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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
18-P-0080
February 15, 2018
Why We Did This Review
We conducted this evaluation to
determine the adequacy of the
U.S. Environmental Protection
Agency's (EPA's) management
controls for implementing the
revised Federal Insecticide,
Fungicide, and Rodenticide Act
Agricultural Worker Protection
Standard (WPS) requirements.
We focused on training
resources, educational materials
and outreach efforts. We also
looked at how the agency plans
to collect and utilize WPS
compliance and enforcement
information to track pesticide
exposures among target
populations.
The WPS is intended to reduce
pesticide exposure incidents
among agricultural farmworkers
and pesticide handlers who use
and have contact with
pesticides. The EPA established
the WPS in 1974, expanded it in
1992, and revised the standard
in late 2015. Compliance with
most of the 2015 revisions was
required on January 2, 2017;
and the final three revisions on
January 2, 2018.
This report addresses the
following:
•	Ensuring the safety of
chemicals.
•	Compliance with the law.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
Listing of OIG reports.
EPA Needs to Evaluate the Impact of the
Revised Agricultural Worker Protection
Standard on Pesticide Exposure Incidents
What We Found
The EPA had policies and procedures in
place to implement the revised Agricultural
WPS. Further, the agency provided training
to regional staff, state inspectors and
program leads. However, we found that
management controls to implement the
revised WPS were not fully adequate as of
January 2, 2017, when compliance with
most of the revised rule was required.
Over 2 million agricultural
workers and pesticide handlers
are protected by the WPS.
Revisions to the standard are
intended to reduce exposure to
pesticides and provide
enhanced protection to
agricultural workers, pesticide
handlers and their families.
Essential training and implementation materials were not available by January 2,
2017. In addition, two key documents—the WPS Inspection Manual and the
How to Comply manual—were not available when the EPA conducted the
majority of its training and outreach activities for states and tribes in 2016. As a
result, many state officials said they did not have the time, tools or resources to
successfully implement the revised WPS by the January 2, 2017, compliance
date. EPA granted a state agricultural association's petition to delay the
compliance date until the necessary training resources and educational
materials were made available to state agencies responsible for implementing
the WPS. However, in a December 21, 2017, Federal Register notice, the EPA
rescinded its plan to delay compliance dates. The agency announced that
compliance dates in the revised WPS published on November 2, 2015, remain in
effect and that the agency does not intend to extend them. The EPA also
announced plans to revise certain WPS requirements.
The EPA does not have the ability to collect agricultural pesticide exposure
incident data to measure the impact of the revised WPS rule among target
populations. The agency relies on information assessed during pesticide
re-evaluations and from voluntary reporting databases. The EPA is working on
improving its Incident Data System, but the agency stated that the improvements
will not enable the collection of additional occupational exposure data.
Recommendation and Planned Agency Corrective Actions
We initially recommended that the EPA establish new compliance dates for the
revised WPS. However, based on the EPA's December 2017 decision to revert
back to the original compliance dates, we rescinded the recommendation. We
still recommend that the agency develop a methodology to evaluate the impact
of the revised standard on pesticide exposure incidents among the WPS target
populations. The agency disagreed with this recommendation, and resolution
efforts are in progress.

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