
There are plausible reasons why each of these extrapolations might be appropriate. In fact,
the Agency is aware of one study that shows a correlation between the pounds of certain
pesticides (mostly insecticides) applied and acute pesticide poisoning hospitalizations, and a
weaker correlation between the size of the workforce and the number of hospitalizations.
However, some of the other extrapolation methods have not been studied, so the Agency is
unable to ascertain with confidence which might provide the most appropriate method.
Indeed, all of the various extrapolation methods involve the use of incomplete or inconclusive
data.
(2) Extrapolation method for this analysis. For the purposes of this analysis, the Agency has
chosen to use a relatively simple, but, in the Agency's view, plausible, basis for extrapolation-
-the ratio of estimated hospitalized acute poisoning incidents due to occupational pesticide
exposures to farmers and agricultural workers occurring in California to the estimated national
rate of such incidents. EPA acknowledges that it has no hard data to support the assumption
that one can extrapolate directly from hospitalized acute poisoning incidents to physician-
diagnosed acute poisoning incidents. That is, EPA is unaware of data demonstrating that the
ratio of such hospitalized cases to total physician-diagnosed cases in California is the same as
that nationwide. However, hospitalized poisoning cases are a subset of physician-diagnosed
cases and the Agency has no reason to believe the ratio of hospitalized pesticide poisoning
cases to physician-diagnosed cases would be different for California than for the remainder of
the Nation.
Hospitalization data. EPA used data from the Third National Study of Hospitalized
Pesticide Poisonings in the United States. 1977-1982 (Keefe et al., 1990) to make the
extrapolation. The study estimates an average of 298 hospitalized acute pesticide poisoning
V-8.
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cases annually due to occupational poisonings to farmers and agricultural workers. The study
estimates that EPA Region IX, which includes California, Arizona, Nevada, and Hawaii, has
an annual average of 22.3 such cases. The Agency is unable to ascertain from this third
study what percent of EPA Region IX cases are from California. However, such data are
available from the first two studies of hospitalized pesticide poisonings in the United States,
which covered the period of 1971-1976 (Griffith et al., 1976; Savage et al, 1980). These
data estimate that California represents approximately 78 percent of Region IX's hospitalized
poisoning incidents to farmers and agricultural workers. Assuming that the ratio remained the
same for the years 1977-1982, the Agency is able to estimate that an average of 17,4 cases
occur annually in California. This computes to 5.8 percent of the estimated national
hospitalized acute pesticide poisoning cases due occupational exposures to farmers and
agricultural workers.
78% X 22.3 4- 298 = 5.8%
California physician-diagnosed cases. The Agency is aware of the difficulties inherent in
using data from the California pesticide poisoning reporting system. The data were not
collected or categorized with the WPS in mind, so they do not directly capture the poisonings
that would occur only to those persons within the scope of this final rule. However, EPA has
identified two subsets of California data that do allow the Agency to estimate the number of
poisonings occurring annually in California to the WPS-covered workforce. One subset of
data published annually by California is designated as the number of "agricultural pesticide
poisonings" for a given year, including occupational and nonoccupatipnal poisoning incidents.
The average number of agricultural physician-diagnosed poisoning cases (after removing
poisonings resulting from .exposures to commodities in packing houses) from these data is 821
cases per year for the years 1982-1989 (CDFA, 1983, 1984, 1985, 1986, 1987; Edmiston,
1988; Mehler, 1990, 1991, 1992).
The other subset of data were recently obtained from the California Environmental Protection
Agency and were based on a computer search designed to obtain "agricultural occupational
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pesticide poisonings." The average number of agricultural occupational physician-diagnosed
poisoning cases from these data is 698 cases per year for the years 1982-1990 (Mehler, 1992).
Both data subsets probably include some poisoning cases that occur to persons who are
outside the scope of the WPS and probably exclude some poisoning cases that occur to
persons who are within the scope of the WPS. The Agency does not know the extent of this
over- or under-reporting. Therefore, for the purposes of this analysis, EPA will use these two
data subsets to express a range of possible numbers of physician-diagnosed poisoning cases
occurring annually in California to persons included in the scope of the WPS. The range is
698 to 821.
California reporting system 85% - 95% reliable. California has the most reliable
physician-diagnosed pesticide reporting system in the country. However, no reporting system
can achieve 100-percent reporting precision. Some cases that a physician diagnoses as being
related to pesticide exposure will-not be reported to the system. Indeed, a 1989 paper by
California Department of Food and Agriculture cited a study that found the California
reporting system to be 90-percent reliable in recording cases where physicians diagnosed an
illness or injury as being possibly pesticide related (Maddy et al., 1990). Therefore, the
Agency has assumed that the California system records approximately 85 to 95 percent of
physician-diagnosed pesticide poisoning incidents, with 90 percent used for the calculations.
(3) Estimate of national physician-diagnosed incidents. The Agency has estimated the
national physician-diagnosed pesticide poisoning incidents by adjusting the California rate
(698-821) for the 90-percent reliability and extrapolating to achieve a national estimate by
using the percent of national agricultural occupational hospitalized poisoning cases occurring
in California (5.8%).
698 -T 0.9 -T- 0.058 = 13,372
821 -r 0.9 -r 0.058 = 15,728
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EPA adjusts this estimate to remove the annual hospitalized agricultural occupational pesticide
poisonings already accounted for in section (a) above to estimate annual physician-diagnosed
(not hospitalized) pesticide poisonings occurring to agricultural workers and pesticide handlers
covered by the scope of the WPS.
13,372 - 298 = 13,074
15,728 - 298 = 15,430
This yields a range of 13,000 to 15,000 for this estimate of the most likely value.
Finally, due to the uncertainties at several stages of this estimating technique, EPA concludes
that the actual value may fall somewhere within a wider range. For the purposes of this
analysis, it may, therefore, be reasonable to estimate a rough range of possible values of from
10,000 to 20,000 annual physician-diagnosed (not hospitalized) pesticide poisonings for the
WPS-covered workforce.
c. Concerns about pesticide-incident reporting systems
Only one state, California, has a mandatory and reasonably reliable pesticide-poisoning
reporting requirement. Other states, including Arizona, Florida, and Texas, require similar
reporting, but widespread noncompliance renders these systems of little value. Even the
California reporting system is not without concerns. A 1991 report by the California
Environmental Protection Agency states: "The completeness of the reporting system is an
ongoing concern." (Calif. EPA, 1991)
EPA has identified at least four steps that are necessary before a pesticide-related illness can
be recorded by any counting system: (1) workers must perceive that they have treatable
symptoms; (2) workers must seek medical attention; (3) the physician must diagnose the
symptoms as being pesticide related; and (4) the incident must be reported to the correct
recordkeeping system and be recorded as being pesticide-related.
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(1) Workers must perceive that they have treatable symptoms. Symptoms of acute pesticide
poisoning illnesses and injuries are, unfortunately, usually not uniquely indicative of pesticide
effects. Dermatologic and ophth'almologic effects, such as skin rashes and eye irritation, also
have many other causes. Systemic poisoning by some of the more common pesticides results
in flu-like or cold-like symptoms, such as headache, nausea, vomiting, dizziness, and a
general feeling of malaise. Allergic effects may be either upper-respiratory problems that
mimic hayfever symptoms, or dermatologic effects similar to those caused by exposure to
poison ivy. Therefore, many workers may not perceive that their symptoms are related to
pesticide exposures and may not realize that the illness or injury can be ameliorated
medically.
(2) Workers must seek medical attention. Except in life-threatening emergencies, many
pesticide-related acute health effects will gradually disappear without medical intervention.
For example, the cholinesterase enzyme, which, when inhibited, causes some of the more
common acute systemic poisoning symptoms, will gradually (depending on the family of
pesticide, severity, and repetition of exposure) regenerate without treatment. Allergic,
dermatologic, and ophthalmologic effects will gradually disappear when exposure to the
causal pesticide diminishes. Therefore, many agricultural workers with treatable symptoms
may not seek physician care.
Furthermore, agricultural workers' access to medical care is poor. A GAO report states:
Hired farmworkers have limited access to Medicaid assistance. Many
are ineligible for the program. In addition, state enrollment procedures
and other administrative requirements pose a barrier to eligible
farmworkers. This is because some of these farmworkers leave the state
before their Medicaid applications are processed. Furthermore, those
migrant farmworkers approved for Medicaid are often unable to find a
health provider who will treat a patient with an out-of-state Medicaid
card. Most migrant farmworkers do not receive medical services
provided by the Migrant Health Program's rural health clinics. The
Department of Health and Human Services estimates that because of
budget constraints, the program serves less than 15 percent of the
nation's migrant farmworkers.
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Poor and uninsured farmworkers have reduced access to physician care
and hospital services. About half of these workers and their families
are estimated to have incomes below the poverty level, with the median
family income between $7,500 and $10,000 a year. Also, about four
out of five farmworkers do not have employer-provided health insurance
(U.S. GAO, 1992).
According to the Census Bureau's March 1991 Current Population Survey, 39 percent of
people whose family head was in agriculture had no health insurance at all, more than twice
the average rate (Numbers News, 1992).
Many agricultural workers average 6-day work weeks during their peak work season.
Without sick leave or similar benefits and often already below the poverty level, they may be
reluctant to miss a day's work (and, thus, a day's wage) to seek medical care. A 1988
Evergreen Legal Services survey of Washington State farm workers found that only 8 to 15
percent of farmworkers who perceive they may have symptoms related to pesticide exposures
seek medical treatment (Mentzer and Villalba, 1988). Furthermore, farmworkers in the
survey were unaware that their medical bills would be covered by workers compensation and
feared employer disapproval if it were discovered that they reported that their illness was
caused by an unsafe practice on the farm. Another 1988 survey of farmworkers in British
Columbia, California, Louisiana, and Ohio found that most farmworkers do not seek a doctor
for pesticide-related illness (Moses, 1988). Many workers did not know whether they were
covered by workers compensation. Even when they did know, they often did not report for
fear of retaliation by the employer and loss of their jobs.
(3) The physician must diagnose the symptoms as being pesticide related. Physicians and
other healthcare providers often have difficulty in ascertaining the cause of agricultural
workers' illnesses and injuries, since the symptoms mimic those of other illnesses and
injuries. A California report that summarizes the pesticide-related poisonings reported in
1986 states:
We recognize that there may be a number of pesticide exposure incidents
which result in vague signs and symptoms and the physician may not diagnose
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the condition as a pesticide-related illness of injury. In recent years,
particularly in rural areas, physicians and health officials have received training
in the recognition and management of illness and injuries related to pesticide
exposure. However, physicians cannot possibly be aware of all the pesticides
and pesticide products available in the marketplace today. More than 1.3,000
pesticide products are registered for use in California which contain more than
800 active ingredients and more than 1,000 inert ingredients. These products
are formulated in many different ways . . . Thus, the combinations of active
ingredients and inert ingredients to which a person may be exposed number in
the thousands. , . In addition, the person seeking medical care may not identify
the chemical which resulted in the illness or injury as a pesticide (Calif. Dept.
of Food and Ag., 1987b).
A second concern regarding correct medical diagnosis is that medical personnel rarely receive
training in the recognition and management of pesticide poisonings during their formal
schooling. The California report above mentions that some physicians in recent years have
been receiving such training while practicing medicine in rural areas. Such training has, until
recently, been relatively rare. A report that will soon be published by the Pesticide Farm
Safety Center (PFSC) Advisory Panel states that there is a great need for more training of
healthcare professionals on the recognition and management of pesticide illnesses. The report
explains: "The lack of information about pesticide-related health problems is symptomatic of
a lack of training in medical and public health schools in the broad field of occupational and
environmental medicine, and more instruction in this discipline should be included in the
medicine curriculum." (Univ. of Calif, 1992)
Another concern regarding physician diagnosis of poisonings as being pesticide-related is the
lack of or expense of laboratory tests to confirm diagnosis. The PFSC Advisory Panel report
observed that physicians who treat farmworkers often are unable to test for the cause of the
illness or injury, and, therefore, treat symptoms only.
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A 1990 report by the Arizona Office of the Auditor General (OAG) regarding an audit of the
Arizona Department of Health Services activities related to agricultural pesticides stated:
Even for those who do seek medical care, physicians and clinic staff told us
that illnesses related to pesticides may not be diagnosed as such. Our review
of medical articles and studies performed in other states confirmed this.
Except in severe cases, the symptoms of pesticide-related illnesses are similar
to those of a number of common complaints such as flu, gastroenteritis, and
allergies, Dermatitis, the most common pesticide-related ailment, has many
causes. Tests to confirm diagnosis are often expensive and uncertain, and for
some types of pesticides, no lab test exists. Diagnosis may be even more
difficult for healthcare professionals who don't often encounter these cases.
Doctors, who work regularly with fieldworkers, said milder cases of pesticide-
related illness may be misdiagnosed if a healthcare professional is not alert to
the possibility, and does not ask enough questions to obtain a thorough
occupational history from the patient (Arizona, 1990).
(4) The incident must be reported to the correct recordkeeping system and be recorded as
being pesticide-related. It is well documented that occupational diseases in general are more
likely to be under-reported than occupational injuries. A 1991 study of farmworker health and
safety in the State of Washington says: "Frequently, occupational diseases simply do not
appear in workers' compensation records, even when clear-cut. This is due to reporting
disincentives and inherent difficulties in health care providers recognizing conditions as work-
related." (Washington, 1991) In addition, a 1988 survey of farm workers in British Columbia,
California, Louisiana, and Ohio found that most workers do not receive workers compensation
benefits even if the illness is diagnosed as work-related (Moses, 1988). And another 1988
survey of Washington State farm workers who indicated past health problems associated with
pesticide exposure found that only 4 percent filed for workers compensation (Gerstle, 1989).
Sometimes pesticide-related poisoning incidents are not reported, because diagnosis and
treatment occurs in a state or country where reporting is not required, even though the
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exposure occurred in-a state where reporting such incidents is mandatory. For example, the
report by the Arizona OAG found: "When farmworkers do seek medical care, some visit
doctors in Mexico because costs'are lower and language and cultural barriers are removed."
(Arizona, 1990) Such incidents are unlikely to be recorded in any U.S. reporting system.
Sometimes the incident is reported to the correct record-keeping system, but it is not recorded
as being pesticide-related. For example, 318 incidents involving vineyard worker dermatitis
were classified by California Department of Food and Agriculture as "Insufficient" in 1986.
The report states: "In previous years investigations of vineyard dermatitis cases included an
application history from the last field worked prior to visiting a physician. This method
assumes no latency period between exposure and onset of symptoms and/or the worker
immediately visited a physician at,the onset of symptoms. . . It was determined that most
vineyard workers do not visit a physician for at least three and often as long as 10 days after
the onset of their rash. They often cannot remember the exact field location associated with
the rash. Thus identification of fields and causative agent(s) involved in dermatitis outbreaks
could not be determined" (Calif. Dept. of Food and Ag., 1987b). Subsequent information,
however, indicates that the dermatitis was probably pesticide related. The California
investigators found that increasing the reentry-interval length for two key vineyard pesticides,
sulfur and propargite, has greatly decreased the incidence of dermatitis in vineyard workers
(Edmiston, 1992). These researchers also indicated that fieldworkers' delay in seeking
treatment and the resultant difficulty in determining the field location associated with the
onset of poisoning symptoms is one of the principal reasons why fieldworkers poisoning
incidents are often classified as "Possible" rather than "Definite" or "Probable."
Finally, there may be disincentives for medical personnel to report suspected pesticide
poisoning incidents to a state reporting system. The Arizona OAG report found: "[Sjome
physicians and healthcare officials suggest that cases may not be reported because healthcare
professionals fear becoming involved in a lawsuit or occupational injury claim in which they
might have to defend an uncertain diagnosis in court. Our review of literature on the subject
corroborated this statement" (Arizona, 1990).
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d. Nonphysician-diagnosed acute poisoning incidents
EPA believes that many incidents' of acute and allergic pesticide effects on agricultural
workers and pesticide handlers are not diagnosed as such by a physician. Such incidents may
vary in severity from skin irritations and headaches to life-threatening cases. The distribution
of such effects is unknown, although, on average, such incidents would be expected to be less
severe than those for which medical care is obtained.
The Agency has identified three principal reasons for such nondiagnosis:
1. Workers/handlers fail to perceive they have treatable symptoms,
2. Workers/handlers fail to seek medical attention,
3. Medical personnel fail to diagnose the symptoms as being both pesticide-
related and occupationally related.
There is considerable uncertainty about the number of such incidents. The available studies
which address this issue often suffer from a number of limitations, including reliance on
recall of workersihat may be affected by the questions asked, samples that are small or that
may not be representative, etc. Nonetheless, the Agency believes that, with all their
weaknesses with respect to this objective, existing studies, taken together, are remarkably .
consistent with a conclusion that undiagnosed cases of pesticide poisoning incidents among
the agricultural work force subject to the WPS are likely to be significantly more numerous
than those that are diagnosed.
Workers/handlers must perceive they have treatable symptoms. The Agency is not aware
of studies that estimate how many agricultural workers or pesticide handlers perceive that the
symptoms they are experiencing may be related to pesticide exposure. In order for
workers/handlers to have such a perception they would need to be both aware they were
being exposed to pesticides and aware of the typical signs and symptoms of pesticide
poisoning. The Agency believes that many workers and handlers do not know the typical
signs and symptoms of pesticide poisoning and that many workers do not know if and when
they are exposed to pesticide residues.
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Workers/handlers must seek medical treatment. The Agency is aware of a few studies
that offer an indication of how often agricultural workers and pesticide handlers seek medical
attention when they perceive they have a pesticide-related illness or injury.
One survey of 460 farmworkers in Washington state found that among those workers exposed
to spray or drift who reported bad effects (99 workers), only 8% (8) sought medical treatment
(Mentzer and Villalba, 1988). Among affected workers who had been exposed by entering
fields within 2 days of treatment (91 workers), only 10% (9) sought treatment. Among
affected handlers who had been exposed through mixing and applying pesticides (40 workers),
only 15% (6) sought treatment. The design of this study limited its usefulness for the
purposes of this analysis. It was a survey that relied on the memory of the cohorts and the
perceived bad effects were not necessarily due to pesticide exposure. Furthermore, this study
would not capture those workers who were unaware they were exposed to pesticides or
unaware that the signs and symptoms of illness or injury might be due to pesticide exposures.
A survey of 1,811 Florida citrus field workers identified 29 field workers who reported
poisoning symptoms due to pesticides (Griffith et al., 1985). However, only 31% (9 out of
29) of the total cases reported seeking medical attention. All nine of the physician-attended
cases were mixer/loader/applicators. (There was a total of 11 mixer/loader/applicators.) Of
these nine, 22% (2 out of 9) reported that the poisoning incident required hospitalization. No
non-mixer/loader/applicators reported seeking medical treatment. A range of symptoms were
reported. Approximately 36% (4 out of 11) of the mixer/loader/applicators and 11% (2 out of
18) of the field workers reported symptoms of systemic poisoning, whereas the remaining
64% and 89% respectively reported symptoms of skin and/or eye effects (irritation, burning,
swelling, etc.). Again, the design of this study limited its usefulness for the purposes of this
analysis. It was a survey that relied on the memory of the cohorts and the possible incidents
were not necessarily due to pesticide exposure. For example, 7 of the field worker incidents
were limited to skin irritant effects and the survey's authors indicated that such an effect was
equally likely to be caused by cirrus dermatitis. Furthermore, this study would not capture
those workers who were unaware they were exposed to pesticides or unaware that the signs
and symptoms of illness or injury might be due to pesticide exposures.
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A study in Nebraska measured plasma cholinesterase levels of 91 farmers and 7 commercial
applicators known to use organophosphate or carbamate pesticides (Spigiel et al., 1981);
Thirty percent of the subjects were found to have a reduction of cholinesterase from their
baseline levels of 20% or more-strong evidence of exposure. Most relevant to this analysis,
22% of the subjects reported having symptoms which are common in mild organophosphate
poisoning, including weakness, headache, excessive sweating, nausea or vomiting, excessive
salivation, or diarrhea. None of these workers sought medical attention for their symptoms.
Again, the design of this study limited its usefulness for the purposes of this analysis. It is
not clear from the recruiting procedure how representative the 98 subjects were of farmers or
applicators in Nebraska or nationwide, or of the entire agricultural work force at risk from
pesticides. In addition, it is unclear whether the frequency or severity of the reported
symptoms were different from those expected through ordinary experience. Furthermore, this
study would not capture those workers who were unaware they were exposed to pesticides or
unaware that the signs and symptoms of illness or injury might be due to pesticide exposures.
Medical personnel must diagnose incident as being both pesticide-related and
occupationally related. When medical treatment is sought, the treating medical personnel
may not specifically diagnose the illness or injury as being caused by an occupational
exposure to pesticides. Many signs and symptoms of such poisoning may be treated
symptomatically or an occupational connection may not be drawn. The Agency is aware of
only one study that provides any indication of how often a physician treating pesticide
poisoning illness arid injuries to agricultural workers and pesticide handlers actually diagnoses
the condition as such. The San Francisco Bay Area Regional Poison Control Center surveyed
all occupational illnesses reported to them in a 6 month period in 1986 (Blanc et al., 1989).
There were 41 apparent occupational poisonings due to pesticides. However, only 7 of these
or 17% were reported to the California Department of Food and Agriculture. California
requires physicians to report all occupational pesticide poisoning incidents. This study is also
imperfect. It is not clear how representative the poison control center was of poison control
centers in California or nationwide. It is also unclear as to what percent of the physician-
treated occupational pesticide poisoning incidents in this study were reported to the California
Department of Food and Agriculture. Furthermore, this study would not capture many
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persons who do not perceive their symptoms are related to pesticide exposure or do not seek
professional advice concerning their symptoms.
Conclusion. The limited and imperfect available data are consistent with the Agency's
expectation, based on the stoicism of the agricultural work force and the fact that medical
care is comparatively difficult to obtain for many members of this population at risk, that
only a small fraction of the symptoms of pesticide poisoning are likely to lead to medical
attention and possible diagnosis.
2. Delayed effects
In addition to acute and allergic adverse health effects, pesticides are known to cause delayed
adverse health effects. Some of the delayed effects caused by pesticides include:
Chronic effects, including tumors, cancer, and genetic changes.
Developmental and reproductive effects, including birth defects, miscarriages,
stillbirths, infertility, sterility, and impotence.
Systemic effects, including toxic effects on the heart and circulatory system,
brain and nerve system, skin, lungs and respiratory system, liver, and kidneys.
Unlike acute and allergic effects, where the. symptoms usually appear soon after the causal
exposure, evidence of delayed adverse effects from pesticide exposures almost always
emerges long after the causal exposure(s). This, coupled with the fact that symptoms of
pesticide-caused delayed adverse effects are not unique, results in a predictable lack of hard
data as to the extent and magnitude of pesticide-caused delayed adverse effects.
Delayed effects are almost never recorded by pesticide incident reporting systems. A 1991
Washington State Department of Labor and Industries report states: "[W]orker's
compensation claims data do not usually count work-related chronic disease, including
cancer." Maddy and Edmiston report: "Chronic illnesses or conditions with a long latency
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period are rarely reported to the CDFA [California Department of Food and Agriculture]
through reporting mechanisms currently established."
At this time, EPA has elected not to attempt to quantify risks, from all agricultural-plant
pesticides, for most types of delayed adverse health effects. There are, however, four types of
delayed effects for which the Agency has some data:
• carcinogenic effects,
• serious developmental defects,
• stillbirths, and
• neurotoxic effects.
These available data still fall far short of enabling EPA to quantify risks with the desired
level of precision. The Agency uses these data in this regulatory impact analysis to provide a
representation of the plausible incidence of delayed adverse effects in the agricultural
population to which this final rule applies. However, the Agency remains convinced that
these and other types of delayed adverse effects are occurring and can be, to a great extent,
ameliorated with the protections provided in this final rule.
a. Carcinogenic (cancer) effects
EPA has received and reviewed the required studies for predicting oncogenic effects for
numerous pesticide active ingredients. About 90 of these active ingredients (about one-third
of the pesticides evaluated so far) have been shown to be, at some level, oncogenic in the
study animals (Engler, 1992). As more oncogenic effects studies are received and evaluated
by the Agency during the reregistration process, it is expected that additional pesticide active
ingredients will exhibit oncogenic effects.
In addition, the Council of Scientific Affairs of the American Medical Association reviewed
53 pesticides and categorized 2 as definite, 13 as probable, and 16 as possible carcinogens
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(Am. Med. Assn., 1988). The registration for many of these pesticides has been canceled or
narrowed in use.
Based on these two estimates of the fraction of pesticides that may be carcinogenic, the
Agency expects that among the over 400 pesticide active ingredients used in the production of
agricultural plants, approximately 120 pesticides may exhibit positive oncogenic effects.
For more than a decade, EPA has quantified pesticide handlers' risk of cancer resulting from
exposures to individual pesticide's active ingredient(s), typically in the context of regulating
that active ingredient's use on a single crop. (It is clear, however, that most pesticide
handlers are exposed to multiple pesticides used on multiple crops.) The magnitude of risk
estimated in each such case depends upon the oncogenic potential of the pesticide and use-
specific exposure factors. A range of risks has been calculated for the lifetime probability
that excess cancers will develop in pesticide handlers exposed to specific carcinogenic
pesticides, with 10"4 as a typical risk for high exposure application activities (EPA, 1983;
EPA, 1983; EPA, 1987).
Fieldworkers engaged in a range of harvesting activities have been documented to experience
hourly dermal exposures to pesticides at about the same magnitude as pesticide handlers
(Zweig et al., 1983; Nigg et al., 1984). However, since fieldworkers are typically not as
geographically stable a workforce as are pesticide handlers, it is extremely difficult to
estimate the hours worked on various activities over the course of a lifetime. This is required
to quantify cancer risks. However, fieldworkers nearly always work in multiple crops treated
with multiple pesticides, several of which may be carcinogenic. The Agency did quantify
cancer risks for fieldworkers on one occasion for a single active ingredient, with the resulting
cancer risks in the same range as that for pesticide handlers (EPA, 1985). The Agency
therefore concludes that a 10"4 value for individual lifetime cancer risks is appropriate to use
for all agricultural workers and pesticide handlers covered by the revised final rule and may
be an underestimate.
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EPA has not attempted to quantify eancer risks from pesticide handlers' or agricultural
workers' exposures to multiple pesticide active ingredients, either through simultaneous
exposures to two or more combined active ingredients, or through exposures to multiple
pesticides over a lifetime. The Agency has also not attempted to assess the additive,
synergistic, or antagonistic effects that may result from such multiple exposures. Any such
data are, by their nature, extremely difficult to obtain and verify.
Estimating the number of cancer cases caused by occupational exposures to all agricultural-
plant pesticides is therefore unprecedented. However, if EPA, for example, applies an
estimate of lifetime risk of 10"4 to all workers and handlers covered by this rule, then six
cancer cases (3.9 mil. X 10"4 -f 70) can be expected annually as the result of occupational
exposures to agricultural-plant pesticides.
The Agency notes, however, that this estimate may be on the low side. A case study of one
type of cancer, non-Hodgkins lymphoma (NHL), is illustrative. A report by the National
Cancer Institute describes a case-controlled study of white men who develop NHL as adults
in Kansas (Hoar, 1986). This study indicates a statistically significant increase in risk of
NHL for white men who lived or worked on farmland as adults. The study further estimates
that 11 percent of the NHL cases in the Nebraska population may be explained by exposures
to herbicides. The national incidence of deaths due to NHL in the agricultural population is
estimated to be 1,637 deaths annually (Blair, 1992). Estimating from the Nebraska population
to adults who lived or worked on a farm, then 220 annual NHL cancer deaths could be
attributed to occupational exposures to agricultural-plant phenoxy herbicides. In addition, a
recently released article in Cancer Research shows evidence linking insecticide exposure to
NHL in the agricultural population (Cantor et al., 1992). The Agency has just received all of
the data from these studies and is convening a panel to review the data and advise the
Agency on the weight of evidence as to the likelihood there exists an unacceptable risk of
cancer due to agricultural exposures to phenoxy herbicides, specifically 2,4-D.
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b. Developmental and reproductive effects
In the United States, it is estimated that about 35 percent of conceptions do not result in live
births (Wilcox et al, 1985). The number of such occurrences due to occupational exposures
to pesticides is unknown, but there are indications that such exposures could be responsible
for a substantial number. There are several types of developmental and reproductive" effects
that are thought to occur as the result of exposure to pesticides. These include: infant
mortality, developmental defects, stillbirths, and spontaneous abortions. Of these EPA has the
most data about pesticide-related stillbirths and serious developmental defects.
Serious developmental defects
Exposing laboratory animals to certain pesticides is known to cause developmental defects in
the progeny produced by those animals. On the basis of developmental toxicity studies
already received and reviewed, EPA has determined that more than 100 pesticide active
ingredients cause developmental toxicity in laboratory animals at some level of exposure.
This represents approximately one-third of the active ingredients evaluated so far. As more
developmental toxicity studies are received and evaluated by the Agency during the
reregistration process, it is expected that additional pesticide active ingredients will exhibit a
developmental toxicity effect.
Based on this estimate of the fraction of pesticides that may cause developmental defects, the
Agency expects that among the over 400 pesticide active ingredients used in the production of
agricultural plants, approximately 120 pesticides will exhibit developmental toxicity effects.
Furthermore, the California Environmental Protection Agency has placed 11 pesticides oh its
list of developmental toxins to be regulated under Proposition 65 (Calif. EPA, 1992).
Developmental toxicity differs from carcinogenic toxicity in that developmental defects may
result from a single exposure, whereas it is thought that carcinogenic effects are increasingly
likely to occur as exposure accumulates over a lifetime. As a result, the risks of adverse
developmental effects are calculated on the basis of a single exposure-day, rather than on the
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basis of amortized lifetime exposure, as cancer risks are calculated. Developmental toxicity is
calculated for the aggregate male and female population at risk, because it can originate from
either sex.
An attempt has been made to quantify the risks of severe developmental defects resulting
from pesticide handlers' and agricultural workers' exposures to individual pesticide active
ingredients. The magnitude of risk in each case depends on the level of developmental-
toxicant hazard and use-specific exposure factors.
No attempt has been made to quantify the risks of severe developmental defects resulting
from pesticide handlers'- or agricultural workers' exposures to multiple pesticide active
ingredients, either from simultaneous exposures to two or more combined active ingredients,
or from exposures to multiple pesticides over a lifetime. Furthermore, no attempt has been
made to assess the additive, synergistic, or antagonistic effects that may result from such
multiple exposures. Any such data are, by their nature, extremely difficult to obtain and
verify.
Estimating the number of serious developmental defects caused by exposures to agricultural-
plant pesticides is extremely difficult. However, the total number of serious developmental
defects that might be expected to occur among the population of agricultural workers and
pesticide handlers who are occupationally exposed to these pesticides can be approximated.
The annual national rate for developmental defects in the United States thought to be serious
by EPA is approximately 3 percent at birth and, with increasing age and the detection of
certain functional changes, increases to 6 percent or 7 percent (Shepard, 1986). EPA is aware
of two different reports that estimate what fraction of those serious developmental defects are
from unknown causes. One study estimates that 70 percent of the severe developmental
defects are from unknown causes, while the other study estimates 43 percent (Wilson, 1977)
(Nelson and Holmes, 1989). If those estimates are averaged (56.5 percent) and applied to the
national (6 percent) rate, it yields an estimate of an annual rate of 3.4 percent of live births
that exhibit serious developmental defects from unknown causes. The total number of live
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births (3.8 million live births annually in the United States)(Ventura et al., 1988) and the
percent (3.4) of those births that exhibit serious developmental defects from unknown causes
may be apportioned to the population to which this rule applies (4 million agricultural
workers and pesticide handlers). From this calculation, approximately 2,000 live births with
serious developmental defects of unknown cause would be predicted to occur annually to this
population.
If, for example, it is assumed that only 1 percent of those cases of serious developmental
defects that result from unknown causes is attributed to occupational exposures to
agricultural-plant pesticides in the population to which the protections of this rule apply, then
20 births with serious developmental defects attributable to such a cause would occur
annually.
EPA believes this estimate of 20 may be conservative, however. A case study by McDonald
et al. is illustrative. Workers with agricultural and horticultural occupations may be at higher
risk than those in the general population. A study published in the British Journal of
Industrial Medicine in 1988 found that the rate of congenital defects in births to workers in
agricultural and horticultural occupations was 2.6 times that of the general population
(McDonald et al., 1988). In addition, individual case studies of women poisoned by
pesticides during their first trimester of pregnancy indicate that serious birth defects can result
from such poisoning (Romero et al., 1989). As is characteristic of epidemiological studies,
the McDonald et al. study is not without flaws. It did not consider alcohol, or the occupation
of the fathers as possible factors. However, it did consider educational level, ethnicity, and
smoking and found that even after adjustment for these factors, their findings of significant
risks associated with pesticides persisted. They concluded: "We do not think it likely that the
risks in specific occupational groups presented [in this study] would be importantly changed if
allowances were formally made for non-occupational confounding variables."
If the Agency used the rate of congenital defects estimated by the study reported in the
British Journal of Industrial Medicine to estimate for this population the total number of
serious developmental defects that result from unknown causes, the total number would be
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5,200 rather than the 2,000 estimate. If only 1 percent of these incidents were attributed to
exposures to agricultural-plant pesticides, the estimated number would be 52 rather than 20.
Moreover, the fact that the rate for agricultural occupations exceeds that of the general
population suggests that the attribution of only 1 percent to pesticides could be far too low.
Illustrative Case History: The agricultural-plant pesticide dinoseb was widely used for a
number of years on several agricultural crops, including crops where hand labor activities are
common. In 1986, EPA determined that dinoseb was potentially a serious developmental
toxicant.- Based on the EPA analyses for dinoseb, the Agency estimated that over 100 serious
developmental defects could result annually among occupationally exposed women if dinoseb
use continued. Dinoseb registration was suspended on an emergency basis and subsequently
canceled. However, once the Agency receives and reviews data on developmental toxicity for
the remaining two-thirds of the pesticides to be evaluated for developmental effects during
reregistration, other existing pesticides at similar risk levels may be identified.
Stillbirths
A case-control analysis based on 9,941 live births and 6,386 stillbirths found that maternal
exposure to pesticides at work and in and around residences was associated with an increased
risk of stillbirth at a rate approximately one and one-half times the control population (Savitz
et al., 1989). This rate was significant for exposure to pesticides on the job, in the home, or
in the area of the residence. In addition, paternal exposures to pesticides in these locations
was also associated with increased risk of stillbirths at a rate above the control population. A
generic problem with all epidemiology studies that rely to some degree on the cohorts'
memory is the potential errors in subject's recall and the potential bias that may be introduced
in surveys by how the questions may have been structured. This epidemiological study
depended on the subjects' memory as to their exposure to pesticides in the 12 months before
the birth. The correlation between exposure to pesticides and stillbirths in this study is not
necessarily a direct correlation with agricultural pesticide exposures; it may include
exposures to non-agricultural pesticides also.
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The annual stillbirth rate for the United States is 7.5 stillbirths per 1,000 life births per year
(Nat. Center for Health Stat., 1988). The total number of live births per year in the United
States is approximately 3.8 million (Ventura et al., 1988). If only those cases of stillbirths
that may be expected to exceed the base rate for the general population based on the odds
ratio of 1.5 are considered, the excess stillbirths among the agricultural workforce would be
222 per year.
[11.25/1000 - 7.5/1000] X 3.8 mil. X [3.9 mil + 250.0 mil] = 222
Even if, for example, it is assumed that only 25 percent of those excess cases are attributed
to occupational pesticide exposures, an estimated 56 stillbirths may be attributable to such
occupational exposures in the population to which the protections of this rule apply.
25% X 222 = 56
c. Persistent neurotoxic effects
Increasing evidence indicates that risks of neurotoxic health effects are related to exposures to
organophosphate pesticides. The World Health Organization suggests that 5 percent of
occupational poisonings due to organophosphates result in adverse neurotoxic effects (United
Nations, 1990). A 1990 report to Congress by the Office of Technology Assessment states:
The pesticides parathion, mevinphos (Phosdrin), and malathion are frequently
reported as causing health problems. Case reports and studies of acute
poisonings of agricultural and other workers indicate that 4 to 9 percent of the
acutely poisoned individuals experienced delayed or persistent neurological and
psychiatric effects. . . [These effects include] irritability, depression, mood
swings, anxiety, fatigue, lethargy, difficulty concentrating, and .short-term
memory loss (U.S. Congress, 1990).
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Two case-controlled studies and several case-series reports indicate that these symptoms may
persist for months or years after the initial exposure (Savage et al., 1988; Rosenstock et al.,
1991; Echobichon et al., 1990; Karalliedde and Senanayake, 1989; Eskenazi and Maizlish,
1988). The population studied was persons who had been poisoned by organophosphate
pesticides. The development of the neurotoxic effects subsequent to the poisoning incident
suggests that this range of percent affected is the excess above the background level.
Approximately 50 percent of the physician-diagnosed acute pesticide poisoning incidents
reported by California are systemic illnesses (Mehler, 1991). Of those systemic illnesses,
approximately 45 percent are caused by exposures to organophosphates. If this 22.5 percent
rate is applied to the national estimate (10,300 to 20,450) of physician-diagnosed acute
pesticide poisoning incidents, an estimated 2,300 to 4,600 physician-diagnosed systemic
organophosphate-caused incidents occur annually. If EPA takes a midpoint of the Office of
Technology Assessment's reported range (4 to 9 percent) of such acute poisoning cases that
lead to mid- to long-term neurotoxic effects, approximately 150 to 300 cases of mid- to long-
term neurotoxic effects may occur annually to agricultural workers and pesticide handlers
poisoned by agricultural-plant pesticides.
3. Cost comparison to estimated cases avoided
Summary of costs and benefits
EPA believes that the benefits that will accrue to agricultural workers and handlers from
implementation of the WPS include the reduction in lost time from the workforce, reduced
medical expenses, and increased well-being and productivity through being less affected by
pesticide poisoning. These and any related benefits cannot be adequately quantified with
available data. The Agency is convinced that the benefits to society from avoided incidents
of acute, allergic, and delayed adverse effects from occupational exposures to agricultural-
plant pesticides exceed the costs attributable to this final rule.
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EPA estimates that the incremental costs of this final rule will be about $95 million in the
first year and about $50 million annually thereafter. To facilitate comparison with other
regulations, EPA has also calculated the costs by annualizing them over ten years at several
illustrative interest rates. Using 3% and 10%, the annualized costs of this final rule would be
about $54 and $56 million per year respectively. The annual cost of the rule is therefore
expected to be $50 to $60 million dollars, while the estimated annual benefits of this final
rule include avoiding 8,000 to 16,000 physician-diagnosed (nonhospitalized) acute and allergic
pesticide poisoning incidents, avoiding about 300 hospitalized acute and allergic pesticide
poisoning incidents, and avoiding potentially important numbers of cancer cases, serious
developmental defects, stillbirths, persistent neurotoxic effects, and nondiagnosed acute and
allergic poisoning incidents.
EPA has not attempted in these analyses to develop specific estimates of anticipated adverse
effects for which the aggregate occupational data that the Agency is aware of is more limited,
although there is some evidence that these effects may occur. Studies have demonstrated that
many pesticides cause adverse effects in animals, and some pesticides have been observed to
have adverse effects on humans. Most pesticides have not yet been adequately tested for
these effects, however. Nor is it yet certain, in most cases, how animal responses to various
doses of pesticides compare with the response of agricultural workers/ pesticide handlers
encountering expected occupational exposure levels. However, the level of current knowledge
is sufficient to cause EPA to conclude that some or all of these effects may be occurring to
agricultural workers and pesticide handlers as a result of their occupational exposure to
agricultural pesticides. These adverse effects may include:
(1) Spontaneous abortions and infant mortality,
(2) Sterility, infertility, and impotence,
(3) Delayed-onset systemic effects to the heart and circulatory system, skin, lungs
and respiratory system, liver, and kidneys.
However, as discussed in the previous sections, EPA has developed specific estimates for two
categories of acute adverse effects based on human incidence data, and for four types of
delayed-onset adverse effects based, of necessity, on more theoretical approaches.
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80% efficacy of the WPS
The Agency assumes that compliance with the comprehensive protections provided in this
final rule will reduce the incidence of each of these adverse effects by approximately 80
percent. This assumption is based on the following rationale.
1. Handlers: Studies indicate that under ideal use situations, personal protective
equipment (PPE) or engineering controls (enclosed cabs/closed systems) can reduce
exposures by at least 95 percent. However, pesticide-handling conditions are not
ideal—hoses break, spills occur, PPE is torn, handlers remove their PPE or accidentally
contaminate the inside of it, PPE is incorrectly or incompletely decontaminated or
maintained, etc. Therefore, in spite of the WPS provisions for handler training and
special instructions, decontamination sites, and routine inspection and maintenance of
PPE, the Agency projects that the handler protections of the WPS may have an
efficacy rate of only about 80 percent
2. Workers Protected During Application and During Restricted-Entry Intervals: The
WPS excludes workers from areas being treated or remaining under an REI, except
under special circumstances. Such an exclusion would be close to 100 percent
efficacious if total compliance were achieved. However, the WPS does allow workers
in treated areas during REIs for short-term activities and for emergency activities.
Such entries are accompanied by handler-like protections, but would still not be
expected to achieve 100 percent protection. Furthermore, noncompliance with the
exclusion of workers during applications and REIs may occur—drift from application
onto nearby workers may occur and notification to workers of treated areas may be
insufficient, incorrect, or ignored. Therefore, EPA projects that the WPS provisions
for protecting workers during application and the REI may have an efficacy rate of
only 80 percent.
3. Workers Protected After REI: The WPS provides workers with training and
decontamination facilities if they will be working in treated areas within 30 days of
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the REI. In addition, workers are notified about any nearby areas where pesticides are
to be applied or where a restricted-entry interval is in effect.
The benefits of training as a mechanism for reducing worker illnesses and injuries have been
documented in manufacturing settings and it is reasonable to expect that such programs would
also be effective in agricultural settings. A 1985 study by ICF, Inc. to assess the possible
benefits from increased supervision, notification, and training requirements of the Worker
Protection Standard states: "the percentage of pesticide poisoning prevented by improved
information flows to workers might be assumed to range between 25 and 75 percent" (ICF,
1985). While this study only considered increased handler training, it is reasonable to assume
that the extension of training to workers in this final rule would result in increased benefits.
The importance of frequent and thorough washing as a means of reducing dermal exposure to
pesticides, which constitutes as much as 98 percent of the exposure of field workers to
pesticide residues, is also well documented. Two experts, Dr. Jesse S. Ortiz of the School of
Public Health at the University of Massachusetts and Dr. Eugene J. Gangarosa of the Public
Health Program at Emory University School of Medicine, have estimated that if adequate
handwashing facilities were available, pesticide-related illness could be reduced by 65 percent
and pesticide-related skin rashes could be reduced 35 to 97 percent (U.S. DOL, 1987).
The WPS protections for these workers are not independent of one another. Training should
reinforce workers' recognition of the need to heed warnings about areas that are unsafe to
enter, as well as their attention to such warnings. Training should reinforce workers' use of
decontamination facilities by informing them of the importance of washing thoroughly and
often, even when the presence of residues cannot be readily detected. The Agency believes
that these combined protections would achieve an 80 percent efficacy in reducing pesticide-
related illnesses and injuries for this segment of the worker population.
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Cases avoided
For the purposes of this analysis, EPA estimates that, in the WPS-covered workforce, the
following pesticide poisoning cases attributed to occupational exposures to agricultural-plant
pesticides could be largely avoided through compliance with the WPS:
a range of 300 to 450 for the annual hospitalized acute pesticide poisoning
cases and a range of 10,000 to 20,000 annual physician-diagnosed (not
hospitalized) acute pesticide poisoning cases that could be attributed to
occupational exposures to agricultural-plant pesticides, using the most complete
and reliable pesticide poisoning data available. An 80% reduction in these
cases would avoid 240 to 360 hospitalized acute cases and 8,000 to 16,000
acute physician-diagnosed cases annually.
a significant number of annual acute pesticide poisoning incidents for which
medical treatment is not sought or for which medical treatment is symptomatic
(no causal diagnosis is attempted) or for which no occupational connection is '
made. Since the Agency has not attempted to estimate the rate of such
poisoning incidents in this analysis, no specific estimate of cases avoided
through WPS compliance is included, although the Agency believes the number
is very likely to be large.
Given the expected effectiveness of the rule, EPA believes that the delayed-onset adverse
effects that would be avoided through compliance with the rule will include potentially
important numbers of cancer cases, serious developmental defects, stillbirths, and persistent
neurotoxic effects. Discussions of these estimates appear earlier in this section. In addition,
as discussed earlier, other potential adverse effects may be avoided through compliance with
this final rule.
The Agency recognizes the inherent difficulty in assigning costs of the rule among six
disparate adverse effects and among the many adverse effects for which no specific estimates
were attempted. One possible method would arbitrarily distribute the costs of the rule equally
among the six specifically estimated adverse effects and compute a cost per case avoided for
each such effect. Such an allocation of costs would be arbitrary. In addition, the approach
disregards the anticipated health effects for which quantitative estimates have not been made.
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Another method would compare all of the costs of the rule to one adverse effect in an attempt
to provide some basis for evaluating the rule's cost-effectiveness. Using this method, the
Agency might base the calculation on the category of health effect for which the best data are
thought to be available—annual physician-diagnosed (including hospitalized) acute pesticide
poisoning cases that could be attributed to occupational exposures to agricultural-plant
pesticides (10,300 - 20,450). With an 80 percent reduction of such cases through compliance
with the final rule, the estimate of the number of such cases that would be avoided by
implementation of this final rule would be 8,240 - 16,360. This range of estimates would
then be compared to the costs of the final rule. This result is, however, highly incomplete
since it fails to incorporate all six types of adverse effects for which EPA attempted
quantification, as well as the numerous effects for which no specific estimates were made.
Note that these analyses are an attempt to quantify overall risks, across all pesticides to which
the population is typically exposed, for several different adverse effects. They do not attempt
to take into account the possibility of currently unrecognized highly significant risks that may
be associated with individual pesticides. When any such highly significant risks are
discovered, they will be dealt with by the Agency on a case-by-case basis.
4. Support .for regulation
EPA issued an Advanced Notice of Proposed Rulemaking in 1984 that announced its decision
to revise part 170 and solicited public comment. Most comments favored revising part 170,
but they expressed wide differences in opinion about the revisions needed. In 1988, EPA
issued a Notice of Proposed Rulemaking (NPRM) and held more than 15 public meetings to
Explain the proposed rules and to answer questions. In response to the NPRM, the Agency
received 380 comments totaling more than 3,000 pages. Of the comments, the overwhelming
majority supported issuance of a new rule, including many federal and state agencies,
universities, agricultural worker organizations and advocates, growers and grower/commodity
organizations, and pesticide registrants. As would be expected in a rule of this scope and
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complexity, there were a number of comments and suggestions specific to the various
provisions.
In addition to the comments received during the rulemaking process, EPA has received
support for this rule from a number of other sources, including EPA's own Science Advisory
Board, a U.S. General Accounting Office report to Congress, and the Council of Scientific
Affairs of the American Medical Association.
In 1990, EPA's Science Advisory Board identified agricultural worker exposures to chemicals
as a relatively high human health risk due to the large number of workers directly exposed to
a range of highly toxic chemicals (U.S. EPA, 1990). They stated: "[Ajgricultural workers are
exposed to many toxic substances in the workplace. Such exposures can cause cancer and a
wide range of non-cancer health effects."
A 1992 United States General Accounting Office (GAO) study concluded that farmworkers
and their children are routinely exposed to pesticides and that the health and well-being of
farmworkers are inadequately protected by federal laws and regulations (U.S. GAO, 1992).
The report states: "Federal laws and regulations give hired farmworkers exposed to pesticides
inadequate protection, which increases the risk of pesticide poisonings." GAO's
recommendations to reduce farmworkers' health risks included the following (all of which are
addressed in this final rule):
(1) Access to labeling information, and specific information about pesticides to
which the workers may be exposed.
(2) Oral and written warnings or notification of pesticide use.
(3) Greater restrictions on entering pesticide-treated areas, including a minimum
reentry period of 12 hours and increased level of personal protective
equipment.
(4) Widespread availability of sanitation facilities, including handwashing facilities.
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GAO concludes: "EPA's modified [worker protection] standards, some of which will be,
effective in 1992, should increase protection to these farmworkers" (U.S. GAO, 1992).
In 1988 the Council of Scientific Affairs of the American Medical Association (AMA)
recommended that the AMA: "Urge the EPA and other responsible state and federal
regulatory agencies to continue their efforts at safeguarding human and environmental health,
especially the health of agricultural workers who may be exposed to pesticides" (AMA,
1988).
Another indicator of the need for such regulation, and of its apparent benefits, is that key
states have developed similar worker protection regulations. The major agricultural states of
California, Texas, Arizona, and Ohio have already promulgated regulations that contain
provisions similar to those in this final rule. Several other states, including New Jersey.and
Washington, are developing such regulations.
B. Benefits to Users
Agricultural-plant pesticide users are the owner/operators and supervisors of agricultural
establishments and commercial pesticide handling establishments that use pesticides in the
production of agricultural plants on farms, forests, nurseries, and greenhouses. These users
will benefit in many ways from the revision of the WPS.
The primary goal of the revised final rule is to mitigate occupational exposures of
fieldworkers and pesticide handlers to agricultural-plant pesticide products and their residues.
The mitigation of such exposures should provide specific benefits to agricultural-plant
pesticide users by:
(1) reducing time lost from the workforce by agricultural workers and handlers,
including users themselves,
(2) reducing medical expenses and insurance premiums for themselves and as
employers of hired workers and handlers,
(3) decreasing liability concerns, expenses, and insurance, and
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(4) increased overall productivity from having a workforce less at risk of adverse
health effects (acute, allergic, and delayed) from occupational exposures to
agricultural-plant pesticides.
Sufficient data are not available to allow the quantification of the value of these benefits.
The Agency, however, believes these benefits are substantial.
Pesticide users will also benefit from having a single standardized set of duties rather than
myriad label-specified duties that may vary considerably from product to product. Over the
past several years, many of the requirements similar to those contained in this revised rule
have been placed on a number of individual specific products' labels by the Agency. These
include: prohibiting early entry, specifying increased personal protective equipment and
exceptions to personal protective requirements, and establishing 24-, 48-hour, and longer
reentry intervals accompanied with various restrictions and exceptions. This final rule will
allow users to become informed, in general, about only one set of duties and requirements
pertaining to worker safety, rather than having to interpret and comply with duties that vary
from product to product.
The revised final rule benefits pesticide users by: (1) allowing them options as to the means
of fulfilling some of the requirements, and (2) creating exceptions to some of the
requirements when employees would not be likely to benefit from the protection. In fact, the
complexity of the WPS is, in large part, due to the number of exceptions and options that the
Agency has built in for many of the key provisions. The exceptions and options allow
employers to choose, for their individual situation, the least burdensome means of meeting a
requirement.
Finally, pesticide users will benefit from having a trained and informed workforce. Studies
indicate a high correlation between safety training and increased cooperation by employees in
safety programs designed for their benefit. Such a workforce is more likely to follow safety
precautions to protect themselves and others, thus reducing the likelihood that pesticide users
will experience enforcement actions, liability suits, and pesticide-related emergencies.
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C. Benefits to Registrants
The revised final rule will require registrants of agricultural-plant pesticide products to alter
their product labeling to add a standardized WPS reference statement and to include product-
specific requirements pertaining to personal protective equipment, restricted-entry intervals,
and notification to workers. Registrants will benefit from many aspects of the implementation
of the WPS, especially from the standardization of labeling statements.
Registrants are incorporating the entire WPS into each pesticide product's labeling by adding
a three-sentence reference statement to the product labeling, rather than by adding the entire
text of the rule into supplemental labeling which would then accompany each product at sale.
This reference-statement innovation will benefit registrants by greatly, reducing labeling length
and complexity and, thus, reducing printing and distribution costs for labeling.
Registrants will also benefit from, the standardization of labeling statements and terminology
pertaining to personal protective equipment, restricted-entry intervals, and notification to
workers. Their users will be better able to interpret the standardized labeling statements and
requirements and thus, presumably, will be able to use the pesticide with increased safety to
themselves, others, and the environment. Such increased safety in the use of their pesticides
would benefit registrants through decreased liability, decreased insurance rates, and improved
public image.
Furthermore, EPA has been establishing interim requirements regarding entry and personal
protective equipment on a product-by-product basis for more than a decade. Since that time
some registrants may have been at a competitive disadvantage if, for example, a registration
standard establishing a reentry interval were issued for their product before one was issued for
their competitors' products. This rule will eliminate that competitive disadvantage by
establishing the same requirements and use limitations for products with similar toxicity,
formulation, and use patterns.
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By standardizing the exceptions concerning personal protective equipment, restricted-entry
intervals, and notification to workers, the WPS makes these statements universally applicable.
Registrants benefit by being able to remove verbiage regarding such exceptions from their
pesticide product labeling, thereby reducing labeling complexity, lowering printing costs, and
freeing label space for other crucial use directions.
Registrants may benefit from the promulgation of this final rule, because its issuance is likely
to reduce pressure for states to adopt state-specific worker protection regulations. Registrants
will save considerable costs if fewer state-specific regulations are enacted, through avoidance
of having to supply supplemental use directions on a state-specific basis.
Finally, registrants will benefit from having users who: (1) are better trained and informed,
(2) are equipped with appropriate personal protective equipment, and (3) have access to wash
water for routine and emergency decontamination. Such users are likely to handle pesticides
more safely and experience adverse health effects far less often. Such an outcome will
benefit registrants through decreased liability, decreased insurance rates, and improved public
image.
D. Benefits to States, Tribes, and Territories
The revision of the Worker Protection Standard is expected to obviate the need for
agricultural worker protection regulations in many states.* Many states would no longer need
to consider legislation or regulation in this area. EPA is aware of states that are delaying
("
promulgation of their own worker protection regulations in anticipation of the issuance of this
final rule. While there is no reliable way to know how often this will occur, there is ample
evidence that states have been moving toward more stringent regulations with respect to
pesticides and worker protection. Arizona, California, Texas, and Ohio are examples of states
with significant regulations designed to reduce agricultural worker and pesticide handler
exposures to pesticides. Washington and New Jersey, among others, are known to be
* Term "states," as used here, includes tribes and territories.
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developing such regulations at this time, and it is likely that pressure exists in many other
states to follow suit.
In general, states enforce federal pesticide regulations, including the original WPS. One of
the primary rationales for revising the original WPS was the difficulty state and federal
officials had in enforcing its requirements, mainly because it failed to make clear who was
responsible for providing the required protections to agricultural workers. The revised final
rule is designed to clarify and make more enforceable the WPS provisions, thus simplifying
the efforts of compliance monitoring officials and, in some respects, easing their burden.
States will benefit from increased standardization of pesticide use directions and related
requirements. The standardization of labeling statements regarding personal protective
equipment, restricted-entry intervals, and notification will allow state training and compliance
monitoring personnel to more easily interpret and enforce those requirements. Instead of
requiring states to train users about or enforce requirements that vary greatly from product to
product, the WPS will establish standardized terminology and statements that, in general, are
applicable to all agricultural-plant pesticides. In addition, the WPS sections on personal
protective equipment, restricted-entry intervals, and notification standardize and clarify the
exceptions to these requirements for all affected products. The need for special enforcement
policy statements and label-specific language on these exceptions will be eliminated.
EPA has set aside special monies for states to fund WPS-related special projects. In fiscal
years 1990 through 1992, $500,000 was available annually to states desiring to develop WPS
initiatives. The states have benefitted from this WPS Special Project funding by being able to
develop WPS-specific projects and to explore innovative means of implementing and
enforcing the WPS. Beginning in fiscal year 1990, EPA has also provided states with WPS-
specific compliance monies. The states have benefitted from those monies by using them to
strengthen the worker-protection compliance, information, and education components of their
programs.
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citrus fieldworkers,' J. Environ. Sci. Health B20(6):701-727.
Hoar, S.K. et al., 1986. Agricultural herbicide use and risk of lymphoma and soft-tissue
sarcoma. Journal of the American Medical Association 256 (September 5,
1986):1141-1147.
ICF, Incorporated, 1985. Analysis of proposed farmworker supervision, training, and warning
regulations under FIFRA, EPA contract 68-02-4064, work assignment 2.
Karalliedde, L., and Senanayake, N., 1989. Qrganophosphorus insecticide poisoning. Br. J.
Anaesth. 63:736-750.
V-42
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Keefe, T.J., Savage, E.P., and Wheeler, H.W., 1990. Third national study of hospitalized
pesticide poisoning in the United States, 1977-1982. (Fort Collins: Colorado State
University).
Maddy, K.T., Edmiston, S., and Richmond, D., 1990. Illness, injuries, and deaths for
pesticide exposures in California 1949-1988. Reviews of Env. Contam. and Tox.
114:57-123.
McDonald, A.D. et al., 1988. Congenital defects and work in pregnancies. British Journal of
Industrial Medicine 45:581-588.
Mentor, M., and Villalba, B., 1988. Pesticide exposure and health: A study of Washington
farmworkers (Granger, WA: Evergreen Legal Services).
Mehler, L., 1991. Tables of hospitalized cases and systemic poisoning - 1982-1989. In letter
to Jerome Blondell, U.S. Environmental Protection Agency.
Mehler, L., 1991. Summary of illnesses and injuries reported by California physicians as
potentially related to pesticides, 1989, HS-1624.
Mehler, L., 1992. Number of agricultural pesticide illnesses and injuries that were due to
exposures to pesticides in packing houses, 1982-1989. Personal communication to
Jerome Blondell, U.S. Environmental Protection Agency, July 10, 1992.
Mehler, L., 1992. Number of agricultural occupational pesticide-related illnesses and injuries,
1982-1990. Fax to Jerome Blondell, U.S. Environmental Protection Agency, June 26,
1992.
Mehler, L., Edmiston, S., Richmond, D., O'Malley, M., and Krieger, R.I., 1990. Summary of
illnesses and injuries reported by California physicians, 1988, HS-1541.
Moses, M., 1988. A field survey of pesticide-related working conditions in the U.S. and
Canada. (San Francisco: Pesticide Education and Action Project).
National Center for Health Statistics, 1988. Vital Statistics of the United States, vol. 2.
Nelson, K., and Holmes, L.B., 1989. Malformations due to presumed spontaneous mutations
in newborn infants. New England J Med. 320:17-23.
Nigg, H.N., Stamper, J.H., and Queen, R.M., 1984. The development and use of a universal
model to predict tree crop harvesters' pesticide exposure. Am. J. Ind. Hygiene.
45:182.
The Numbers News, 1992. Health insurance is not a given in the U.S. March 1992.
V-43
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Research Triangle Institute, 1986. Final report: A recommended design for an annual survey
of hospital-treated pesticide poisonings, RTI/3094/10-12F. (Research Triangle Park,
NC: Research Triangle Institute).
Romero, P. et al., 1989. Congenital anomalies associated with maternal exposure to
oxydemeton-methyl. Env. Res. 50:256-261.
Rosenstock, L. et al., 1991. Pesticide health effects study group: chronic central nervous
system effects of acute organophosphate pesticide intoxication. Lancet 338:223-227.
Savage, E.P. et al., 1988. Chronic neurological sequelae of acute organophosphate pesticide
poisoning. Archives of Env, Health 43:38-45.
Savage, E.P., Keefe. T.J., Wheeler, H.W. and Helwic, L.J., 1980. National study of
hospitalized pesticide poisonings, 1974-1976. U.S. Environmental Protection Agency
540/9-80-001.
Savitz et al., 1989. Self-reported exposure to pesticides and radiation related to pregnancy
outcome — results from national natality and fetal mortality surveys. Pub. Health
Rep. 104:473-477.
Shepard, T.H., 1986. Human teratogenicity. Adv. Pediatric. 33:225-268.
Spigiel, R.W., Gourley, D.R., Holcslaw, T.L., Young, B., and Haggerty, J.A., 1981.
Organophosphate pesticide exposure in farmers and commercial applicators. Clinical
Toxicology Consultant 3:45-50.
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pesticides in agriculture, and organic solvents in the workplace. Neurotoxicity:
identifying and controlling poisons of the nervous system, OTA-BA-436 (Washington,
DC: Government Printing Office), pp. 281-311.
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employment and wage rates 1910-1990, SBN-822, pp. 55-56, 210.
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sanitation; final rule. Federal Register 52:16050-16096 (5/1/87).
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V-44
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review. Federal Register 48:49596 (10/7/83).
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GAO/HRD-92-46.
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rates for .the United States, 1976-1985. American J Pub Health 78:504-511.
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VI. IMPACTS ON SMALL ENTITIES
The Regulatory Flexibility Act (RFA) (P.L. 96-354) requires governmental regulators to make
a conscious effort to lighten the regulatory burden of their actions on the "small entities"
within regulated communities. Regulatory options must be considered in an attempt to avoid
"a significant economic impact on a substantial number of small entities."
The following analysis responds to the RFA requirements, presents the rationale for the
Agency's regulatory actions, and assesses the relative economic impacts on small entities
within the proposed regulatory community. It provides a preliminary assessment on whether
the proposed action causes "a significant economic, impact on a substantial number of small
entities." While this is a subjective criteria, the following analysis indicates that the rule has
avoided or mitigated, to the extent feasible, potential disproportionate burdens on small
entities and is structured to provide a nearly equitable burden on both small and large entities.
This revised Worker Protection Standard (WPS) impacts those agricultural establishments -
farms, forests, nurseries, and greenhouses — that use pesticides and are primarily involved in
the production of agricultural plants. EPA estimates that there are approximately 570,000
such establishments nationwide. Nearly all these establishments would be classified as small
businesses based on conventional size-classifications for U.S. businesses. Because of their
unique characteristics, however, agricultural businesses are often classified using other criteria
than those used for conventional businesses. For this analysis, two forms of classifying small
versus large farms were used to consider if "significant economic impacts" occurred "on a
substantial number of small entities. They were:
(1) Impacts on family-operated establishments, in comparison with impacts on
hired-labor agricultural establishments, and
(2) Impacts on hired-labor agricultural establishments that have 1 hired employee,
in comparison with establishments that have 10 hired employees.
VI-1
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Overall, EPA has attempted in several ways to relieve the regulatory burden of this final rule
on small entities. Family-operated agricultural establishments will be exempt from many of
the provisions in the rule. In addition, the rule allows employers considerable flexibility in
the ways that they may fulfill the requirements. In some circumstances, it allows them to
bypass requirements altogether when no employees would be likely to benefit from the
protection. The extent of the economic burden or relief to small entities from these actions is
detailed below.
A. Impacts on Family-Operated Establishments
The revised rule exempts owners of agricultural establishments and members of their
immediate family from the provisions pertaining to safety training and information,
decontamination facilities, notification of pesticide treatments, and emergency assistance.
EPA presumes that owners and family members will provide themselves and each other with
these protections, but has chosen not to regulate such behavior. This decision represents a
significant exemption for small entities, since about 45 percent (250,000 of 570,000) of the
agricultural establishments within the scope of the WPS do not hire labor and are, therefore,
exempt from all but a few of the final rule's requirements. These establishments use only
unpaid employees who, presumably, are the owners and their family members.
In terms of acres per establishment, family-operated agricultural establishments (those without
paid employees) have an economic base that is one-third to one-sixth the size of agricultural
establishments that employ paid workers. The size varies according to the primary crop
produced (Table III-l). For example, family-operated feed and grain farms average 213 acres
per farm, while those with hired employees average 607 acres per farm. For cotton farms,
the ratio is 133 acres to 806 acres respectively, and for fruit/vegetable/nut farms the ratio is
16 acres to 121 acres respectively for those without and with hired employees.
Recognizing the need to minimize burdens on small family-operated establishments, EPA has
reduced the requirements — and therefore the costs — for this sector, which represents
approximately 45 percent of the regulated establishments. This analysis reveals that family-
VI-2
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operated agricultural establishments will bear a low cost-burden as compared to agricultural
establishments with hired labor. The annual incremental out year costs averaged across all
family-operated establishments are about $15 per establishment, whereas the annual costs
averaged across all hired-labor agricultural establishments are about $140 per establishment.
Family-operated feed and grain farms, which make up the largest crop segment, will incur
yearly incremental out year costs averaging nearly $10 per farm. Feed and grain farms with
hired employees will incur annual incremental out year costs averaging almost $55 per farm
(Table VI-1).
B. Impacts on Hired-Labor Establishments AccordinR to Number of Hired Employees
This Regulatory Impact Analysis also has considered the impacts of this final rule on hired-
labor agricultural establishments that have one hired employee, in comparison with
establishments that have ten hired employees (Note: the mean number of hired employees on
establishments with hired labor is 4.8). None of the provisions of the regulation provide a
direct efficiency of size to establishments with many employees. Most of the provisions are
totally or mostly variable (per worker) costs. However, the cost of familiarization with the
rule is considered a per-establishment cost. Also, two provisions that contain some fixed (per
establishment) cost elements are training and notification. Even these provisions are not
directly efficiency-of-size cost factors, due to: (1) the diverse and sporadic nature of
pesticide-use and labor-use practices, and (2) the exceptions and options in the rule that allow
employers to select the most cost-effective option for their particular circumstance. The
variability in the cost-factors due to these exceptions and options is difficult to quantify.
Therefore, this estimate of the impact on one-worker agricultural establishments versus the
impact on ten-worker agricultural establishments is a "worst-case" analysis that assumes that
all costs of training and notification are fixed rather than variable. This results in an over-
estimate of the impact of this rule to one-worker agricultural establishments and an
underestimation of the impact to ten-worker establishments. However, results indicate that
the burden is not unreasonably higher for such small establishments.
VI-3
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Table VI-1. Worker Protection Standard costs for small (without hired employees) versus large (with hired employees)
crop production establishments, 1991 dollars.
Incremental CompUauce Cwt J/ AartUal CBmpBancy«>S> ' hfr«teE
Stttafl Lai^ge islyese Oat year 1st year
/"Aprpql /'^/FaTm^
213 607 25.72 10.96 127.11
133 806 29.80 13.60 163.56
19 69 28.88 13.25 125.39
47 264 19.95 8.19 225.79
16 121 90.76 73.52 567.22
6 35 31.31 16.00 294.95
n.a. n.a. n.a. n.a. 238.11
136 362 $30.76 $16.15 $232.00
sptoyew)
Oat year
54.54
75.19
52.73
81.26
458.79
164.89
168.56
$141.15
I/ Appendix Table RF-1.
2/ Those agricultural-plant establishments that use pesticides (Table IE-3).
3/ Table m-1.
4/ Some farms in some states may be in compliance with some requirements of the Worker Protection Standard due to existing state regulations. No attempt was made to net out these farms as it
should be proportional across all farms. This would underestimate state actual averages for all farms but the extent is unknown.
-------
The revised rule allows employers options in the means of fulfilling some of the requirements
and also creates exceptions to some of the requirements when employees would not be likely
to benefit from the protection. In fact, the complexity of the WPS is due in large part to the
number of exceptions and options that the Agency has built in for many of the key
provisions.
The rule provides options to employers by allowing them to choose the least burdensome
means of meeting a requirement for their situation. For example, the rule requires that
employers notify hired workers of treated areas on farms, forests, and nurseries, but allows
employers to choose (except with the most highly toxic pesticides) whether to notify orally or
by posting signs at entrances to treated areas. On many small establishments with only a few
workers, an oral warning probably would take less than a minute per pesticide application, as
opposed to posting warning signs at entrances to the treated fields. On small establishments
where a large variety of crops are grown in a small area, such as herb farms or potted-plant
nurseries, posting a warning sign -next to treated plants probably would take less than a
minute per pesticide application, as opposed to orally warning employees about all the
different applications taking place.
The rule also provides exceptions to several key provisions. For example, employers need
not notify workers if (1) the workers will not be in or within 1/4 mile of the treated area
during the pesticide application or the restricted-entry interval, or (2) the workers applied or
supervised the application for which the notification is being given and therefore know the
information that an oral notification would convey. On farms with a small number of
employees working only in one area, employers would not have to warn those employees —
either orally or by posting signs — if the application or area under a restricted-entry interval
was located in another part of the farm. If a farm had only one or two employees, and those
employees performed the pesticide applications, the employer would have no notification
duties.
The rule also provides exceptions to the decontamination and training provisions for
employees working in areas where pesticides have not been recently applied. Training and
VI-5
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decontamination facilities are required only within 30 days of a pesticide application or a
restricted-entry interval. For example, a feed and grain farm that applies a pesticide only at
planting and hires no workers until harvest would not have to provide those workers with any
protections under this rule.
All the workers who are on an establishment when training is held can be trained at one time,
so that the labor cost for the trainer could be incurred only once. On establishments with
many employees, however, worker turnover is common. USDA has advised EPA that 1,000-
percent turnover within labor-intensive agricultural work groups is not unusual. Workers not
trained during the initial training would have to be trained on another occasion, if they have
not been trained before their employment on that establishment.
Notification costs also could be strictly per-establishment costs but, in reality, probably will
not be. As noted earlier, only those workers who will be within 1/4 mile of a treated area
need be notified about an pesticide application. Establishments with only one hired worker
may have no notification costs, while establishments with more than one crew of workers
may have to notify each crew separately, depending on which treated areas each will be
within 1/4 mile of.
The decontamination provision might be expected to contain fixed (per establishment) costs
for purchase of the water container and the labor required to rinse and fill the container, but
such is not the case. The size of the container needed and the amount of time needed to rinse
and fill it are directly related to the number of workers for whom the decontamination facility
is being provided. For example, establishments with only one worker would need to obtain
and fill only a one-gallon container (such as a plastic milk jug). Establishments with 10
workers would need to obtain and fill either 10 one-gallon containers or one or more larger
containers. Therefore, in the main, this analysis figures the decontamination provision as a
variable (per worker) cost.
As stated earlier, quantifying these options and exceptions to determine a direct efficiency-of-
size impact is difficult. Therefore, EPA completed a sensitivity analysis and considered
VI-6
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effects on costs if direct efficiencies of size related to the training and notification
requirements of the WPS and the cost of familiarization with the rule were realized, and how
costs for establishments would vary depending on the number of hired employees (one, ten,
or average number). This would be a worst-case analysis in terms of relative per-employee
costs for small establishments. To analyze the per-employee cost for agricultural
establishments with between 1 and 10 hired employees, EPA separated the cost elements of
the WPS into those which are mainly fixed (per-establishment) — training, notification, and
rule familiarization — and those which are mainly variable (per-employee) costs. Table VI-2,
which was derived from Appendix Table RF-1, summarizes the results. The assessment of
relative burden is shown with two sample cases: feed and grain farms, which represent the
crop sector with the most entities affected, and vegetable/fruit/nut farms, which represent the
crop sector with the highest cost impacts, both total and per establishment.
Even with impacts for one-worker establishments being exaggerated, the results indicate the
burden is not unreasonably higher for establishments with only 1 hired employee than for
those with 10 hired employees (Table VI-2 and Figure VI-1). The average incremental out
year cost for a feed and grain farm with one hired employee is about $25 per year (or $25 per
employee). For a feed and grain farm with 10 hired employees, it is about $115 per year (or
$10 per employee). For vegetable/fruit/nut establishments with 1 hired employee, the average
incremental out year cost is almost $95 per establishment (or $95 per employee). The cost is
nearly $650 (or $65 per employee) for a vegetable/fruit/nut establishment with 10 hired
employees.
C. Impacts on Other Small Entities
This regulation should not cause any significant burden on any forms of small entities other
than farms, nursery/greenhouses, and commercial handlers.
No provisions of this rule will require implementation support or compliance from typical
small cities, counties, towns, villages, school districts, not-for-profit enterprises, or other
similar public or private institutions.
VI-7
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Table VI-2. Incremental costs of compliance per year, for representative establishments with different levels of hired employees
€08*plU»nce cost
Per
Per Y&ar (Q«t
of feed
establishments
0«e Ten
aire
-------
Figure VI-1. Incremental costs of compliance for different establishment
sizes and number of employees
700
Ave., 6.9 hired/estab
and Grain Establishment
Ave., 3.9 hired/estab.
345678
Number of hired employees per estab.
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VII. LIMITS OF THE ANALYSIS
r
A. Need for Additional Data
Several data deficiencies were identified during the completion of the WPS regulatory impact
analysis, both in terms of the cost to and benefit of the regulation. Throughout the WPS
compliance analysis, EPA relies on USDA data approximating 1.6 million hired farmworkers
in the U.S. work on agricultural-plant establishments (Oliveira and Cox, 1989). Other
estimates of the number of hired farmworkers vary widely, and the estimates of both the costs
and benefits rely on this number. The revised RIA also relies on USDA estimates of the
number of hired (paid) and nonhired (unpaid) agricultural farmworkers by crop sector.
However, no data were available on how many of the hired or unpaid farmworkers were
pesticide handlers.
A significant portion of the calculations and assumptions relied on pesticide usage data by
agricultural crop sector and restricted-entry interval to help determine cost estimates. The
pesticide usage data utilized in this study was from a single proprietary source for the year
1989.
Another limitation of the analysis was the lack of data available on the quantitative impacts of
restricted-entry intervals on the yields and quality of fruit and vegetable crops. Only one
study could be found that addressed this concern to any degree (DPRA, 1985). The DPRA
study found that several hand-labor-intensive crops would be primarily affected around
harvest time if restricted-entry intervals were 24- or 48-hours after a pesticide application.
However, the study did not estimate REI impacts on a quantitative basis. In the revised WPS
RIA, average per acre cost impacts were estimated to those crops identified in the earlier
DPRA study to incur none - minor, minor - potentially significant, and potentially significant
impacts from 48-hour REI's. EPA has created two additional impact categories-significant
and major-to describe the impacts that are probable to the cut flower and cut fern industries
in the event that an early-entry exception is not granted.
VII-1
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The lack of data on the distribution of agricultural-plant establishments by the number of
hired employees was an additional limitation of the revised RIA. This information would
allow more precise estimation of impacts of the regulation on small entities and the relative
efficiency of the regulation. Due to the lack of agricultural establishment distribution data by
hired employee numbers, the revised RIA considers three sizes of establishments:
establishments with no hired employees, establishments with one -hired employee, and those
with 10 hired employees.
The benefit analysis of the revised WPS RIA also had data limitations on occupationally
caused pesticide poisonings. Pesticide exposures can result in acute adverse effects and
delayed adverse effects.
Acute effects: Reliable estimates of the numbers of acute pesticide poisonings among
agricultural workers are difficult to obtain for several reasons including:
the nature of agricultural labor, as well as economic and social factors, hamper
data collection;
the geographic and seasonal heterogeneity of the population under scrutiny
makes estimates of the number of workers at risk elusive;
agricultural workers adversely affected by pesticides often do not seek medical
attention; and
pesticide poisoning incidents often are treated symptomatically without being
diagnosed as pesticide-related and may not be reported as such.
Delayed effects: Unlike acute and allergic effects, where the symptoms usually appear soon
after the causal exposure, evidence of delayed adverse effects from pesticide exposures almost
always emerges long after the causal exposure(s). This, coupled with the fact that symptoms
of pesticide-caused delayed adverse effects are not unique, results in a predictable lack of
hard data as to the extent and magnitude of pesticide-caused delayed adverse effects.
The available data fall far short of enabling EPA to quantify risks with a desired level of
precision. The Agency uses the available data in this regulatory impact analysis to provide a
VII-2
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representation of the plausible incidence of delayed adverse effects in the agricultural
population to which this final rule applies.
B. Potentially Overestimated Compliance Costs
The EPA, in consultation with knowledgeable persons from the agricultural community, found
it necessary at times, to supplement published data with proprietary data and estimates.
Often, a range of estimates was acquired over several sources. In many instances, estimates
at the higher end of the range were used in the analysis that eventually caused higher
compliance costs than might be warranted. In addition, certain "what if' scenarios could
affect the cost of compliance to the regulated community, however, quantifying these
situations was not feasible. For example, the WPS generally has more restrictive, and thus,
more costly provisions for pesticides with higher acute toxicities. Agricultural operators may
choose less toxic or even non-chemical pesticide control methods to help reduce compliance
costs associated with the regulation. The following section describes some of the major
potential overestimates of the WPS by cost factor, for the forestry sector, and for the cost of
labeling changes to registrants.
1. Restricted-Entry Interval (RED
\
The WPS sets a 72-hour REI into fields after application of organophosphate (OPs) or N-
methyl carbamate pesticides in arid areas. Due to limited state acreage data on vegetable and
fruit crops, EPA estimated the percent of fruit and vegetable acreage that is treated with OPs
or carbamates in arid areas to be five percent of the total U.S. acreage of the seven vegetable
and six fruit crops identified as being affected by REIs. This is likely an overestimate of the
number of acres affected by the 72-hour REI. While arid areas (defined as areas that receive
less than 25 inches of precipitation per year) are predominately restricted to certain portions
of the country (California, Arizona, Texas, Colorado, etc.), many of the affected crops are
also grown nationwide and are not located in arid areas.
VE-3
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Probably the most significant overestimate of expenses due to REIs of the WPS are out year
total and out year incremental posts. EPA believes that some vegetable and fruit
operator/owners will switch from the more toxic pesticides to the less toxic pesticides or to
non-chemical pest control methods, to lessen the impacts of the longer REIs for the more
toxic pesticides, especially with time-sensitive crops. Not only will this decrease yield/quality
losses associated with time-sensitive harvesting concerns, but it will have the additional
benefits of lessening the exposure to handlers and workers of highly toxic pesticides, along
with reducing several other cost factors associated with the WPS (PPE, notification, and
emergency assistance).
2. Personal Protective Equipment (PPE)
PPE costs vary directly with the toxicity of the pesticide being applied—toxicity I and II
pesticides have greater PPE needs, and hence higher costs, than toxicity III-IV pesticides. It
is likely that there are some commercial handlers that never handle toxicity I-n pesticides in a
given year whether due to crop-specific pesticide requirements, reduced pest infestations,
personal preference, or liability concerns. However, determining the actual percentage of
commercial pesticide handlers that never handle toxicity I-II pesticides in a given year is
difficult. Therefore, the revised RIA estimates the cost of PPE assuming that 100 percent of
all commercial handlers handle toxicity I-n pesticides at some time during the year.
3. Notification
Oral notification cost calculations are based on several factors including the number and
toxicity of pesticide treatments, the probability that workers are within 1/4 mile of treated
fields, the wage rate of workers and supervisors, and the amount of time it takes to orally
notify workers of pesticide treatments. Wage rates and notification time comprise the greatest
percentage of oral notification costs--both workers and supervisors are paid for their time
during notification. The costs estimated for oral notification assume that it takes five minutes
to orally notify workers of any pesticide treatments. This is probably an overestimate of the
time needed, as in all likelihood it would take less than one minute for a supervisor to tell
VII-4
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workers to "Stay out of the beans today and tomorrow because we're going to apply a
pesticide today".
4. Training
The revised Rule exempts certified pesticide handlers from the training requirements of the
WPS. However, published data on the number of certified agricultural-plant pesticide
handlers is not useful for this analysis in its current aggregated form. Therefore, estimated
compliance costs for training is based on the assumption that none of the hired handlers are
certified. This is very likely an underestimate of the number of certified hired handlers,
which in turn, overestimates the cost of the training component of the WPS.
The training provision of the WPS requires that hired agricultural workers and pesticide
handlers receive pesticide safety training. Due to lack of detailed data on agricultural hiring
practices, the training cost computation assumes that agricultural employees are hired
singularly and will receiving training on a one-on-one basis with the trainer. This is likely an
underestimate of the number of employees that are hired at once, especially on
vegetable/fruit/nut establishments, where crews of workers are often hired at one time.
Several employees can be trained at one time with one trainer, substantially reducing the costs
of training.
5. Decontamination
There are several costs associated with decontamination requirements. Containers that hold
wash water and the labor necessary to rinse and refill them, account for approximately 75
percent of total decontamination costs. The revised R1A assumes that all hired handlers and
hired workers and all commercial handlers use a container to hold the decontamination water.
EPA believes this is an overestimate of the number of containers necessary because it is
likely that most greenhouses and nurseries and mix/load sites, and some farm and forestry
application sites already have running water immediately available.
vn-5
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6. Emergency Assistance
While the cost of emergency assistance is relatively small when compared to other cost
factors of the WPS, EPA believes that the numbers may be reduced even further in out years.
As stated in the earlier section on overestimates of the costs of REI's, it is likely that some
agricultural operator/owners may switch to less toxic or non-chemical pest control methods
after the implementation of the WPS. With a decrease in the use of the more toxic pesticides
on agricultural establishments, a decrease in the number of occupationally related poisonings
among pesticide handlers and workers can be expected. Likewise, with a decrease in the
number of poisonings, comes a decrease in costs associated with the emergency assistance
provision of the WPS. Furthermore, some poisonings, especially skin rashes and ulcerations,
may not require emergency transportation, i.e., the victim may provide for their own
transportation.
7. Forestry
Due to the relatively insignificant impacts of the WPS on the forestry sector (about $145,000
incremental out year costs), the costs of the six compliance factors were averaged across the
six types of agricultural establishments (feed and grain, cotton, tobacco, other field crops,
vegetable/fruit/nut, and nursery/greenhouse) to determine compliance expenses to forestry.
Pesticide usage (both amount and toxicity), days that, pesticides are handled, days working in
the field within the 30-day period following a pesticides's REI, and the probability that
workers are within 1/4 mile of fields during a pesticide application and a REI are likely to be
more similar to "other field crops" than to the average agricultural establishments. For this
reason, EPA believes that the compliance costs of the WPS are overestimated to the forestry
sector.
8. Pesticide Labeling Changes
The one-time cost of changing all pesticide product labels which are registered for agricultural
uses has been estimated. The Agency is aware that many labels require amendments during
VH-6
-------
the course of a year for other reasons. Registrants which are revising labels for other reasons
would incur less cost to include revisions necessary for WPS compliance. However, the
Agency had no basis from which to project the portion of applicable product labels which
would require amendment during the course of a typical year. Therefore, no costs were
subtracted from estimated total costs and, as such, incremental costs of label changes are
overestimated.
In summary, when data "gaps" presented estimation problems that necessitated the use of
rational assumptions, EPA attempted to err on the high side, or to overestimate compliance
costs associated with the rule rather than to underestimate costs.
VII-7
-------
-------
BIBLIOGRAPHY
DPRA, Incorporated. 1985. Analysis of Proposed Reentry Interval Regulations Under h'lh'KA.
EPA/BEAD. 1991 (July). Pesticide Industry Sales and Usage: 1989 Market Estimates.
Washington D.C.
EPA/BEAD. 1990 (July). Pesticide Industry Sales and Usage: 1988 Market Estimates.
Washington D.C.
Federal Register. 1987 (May 1). Vol. 52, No. 84. Pages 16073 and 16084.
ICF, Inc. 1985 (August). Analysis of Proposed Farmworker Supervision, Training, and
Warning Regulations Under FIFRA.
Oliveria, Victor J. and E. Jane Cox. 1989 (May). The Agricultural Work Force of 1987: A
Statistical Profile. U.S. Department of Agriculture. Washington D.C.
Oregon State University Extension Service. 1989 (August). Oregon Pesticide Use Estimates
for 1987.
State of California, Department of Food and Agriculture. 1988. Pesticide Use Report by
Commodity.
U.S. Department of Agriculture. 1991 (December). Vegetables and Specialties Yearbook.
Washington D.C.
U.S. Department of Agriculture. 1991 (August). Fruit and Tree Nuts Yearbook. Washington
D.C.
U.S. Department of Agriculture. 1991 (June). ARricultural Chemical Usage 1990 Vegetable
Summary. Washington D.C.
U.S. Department of Agriculture. 1991 (February). Report of the Forest Service Fiscal Year
1990. Forest Service. Washington D.C.
U.S. Department of Agriculture. 1991. 1990 Farm Costs and Returns Survey. Washington
D.C.
U.S. Department of Agriculture. 1990. Agricultural Statistics 1990. Washington D.C.
U.S. Department of Commerce. 1991 (August). Census of Horticultural Specialties (1989).
Bureau of the Census, U.S. Government Printing Office. Washington D.C.
-------
U.S. Department of Commerce. 1990 (December). 1988 County Business Patterns. Bureau of
the Census, U.S. Government Printing Office. Washington D.C.
U.S. Department of Commerce. 1989 (November). 1987 Census of Agriculture. Bureau of the
Census, U.S. Government Printing Office. Washington D.C.
U.S. Department of Labor. 1989 (August). Handbook of Labor Statistics. Bureau of Labor
Statistics. Bulletin 2340. Washington D.C.
-------
APPENDIX A
Compliance Cost Calculations and Documentation
By Cost Factor
-------
Section 1
Restricted-Entry Interval
-------
Stdor ' •. .-• ff
_-.',', " ' Nypibsrof IncremejitaiCosasperestablisnmefit
KttM '•:-' ' - ' , Incrwientaf Etts^jStshtrwr^s Thrt ttee* Pe$
-------
Appendix Table REI-2. Totalfirstyear andI total out year restricted entry interval (REI) costs to vegetable crops
Per Ac« Far Acts
* m
m
(i/Acre)
3.212
2,734
1,578
7.428
1,714
1.353
loesdw*
to (6)
J2L
ArfohokM
CauHoww
Snap Beans
Tomatoes
Cucumbers
Matana
Sqpjeah
86%
86%
86%
86%
86%
85%
86%
6%
5%
5%
6%
6%
6%
5%
10.244
60.526
34.564
128.028
110.547
242.813
20.021
0.5%
0.5%
0.5%
05%
1.50%
1.50%
3.50%
1.0%
1.0%
1.0%
1.0%
3.0%
3.0%
7.0%
(VAcre)
15.26
12.99
7.50
35.28
24.43
19.28
2.902 96.50
Total first* Out Year Costs of REI
(VAcre)
1.61
1.37
0.79 •'
3.71
2.57
2.03
10.16
($)
172.768
868,694
286.396
4,992.976
2.984,787
5,173.310
2,135,391
$16,614,321
NokrAMumM tore ara no price aiacb.
SOURCES:
(1); DPRA. he. Andys* of Proposed Reentry Interval Regulator* Under RFRA. 1985.
(2); Estimate bated on acre treatments of Toxkay I peefcides as reported by:
-U.S. Department of Aohcuhure AgricUMal Chemical Usage I860 Vegetables Summary. 1991 (June).
-<>sgc«SM»»Llrwe^ExlemBnServi».OieppnP»»1^^
-S»*o<(^**)rn^Dep«r»nerto^
AMUDM twl l» wMbMirmnli i»l doot u»» pastioidH am
orMvrHtf M much M tm number of farm not using partcktaa.
). CiiniirtiidtiyDrnft.hr •nriFPfthaMTiirTm(l)
Crap Impact
Mnor - Po**nfaaV Signifcant
Potanctay StgnfeanJ
Signifcant
Major
Rangaof
Yield Loss
0.00-1.00
1.00-2.00
2.00 - 5.00
5.00-7.00
7.00-15.00
Average
YieULoss
.5
1.50
3.50
6.00
11.00
(6); Eafcnatod by DPRA (doubb tw impact of (5)).
(7};AppsntixTabtoR£l3.
(8); C^outa*4 |(2)X(4)X(5)X(7)F(4).
(9); CaJcutated. [(3)X(4p((6)X(7)y(4).
(10): Calculated, (4pq(8H(9)J.
-------
Appendix Tattt RE1-3. VEGETABLE CFOPS - - VWi impacts from 48 hr. rattricud entry interval'
OspS
Squash y
Cucumbers 3/
Melons 4/
Tomatoes (trash)
Artichoke!
Snap Beans 5/
Cauliflower
Total of affected crop*
HttvWHMt >
21,644
119,510
26Z500
138,410
11,075
37,367
65,433
655,939
5S
62317
204376
355,090
1,028,155
35,576
56,975
178382
1,924377
VWO*
2^02
1,714
1,353
7,428
3.212
1,578
2,734
• Crops indudad are based on DPHA's 1985 report, "Analysis of Proposed
RMniry Intarv^ Regulations Undar F1FRA".
V.Unles* cKh«wi»» noted, from USDA Vegetables and Spaciait** Yeartxxik, 1991 (D«c).
3-year avorag»>l 968-90.
II Squash Stats:
ACT** Valut
Harv»»i«d ($1.000)
Rorida
Cali!
Arizona
Total
13,117
7,979
549
37,567
23505
21,644
62317
Noli: Florida data Irom 1988-90. Caiif from 83-89, Arizona data trom 1988-90. T«w data NA.
Sourc*: Honda & Arizona Ag Stats and USOA V*ggi« and Sp*aaH« Yearbook
3/ Procutting cucumbtre only, 8640
4/MetonStati:
Aoaa Va(u*o(
HarvMMd Prod ($1,000)
Horwydew
WMrmclon*
Cantaloup* "
Total
California
Arizona
Texaa
Rooda
Touri
30,550
127^00
104,750
262,500
73,020
33312
198,264
*355,QBS
14,600
4,600
55,000
53,000
12T26T
80
90
C&tcrrt*
AriZGnft
Total
Zyrtvt
narrat
84.000
7^00
NA
aojoo
8,700
18,000
91300
117,900
104,750
S/Snap bMra for frMh rnarkac
AOM
PtanwJ
Florida
Mcrigan
N.Carolina
Arizona
Tottf
Vak»
(11.000)
Vahj«p«Acra
27333
2300
6333
200
40,274
3330
6,105
1,770
1332
603
1332
37387
ssaro
Not*: Florida vd N.C. data trom 198840, M*ioan & Ariz, only 1380,
Now: Meh. I Ariz. V*J« DgurM dariv«d trom tv» avmo* vakM d Ftaidt A N.C. tnaphMna.
Souros: Florida, N.C, KM ag jtstu; Meh. 1 Artz. from USOA Ag. Ch»n*aJ Us^«.
-------
Appendix Table REI-4. incremental first year and Incremental out year restricted-entry interval (REI) costs to vegetable crops
PfWiBM* Wfw •• Aw^JUpP^
wwfWfcCwwn^f , AwBtgttjMif AnftnpaR
P*)mp9ci»dAa*
HI '
.fift..
CunfrtHtoW
< Jfa^t. j^^-. jyyh^
Jfi_
8*
A*****?
*P$l
JS_
OOP VMM
a*})
@L
(10)
»<$
townt
ArfctakM
SncpBunt
TonMciw
CuoniMn
•05%
QS%
86%
06%
05%
05%
05%
9%
S%
S%
8%
S%
9%
6^34
34.783
34,472
103.714
10W60
180,707
16,440
0%
0%
0%
0%
20%
10%
25%
5,634
34.783
34.472
108.714
87240
170,738
12334
0.5%
0.5%
0.5%
0.5%
1.50%
1.50%
3.50%
1X1%
3.0%
3.0%
(VAcrs)
3212
2.439
1,577
7.520
1,686
1,445
7.0% 2.756
Incremental irs) t om year costs ol REI
(VAcre)
15.26
11.58
7.49
35.72
24.02
20.59
91.63
0.79
3.76
2.53
2.17
9.65
95,021
445,350
265,425
4281.770
2316.008
3,884,631
1249,192
$12.567^99
NaM:AMunMtMr*wampric«*&ic»r
SOURCES:
(2); EMkmM l»Md an acre rMtrnma ol ToKkirjr I pfttad* M r«port»d by:
-US. O^mtrmt d A^icufeur*. A0icuhnl Chwnkal Utao» 1000 V^jMttMSumn«fy.10fl1 (Jun«).
-On«tn Sttto Uriwnlry Eflwion Swvfc*. Or^jon P»*«J« UM Ertrwttd tor 1087. 19S0 (Auguo).
-SMM d Crtfcm*. CNwmNrt d Food «J Agriculu*. Pwicid* UM H^on by CommorJiy. I0aa
(3);EMknMKibyDPRA.Inc.
(4); Dwivw tan U4 oop »•«« h App«fa T*to HEI-5 «rr»« OiS* (r«p«Mnli t» p«owMg*ol walcropacrw
M «• t«Md «Mi pMtcidM). 02J% MB
-------
Appendx TaWe REI-5. VEGETABLE CROPS - - With impacts from 48 hour RE1,
removinq acreage from states with WPS equfvatent REIs already in effect.
• - - isi -SSS 3:
£|uair)2*
Cucutfctnaf
M*c«4/
Tomato* (ln«h)
Artchotaa
SnapB*am&/
Cadifawar
Total ot affactad cropa
117,802
205.0M
117,S2«
6.091
37287
37.803
538249
4fl 9B7
198.714
23626*
S83.7S2
19.567
58,775
91.708
1.567,788
2.756
1.6M
1,448
7,520
3212
1.577
2.430
SOURCES:
t/ USOA Vagaiablai and SpadaKaa Yaartxx*. 1991 (Dec* , unlaaa o»an»iai noted
Catfcmia haa RE1» n rfK* lor tmnl d th* mo* common Toxoty I pwtiadM (Atp»fidn Tatal* RE1-8).
M o( »» pvtiadM fatod in Appendix TiMt R£K K*n REI> *> !«ng»iy u tho»» prapOHd b/ to* WPS.
Th»«»or». «% o( th» Citomii «ora^» of 8 o( th» 7 «9«*t» erep« from AppwKfa T*(» RE k3 h» bMn
Antorn HUM i ho HEfa in ifttd be Tat I «nd II «9>raphci>pMM and cart»m««a
th« v* |u* m tongthy M IhoM poMd by lh« WP& 1 w«* vurad «ut 50* o* «w iqu»K
rabn, and «n«p b«n tcrtuyt in Anona > IraoM ««h OPi or uiUniKto and thmrom <
r«mo«d to d*«mn« ncnmartal Gotttt.
Val»
($1,0004
Rorida 13,117 37.S87
4SXCaa1 4.3M 10,757
30%Ara 274 873
Total \tjft 4S,9Sn
r**a: Fkxrta data Irom 1 96»-gO, Ca» (rom M-M , Araona data from 1 a»»90. Taua cWa NA.
Souroa: Raila t Araont Afl SM» and USOA V*ggiM and SpmAiaa Yawbook.
3/ Pmoaaiing ououmban only. 88-90
4/IMonSMa:
Ao«t Vakjaof
HarnaM Prod (J1, COO)
80,7O«
WaHrmabn' 1ia,3X 71,513
Cantak*i»" 81,480 157,047
Total " 206 OM tZM^a
I,Q3>
50%Anzona 2.300
Tana 55,000
To* It
4S%CaB
90%Anm 3*» 4J60
Tam _ K* 1«,000
Total 50,000 72^0
S Snap baan* tor fraah rrwtat
Aoaa Vak» VaJuaparAen
Plantad 0100C| «
Ftoidi STB! «274 1,770
Merman 2X0 3300 1332
N.CareJna 8*33 (,101 WI
SOKArom 100 «7 8M
Total 5T2f $Si,77»
Nola: Ftend. and HC. date kom IStMO, McNgM » Alk. ontf 19Sft
NoSr dUi. t Arit Valua figuraa darind horn *• a«rae» valua el Fbrita & HC. map own
-------
Appendix Table REI-6. Restricted entry intervals for the most commonly used Toxicity I pesticides in California by selected vegetable and fruit crops.
V?$3B?>
Endosulfan
Methomyl
Mevinphos .
Oxamyl
Captan
Methyl parathion
Azinphos-methyl
Methidathion
Methamidophos
All Toxicity I
Pesticides
'' ' Artkfcokw
48
«
48
--
~
14 days
24
48
48
24
Dftttftfewti
48
~
48
-
-
14 days
24
48
48
24
•': ftS*
48
--
48
-
-
14 days
24
48
48
24
TviosSote
48
-
48
~
--
14 days
24
48
48
24
C*e«ttfe«rt
48
--
48
-'
-
14 days
24
48
48
24
M**
48
-
48
...
-
14 days
24
48
48
24
Jwjeasii
48
-
48
-
--
14 days
24
48
48
24
48
--
48
--
-
14 days
24
48
48
24
****
48
48
%
48
,
21 days
7-14 days
48
-
24
"ii*
48
--
48
--
--
14 days
24
48
48
24
Cfcwrte*
48
--
48
-
-
14 days
24
48
48
24
Source: Barclays California Code of Regulations.
-------
r"r:r;;" - •<•? • 7-- v ^ . ,.,;-.,--: ^ -im»&w • — ' v : • — ' —
: -• -llRllOnssj " '- pJmfckiMi ' ;lpA0^ApMi> - (t9@&*9$4M& &{3tets88& •• quafejkotft - H9SS>K)»(a> tofsi
(VAcre)
BSactoaniM 95% 6% 4.061 0.5% 1.0% 2,495 11.85
ChMriat (Sweat) 95% 5% 44.801 0.5% 1.0% 2.753 13.08
Paactea 06% 5% 171.063 0.5% 1.0%' 1.838 9.49
Hum 86% 6% . 38.573 0.5% 1.0% 2,659 1263
RaspbttriM 98% 5% 9.016 0.5% 1.0% 2.586 12.28
Stawiwrias 05% 5% 42,682 3.5% 7.0% 12,106 403
ToM First & OU Year Costs of F£i
Note: Aaaumaa hare ara no price efectt.
SOURCES:
(1); DPfW, Inc. AnaJyaia of Piopcaad Haanty Interval RaguWioni Undar HFBA. 1985.
(2); Etimata baaed on act* tfMknank> oJ Toxkiy 1 paafckte as raportad by :
-US. D*p*man» of AQticulkra. AgricUuaJ ChamicaJ Usage 1090 Vagatobtes Summary. 1091 (Juna).
Orooon Stata Uiwariity EKtonwon ^atvin Onfjon Paufcida 1 It* Piliiiialail for 1987 1980 (Augtnl)
-Stala at Caffcmia, Dapartnant of Food and AgricuMura. PartoctoU»»HaportbyCommo*y. 1068.
(3); EsamatKl by DPRA. Inc. CaStomi* producaa tw majorHy of tthctod 1^cre(MtM ara oiDtm in arid anas. Hcwaver.besaacraaoes
aalinalad a«unv« 8% of total U.a fcuit (8 crop*) acreage i§ aAtdad. Tharafora. ^ p*r«nta(^ of •c«^ ecmags » Ist^ owetsstmalad
(4); Baaad on bM crop acreage* in Appandx Tabb RS-8 limaa 92.6% (nprcMnti twperoanta0a of total crop acres
ftat am MaMd **h paakodaa). OZ5% WM darivad by dMdbig column (3) in Tebte 1(1-2(1 5% tor In*) by 50%.
AMUHM* ha •atabMmanto hat ttorrt UM (waicidw ara amafcr opantoraandurane^aciMgaiaproporlbnataly
ona-ratf m much a* t» numfaar of farm* not img padicidat.
(5); EHRwM by DPHA, he. and EPA baaed upon ( 1 ). ccnauteaon wAndus^expar^andginardlnMtodga.
Rjngaof Avaraga
dcpht^Mct YwWLots r»UU»
Ikna-tyBnor 0.00-1.00 0.5
Mrtor-PoJsnlirfyS^acafil 1.00 -ZOO 1.50
Pottnaak/ Signicanl 2.00-5.00 3.50
SJgnfCcant 5.00-7.00 6.00
l^or 7.00-15.00 11.00
Uxwdu* ; -IOOOBW
to (6) •• lAt*
fS» <101
1.25 53,191
138 647,513
1.00 1.794.366
1.33 538,462
1.29 122,406
42.37 18,989,152
$22,145,089
(6), Estimated by DPRA (doute tv» impact d (5)).
(8); Cafetalad. K2)X(4)X(5)X(7)y(4).
(9); Calculated. I(3)X<4)X(6)X<7)y{4).
(10);CalcUalBd.(4pq(8H9)l.
-------
Appendix Tabte REI-8. FRUIT CROPS - - With impacts from 48 hr restricted-entry interval *
:
Crop
Blackberries
Oregon 4,250
Washington 140
Total
Cherries (sweet)
Peaches
Plums
Raspberries 21
Oregon 5,400
Washington 4,347
Total
Strawberries
Total of affected crops
>,
Acres it ' o
Harvested
(3-year ave}
10,586
366
4,390
48,433 '
184,933
41,700
12,365
12,838
9,747
46,143
335,34?;
Total va&0t/
rProdue&jft
(3*y68f ave}
($1,000)
10,952
133,348
369,'459
110,870
25,203
558,591
1^08,423,
Par Acre
Crop
Value
($)
2,495
2,753
1,998
2,659
2,586
12,106
Crops indudeo! are based on DPRA s 1985 report, Analysis of Proposed
Re --rtry interval Regulations Under FIFRA".
17 Fruit and Tree Nuts Yearbook, USDA, 1991 (August). 3-yr ave=1988-90.
21 Raspberries includes both black and red
Acres Harvested Value of Prod. ($1,000)
OR WA OR WA
Black 1,433 80 1,811 54
Red 3,967 4,267 10,555 12784
Total
5,400
4,347 12,365
12,838
Note: Data on Wash, black raspberries was only available for 1988
-------
Appendix Table REI-9. Incremental first year and incremental out year restricted-entry interval (REI) costs to fruit crops
fwwtoifew
Fit* CMP*
48Hrft&
PMttttM
fearing too**
kctxnt
8)
m
m
m
Urn
Btadtbwriw
Chwriw (Sw*M)
Pkira
FtaptMiriM
SMwtMrrtos
os%
95%
95%
95%
95%
95%
5%
5%
5%
5%
5%
5%
4,061
39,629
143.540
21.215
9.016
32364
0%
0%
0%
0%
0%
50%
4,061
39.629
143.540
21.215
9,016
16,432
0.5%
0.5%
0.5%
0.5%
0.5%
3.5%
1.0%
1.0%
1.0%
1.0%
1.0%
($/Acre) --
2.495 11.85
2338
1,725
2JSSB
2,586
7.0% 9,575
InawTwiial Irat & cut yaar cods al RE I
13.43
8.19
12.63
12^8
318.36
1.42
OB6
133
33.51
53.183
590,531
1^90.749
296.128
122^394
5,781,8BB
18.143.852
SOURCES:
-US. D^i«*n*nl ol A^ioAjf.. Apfcutknl Ctwncal Uug* 1990 VcgcSablM Summary. 1991 (Jim).
-Oregon SUM Uriranty Extmkn S*rvic». dragon PM«dd» Uw EMknoiad lor 1987. 1989 (Augu»i).
-SM* oi CaHanta, Dapartnmi d Food and AgncuHur*. PMtaO* Ut» Ftoport by ConinodNy. 1988.
(4); Dwira) fcnm total ctop acr«mM In Appcndx Trf*» HEUO lm«« 92.8% (rapraMrts »»• p«c«ntBo» of total crop acrei
M v» ir«l «d w* pwfctt*). 9i5% «•* dwved by dhfcfng bdumn (3) in T*to IB-2 (1 5% tor kuk) by 50%.
AHURMC t» «leM(hnMnl> tm don'l uia pw«cid*t «• imatar opwako
on»taM •* much m tw numtMT d term no» uting (MMicidM.
(5); On« d tw lour mM oarmranhr uMd pwliddH on thMtwntai (Captor) rirMdy requjr«
II mnwrc rMrtw *w Md( wttin 4 d^s ol an appfcafcn. In tm CM* k t» Mwlir tal chw«alr«»»unlgto»««aJdb»
tevwtfng cmn Into tM draartwry MA.
10 «(UoltM48haurREI
to nMtamyl UM on «MMb«ii*« • dm to t» WPS.
(7); SM AffMnb T*to FCI-7. Saurc* (5).
(B); E«*MMd by DPRA (daubto tw knpKt o( (7)).
(S); AffMndx Ttf* REMO.
<10);C*c**id.(2)X(7)X(9).
(11);C«teuhB«d.(3)X(8)X(9).
(12);
-------
Appendix Table REI-10. FRUIT CROPS - - With impacts from 48 hr restricted-entry intervals,
removing acreage from states with WPS equivalent REIs already in effect
'; ' ' ftMtatei/
CR£ $"£e*r«w»i ' ($1tQQ0>
Blackberries
Oregon 4,250 10,586
Washington 140 366
Total 4,390 10,952
Cherries (sweet) 42,842 121,602
Peaches 155,178 267,645
Plums 22,935 60,979
Raspberries 2J
Oregon 5,400 12,365
Washington 4,347 12,838
Total . 9,747 25,203
Strawberries .35,528 340,172
Total of affected crops ^/OySSfis 826>S53K
- VJdu*
.... m
2,495
2,838
1,725
2,659
2,586
9,575
SOURCES:
1/Fruit and Tree Nuts Yearbook, USDA, 1991 (August). 3-yr ave-1988-90.
California has REIs in effect for several of the most common Toxcfty I pesticides (Appendix Tabb REI-6). Noarty
half of the pesticides listed in Appendix Table REI-6 have REIs as lengthy aa those proposed by the WPS.
Therefore, 45% of the California acreage of four of the six fruit crops from Appendix Table REI-8 has been
removed to determine incremental costs of the restricted-entry intervals posed by the WPS.
2/ Raspberries includes both black and red.
Acres Harvested
Value of Prod. ($1,000)
Black
Red
Total
OR
1,433
3,967
5,400
WA
80
4,267
4,347
OR
1,811
10,555
$12*365
WA
54
12784
$12,838
Note: Data on Washington black raspberries was only available tor 1988;
-------
Append* Table REI-11. Total and incremental first and out year restricted-entry interval (REJ)
costs to greenhouse establishments, per worker and for the total sector*
-
Hem
Personal 1/
Protective
Equipment (PPE)
PPE Cleaning 21
Decontaminations/
Instruction 4/
Total per Worker
Total Cost for 5/
AH Greenhouses
f
™;^ft**"
57.85
100.00
8.75
23.43
$190
$604,124
n
>OtS
22.35
100.00
8.75
23.43
$155
$491,266
'
Hrst
- ($/worker)
4.60
100.00
8.75
23.43
$137
$434,837
«tt % „
»****-*
OUI
4.60
100.00
8.75
23.43
$137
$434,837
' These costs are due to PPE, decontamination, and earty entry instructions that are required
for earty entry workers on those establishments where earty entry is allowed (cut flowers and cut ferns):
EPA believes these costs are greatly overestimated because the majority of early entry workers
on cut flower estabishments are owner/operators who are exempt from early-entry PPE cleaning,
decontamination, and instruction.
1/ First year PPE costs per worker were based on the following:
- One pair of cotton coveralls 30.00
- Two pair of nitrite gloves 4.60
- One pair of safety glasses 4.00
- Protective headwear (one hat or hood) 825
- One pair of water proof boots 11.00
Total first year costs per worker $57.85
Out year PPE costs per worker were based on the fotewing:
- AM PPE terns with the exception of
nitnTe gloves last three years.
Total out year costs per worker $22.35
First and out year incremental costs per worker were based on the totowing:
- Early entry workers on cut flower or fern estabfehments are
assumed to be handJers (stable, trusted, permanent employees
or owner/operators).
- These handlers are already trained and already have a set of PPE due to the WPS.
- However, it is assumed that these handters wi need two extra pair of stoves
for earV entry duties ($4.60 for 2 par).
Incremental first and out year costs per worker for PPE
$4.60^
Footnotes continued...
-------
Footnotes for Appendix Table REI-11 continued...
21 Total and incremental first and out year PPE washing costs per worker
were based on the following:
- It takes 12 minutes to wash aJ PPE items.
- Person doing the washing is empbyer with a wage rate of $10 per hour.
(12/60) X $10 - $2.00 labor cost per washing per worker
- 33% of the 50 total pesticide applications in greenhouse's are of
pesticides with 48 hour REI's, 33% are of 24 hour REI's, and 33% are of 12 hour REI's.
- One early entry day per application of a 24 hour REI pesticide will be necessary.
-Two early entry day per application of a 48 hour REI pesticide will be .necessary.
-The totaJ number of early entry days per earty entry worker per year -
{33% are 48 hr REI X 50 apps. X 2 days) + (33% are 24 hr REI X 50 apps. X 1 day) - 50
TotaJ and incremental first and out year costs per worker - $2.00 X 50 - $100.00
3/Total and incremental first and out year decontamination costs per worker
were based on the following:
- 2 oz. of soap is needed per earty entry day. Soap costs $0.96 for 32 oz.
[(2 oz X 50 earfy entry days) / 32 oz] X $0.96 - $3.00
-16 paper towels are needed per earty entry day. Paper towels cost $0.69 for 96 towels.
[(16 towels X 50 earty entry days) / 96 towels] X $0.69 - $5.75
TotaJ and incremental first and out year costs per worker - $3.00 + 5.75 - $8.75
4/ TotaJ and incremental first and out year instruction costs per worker
were based on the following:
- it takes 5 minutes for employer to instruct earty entry worker for each earfy
entry episode (Le., 1 episode during a 24 hr REI and 2 episodes during a 48 hr REI).
Earty entry workers would receive instructions at the same time.
[(5 minyeo min.) X ($7 worker wage + $10 employer wage)] / 2 early entry workers - $0.71
- There are 33 early entry episodes per cut-flower or fern establishment
hour REI's + 16.5 24 hour REI's . 33 early entry episodes
Total and incremental first and out year costs per worker- $0.71 X 33- $23.43
Note: It is assumed that no earty entry workers can read well snough to instruct
themselves. However, those capable of reading and understanding English would not
need an instructor for the labeling instructions. Therefor*, early entry instruction
costs are Ikety overestimated.
51 Calculated, cost per worker X 3,179 workers,
3,179 early entry cut-flower workers was derived by:
18,613 Nursecy^reenhouse estabishmerrts that hire labor and use pesticide* (Table III-2)
61% Are greenhouses and greenhouse-Ik* nurseries (U.S. Dept of Commerce,
1987 Census of Horticulture Specialties, 1989)
11,354 Greenhouses
14%of greenhouses are primarty cut flower estabishments (U.S. Dept of Commerce,
1987 Census of Horticulture Specialties, 1989)
1,590 Cut flower estabfehmento
2 Early entry workers per estabfishment (EPA estimate).
3,179 Potential early entry workers on cut flower establishments
-------
No Early-Entry Exception for Cut Flowers/Ferns
Information that the Agency received from the cut flower and cut fern industry during the
comment period for this rulernaking has persuaded EPA that there could be substantial
economic repercussions in this industry if routine hand labor tasks were prohibited during the
restricted-entry interval. The Agency has reviewed the information received on the subject
and is inclined to grant an exception to such a prohibition for this industry, because, in light
of the economic benefits and new conditions of entry that would be imposed, the Agency
believes it is likely that early entry.would not pose unreasonable risks to workers in this
industry. As a result, such an exception is being proposed under the exception process in the
final rule. Therefore, this RIA contains cost estimates based on the premise that such an
exception will be granted. The costs attributed to REIs for greenhouses and nurseries arc the
costs associated with permitting workers to enter during the REI. Such costs include
supplying labeling-specific instructions, and decontamination soap, water, and towels, and
providing, cleaning, and maintaining personal protective equipment The incremental first
year cost estimate for this is approximately $604,000 and the incremental out year cost
estimate is approximately $435,000 (Appendix Table REI-11).
If the Agency receives information during the public-comment period that persuades it that
granting an early-entry exception for cut flowers and cut ferns would pose unreasonable risks
to workers in this industry, greenhouse and nursery employers will bear a higher cost-burden
due to this final rule than is now being assumed. The Agency estimates that the incremental
first and out year cost to the greenhouse and nursery industry of a prohibition of routine hand
labor during REIs will be $43.7 million (Appendix Table REI-12). Therefore, if EPA is
persuaded not to grant the early-entry exception for cut flowers and cut ferns, the additional
continuing annual incremental cost to this industry would be $43.7 million - $0.44 million or
$43.3 million.
Additional Early-Entry Exceptions. In this final rule, the Agency is offering interested
persons the opportunity to submit requests for exceptions to REIs. Any exceptions granted to
-------
the thirteen crops where the prohibition of routine early entry is reflected as a cost burden in
this RIA, would substantially reduce such burden. Thus, the granting of any such exceptions
would result in an overall reduction in costs attributable to the WPS.
-------
Appendix Tabte REI-1 2. Total and incremental first and out year restricted-entry
interval (REI) costs to cut flower and cut fern crops, if no exception is granted
CM. Rower
iandf&BC
Cut Roses
AttnuaJ
' Whpiesate
»ps- Bate*
m
(Million $)
187,950
Other Cut Rowers 293,277
Cut Ferns
Total&
89,746
incremental first & out year costs of
Average
Safes Impact
ItOPftJ^fe
,f&yfeid/
quatytoss).
$5
(%)
11.0%
6.0%
6.0%
REI4/
-
-
A^rega^e
taoome
toss
($
($)
20,675
17,597
5,335
$43,655,880
Note: Assumes there are no price effects and as such aggregate income toss is likely
to be an overestimate.
SOURCES:
(1); U.S. Department of Commerce.. 1991 (August). "Census of Horticultural Specialties (1989)".
(2); Estimated by DPRA, Inc. and EPA based upon consultation with industry experts and general knowledge.
Crop Impact
Range in
Yield Losses
Estimated
Yield Loss
None - Minor
Minor - Potentially Significant
Potentially Significant
Significant
Major
0.00-1.00
1.00-2.00
2.00-5.00
5.00 - 7.00
7.00-15.00
0.5
1.50
3.50
6.00
11.00
(3); Calculated; (1)X (2).
41 The Agency is unaware of any State imposed REIs with proNbrted entry for toxfcity
IMV pesticides. Due to this reason and the fact that the majority of the pesticides
that are used in cut flower cufture are of toxidty IMV, incremental compliance costs
are the same as total compliance costs (i.e. no reduction for state imposed REIs or
other current compfiance).
-------
Section 2
Personal Protective Equipment
-------
Appendix Table PPE-1. Revised Worker Protection Standard compliance costs for personal protective eqaipment in 1991 dollars, by sector.
; ', / - , \\
Feed & Grain
Cotton
Tobacco
Other Field
Vegetable & Fruit
Nursery & Greenhouse
Commerce Handtere
Total
-
in <
35,996,985
4,716,802
8,774,483
5,522.438
17,282,620
6,451,315
6,155,884
$84,900,536
C««»ttGft*.
M -* '
It
\*
17,016,750
2,415,899
4,154.564
2.772.573
7.527,909
3,545.578
3,684,384
$41,117,658
•M- *. > -M- + >*••*< ,.
IftcwtftftW
8i
\
j
8,498,202
814,424
2,535,653
1.702,249
3,244,038
1,059,045
1,575,908
$19,429,519
-
" M
4,444,864
441,217
1,382,541
929,080
1,732,142
564,632
1,081.608
$10,576,083
l*"Bjj¥p50f vf
i*«« •-* t rf k"" T ,1
inaivseressiwfl*
300,820
20,680
57,000
71,340
79,050
31,500
8,500
568,890
Jrmroafltal Costs per g
.J9*
/
V
28.25
39.38
44.49
23.86
41.04
33.62
185.40
$34.15
- vut rear
14.78
21.34
24.26
13.02
21.91
17.92
127.25
$18.59
Note: For hired handler PPE cteanng, costs were apportioned by multiplying total cteariing costs by the percentage
of hred handtors in each crop sector (Tabte III-2). A skniar proceedure was used for apportioning incremental
PPE costs: total incremental PPE costs were multiplied by the percentage of hired and family member handlers in
each crop group (Tabtes III-2 and III-5).
SOURCES:
(1); Appendix Tabtes PPE-2. PPE-5. PPE-9. and PPE-10.
(2); Aoparrfx T»bte« PPE-5, PPE-6, PPE-10, and PPE-ia
(3); Appendbc Tables PPE-7 and PPE-14.
(4); Aopandbc Tabtoe PPE-8 and PPE-15.
(5); Tabte III-2, column (1) Total Number of Establishments" minus column (4) "Establishments that Don't Use Pesticides".
(6)! Calculated, (3)/(5).
(7); Calculated, (4V(5).
-------
Appendix Table PPE-2. Total fast year PPE costs for hired and famiy member handters by crop sector.
•'^ '"• % ^ /
Faad ft Grain
Cotton
Tobacco
OherfiaH
Vefll^
Nunary/G.H.
Totab
".-'" \
7,018,164
57.463
88,748
44,633
261,806
47,574
$7,518,386
f -.•" "" .. ' / ',
3.587.062
330,275
1,020.464
684,227
1,337,974
437.538
$7,397.541
' •• 1ST
2,573,327
631,831
976.096
490,859
2.879,554
523.144
$8.074.810
<:i3t-
2.210,722
542,800
838,555
421,692
2.473,798
449,428
$6,936,996
••RSB""
15,206,022
1.400,081
4,325,880
2,900,528
5,671,848
1,854,782
. $31,359,140
^ ftehtei*
1,871,510
459,514
709,888
356,988
2,094,221
760,936
$6,253,057
H.i^V
1,929,995
473,873
732,072
368.144
2,159,665
784,715
$6,448,465
fcardfer*
150,487
85,229
6,717
30,779
41,064
170,025
$484,301
- Total
"ppg Casts'
34,547,289
3,981,067
8,698,420
5,297,848
16,919,929
5,028,141
$74,956,995
Notes: Al costs ara in 1 w 1 dolars.
We assume that dlriredand famiy member handbrs mix, bad, and appfy peslkxias. Therefore, we must outfit hired and family member handters
T,b»cauB»»^
I/ Wilh tw oxcepbon of respiratory protection, al indwduai costs are cakxdated by:
Par handar cost o» PPE item (Appendix Table PPE-4) X tw number of hired and famiy member handtefs by crop category (Tabteslll-2 and 111-4)
Xt»pe«»nl^o
-------
Appendix Table PPE-3. Personal Protective Equipment Required for Hired and Family Member Handlers, by Type of Pesticide Handling Activity
and Pesticide Toxlcity Category
Typ*o!PMfcUa1/
Handing Coveralls Glovas
AoMly Tox HI' TaxllMV Taxi-Ill' Tea IV
GROUND APPUCATON YM No Yes No
SUPPORT
(Midr«t,La«Jirg) YM No Yw No
Chemical Resistant
Foonvare
Tox HI' Tox IIHV
Yes No
Yes No
Chemical Resistant
Eye Protection Respiratory Protection Apron Protective Headwear
Tox Hit ToxllHV ToxH!@ Tox III-IV Tox I-IW Tox III-IV Tox HI" Tox III-IV
Yes No Yes No No No Yes No
Yes No Yes No Yes No No No
* For dermal toxicity or skin irritation potential.
+ For eye irritation potential.
@ For inhalation toxicity.
# For dermal toxicity or skin irritation potential while performing mix/load or equipment cleaning tasks.
" For dermal toxicity or skin Irritation potential with overhead exposure.
-* "
1/ We assume that none of the hired & family member handlers apply pesticides by aerial methods. If any do apply aerially,
only chemical-resistant gloves would be required.
-------
Appendix Table PPE-4. Personal protective equipment costs
for hired and family member handlers
Coveralls 2/
Gloves 3/
Waterproof 4/
Boots
Eye Protection 5/
Respiratory Protection 6/
hemical 71
Resistant Apron
'reflective Headwear 8/
TotaJCost
30.00
4.60
11.00
9.45
19.50
8.00
8.25
$90.80
SOURCES:
1/ Prices are from current (1991), personal and environmental safety supply catalogs.
21 Based on one pair of cotton coveralls per handler ($30 per pair).
3J Based on two pair of nitrite gloves per handler ($2.30 per pair).
4/ Based on one pair of waterproof boots per handler ($11 per pair).
5J Based on the assumption that one-third of the handlers wear goggles ($4.50), one-third wear a face shield
($19.85), and one-third wear safety glasses ($4). (4.50 + 19.85 + 4>3 . $9.45.
6/ Based on the following:
- Hired and family member handlers handle pesticides an average of 13 days per year (Table III-6).
- On average, 15% (EPA estimate) of the 13 days handling wffl require respiratory protection: 13 X15% . 2 days.
- Half the handlers use a non-disposable respirator that costs $22. Cartridges cost $6 each and must to
replaced 2 times per year: $22 + ($6 X 2) - $34.00.
- Half the handlers use a disposable dust/mist cup-style respirator that costs $2.50 each and must
also be replaced 2 times per year $2.50 X 2 - $5.00.
Average cost per hired and family member handler for respiratory protection:
($34 + $5)/2-$19.50
II Based on one heavy-duty neoprene apron per handler ($8).
B/ Based on the assumption that ha* of the handlers wear a hat ($15), and ha« wear a hood ($1.50).
* Protective headwear cost - ($15 + $1.50X2 - $8.25.
-------
Appendix Tabte PPE-5. Total first and out year cleaning costs tor hired handlers by crop sector *
Feed & Grain
Cotton
Tobacco
Other ReU
Veg/Fruit/Nut
Nursery/G.H.
Oaring Cost
, m
0.57
0.93
0.45
0.89
0.81
1.26
- £P£&ppr*»
CteariflgCO!
- - ($jhandter/day}
0.34
0.19
0.30
021
024
0.06
t . TOM
« - Cos!
&
0.91
1.12
0.75
1.10
1.05
1.32
Nart&arot
(Number)
6
21
1
3
3
PerHafiCRer
Total
Cteaning
($/handler/year)
5.46
23.48
0.75
3.29
3.15
29 38.23
of Hired
Handlers
(Number)
265,410
31,340
101,000
68,170
115,025
37,225
Total first and out year PPE cleaning costs
TofcltW
Clearing
Cost
w
1,449,696
735,735
76,073
224,589
362,691
1,423,174
$4,271,958
Note: FamHy member handters are exempt from the PPE cleaning requirements of the regulation.
SOURCES:
(1); Based on the fotowing:
It takes 12 minutes to wash al PPE (al PPE required for Tox Ml pesticides) and the employer is responsible for the cleaning
at $7 an hour 12 rrin/60 min X $7 - $1.40
Calculated, $1.40 X the % of acre treatments of pesticides that are Tox l-ll by crop group (Table III-8).
(2);Basedonthetolovtfng: .
R takes 5 rrfnutes to wash a paM-of gtoves (the only PPE required for Tox IIHV pestkades) and the employer is responsible for the cleaning
at $7 an hour: 5 rrtn/60 rrin X $7 - $0.58
Calculated, $058 X the % of acre treatments of pesticides that are Tox III-IV by crop group (Tabte III-8).
(3); Calculated. (1) +(2).
(4);Tabtelll-6.
(5); Calculated, (3) X (4).
(6);Tabtelll-2.
(7); Calculated. (5) X (6).
Total first year
PPE and Cleaning
Costs
$79,228,953
-------
Crat..' ..
FwdlOnin
Cotton
Tobacco
OharRsU •
Ve^Fruit
Nur*ery/G.H.
Tot*
.«4>*
2,339,388
19,154
29,583
14,878
87.268
15.858
$2,506,129
••taff
3,587,062
330,275
1,020,464
684.227
1.337.974
437.538
$7.397.541
•«?•
857,776
210.610
325,365
163,620
959,851
174.381
$2,691,603
^«
736,907
180,933
279,518
140,564
824.599
149,809
$2,312,332
*^,'
6,628,266
610.292
1,885,640
1,264,333
2.472,344
808.495
$13,669,369
Aaron
623,837
153,171
236,629
118,996
698,074
253.645
$2,084,352
******
643,332
157,958
244,024
122,715
719,888
261.572
$2.149,488
*****
150,487
17,770
57,267
38,652
65.219
21,107
$350,502
T«al
15,567,054
1,680,164
4,078,491
2,547,984
7,165,218
2,122,405
$33,161,316
I/ OU ywr cosS era based upon Appsndx Tabte PPE-2 and tw folowi^) aasumpttans:
-Non-dspcsabla laspiratar bodfas last indefinitely
-Gloves are replaced amuaty
-FteapiratocartidgesaxJdusVm^rBspkBtorearore^^
-Al olhar PPE tens an replaced awry tree years
2/Told out yaer costs ara estimated to be the sanw as first year costs. However, due to the possibility of agricufcurai operators
switching to less toxic pestkxfes and ftus tie decreased need tor monitoring, out year eslirnates are Skalyovereslimated.
Total oU year cleaning costs are fre same as total list year costs
$4,271,958
Total out year PPE Costs
(PPE + Cleaning)
$37,433,274
-------
Appendix Table PPE-7. Incremental first year total PPE costs for hired and family member hand
TotaTfirst year PPE casts 1/ =
- Percentage of PPE costs
already required on labels 21
Incremental first year PPE costs
Total first year cleaning costs 3/=
- Percentage of cleaning costs
currently incurred 4/
Incremental first year cleaning costs
Total incremental first year PPE and
cleaning costs (in 1991 dollars)
/4,956,995
80%
4,271,958
33%
$14,991,399
$2,862,212
$17,853,611
SOURCES:
1/Appendix Table PPE-2.
21 About 80 percent of trie volume of all pesticides used have been
reviewed under EPA's Registration Standards program. Chemicals
reviewed to date have had specific requirements for PPE established.
3/Appendix TabtePPE-5.
4/ EPA estimates that hired handlers are currently cleaning their PPE
items at least every third handling day (33% of the time).
Appendix Table PPE-8. Incremental out year total PPE costs for hired and family member handte
Total out year PPE costs 1/- 33,161,316
- Percentage of PPE costs
already required on labels 21 80%
Incremental out year PPE costs
Total out year cleaning costs 3/- 4,271,958
- Percentage of cleaning costs
currently incurred 4/ , 33%
Incremental out year cleaning costs
Total incremental out year PPE and
ctearjng costs (in 1991 doiars)
001 iDr-CG'
$6,632,263
$2,862,212
$9,494,475
SOURCES:
1/Appendix TabtePPE-6.
21 About 80 percent of the volume of aB pesticides used have been
reviewed under EPA's Registration Standards program. Chemicals
reviewed to date have had specific requirements for PPE estabished.
3/Appendix TabtePPE-5.
4/ EPA estimates thai hired handlers are currently cleaning their PPE
iteTOatteasteverytNrdnardlingday(33%ofthetirne).
-------
.Appendx Table PPE-9. Total first year PPE costs for commercial handlers
vWrttfi; towB*^ fifew
GROUND APPLICATIONS 730,000 59300
AERIAL APPLICATION 3/ 27 ,600
SUPPORT (Wimg 1 1,140,000 87,400
Loading)
Subtotals $1520,000 $174300
3ost of monrtonng handters S/
TOTAL COSTS
^a* '^. «^.'
-------
Appendix Table PPE-11. Personal protective equipment required for commercial handlers, by iypo cf pesticide handling activity
and pesticide toxicity category
TypeofPastkida
Handing
Activity
GROUND APPLICATION
AERWLAPPUCATiON
SUPPORT (Mbdng&
Lo**nQ>
Coverafe
Tox Ml*
Yea
No
Yas
Tox III-IV
No
No
No
Gloves
Tox l-lir
Yes
Yas
Yas
Tox IV
No
No
No
Chemical Resistent
Footware
Toxl-ll*
Yes
No
Yes
Tox HI-IV
Ho
No
No
Eye Protection
Tox I-II+
Yes
No
Yes
Tox III-IV
No
No
No
Cbamica! Resistant
Respiratory Protection Apron
Toxl-ll@ Tox III-IV Toxl-ll* Tox III-IV
Yes No No No
No No No No
Yes No Yes No
Protective Heackvear
Tox l-ll" Tox III-IV
Yes No
No No
No No
* For dermal toxicity or skin irritation potential.
+ For eye irritation potential.
@ For inhalation toxicity.
# For dermal toxicity or skin irritation potential while performing mix/load or equipment cleaning tasks.
** For dermal toxicity or skin irritation potential with overhead exposure.
-------
Appendix Table PPE-12. Personal protective equipment costs for commercial handlers.
_33= "l" ^^.^.
CoveraSs2/
Gloves 3/
Chemical 4/
Resistant Footware
Eye Protection 5/
Respirator/ Protection 6/
Chemical 71
Resistant Apron
Protective Headwear B/
Total Cost
60.00
4.60
22.00
9.25
32.25
8.00
8.25
$144.35
SOURCES:
1/ Prices are from current (1991), personal and environmental safety supply catalogs.
2/ Based on two pair of cotton coveralls per handler ($30 per pair).
3/ Based on two pair of nhrile gloves per handler ($2.30 per pair).
4/ Basad on one pair of heavy rubber boots per handler ($22 per pair).
5/ Based on the assumption that one-third of the handlers wear goggles ($4.50), one-third wear a faco shield
($19.85), and one-third wear safety glasses ($4). (4.50 + 19.85 + 4)/3 - $9.25.
6/ Based on the foBowing:
- Commercial handlers handle pesticides 33 days per year (Table lfl-6).
- On average, 15% of the 33 days handling wiH require respiratory protection: 33 X15% - 5 days.
- Haff the handlers use a non-disposable respirator that costs $22. Cartridges cost $€ each and must be
replaced 5 times per year: $22 + ($6 X 5) - $52.
- Half the handlers use a disposable dust/mist cup-stypa respirator that costs $2.50 each and must
also be replaced 5 times per year: $2.50 X 5 - $12.50.
Average cost per commercial handler for respiratory protection:
($52 + $12.50) 12m $32.25.
71 Based on one heavy-duty neoprene apron per handler ($8).
8/ Based on the assumption that half of the handlers wear a hat ($15), and half wear a hood ($1.50).
Protective headwear cost -(15 + 1.50)/2 - $825.
-------
Appendx Tabte PPE-13. Total out year PPE costs for commercial handlers
g^^*^'
GROUND APPLICATION 260.000
AERIAL APPLICATION
SUPPORT {Mbdrg & 380.000
Loading)
Subtotal $640,000
Cost of monitoring harriers
Total cost
fte&tart Ftes&fcnt £ye#
59,800 95,333 40,083
27,600
87,400 139,333 58,583
$174.800 $234,667 $98,667
Ftespsa&cy'l/ ffesjsfcu* Protective t/
276,250 35,750 767,217
27,600
403,750 50,667 1,119,733
$680,000 $50,667 $35,750 $1,914,550
$620,730
$2,535,280
1/ Out year costs are based upon Appendx Tabte PPE-9 and the following assumptions:
-NorKfsposabte respirator bodes last indefinitely
-Gloves are replaced amuaty
-Respirator cartridges and dust/mist respirators are replaced after each day of use.
-AH other PPE items are replaced every three years
Total out year cleaning costs are the sama as total first year costs
$1,149,104
Total Out Year PPE
Costs (PPE + Cleaning)
$3,684,384
-------
Appendix Table PPE-14. Incremental first year total PPE costs for cc-" mercial handlers
Total first year PPE costs 1/ = 5,006,780
- Percentage of PPE costs
already required on labels 21 ' 80%
Incremental first year PPE costs ,.
Total first year cleaning costs 3/ =
- Percentage of cleaning costs
currently incurred 4/
Incremental first year cteaning costs
Total incremental first year PPE and
cleaning costs (in 1991 doHars)
$1,001,356
1,149,104
50%
$574,552
..$1,575,908
1/Appendix Table PPE-9.
2J About 80 percent of the volume at all pesticides used have been
reviewed under EPA's Registration Standards program. Chemicals
reviewed to date have had specific requirements for PPE established.
3/Appendix Table PPE-10.
4/ EPA estimates that commercial handlers are currerrtty cleaning their
PPE items at least every other handling day (50% of the time).
Appendix Table PPE-15. Incremental out year total PPE costs for commercial handlers
Total out year PPE costs 1/ - 2,535,280
- Percentage of PPE costs
already required on labels 21 80%
Incremental out year PPE costs
Total out year cleaning costs 3/ -
• Percentage of cleaning costs
currently incurred 4/
Incremental out year cleaning costs
Total incremental out year PPE and
cleaning costs (in 1991 doftars)
$507,056
1,149,104
50%
$574,552
$1,081,608
1/ Appendix Table PPE-13.
21 About 80 percent of the volume of afl pesticides used have been
reviewed under EPA's Registration Standards program. Chemicals
reviewed to date have had specific requirements for PPE estabfished.
31 Appendix Table PPE-10.
4/ EPA estimates that commercial handlers are currently cteaning their
PPE items at least every other handSng day (50% of the time).
-------
Section 3
Notification/Posting
-------
Appendx Tabte NP-1. Revised WPS compiance costs tor notification in 1991 dollars, by sector
: .. v
', ' ^ "" '
*
5^wOf , . . . ' '
Feed & Grain
Cotton
Tobacco
Other Field
Vegetable & Fruit
Nursery & Greenhouse
Total
.. .. T '"*, **
""" '"'"'Twi
^P^Vdar
. " ..' ....' O-f
3,374.102
699,902
1,313.970
3,780^97
4,700,325
2.894,371
$16,762,967
9*f**f9T^f^K& 9
'' ' %" &
rtft'
1,100,423
264,067
336,964
868.529
2,056,456
1,488,219
$6,114,658
' "• •••.
': fetVdar
"" ""•*•* •v-|^|" - ft
3,280,806
672,216
1,287,644
3,755,689
3,898,355
2,680,026
$15.574.737
Mita) '
Ou*Year
'\Tj
1,007,127
236.381
310,637
843,921
1,254,487
1,273,876
$4,926,430
-
l^SJ^
ThaiU^Pesfe*i88
v*i
132,705
15,670
50,500
34,085
57.513
18,613
309,086
;
IrtcfSmentaJCo^sperE
First Yfc»
\vj
24.72
42.90
25.50
110.19
67.78
143.99
$50.39
stattshroert
PesticMes
Out Year
t*t\
w
7.59
15.08
6.15
24.76
21.81
68.44
$15.94
S30RCE5T
(1); Appendx Tabte NP-2.
(2); Appendx Tabte NP4.
(3); Appendx Tabte NP-5.
(4); Appendx Tabte NP-7.
(5); Tabte III-2, column (7).
(6); Calculated; (3V(5). .
(7); Calculated; (4V(5).
-------
Feed & Grain
Cotton
Tobacco
Other Fiefcl
Veg/Fruit/Nuts
Nursery
Greenhouse
Total
188,441
22,251
71,710
48,401
81,668
10,308
16,123
$438,902
Gerfcaf
m
479,812
117,406
49,557
119.575
474,231
161,858
664,205
$2,066.644
0) <
f&\
17,181
26,558
17,076
10,529
713,449
229,794
47,006
$1,061,592
ft&m'&e*
{4)
2,688,669
533,686
1,175,627
3,601,792
3 •^•••976
1.481,229
283,850
$13,iy5,828
Total
NoSteation Costs
3,374,102
699,902
1,313,970
3,780,297
4,700,325
1,883,188
1,011,183
$16,762,967
(in 1991 dollars)
(1) Based on the following assumptions:
-One safety poster per establishment that hires labor.
-Posters cost $025 each.
-Empbyer or supervisor receives $7.00 per hour for labor.
-Writing the name, address and phone number of mecScal f adSty takes 5 minutes of enrptoyer's or supervisor's time.
Thus the cost of labor would be $7 per hour X 5 minutes/60 minutes - $0.58 perposter.
-Posting the safety poster takes 5 minutes of employer's or supervisor's time
Thus the cost of labor would be $7 per hour X 5 minutes/60 minutes = $0.58 per poster.
-Total per estabishment cost for the sign and labor - $.25 + $1.17 - $1.42.
Calculated; Estabfehments with hired labor that use pesticides (Tabte III-2) X $1.42.
Footnotes continued...
-------
pendix Table NP-2 footnotes continued...
Based on the following assumptions:
—One centrally posted notice per pesticide treatment per establishment that hires labor.
—Paper or form cost for notification is negligible.
—Employer or supervisor receives $7.00 per hour for labor.
—Posting the notice takes 10 minutes of employer's or supervisor's time.
Thus the cost of labor per treatment would be $7 per hour X 10 minutes/60 minutes = $1.17 per posted notice.
alculatcd; Establishments with hired labor that use pesticides (Table III-2) X $1.17 X Average number of all treatments applied per acre, per year,
f crop group (Appendix Table NP-3).
•v
Based on the following assumptions:
—Employer's have the choice of either orally notifying hired workers of any pesticide treatments or posting fields that have been treated.
-With the exception of greenhouses, it is assumed that all hired workers will be orally notified instead of posted notification.
—One oral notification is necessary for each pesticide treatment, when hired workers will be within 1/4 mile of a treated field and the
pesticide treatment is within the restricted entry interval.
—The expected probabilities that hired workers will be within 1/4 mile of a field after a 48/24/12 hour REI pesticide application, is given
in Table ffl-7."
—An average of one oral notification per pesticide application is derived by averaging applications with 12-hour REI's (Tox III-IV), where
no oral notification is probably required, with applications with 48-hour and longer REI's (Tox I), where more than one oral
notification may be required due to new hires.
—Oral notification of any pesticide treatment is given by an employer or supervisor; wage rate is $7.00 per hour; oral notification takes 5
minutes.
5 minutes/60 minutes X $7.00 = $0.58 per notification
-Oral notification of any pesticide treatment is received by all hired workers on the farm; wage rate is $5.00 per hour; oral notification
takes 5 minutes.
5 minutes/60 minutes X $5.00 = $0.42 per notification per worker
-Oral notification of any commercially applied pesticide treatment is also received by hired handlers when they are working in fields;
wage rate is $7.00 per hour; oral notification takes 5 minutes.
5 minutes/60 minutes X $7.00 = $0.58 per notification per handler working in fields.
—5% of all pesticide applications in greenhouses are of Toxicity I pesticides for dermal or eye irritation potential and must have double
notification.
Footnote (3) continued ...
-------
1) continued ...
Calculation for feed & grain farms (all other crop groups would be the same procedure except greenhouses):
{[(3.1 treatments applied per acre (Appendix Table NP-3, column (7» X 27% of all acre treatments are of 48 hr. REI pesticides (Table IH-8) X
5% probability that hired workers are within 1/4 mile of field after a 48 hr REI pesticide application (Table I1I-7)) + (3.1 treatments per acre X
13.4% arc of 24 hr REI's X 5% probability) + (3.1 treatments per acre X 59.1% are of 12 hr REI's X 0% probability)] X [$0.58 employer's wage
+ ((1.9 workers per establishment (Appendix Table NP-3) X $0.42 worker's wage)]} + {[(1.9 treatments applied commercially per acre (Appendix
Table NP-3, column (8)) X 27% of all acre treatments are of 48 hr. REI pesticides (Table IH-8) X 5% probability that hired handlers working in
fields arc within 1/4 mile of field after a 48 hr REI pesticide application (Table IH-7)) + (1.9 treatments per acre X 13.4% are of 24 hr REI's X
5% probability) + (1.9 treatments per acre X 59.1% are of 12 hr REI's X 0% probability)] X [(2 handlers per establishment working in fields
(Appendix Table NP-3) X $0.58 handler's wage)]} = $0.13 per feed & grain farm for oral notification X 132,705 feed and grain farms that hire
labor and use pesticides.
Calculation for greenhouses (hired handlers that arc working in the greenhouse do not need oral notification because they applied the pesticide):
[(50 treatments applied by hired handlers per greenhouse (Appendix Table NP-3) X 5% of all treatments are of Tox I pesticides for dermal toxicity
or skin irritation potential X 90% probability that hired workers will be returning to the greenhouse within the 48 hr REI (Table ni-7)] X [$0.58
employer's wage + (3 workers per establishment (Appendix Table NP-3) X $0.42 worker's wage) = $4.14 per greenhouse for oral notification X
11,354 greenhouses that hire labor and use pesticides.
4) Based on the following assumptions:
—Only pesticide applications of Toxicity I dermal toxicity or skin irritation potential require treated area posting (with the
exception of greenhouses).
—Number of treatments requiring posting = % of Tox I treatments (Table IH-8) X % of Tox I treatments that are also Tox I for
dermal toxicity or skin irritation potential (IH-8) X % of treatments requiring notification (Table IH-7, column (1)) X average
number of all treatments applied per acre, per year, per crop group (Appendix Table NP-3).
Example for feed & grain: 27% of all acre treatments are Tox I X 18.6% of all Tox I treatments are Tox I dermal/skin
X 5% of treatments require notif. X 3.1 treatments applied per acre, per yr = .01 treatments per acre (or per
establishment) require posting.
—There are 300 acres per feed & grain farm field; 240 per cotton field; 30 per tobacco field; 25 per other field; and 22 per
veg/fruit/nut field (Appendix Table NP-3).
—There are 2 feed & grain fields per farm; 3.4 per cotton farm; 2.3 per tobacco farm, 10.6 per other field farm; and 5.6 per
veg/fruil/nut farm (Appendix Table NP-3).
—Two signs will be needed per field; 50 signs are needed per greenhouse establishment.
-Signs for greenhouses cost $0.50, all other establishments' signs cost $5.00.
-A pesticide handler-employee would post and remove signs with a wage rate of $7.00 per hour.
—Posting & removal would take an average of 30 minutes per field (10 minutes to post, handler on site, + 20 minutes to remove
which may require special trip to field).
'ootnotc (4) continued ...
-------
ntinued... '
—Labor costs to post & remove signs = $7.00 per hour X 30 minutes/60 minutes = $3.50 per field.
-Labor costs to post and remove signs on greenhouses would be negligible because handlers are always present.
Iculation example for feed & grain farms (cotton, tobacco, other field, veg/fruit, and nursery would be the same):
elds per farm X 2 signs per field X $5 per sign] + [.01 treatments require posting X $3.50 labor costs] X 132,705 establishments.
ulation for greenhouses:
treatment sites per estab. X 1 sign per treatment site X $0.50 per sign] + $0 labor costs X 11,354 greenhouse establishments.
-------
Appendx Table NP-3. Supplemental data used for calculating notification costs.
Spmrmretf
j<* ®t ja) JQ , n ' &> : M t*n
733 60% 2243 3.1
I.O 0.0% 1/1 A) d/aa 6O%
-------
Appendix Table NP-4. Total out year notification costs for agricultural establishments that hire labor and use pesticides.
;*':*qi»\!
~ tS^OtisftHI' -"
Feed & Grain
Cotton
Tobacco
Other Reid
Veg/Fru'rt/Nuts
Nursery
Greenhouse
Total
* J \ ":'' ^Ptf*<; :
- - ,'%$"'>, ^~ ^£ -, ••:
62,814
7,417
23,903
16,134
27,223
3,436
5,374
$146,301
Central - ;-
}, '$&; ";
479,812
117,406
49,557
119,575
474,231
161,858
664,205
$2,066,644
NoSbn
$5
t&\
17,181
26,558
17,076
10,529
713,449
229,794
47,006
$1,061,592
?l^^a
1 «:, «; '
540,617
112,685
246,427
722,291
841,553
319,777
56,770
$2,840,121
(in 1991 dollars) .'
Total ;
Notification
Costs ,
1,100,423
264,067
336,964
868,529
2,056,456
714,864
773,354
$6,114,658
SOURCES:
(1) Appendix Table NP-2 and the assumption that safety posters last 3 years.
(2) Appendix Table NP-2.
(3) Appendix Table NP-2 and the assumption that treated area signs last 5 years (labor costs remain the same
as first year costs since signs must be posted and removed).
-------
Appendix Table NP-5. Incremental first year notification costs for agricultural establishments that hire labor and use pesticides.
.•!<*> - '
*3fi3MJ3te(f
Feed & Grain
Cotton
Tobacco
Other Field
Veg/Fruit/Nuts
Nursery
Greenhouse
Total
'$afe#p0st«ir
•• * Jf*&\ •• ••
in
188,441
22,251
71,710
48,401
81,668
10,308
16,123
$438,902
.Central
PiQwKnwIQft
irtx ,,
{£$
390,249
95,491
40,307
97,255
385,711
131,645
540,224
$1,680,882
Oral
(3)
/tf»\
13,447
20,787
0
8,241
0
179,859
36,791
$259,126
Treated Area
1 ^4)
2,688,669
533,686
1,175,627
3,601,792
3,430,976
1,481,229
283,848
$13,195,827
(in 1991 dollars)
Total
Notification
Cosfe
3,280,806
672,216
1,287,644
3,755,689
3,898,355
1,803,041
876,986
$15,574,737
SOURCES:
(1) Incremental first year costs for safety posters are the same as total first year costs.
(2) Calculated by reducing total first year costs (Appendix Table NP-2) by 19%. Five states already require central
notification on agricultural establishments (Appendbc Table NP-6) and their percentage of U.S. farms = 19%.
(3) Calculated by reducing total first year oral notification costs (Appendix Table NP-2) by 22%. Eight states already
require oral notification on agricultural establishments (Appendix Table NP-6) and their combined
percentage of U.S. farms = 22%. Additionally, pesticides that are used on labor intensive crops are currently
required to have oral notification statements on their labels. Therefore the cost of oral notification is already
being incurred by those establishments with labor intensive crops (tobacco and veg/fruit/nirts).
(4) Incremental first year costs for treated area posting are the same as total first year costs.
-------
Appendix Table NP-6. Calculation of WPS Notticafam Costs ABributabta to Stela Regulations
^TP^^ff^P****^*^*^^^^*^^^*^*^***^^*^^^^^^^^^1^^^^^^^^ rfW^i^ ~\ Si^-Li. ^ _•*•»__ i_ ^ii ~_jH^_ '-".'-*J.".'-'Jr ^y*.
Ces&af
Ncifcsfcft
#* $
m
wc
Exampfct*
Arizona
088fe$H
Florida
|&btol£
Minnesota
™8f*(
Oh»7/
fwP^P,
Wgkift
0.4%
1.9%
'3.7%
***
3.9%
V '>J"';^
X
X
X
X
X,
X
*
X
X
48hror>REIon 11 spedfic crops (mainly fcuh&veg)
If a reentry interval B stated on the label
Wbconwn
\^ -'
-. " ^
Tatst
3.7%
Ho
No
N» >J4^(ws5%|«8rvalmteba-i*ifM^cn^t^
No If a reentry riterval is stated on the label
33.0%
19%
22%
13%
(1);Souro:U.S.DepartYmrto
-------
Appendix Table NP-7. Incremental out year notification costs for agricultural establishments that hire labor and use pesticides.
'~**Sk-'r> '•""
Feed & Grain
Cotton
Tobacco
Other Field
Veg/Frutt/Nuts
Nursery
Greenhouse
Total
62,814
7,417
23,903
16,134
27,223
3,436
5,374
$146,301
Central
, ,- Notjttoa^
390,249
95,491
40,307
97,255
385,711
131,645
540,224
$1,680,882
-Oral
/
-------
Section 4
Training
-------
Appendix Table TR-1. Revised WPS compliance costs for training, by sector
Mt* ' --'
Feed&Grain
Cotton
Tobacco
Other field
Vegetable i Fruit
Nursery & Greenhouse
Commercial Handters
Total
?§*"
4.138,343
732,081
1,140,751
1.629,043
2,785.302
692,479
490.200
$11,608,197
' ' •.
"'$Aywsr
($)
1.392,581
261306
356,310
584.129
1,000.246
240,139
147.060
$3,982,271
'
' IS)
2.624.899
436,530
773,172
968,581
1,653,331
426,424
61.275
$6.944.212
«W
HI
866,030
152,893
239,276
340,191
581.620
144.773
55.148
$2.379,931
Mrtxr*
!MU»n*M»-
132.705
15,670
50,500
34,085
57,513
18,613
8,500
317,586
' wahHrodUfcor That Use Psstkxtes
.;.5^
19.78
27.86
15.31
28.42
28.75
22.91
7.21
$21.87
-- (5) --
6.53
9.76
4.74
9.98
10.11
7.78
6.49
$7.49
and aottng that to total first year training costs for hanotere nwtepled by the percentage of handters in each crop sector.
This oroceedure was repeated for total out year costs, and incremental first and out year costs.
SOURCES:
(1); Appendx Tabte TR-2.
(2); Appendx Tabte TR-3.
(3); Appendbc Tabte TR-4.
(4); Apperrfx Tabte TR-6.
(5); Tabte III-2. column (7) and Tabte III-5.
(6); Calculated. (3V(5).
(7); Calculated. (4V(5).
-------
Appendix Tabte TR'2-Total fifst Ve^ frying coste for agricultural workers, handlers, and commercial pesticide handlers
T«**tg fcbtwtal
Norton
Hmfm
ConvTMKttJ Handni
Tout
0.50
0.75
0.75
5.00
6.00
7.00
6.50
7.00
10.00
5.75
9.75
12.75
- 'j£bnif)toyae)~
0.15
015
0.15
530
950
1250
SOURCES:
(l);EPAMicnM».
(2);Wartww«B»n^lnmUS.D«p«tT>«dl^xi.H«idho*^ Handter and oommarctt handler *HQeia» is an EPA astmae.
(3); For mtem: ofcUMKl by •nuning tMH d Wining ia from mptoyv ($74v, «ourc^2))ardh^kcniNr^hanckr($6/tv,mkh*ayalwGrkarardemdayer«»a]«raia)
(4); CdoteMd. (1)XJ2M1)X(3).
(7); Wortm «id hwfm horn Tatto KI-2. ooromraal twndm from Trite «-5.
TittoTBa. Total out yaar Mining com tor agriojfcjral mmtott, lMnd«ft, and cotnmociai petuckte handtert
,f**»6*<* *l^***i* gffy*»Mi^ T««Awtta»A!«W* flMf«Mr T**l-_tll Toa*0ot1fr|"
..*»
Wxfcm
Hmtot
ConiMRW
c
847.136
018.170
38.000
20%
10%
10%
20%
20%
20%
40%
30%
30%
336366
185.451
11.400
530
950
1230
(*)
1,999.246
1335.965
147.060
Jatt
SOURCES:
(1)4^; Rom App*ndbc Trtto TR-Z
(2); EPA MimM taMdon«i ww^j* CVMTintonaAno(5 ywri.(or woriwrt and 10 years tor handlers and commwcial bandars.
(3); EnpbyM* »• to racaiv* ranining «v«y 5 yMn. tMf *r•. in any cr» yiar 2O% o( tM amployeM win receive retaining.
(4);Cateutal«J.(2) + (3).
(5);Cafcttal«d.(1)X(4).
(7). r*HaM(1. (5) X (6).
-------
typencix Tabte TR-4. Incremental first year trartng costs for ^ricullural worters, handters, and commercial pestkade handlers
SOURCES:
(2); T«U« 11-6. Do« lo ta* d dou. no hmdtara are aHurod to b* otfUait pMtcid* handtars. EPA bafevet (hit it muratesrfmateoltwtHJrnbafolcanifedhandtefs which in turn,
*M oott d niNng dua to tn WPS.
..
(4);OSHA'»H«2*dCornn*iicalic«Swd«ri«pp*«Btam»^ or more emptiyees- Tlwly-six parcert (36%)
o( rf Ml wortwrt m conrod by to HCS (F«tard (tegiEMr. Vd. 52. No. 84. 1flB7 (May 1 ». PiQt 16034. Adtttonaly. rin« Mala cumnly rsqure some taniig
tar pMtiari* tandtara v M0ifc«i h« oauU b« I^XM^ la pwfcidi*, an MiaUJshMntt
tern tabor wptntM . 34%. wMch ••» UMd m a pnaty tar r«Jucng t» numbv ol workJ««ndhandtettiali»q^eWrerair^Cornrr^cdhancJ«f»ar8 cover sd by HCS
(5J:C*i*tt«d;{3)X(4).
nTH^ffl tomtlmmtiWm trThanrflrtlFPftiri "— - — ' -- -.^Tr_.»^^n
-------
AppendKTabtoTRS. CafcUalradW
<;$>aiia^;C!i»fflni^;iri
(»
tf)
Vfortw
«*«**
riwTtB
1Ahm**
WfBHW
m
S**w<
Handar Trainees
SybWet Si****
Hmtter Hap**-Trainer
Mask*
r«jti'»v
''^^W^WS
MMW
Naw Hampr*
ftl#l
Ohio
PonnsyMmk
^A •&••>
TBXM
:^?Wl^^R'v
Totd
0.0%
jK^ii
0.5%
0.
H
£0%
vWB-W
Z7%
*^>
58%
X
X
X
X
X
X
,*
X
X
X
X
X
X
X
X
'X
X
X
X
X
X
X
X
X
X
3.9%
X
•^4%~
32%
T%~
35%
X
X
X
K
X
30%
1%
•RiMutoiifm
(1); Source: U.S. DaoMfenwHof Comcrami. 1887 Ctmut oi Agricuhm. 1989 (Novsmber). Bureau of *» Cwwa.
Suivw ouMlions oonwpondng to tabto oohnm MM:
(2)-1 •DOM «w State IMIM • *Hgnt4o^(no«^ or Huwd Connunicalion ta^^
* *' " _ „ - ... .^ i^ • — __»
.
AppkM b torn w* 10 or
(3). 1. ftequras pMliciaVqMciic training*.
(4); 4 (c). Is «n inskuctDf/lrairwr mquirwf.
(S) 1 . ffcquww tact *hM(i on p«ickto« to mada Mwtabto to woiten-.
(6);4.{«)..»innB«iu»nonc«
(7); 4.(c). If M h^uctortnlnw » mojuirad, l«y nwt m««c«rtMn
-------
Appendix Table TR-6. Incremental out year training costs for agricultural workers, handlers, and commercial pestkxfe handlers
w***t-»i jl »> I«i1 ypiM m tnrm wmVai mrt twirteft fia ma arylnynrl rm tnnm wilti 1 1 or more employees. Thiny-sii percani (36%)
'o4 rf Md MXk«n w» oonr«J by to HCS (Fviml R^jiMw. Vd. 52. No. 84. 1987 (Itey 1)). Pags 16084. AdtWonaly. nin« Sates curanty raquife some fajning
lor curicMt Nntas or worfcm tut oouk) tw npoMd C ptfKvf°<. on MtdfehrrMnls w* 10 or lacs emptoyMt (Appendix Table TR-5). Tha runs slates' percentage of U.S. hired
tarn Unr aqMnsM - 34%, anfch «M uMd w • proxy tor riducirx) tw numb«r ol worker* end handto**»lrBquirBWPSraJr^.Cornrn«rcialhandl«rsareoovaredbyHCS
•nd by *M* rcguWorw.
(BI'CdculCMd (6)X(7)
(0)!ciln>.
-------
-------
Section 5
Decontamination
-------
-------
Appencfx Table DC-1. Revised WPS oompiance costs for decontamination in 1991 dollars, by sector
•ffWMWWWWWffSIIwiWWW^
- f %<••'• f^ffff J,
Sector
Feed & Grain
Cotton
Tobacco
Other Field
Vegetable & Fruit
Nursery & Greenhouse
Commercial Handlers
Total
'-* " , '
**%&*•„
7,355,078
1.040,043
2,984,258
2,182,776
13,866,287
2,808.124
1,089,117
$31,325,684
' A f *"
[***&*
...... /*
^*
4.375,776
.662.072
1,912,289
1,355,655
12,465,703
2,418,602
950,717
$24,140,815
•" A—
; m
i .. --..
;
3,785,480
587,797
1.267.690
. 1,247.629
4,347,143
1,058.963
421.210
$12,715.912
Ital \
M r
2.267,375
397,155
734,481
829,460
3,714,044
864,245
366,406
$9,173,166
M&W«£t Labor
-------
Appendix Table DC-Z Total first year decontamination costs for commercial handlers
Eyewash Dispensers:
Ground applicators on foot 1/- 0
Total first year eyeflush dispenser costs $0
Decontamination Site:
Tyvek coverall 2/ - 3.75
Container for wash water 3/ . • 3.08
Soap 4/ 2.97
Towels SI 5.69
Labors/ 27.50
Total first year decontam ination
costs per site $42.99
Total number of handling sites 71 X 25,333
Total first year decontam ination $1,089,117
costs for commercial handlers .
(in 1991 dollars)
All prices are from current personal and environmental safety supply catebgs.
1/ Based on the assumption that only a small number of hired handlers on foot need eyewash dispensers.
These applicators and the associated eyewash dispenser costs are addressed under hired handler decontamination costs.
2/ Based on one change of dean dothing per decontamination site.
31 Based on the assumption that aerial applicators and support crew have running water at their loading site.
Calculated, (13,000 comm. ground appfcators/38,000 total applicators (Table III-5)) X $9 per 3-gal container.
4/ Based on the foHowing assumptions:
-Each handler requires 2 oz. of soap per handling day. (EPA estimate).
-There are 1.5 handlers per sie (40% of comm. handlers work alone and 60% work together
with mixers/loaders/deaners). EPA estimate.
-There are 33 handing days per commercial handler per year (Table III-6, footnote 4).
-Soap costs $0.96 for 32 oz. (EPA estimate).
Calculated, ((2 oz. soap X1.5 handlers X 33 days>32 oz.) X $0.96.
5/ Based on the following assumptions:
-Each handler requires 16 towete per handling day. (EPA estimate).
-There are 1.5 handlers per site. (40% of comm: handlers work alone and 60% work together
with mixers/loaders/deaners). EPA estimate.
-There are 33 handfing days per commerdai handler per year (Table 111-6, footnote 4).
-Towels cost $0.69 per 96 towel roll (EPA estimate).
Calculated, ((16 towels X 1.5 handlers X 33 days>96 towels) X $0.69.
6/ Based on the need to raise and refl wash water containers and the fotowing assumptions:
-Commercial handler's wage rate - $10.00 per hour (Appendix Table TR-2).
-It takes 5 minutes per handng day, per site, to rinse and refill containers (EPA estimate).
-There are 33 handing days pw commercial handler per year (Tabte 111-6, footnote 4).
Calculated, $10.00 per hour X (5 min/60 min) X 33 days.
11 Calculated, 38,000 commercial handlers/I .5 handlers per site.
-------
Appendix Table DC-3. Total out year decontamination costs for commercial handlers
Decontamination Site:
Tyvek coverall 1/
Container for wash water I/
Soap
Towels
Labor
Total out year decontamination
costs per site
Total number of handling sites X
Total out year decontamination
costs for commercial handlers
(in 1991 dollars)
0.75
0.62
2.97
5.69
27.50
$37.53
25,333
$950,717
Source: Appendix Table DC-2.
1/ Based on the assumption that coveralls and containers are replaced every 5 years.
-------
Appendix Table DC-4. Total first year incremental decontamination costs for commercial handlers
DwontamiufenSi*:
PwcOTtAMbubbfcl/
Tynkoomi 19%
Contain* lor MMhmfcr 23%
Soap 23%
ToMk 23%
Lrfior 23%
Cort
FWnrvrg ExMng2f
3.04 60%
237 60%
228 60%
4.38 60%
21.18 60%
ToW fc* yMT incr«nnlal
dvoontenvwbon oovta ptf sjte
ToUl nunilH d hwlha •*•» X
ToM fnl y«v incnmrtd
daconlni •• 23% 229 60% 1.14
Ton* 21% i 4.38 60% 219
23% 21.18 60% 10.69
ToU! oU ft* inummnUI
d»nonUmnJionooil»p»r«i»» $1446
25.333
Tolil oU y«r nonmcntd
dvoontwfwfeon oovt toe IMIIIWCHI nAndun (366.406
M^BHMai^^M
(h 19&1 dpfam)
OO3.
-------
Appendix Table DC-6. Calculation of Worker Protection Standards Decontamination Costs Attributable to State Regulations
'""'I iiijnui ill ij IIIIIMIII i ijiiuiJIiiiii nil.. mil p. V_J__ I , !_.! I.. !• I I P!_ I I K*i._.!_ _
State Field Sanitation law/regutatbns equal to Federal Reid Sanitation Standards
w
Alaska
0.9%
X
X
Florida
6.6%
New Jersey
Oregon
*^i"
0.6%
J^
2.1%
Texas
5.2%
£3*
%
X
X
">
X
X
X
X
'X
X
X
X
Total
45%
44%
19%
23%
7%
14%
H2O H2O
X
x
X
6%
5%
' Souica: Rasuls of an EPA WPS questionaire from each state.
(1); U.S. Department of Agriculture. Agricultural Statistics, 1990.
Survey questions corresponding to table column titles:
(2); 2. "Apple* to farms w«h 10 or tess employees-.
(3); 2. 'Requires a dean change of clothing for emergencies*.
(4); 5.(a). "Is wash water required for agrcuSural pesticide handlers'.
(5); 5.(a). 'Is wash water required for early entry workers'.
(6); 5.(a). 'Is wash water required for aB agrfcultura! workers'.
(7); 5.(c). 'Is eyeflush water or dispensers required for agrufcutoiral pesticide handters'.
(8); 5.(c). 'Is eyeflush water or dispensers required for early entry workers'.
(9); 5.(c). 'Is eyeflush water or dispensers required for al agricultural workers'.
-------
Appendix Table DC-7. Total first year decontamination costs for hired handlers
Eyewash Dispensers:
Hired ground appfcators on foot 1/
Percent of pesticides that are Toxicity l-ll 2/
for eye irritation potential
X
13,010
35%
= Number of eyewash dispensers needed by hired handlers 4,554
Cost per eyewash dispenser 31 X $6.00
Total first year cost for eyewash dispensers $27,321
for hired handers """"""""""""""""
Decontamination Items (cost per hired handler):
Tyvsk coverall 4/
Container for wash water 5/
Soap&
Towete//
Labors'
Total first year decontamination
casts par hired handtor $22.61
Number of hired handters & X 618,170
Total first year decontamination
costs for hired handters • $13,975,793
Grand total first year eye wash dbpeoser and decontamination costs for hired handters
3.75
9.00
0.78
1.50
7.58
Al prices are from current personal and environmental safety supply catalogs.
1/ Based on the assumption lhat 5% of tho hired handters on frutVegetabte (arms apply pesticides by
foot [115.025 handters (Tabte III-2) X 5% (EPA e*t)] and that 50% of tfx» hired handters in nurseries do not
have wafer immediatery available and apply pesticides by foot [37,225 nursery/greenhouM handters (Tabte III-2) X
X 39% are nursery handters (based on 1987 Census of Agriculture data) X 50% of nursery handters do not have
running water immedately available (EPA estimate)].
2/ EPA estimate based on the proportion of Tox l-ll pesticides for eye irritation potential to at pesticides.
3/The cost of eyewash dbpertser water is regiigabte. Water used is drinWng wat^frcrnthaostabSshrnant
4/ Based on one change of ctean ctoWng par hired harder.
5/ Based on one, thre* galbn caibcy^ypa ccfltair^ p^ Nred handter. EPA beievM this is an overestimate of the
number of water containers needed because most greenhouse* arri rrcst mixing arri loach^ sites already have
running water available.
6/ Based on te fotowing assUmpltora:
-Each handtor requiret 2 or of soap par handfhfl day. (EPA estimate).
-There are an average of 13 harxlng days par hired handter par year. {Tabte 111-6, footnote 6).
-Soap costs $0.96 for 32 oz. (EPA estimate).
Calculated, ((2 oz. soap X13 days>32 oz.) X S0.96.
71 Based on ths folowing assumption*
-Each handter require* 16tmvete par handhg day. (EPA estimate).
-There am an averaga at 13 handing days par hired handtor par year. (Tabte III-6, foo»ioa» 6).
-Towete rost $0.69 per 96 tovwlrol (EPA estimate).
CalcUated, ((16 kjwab X13 day»y96 towels) X $0.69.
8/ Based on th« need to rinse and refil wash water containers and t» folowing asaumpfcra:
-Hired handtef s waga rate » $7.00 par hour
--It takes 5 minutes par handkig day, to rinsa and refl cartwy-typa container (EPA asKmate).
-Them are an average of 13 handng days par hired handter par year. (Tabto III-6, footnote 6).
Calculated, $7.00 per hour X (5 min/60 min) X13 days.
9/Tabte a-2.
-------
Appendix Table DC-8. Total out year decontamination costs for hired handlers
Eyewash Dispensers:
Number of eyewash dispensers reeded by hired harriers 4,554
Cost par eyewash dspenserl/ X $1.20
Total out year cost for eyewash dispensers
for hired handlers $5,464
Decontamination terns (cost per hired handler):
Tyvek coverall 1/ 0.75
Container far wash water 1/ 1.80
Soap 0.78
Towels 1.50
Labor 7.53
Total out year decontamination
costs per hired handter $12.41
Number of hired handlers X 618,170
Total out year dacontaminaton
costs for hired handlers $7,670,459
Grand total out year aye wash dispenser and decontamination costs for hired handters
(in 1991
$7,675,924 ddbrs)
Source: Appendix Tabte DC-8.
1/ Based on the assumption that eyewash dbponsers, covarals, and carboy water containers are replaced ovary 5 years.
-------
Appendix Table DC-9. Total first year incremental decontamination costs for hired handlers
Eyewash Dispensers:
Dispensars
Decontamination Items (cost per hired handler)
Tyvekcoveral
Container for wash water
Soap
Towels
Labor
Percant Attributable V
to State Regulations
2%
Percent Attributable V
to State Regulations
24%
22%
22%
22%
22%
CostAIW
Removing
State Regs
$26,775
Cost Attar
Removing Existing 2/
Stale Regs Voluntary Complance
2.85 35%
7.02 35%
0.61 35%
1.17 35%
532 35%
Total first year incremental
decontamination oosa per hired handler
Total number of hired handlers X
Total first year incremental
decontamination cost for hired hand en
Grand Wai first year incremental eye wash dispenser and deoontamhaiion costs tor hirad harder*
Total' Incremental
Cost of Eye Wash
Dispenser!
$26,775
Cost Removing
Voluntary
Compliance
1.85
4.56
0.40
0.76
3.84
$11.41
618,170
$7,055,591
$7,082,366
Source: Appendix Table DC-T.
M Appendix Table DC-6.
2/ EPA estimate.
Appendix Table DC-10. Total out year incremental decontamination costs for hired handlers
Eyewash Dispensers: Percant Attributable V
to Stata Regulations
Dispensers 2%
Decontamination Items (cost par hired handler):
Percant Attributable V
to SUM Refutation*
Tyyakcoveral 24%
Container for wash water ' 22%
Soap 22%
Towel* 22%
Labor 22%
Cost Attar
Removing
Stata Rags
$5,355
Cost Attar
Removing Existing »
State Rags Voluntary Comptanca
0.57 35%
1.40 35%
051 35%'
1.17 35%
532 35%
Total out year incremental
H . UIIMMI — «.!,, 1*4 ,. , , ! •!• i i ml 1 nin> |1 1 1 mi n I •!
oeoontarrinaBon costs par rvrao ha/oar
Tort rxjmbarol hired handler* X
Tort out year iiaemarrtal
uvcunui i imuun con nr nv«u nBranra
Grand Wai out year incremental eye wash disparts*- and decontaminaton cost* for hired hardan
Total Incremental
Cost of Eye Wash
Dispansers
$5,355.
Cost Removing
Voluntary
Compliance
037
031
0.40
0.78
334
$6.28
618.170
$3382396
$3388251
(in 1991 dotar*) *""' ^™ "™ "
SourcaAppsndo
1/AppsnoixTabl«DC-6.
2/EPAestimaM.
-------
•• faMra
Feed & Grain
Cotkxi
Tobacco
Other Field
Vegetable/Fruit
Nursery/Greenhouse
'. \- * Wtortf
* *- ftxtttar.
0.00
0.00
0.00
0.00
0.00
'So**
0.48
0.36
1.44
0.36
4.92
yT
-------
Appendix Table DC-12. Incremental first and out year decontamination costs for hired hand
Cotton
Tobaooo
OtorFMd
1.40
3.06
4.20
NufMiy/QrwnhouM
37.73
16.63
0.28
0.62
0.84
0.59
7.55
3.33
1.12
2.47
3.36
£37
30.16
13.30
(*)
•30%
30%
30%
30%
30%
30%
(t
0.78
1.73
2.35
1.66
21.13
9.31
256.0SS
71,494
23,873
161,722
279,077
54,907
0
7.149
11,220
14,555
192,563
27.454
a^Deoontani^^
256,065
64,345
12,653
147,167
85,514
27,454
($)
$200.755
$111,027
$29,759
$244,089
$1,827,798
$255,592
$2,669,021
(1).(6);App«t
-------
'Ill* IJI
' s Qitjp
^SeOtor
Feed & Grain
Cotton
Tobacco
Other Field
Vegetable/Fruit
Nursery/Greenhouse
Container
1.28
1.00
2.00
1.00
1.00
Soap2/
0.48
0.48
1.44
0.36
5.04
0.20 7.44
Total First Year Decontamination
*****
-($/hired work
0.92
0.92
2.76
0.69
9.66
14.26
Cost for Hired
Labor 41
art - -
3rj
1.11
0.87
5.20
0.65
9.10
2.62
Agricultural
TofetfCost
3.79
3.27
11.40
2.70
24.80
24.51
Workers (1991
Total Number5/
of Hired Workers
(Number)
256,065
71,494
23,873
161,722
279,077
54,907
dollars)
total First
($)
$971,296
$233,547
$272,152
$436,649
$6,921,110
$1,346,018
$10,180,772
Footnotes on following page.
-------
Footnotes from Appendix Table DC-13
1/Based on the following assumptions:
"Each worker require* on* gated of w«h water par work day In tho told. Although OSHA require* two gallons par worker
EPA estimates thai on* gallon is sufficient for hand washing purposes.
-Water containers cost $5 each (5 gaSbn colapsiWe with spigot, food approved). On establishments with greater than 5 employees
it is assumed that the carboy-type water container that was purchased for hired handlers (who are also working in the fields),
can be used in addition to the 5 gaton colapsibte container.
-Non* of th* workers in f**d & grain, cotton, tobacco, other field, and vegetable/lruit fields currently have running water available within 1/4 mil*.
-AM greenhouse (& greenhouse-it* nursery) workers have running water available, therefore they do not need a water container
(Greenhouses & greenhouse-Ike nurseries - 61% of nurserytyeenhouses, Source: 1987 Census of Agriculture).
-Half of the nursery workers have running water available (Nurseries - 39% of aU nursery/greenhouses) (EPA estimate).
Feed & grain calculation: $5.00 container/3.9 employees per establishment - $1.28 per worker.
Cotton calculation: $5.00 container/5 employees using the 5 gallon coflapsble container - $1.00 per worker.
Simiar logic for tobacco, other field, and vegetable/fruit crops.
Nursery/greenhouse calculation: ($5.00 per container/5.0 employees per establishment) X
(39% of nursery/greenhouses are nurseries X 60% of nurseries don't have running water immediately available).
21 Based on the folowing:
-Each worker requires 2 oz. of soap per work day. (EPA estimate).
-Th* number of days that workers spend in the field within 30 days of the expiration of an REI, per year, par crop sector (Table 111-6).
-Soap costs $0.96 for 32 oz. (EPA estimate).
Calculated, ((2 oz. soap X days in fieldy32 oz.) X $0.96.
3/Based on the fotowing:
-Each worker requires 16 towels per work day. (EPA estimate).
-The number of days that workers spend in the field within 30 days of the expiration of an REI, per year, per crop sector (Table III-6).
-Towels cost $0.69 per 96 towel red (EPA estimate).
Calculated, ((16 towels X days in f ietd)/96 towels) X $0.69.
41 Based on the need to rinse and refll wash water containers and the following:
-The workers' supervisor's wage rate - $6.50 par hour (Appendix Table TR-2).
-h takes 5 minutes per work day, to rinse and refi each container (EPA estimate).
-Th* number of days that workers spend in the field within 30 days of the expiration of an REI, per year, per crop sector (Table 111-6).
Calculated, ($6.50 per hour X (5 min/60 min) Xdays in fieldy Number of employees per establishment (up to 5)
Calculated for nursery/greenhouses, [($6.50 per hour X (5 min/60 min) X124 days in field)/5.0 workers per estab.] X 39% X 50%.
5/Table III-2.
-------
Appendix Table DC-14. Total out year decontamination costs for hired agricultural workers
^1(*$&^
Feed & Grain
Cotton
Tobacco
Other Field
Vegetable/Fruit
Nursery/Greenhouse
•' " • ''''S^'
0.26
0.20
0.40
0.20
0.20
s«*
0.48
0.48
1.44
0.36
5.04
S
, tiswets
0.92
0.92
2.76
0.69
9.66
1.11
0.87
5.20
0.65
9.10
0.04 7.44 1426 2.62
Total out year decontamination cost for agricultural workers (1 991
Totol€QSi
2.77
2.47
9.80
1.90
24.00
24.36
dollars)
of Hired Workera
(Number)
256,065
71,494
23,873
161,722
279,077
54,907
YsarC0st
($)
$708,560
$176,352
$233,955
$307,272
$6,697,848
$1,337,507
$9,461,494
Source: Appendix Table DC-13.
1/ Based on the assumption that water containers are replaced every 5 years.
-------
Appendix Table DC-15. Incremental first year decontamination costs for hired agricultural workers
; titan
FtwdlGrain
Coaon
Tobacco
OtwFWd
V«*«H«frurl
Nurury/QTNnhauM
$Q(iiCw*; :0o$t$ttwit
m » ...
($/twed worker)---
3.79 0.76 .
3.27 0.65
11.40 228
2.70 0.54
2430 458
24.51 420
~ i r~i *t »•«
. Incrtmantfl Href Yw LMKJUIUI
is? sss.
(%)
3.03 30%
2.61 30%
9.12 30%
2.16 30%
19.84 30%
18B1 30%
- SW*
(I)
2.12
133
6.38
1.51
13£Q
13.73
era (1991 dollars)
DrttotfWcrt** Oowpffd^OSHVR
K» , -Ci
(Number)
256,065 0
71,494 7,149
23.873 11 ,220
161,722 14,555
279,077 . 192,563
54,907 27,454
& Cc*e(«Jb»OSHA.FS$
256,065
64^45
12,653
147,167
' 86.514
27,454
"SST
(*)
$543,926
$117,708
$80,775
$222.517
$1^01,505
$376^85
$2,543^14
(2); F«d«d Ftagi«)«. VoL 52. No. 84. May 1.1987. Pao» 16082. OSHA oHtrti approrimelefy 20% of tie FSS decontarrtnafcn oostt tan voluniary oomplanca.
(3)!c«tetta»d.(1H2)-
(4);AppvidhTdU»DC-6.
(5); CricutaMd, (3H(3)X(4)].
fTI'C^cubMd (61-% covered by OSHA. FtderJFlioister Vol. 52,No. 84, May1.1987. Page 16073. OSHA esfimaies tial10%o( hired oDtlon workers, 47% ollobafXD,
9% o( o**r IWd crop, 70% rt v*Q*Mbto. vd 67% ol Kr«d h* wotan ar* oovared by *w FSS. EPA Mlinia«e$ti8l5u%olnursery/a/»«rihousa workers are also covered
byOSHA'iFSS.
-------
Appendix Table DC-16. Incremental out year decontamination costs for hired agricultural workers
f'f. t. f- < •> •••. • ^ ._ _,
"~ £^Wh. i- "" "UfrvttM^ ' >< .. i|^%» l^MW^^H^^
ftww ift. . ..... fift. ', M
($A)lr8d woritar)
FMdlGntn 2.77 0.55 2^2
Cotton 2.47 0.49 1S8
Totsaxo 9.80 1S8 734
OAwFMd • 1.80 038 1.52
V«QSttbJ*Fruit 24.00 4.80 1950
!^H.
30%
30%
30%
30%
30%
St&te
(*)
1.55
1J8
5.49
1.0S
13.44
Nurewy^nnhouM 24J8 4B7 19.49 30% 13.64
Incramantd Ow Yaw DgoormmiraUion Co«l br Hirad AgraAural Workers (1 991 do«ars)
j^ml»ff
-------
-------
Section 6
Emergency Assistance
-------
i fB3r tf&df^fenWSJlKSj
S*S9f
Feed & Grain
Cotton
Tobacco
Other ReM
Vegetable & Fruit
Nursery & Greenhouse
Commercial Handlers
Total
J**tt«.
13,746
2,711
3^92
6,060
10,389
2,429
1,002
$39,628
CMYMT
($)
13.746
2.711
3.292
6.060
10,389
2,429
1,002
$39,628
MM
3.385
688
811
1,492
2.559
598
247
$9,759
"f^ rf" Jy
-------
Appendix Table EA-2. Total and incremental first and out year emergency response costs for hired
handlers, commercial handlers, and hired workers
Hired Ag. Employee Poisonings 1/
Total Nred employee poisonings
Cost of respondng to each emergency
information request 21
= Cost of responding to all emergency
information requests
2. Total hired employee poisonings
Cost of transporting each employee to
medcal facility 3/
= Cost of transporting all employees
to medical facilities
Total first and out year emergency response costs (in 1991 dollars)
fftCRiMEHTA FIRST &OJT YEAR COSTS
1. Cost of respondng to aH emergency
information requests
Cost of transporting a8 employees
to medical facilities
Percent of transportation costs 4/
attributable to state regulations
and easting voluntary compliance
1,965
1,965
$1.17
$2,293
1,965
$19.00
$37,335
$39,628
$2,293
$2,293
$37,335
80%
Cost of transportation, removing state
regulations and voluntary compliance
ncremental first and out year emergency response costs
(in 1991 dollars)
$7,467
$9,759
1/ The number of physician-dagnosed poisonings for agricultural employees is 15,400. Hired agricultural handlers,
commercial handlers, and agricultural workers account for 63.8% of the total agricultural work force (hired + nonhired).
Therefore the number of physician-diagnosed poisionings among hired agricultural employees is 15,400 X 63.8 = 9,825.
However, there should be at least an 80% reduction in the number of poisoning after the Rute is in effect.
9,825 X .20 = 1,965 phystean-diagnosed poisonings for hired agricultural employees after the Rule becomes effective.
2/ Based on an employer wage rate of $7.00 per hour (U.S. Department of Labor) and the assumption that
it will take 10 minutes for the employer to respond to a telephone call for emergency information.
Calculated, $7 an hour X (10 minutes / 60 minutes).
3/ Based on an employer wage rate of $7.00 per hour, a 50 mite round trip to the medical facility which
will take one hour, and a vehicle depreciation rate of $0.24 per mile.
Calculated, ($7 an hour employer wage X 1 hour to transport employee to and from medcal facility) +
(50 mites X $0.24 per mite) = $19.00
4/ EPA estimate.
-------
Section 7
Rule Familiarization
-------
Worker Protection Standard Costs of Familiarization
When the Worker Protection Standard (WPS) becomes final, operators/managers of
agricultural establishments and commercial pesticide handling establishments covered by the
WPS must learn how to comply with the requirements of the WPS. The Agency is drafting a
"How To Comply" manual, including a 2-page summary chart. The' "How To Comply"
manual and summary chart will serve as a far more readable document than the rule itself.
EPA estimates that operators/managers on agricultural establishments with hired labor will
need about 2 hours to become familiar with the WPS provisions during the first year of
implementation and approximately 20 minutes per year thereafter. EPA also estimates that
operators/managers of agricultural establishments without hired labor and of commercial
pesticide handling establishments will need only about 1 hour in the first year to become
familiar with the WPS's provisions that pertain to them and approximately 10 minutes per
year thereafter.
The Agency based its estimate on the following assumptions:
1. Operators/managers of agricultural establishments with hired labor may need as much
as 2 hours to read the sections of the "How To Comply" manual about the basic WPS
requirements and the exceptions that may apply to their circumstances. The "How To
Comply" manual is designed to facilitate familiarization with the general provisions of
the WPS (through the 2-page summary chart) and provide ready access to applicable
exceptions. If a feed and grain farmer, for example, has no need to send workers into
a treated area before the expiration of the restricted-entry interval, that farmer need not
become familiar with the exceptions to restricted-entry intervals. If a
fruit/vegetable/nut farmer uses pesticides frequently while workers are present, that
fanner need not become familiar with the exceptions to notification and
decontamination facilities.
2. Operators/managers of establishments without hired labor or of commercial pesticide
handling establishments must comply with far fewer requirements and are not expected
to need more than 1 hour. The "How To Comply" manual is constructed with an
-------
index for owners of establishments without hired labor that directs them to the
provisions applicable,to them. The manual also separates the requirements for
pesticide handlers from those for agricultural workers, which allows
operators/managers of commercial pesticide handling establishments to read only the
applicable provisions.
3. As an option to becoming familiar with the content of the revised Standard on their
own, many operators/managers will receive information about the WPS in their annual
industry-, commodity-, or Cooperative Extension Service-sponsored meetings. EPA
has a -"ady been approached by many of these organizations for information and
assist- we in conducting such a program and is developing a "How To Comply" slid
set that will present an overview of the requirements of the WPS. As a result of sue,,
informational meetings, the operators/managers may be more efficient in reading the
"How To Comply" manual due to their increased understanding of the general content
of the revised Standard and the exceptions that would be most applicable to their
situation.
4. EPA also plans to help reduce the time necessary for operators/managers to become
familiar with the revised Standard by cooperating with certain industries and
commodity organizations to develop "How To Comply" manuals specific to those
industries and commodities. ;VPA has already held preliminary discussions about the
development of such manuals with the greenhouse, nursery, and forestry industries.
5. After the first year, operators/managers would need a short time each year to remind
themselves about the requirements in the WPS. However, this time is expected to be
small, because most of them will have been complying with the WPS throughout the
previous year and will be familiar with the requirements and exceptions in the WPS
that are most applicable to their situation.
6. Time estimates are based, in part, on the comparison of the WPS "How To Comply"
manual with the national core manual for pesticide applicator certification. Persons
-------
wishing to become certified applicators must be trained about the contents of the core
•t
manual, which is approximately 5 times longer than the WPS "How To Comply"
manual. The average length of training using the certification core manual is
approximately 8 hours for initial certification. For recertification (usually within 3-5
years), the certified applicator must usually attend "update courses" that last, on
average, about an hour each year.
-------
Appendix Table F-1. WPS compliance costs for Rule familarization in 1991 dollars, by sector
?***
Feed & Grain
Cotton
Tobacco
Other Field
Vegetable & Fruit
Nursery & Greenhouse
Commercial Handtere
Total
; \ [
_rr*,_
Jt^^WF^
3,034.675
254.450
759.500
3
737,975
949,263
350,875
85,000
$6.171,738
'-.. ' : ... JnCrtWJadfol Tto**Htot.^Ay!*^idd»Ji WBxXJtHkadLabOT.bUtUs^J^ftitfcldiMi
'' CS*Y«wr ;
505,779 .
42,408
126,583
122.996
158^11
58,479
14,167
$1,028,623
F««y«r
3,034,675
254.450
759,500
737.975
949,263
350.875
85,000
$6.171,738
OrtYoar
505,779
42.408
126,583
122,996
158,211
58,479
14,167
$1,028,623
£ta*Yi»f
---(*)
14,00 .
14.00
14.00
14.00
14.00
14.00
14.00
$14.00
OMlYwr
2.33
2.33
2.33
2.33
2.33
2.33
2.33
$Z33
RntfYflar
7.00
7.00
7.00
7.00
7.00
7.00
7.00
$7.00
OutYov
1.17 '
1.17
1.17
1.17
1.17
1.17
1.17
$1.17
SOURCE: Appondbc Tabta F-2.
-------
Appendix Table F-2. Costs associated with owrrer/opefators becoming familiar with the Worker Protection Standard
Crcp&oupType-ot
Esabfarmsni
FEED 4 GRAIN
With
Nred labor
Without
hired labor
COTTON
With
hired labor
Without
hired labor
TOBACCO
With
Nred labor
Without
hired labor
OTHER FIELD
Witfi
hired labor
•Without
hired labor
VEOFRUnVNUTS
Wrtfi
Nred labor
Without
hired labor
NURSERY/G.H. .
With
hired labor
Without
hirad labor
Commercial
xasfcsde
\aridhno,
Total
" Nun**r-pf$»BSpfa AW****-
r*quMtefla!« MfXtarr *>**&»*
Estetfabmerta Htf£»ttaiart farnStarwfttfluta-
jsingp«*ttaB**T/-" per esfi^stisn-,: "Kilty, "CUETr.
(Number} (Hours)-
132,705 1 2 0.33
168,115 1 1 0.17
15,670 1 2 033
5,010 1 1 0.17
50,500 1 2 033
7,500 1 1 0.17
34,065 1 2 033
37,255 1 1 0.17
57,513 1 2 0.33
20,563 1 1 0.17
18,625 1 . 2 033
12375 1 1 0.17
8,500 1 1 0.17
568336
Owntrtopwcr
**Q*nt*V
(*Hour)
7.00
7.00
7.00
7.00
7.00
7.00
7.00
7.00
7.00
7.00
7.00
7.00
10.00
T«*OW»
Htttsrr,
($)-
1.857370
1.176,805
5.034,675
219380
35,070
254,450
707,000
52,500
759,500
477,190
280,785
737375 .
805,182
144,081
948.253
280,750
90,125
350375
85,000
$8,171,738
fri * yd •
DKUW
%)«&
UW.tti
309.645
196.134
505,,rYS
36,563
5345
42,408
117333
8,750
128,583
79332
43,464
122388
134,197
24,014
156,211
43,458
15,021
58.479
14,167
$1,023323
ca«teb»cwn*
teniariKftRut*4/
i-rw It. OLA TT.
(tEsiab.)- - - -
14.00 2.33
7.00 1.17
14.00 2.33
7.00 1.17
14.00 2.33
7.00 1.17
14.00 233
7.00 1.17
14.00 2.33
7.00 1.17
14.00 2.33
7.00 1.17
10.00 1.67
SOURCES:
V RIA Table III-3.
2/ RIA Appendw Tabta TR-2.
3/ Numb* of Mtabiihm«nt» X number of peopte requiring Bute tsmlMzsftcn per estabishrnent X annual *TM necwsafy to become larriiar wtri RU«
X owner/operator wee* "*•
4; Total cost to beoome tamiier wWi RUe / number o( e»tab)i»hmenti.
-------
-------
APPENDIX B
Compliance Costs to Forestry
-------
-------
PS Cost Calculations for Forestry
HandJsn Water*
tlnutmc 282 2,538
tte 7.000 200
72822.736
HY««f OuY««f Con Fador
1. RESTRICTED-ENTRY INTERVAL
NctS&kmt
2. PBCONAL PROTECTIVE EQUIPMENT
Tort incremental iral yur PPE o»l tor hired «nd bmiy mambsr handten on lamtt . $17£ mJlfon/1.6mlionh»fed&taniilyhandiart.$11 perhareler
60,102 7^B2Nrtdl«ndminlar«il(X$11-tao,102
Tcxri ncrarrwnal ou y«r PPE oo«t» tor hirad and Imty nrarrbar handars on (arms - 89.4 rntton /1.6 rntton hired & lamiy banders . (S£8
42318 7^82 NradhmflM in fcrWiX»5JB8. (42318
3. NOTIFICATION
Tout ncrcmiMi trtf year cau tat rxnifaaBion per hired hand* or hsad «mrtw-$15Jndibn/1.SrnConrwsdiKiri(an&handtes»$10^perernploye
1(M>20Nr«ltandton&war1rjnJntarMMX$ia20.$102^04
Ton) incrcnrwnMl oU ytn oaM br noftfccion par hired handtar or rasd »ork«-
31,383 1O020rw»dt«xton A mtun in tarwkX $3.13- $31.363
Fofnty ooctt ooncniMd...
-------
Incremental Increment 4. TRAINING
FiratYMT OutYMT
......... (*). ...... --- Total txnwrolalirstyiitr COB* tor fcajn^hinrihanoV«^
Total hcramanlal irst year costs tor raining hired workers = $2.6 milioo/ 847. 138 Mredwoitefs^ $3.07 per hired woriwr on farms
7,282 hired bandars in forests X $6.93 - $50.464
68.870 2.738 hired worker* in forests X $3.07 -$8.408
Total incremental out year costs far training hired harriers » $ 1 ,285.175/618,170 NredhancisfS = $2.08 perhiredhandter on farms
Total incremented out year cart tor taring hired workers » $1 ,03a«08 / 847. 138 h«^mxkera = $1. 23 oer hired workw on farms
7,282 hired handtora in fcrato X $2.08 ~ $1 5, 147
18,515 2.738 hired wortan in tonubX $1.23 »$3.368
5. DECONTAMNATION
Incramantol fotyMr com* iordMontmratian par hired hendter on tanra«$11.03
IncnnMnM out y*w ooM W dHonlnirullan pw hind h«y*« on fesmw - Sfi.eo
Incramantal fnt yaw cos* lor daoonlmirwlion par hirad woikw on lams > $3.00
IncranwnMl out yaw cocto tor dMontominfllian pw hrad mnrtor an (amis > $2.66
,634 ToMincrwiwnbliratyMrc0sti.(11.03X7,2fi2) + (3.00X2.738). $88.534
60^20 TotriincranMnMoutyatfO(»tt.(5.MX7,282h (266X2,738). $50.220
6. EMERGENCY ASSISTANCE
Thora wara 0.825 hrad ampfoyea poiunings on fesms (Appandw Tabta EA-2)/ 1.503,308 hired employees on farms
- 0.6% poMJorwig tatt among hired amptoyae*.
Incramantf fnU and out y*ar amMgancy iMictinoa coot par potaionsng » $1 .1 7.
70 70 IncremanMbtfandoutyMrocMtforamHpanyaMtAanciabrhi^
7. FftJLEFAMMJAHZATON
FntyMrincremanM coat to torn* » $6.2mJBon; $6.2 M / 1 .194.000 tarn operatom»$5.17peroparatof
Out yw jnoamantal cost to ianrn - $1.0 mtfon; $1 .0 M / 91. 194,000 farm opmton- $0.86 par operator
Ratio of tarn opentkn to al ag. amptoyBea - 41 .7%
7,282 torstty hwdton X 41 .7% - 3.036 foretiry hsndtore lhat need ru5a tanviiarizsSon
15,000 tncn«Mnta)intyMrcosk>3.03SX$5.17. $18000
3,000 IncranMntoJ out yMrcoctt- 3.036 X $0.86 >= $3 ui<0
$346 780 $145 »86 TOTAL RRST AND OUT YEAR INCREMENTAL WPS COST TO FORESTRY
-------
APPENDIX C
High and Low Options
-------
-------
Total First Year Costs
High Option Low Option
(Mitton$) HIGH AND LOW OPTION CALCULATIONS
1. Restricted-Entry Interval
31.6 7.9 Total first and out year cost to vegetable crops (Appendix Tables HL-1 and HL-2).
422 105 Total irst and out year cost to fait crops (Appendbc Tables HL-1 and HL-2).
a. Costs due to earty entry on out flower and cut fern estabishments.
Under the high option, NO early entry is allowed on any agricultural establishment.
43.7 Appendix Table REI-12 calculates this cost ($43.7 msion) to the cut flower and fern industry.
Under the bw option, earty reentry on cut flower & fem estabishments is allowed with PPE.
Per worker cost of PPE - $57.85 (Append* Table REI-11).
There would be an estimated 3.179 earty entry cut fiawer workers (Appendix Table REI-11).
02 Low option cost-$57.85X3,179-$183.905
2. Personal Protective Equipment
HSGHOPTKDN:
The cost of work dofhing - $25 per hanger (shirt & parts. Old RIA).
$25 X 618,170 hired harriers - $15,454,250
$25 X 38,000 commercial handtere - $950,000
No cost for family member handlers (already have work clothing)
Current total first year PPE costs to hired handters. commercial handlers
and unpaid family-member handlers = $84.9 mi»on
101.4 $84.9 M + $15.5 M + $1M- $101.4 rraBon total
LOW OPTION:
2.2 From old RIA $2.2 rrilion
High & Low Options continued...
-------
Total FtatYwCorti 3. Decontarninaton HIGH 4 LOW Options •
Kgh Option Low Option
.---(MH8on$)---- HIGHOPTION:
Eyewash disps for al handlers:
$6 X 618,170 hired handlers - $3,709.020
(6 X 38,000 commercial harriers - $228.000
$22.3 Milan for decontamination k«ms provided for total days of work-hired handlers
$iaB mUton decontamination tor commercial handler* (same a» final rule)
$31 per farm tor emergency change 4 eyef lush dispenser X 309,085 farms - $9,581.635
$31 par oommflfriai handling eetabishment for emergency change & eyeflush dispenser X 8,500 estab-$263,500
$113 per farm for body drench hose X 309,085 farms - $34,926.605
$113 per oomm. hdlr astab for body drench hose X 8.500 farms - $960,500
86.0 Total Wgh option cost-$86 mBbn
LOW OPTION:
Final rule cost for oomm. hdtrs - $894.789
Final rule cost for hired hdrs - $13,534,336
14.4 Total low option cost- $14.4 mifcn
4. Notification
HIGHOFHON
240 $24 rrufcon-- Based on treated area posting, oral warnings, and central notice
for al pesticide applications, in addition to daily oral wamigs.
LOWOPTION
$82 milbn - - Based on treated area posting and oral warnings for pesticides with greater than 48 hr REIs.
Oral warnings or treated area posting for al other applications for a« other applications.
8.2 Posted* specific information avaiable on request
High & Low Options continued...
-------
Total Rret Year Costs 5. Training
High Option LowOption
(MSonS) HIGHOPTON
Workers gMhandtef level iajntng = $8.90 per worker X 847,138 workers * $8.4 million
Hired Handera o» Tox I's get trained & certifed: 326.000 banders X (12.80 for frainmg + 7.00 more for certil.
(1hourlotateairtiicJU!ontes»)} = $20. $20 X 326,000 - $6,520,000
Al ofer hanoters gi* kanad: 292,000 X $1 a90 . $3.8 rntton
9,500 comm hotea need csrtif: 9.500 X ($7 cart oost + $17.40 training cost) + (28.500 X $17.40 trainina. cost) = $727.700
19.4 Toy high opfaooort- $19.4 m«on
LOWOP1K1N
Hvtden: $5 m*on fer tnaning hired hancfiers + $0.7 mifeai for oommarciBl handars = $5.7 M
5.7 Nowntarlnining
6. EmarQancy Aawe&nce
HGHOPTION
MSOS tor ^ »wrkare: .05 pur copy X 847,138 workers » $42.357
+ fend wtooMt- $39.628
0.08 Total fieJioortf. $81,885
LOWOPTIGN
0 Noting
7. ChoinattaraM Moratoring
HtGH OPTION
9^ $250 pwoonvnercialhanoterX 38,000 commerctal handtars- $9.5 rraScn
LOW OPTION
0.
HIGH OPTION * LOW OPTION
62 62
J364! |K5 TOTAL HIGH AND LOW COSTS
-------
Artichokes
CauHower
Snap Beans
Tomatoes
Cucumbers
Melons
Squash
WWjWr *• •-
ftflftfti^iEft flfclA-1^
10244
60,526
34.564
128,029
110.547
242,813
20,021
aseAor^ie
r«wtedwfe{i
100%
100%
100%
100%
100%
100%
100%
Av$$0*pe
Ao^impaaf*
c^Jybssj
1.0%
1.0%
1.0%
1.0%
3.0%
3.0%
7.0%
VaJua
(?/Acre)
3212
2,734
1,578
7,428
1,714
1,353
2.902
P0T Afire
income.
Loss
(i/Acre)
32.12
27.34
15.78
7428
51.43
40.58
203.16
«•!
329.081
1,654,655
545.515
9.510,431
5.685,309
9,853,923
4,067,412
$31.646,326
Note: Assumes there are no price effects.
Source: Appendix Tabtes REi-1 to REJ-12 and the assumption that yietd loss with 72-hour REIs
would be double the yield toss of 48-hour REb.
-------
Appendix Table HL-2. Total first year restricted-entry interval (REI) costs to vegetable crops UNDER LOW OPTION
torn*
LOSS
Income
loss
Artichokes
Cauliflower
Snap Beans
Tomatoes
Cucumbers
Melons
Squash
10,244
60,526
34,564
128,029
110,547
242,813
20,021
100%
100%
100%
100%
100%
100%
100%
0.3%
0.3%
0.3%
0.3%
0.8%
0.8%
1.8%
($/Acre)
3,212
2,734
1,578
7,428
1,714
1,353
2,902
($/Acre)
8.03
6.83
3.95
18.57
12.86
10.15
50.79
($)
82,270
413,664
136,379
2,377,608
1,421,327
2,463,481
1,016,853
$7,911,582
Note: Assumes there are no price effects.
Source: Appendix Tables REI-1 to REI-12 and the assumption that yield loss with 24-hour REIs
would be half the yield loss of 48-hour REIs.
-------
Appends TabteHL-3^
income
income
los*
Blackberries
Cherries (Sweet)
Peaches
Plums
Raspberries
Strawberries
4,061
44.801
171.063
38.573
9,016
42,682
100%
100%
100%
100%
100%
100%
1.0%
1.0%
1.0%
1.0%
1.0%
7.0%
2,495
2,753
1,998
2,659
2,586
12.106
($/Acre)
24.95
27.53
19.98
26.59
25.86
847.42
($)
101,316
1,233,358
3,417.839
1.025.643
233,153
36,169,813
542,181.123
Note: Assumes there are no price effects.
Source: Appendix Tables REM to RB-12 and the assumption that yield loss with 72-hour REls
would be double the yield toss d 48-hour REIs.
Veg& Fruit Total
$73.827.449
-------
Appendix Table HL-4. Total first year restricted-entry
'•jr * ' !'
': J8& •
Blackberries
Cherries (Sweet)
Peaches
Plums
Raspberries
Strawberries
,;£§^:
il!
4,061
44,801
171,063
38,573
9,016
42,682
Pwowtfaf
; ,!*!*&?
100%
100%
100%
100%
100%
100%
interval (REI) costs to fruit crops UNDER LOW OPTION
>' Ayeraaejttr" *
Aae Impact from
{% yield/ (
0.3%
0.3%
0.3%
0.3%
0.3%
1.8%
f*er Acre
**W(*V^^9# W*T*f
2,495
2,753
1,998
2,659
2,586
12,106
tricqma
" Loss
($/Acre)
6.24
6.88
5.00
6.65
6.47
211.86
Aggregate
Income
Loss
($)
25,329
308,340
854,460
256,411
58.288
9,042,453
$10,545,281
Note: Assumes there are no price effects.
Source: Appendix Tables REI-1 to REI-12 and the assumption that yield loss with 24-hour REIs
would be half the yield loss of 48-hour REIs. LOW
Veg& Fruit $18f456,862
-------
-------
APPENDIX D
Small Entities Cost Data
-------
-------
HESTRCTEO ENTRY
ft W/hnd0V
FEEDtORAN
OOTTOH
TOBACCO
OTVERRELD
VEaFRurwt/r 20,711 i8,4«8
HURSIGRNH9 436 3(3
CraUAPP.
Told 21.14* 18,861
FEEOkORAN
COTTON
TOBACCO
CHER REID
vEOFHurr#*/r 20.711 i9,4a*
NURSX3RNHS 436 3(3
COUU.APP.
Tetri 21.14* 18J61
TRAMMQ DECONTAMNATCN PERS. PROTECT. EOUP. NOTFCATON
Whrrt H HftMUffPlW H */ti^K'$^imtt.^.ti&,%°&^,ft .-WirrtS-w;
437
773
888
1,243 1.863
62 428
81
1286 8,844
(88
163
238
340
1243 682
62 146
66
1286 2,3(0
2,826
437
773
8*8
1.863
42*
«t
6,944
(88
163
238
340
682
146
66
Z380
3,786
688
1288
1248
4,347
1.068
421
0 12.71*
2287
387
734
(28
3.714
(84
388
0 9,171
3,786
6M
1288
124*
4,347
1,0GB
421
12,716
2287
387
734
828
3,714
884
9,171
8.488 6.364
(14
2.538
1,702
3244
1,056
1.576
700
2.368
1226
£726
7»4
1.676
JSIS.tl.UM
3,144 3281 3281
114
178
477
519
286
0
0 18,429 14,733 4.698 1
INCREMENTAL OUT YEAR COSTS. $1 .000)
4.446 2,800 1,646
441
1,383
828
1.732
686
1 082
0 10.677
379
1288
889
1.466
424
1 082
8.086
82
97
290
277
141
0
2,482'
872
1288
3.768
3.898
2,680
0
5,575
1,007
236
311
844
1264
1274
0
4,828
872
1289
3,758
3.888
2,680
0
15,675
1.007
236
311
844
1264
1274
0
4.928
EMERGENCY ASSETANCE FAMLlAflEATCN
3
1
1
1
3
1
0
0 10
3
1
1
1
3
1
0
0 10
3
1
1
1
3
1
0
10
3
1
1
1
3
1
0
10
3,035
254
760
738
948
361
85
0 6,172
606
42
127
123
158
58
14
0 1.028
1.858
219
707
477
805
261
85
4.412
310
37
118.
80
134
43
14
736
TOTAL
/Ohired Al }
1177 21.227
36 2.788
53 6.628
281 8,414
144 34,806
90 6,011
2143
1.780 81.992
198 9.094
6 1.270
9 2.795
43 3.088
24 28.164
15 3.342
1.617
293 49238
16.906 4,321
2.617 148
8.385 231
7,677 738
32.808 1.906
5,804 407
£143 0
74241 7,751
7.264- 1.841
1203 68
2,688 106
2.763 303
26,610 1.544
3,133 203
1.517 0
45.189 4.070
ft BMd «i pmrt d *am fram TcUc B-1.
H Cdajt+4. Pmrt fam M*I My btoor «* p
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