1. Pesticide Inspectors’ Forum Oregon OSHA Pesticide Storage
Garnet R Cooke

2. Unfortunately, all pesticide storage areas don’t look like this:

3. Some look like this:
Then stay tuned.

4. Pesticide Storage Violations
2009 – 38 out of 394 pesticide related violations
out of 479 pesticide related violations
out of 352 pesticide related violations
out of 275 pesticide related violations
2005 – 23 out of 272 pesticide related violations
From Oregon OSHA’s pesticide emphasis programs’ annual reports.
Oregon OSHA has had a Pesticide Emphasis Program in operation since The annual reports are posted on our web-site to assist growers in complaince.

5. Understanding Pesticide Storage Requirements – Why is it so hard?
Multiple Agency Jurisdiction
A universal seal of approval is not available
Resources not readily accessible
The belief that a good storage facility will cost lots of money
Difficulties finding solutions
Fear of calling attention to their facility
Don’t know who to ask
Because multiple agencies have a piece of the pesticide storage pie, producing a document with each agencies requirements in place has not been done. It’s an area that has been overlooked.
The belief that a good storage facility will cost lots of money is true: However experiencing an ‘event’ of crop loss, spill, employee(s) injury, or fire would greatly exceed the original bill.

6. Multiple Agency Jurisdiction
Oregon State Fire Marshal
Oregon Department of Environmental Quality
Oregon Department of Agriculture
Oregon OSHA
Local Building Codes
US Environmental Protection Agency
US Department of Homeland Security

7. Multiple Agency Jurisdiction
Fire Marshal- Fire – exposures to responders, neighbors
DEQ- Spills on land, into water, up in smoke
ODFW & US Fish & Wildlife
ODA- Use not consistent with the label
Oregon OSHA- employee exposures
Building codes- tied to fire codes
US EPA – following label
US Homeland Security – not abetting terrorists
Each agency has different areas of expertise.

8. Financial Costs & Pesticide Storage
Crop loss from inadvertent contamination in storage
Loss of pesticides due to fire
Environmental cleanup costs > $1000/hour
Loss of pesticides due to theft
Liability to neighbors
Equipment & structure loss
Insurance costs
When considering the cost of a new pesticide storage area, compare those costs with these. Be sure to check with your insurance carrier to see whether environmental cleanup costs are included in your policy, and whether or not your insurance policy will pay out if the fire department does not put water on the fire.

9. Pesticide Storage : First Steps
Growers need to conduct an inventory of the pesticides they have.
OR-OSHA has different regulations for general use pesticides and restricted use pesticides.
General Use: OAR (1-5)
Restricted Use: OAR (1-9)
If restricted use products are present the rule applies to all pesticides in storage ( (1-9).
Oregon OSHA looks for HAZARDS.
All things pertaining to pesticide storage my not all be found in Subdivision N……A compliance officer will look first for the hazard and then find an appropriate rule. Learning to ask yourself “what’s the hazard?” will assist you in correcting hazardous conditions.

10. OR-OSHA Pesticide Requirements General Use
-Hazardous chemicals must be stored separately if they could cause hazardous reactions. Label by category
For example, Lime Sulfur reacts with acids (including the phosphoric acid in NPK fertilizer) to produce deadly hydrogen sulfide gas. The pesticide label carries the warning, “Do not mix with acid or deadly hydrogen sulfide gas will result.” Do you know which products are acids in YOUR storage area??
A near fatal accident in So. Oregon prompted BSP to make these stickers.

11. Store Pesticides in Accordance with:
Label, packaging, or MSDS
Granted this is a Restricted Use Product, but the Applicator’s Manual, an extension of the label, requires these signs to be posted.
Signage required for aluminum phosphide

12. Follow the Label DO NOT STORE WITH FOOD
While OR-OSHA’s rules do not require the employer to provide a break room, when one is provided there cannot be toxic substances in the area.

13. Follow the Label Do NOT store within 100 feet of a well
The desire to keep products from freezing may incline folks to put pesticides in the well house, but find another way to accomplish that goal. Check the label for additional restrictions for groundwater protection.

14. Following the Label Is hard to do when there Isn’t one.
If a label is starting to degrade, copy and attach with a zip tie.
Secondary containers must be labeled with the name of the product and the signal word.

15. Control the Conditions
Excessive freezing or heat may cause containers to break, melt, explode, and some pesticides to volatilize, drift, degrade
Use exhaust fans to reduce temperature, remove dust and vapor to the outside
Keep storage area cool well-ventilated, and dry
Azinphos-methyl at a repackaging operation was received, stacked near a steam pipe, over heated producting yellow smoke. The plant was evacuated, and while the fire chief questioned the plant owner about whether an explosion hazard existed; the material exploded killing 3 firefighters and injuring a fourth.

16. Provide Adequate Lighting
Lighting equal to 20 foot candles
For reading labeling, spotting leaks, and cleaning up spills
Use spark-proof fixtures and switches!
Applies to general use and restricted use pesticides

17. OR-OSHA Pesticide Requirements General Use, cont.
Storage and removal of hazardous chemicals must not cause hazards to workers.

18. Personal Protective Equipment
Store PPE away from Pesticides
Do NOT store with pesticides
This requirement is found in the Worker Protection Standard in Division 4, or in Subdivision I under Personal Protective Equipment.

19. Decontamination
If pesticides are mixed adjacent to the pesticide storage area:
Soap
Water
Paper towels
Change of coveralls
15 minute emergency eyewash when mixing Danger or Danger Poison pesticides.
WPS and First Aid requirments

20. Emergency Eyewash AT MIX SITE
ACCEPTABLE
ACCEPTABLE / PORTABLE
If the label carries the signal word “Danger” it means the product is CORROSIVE and will produce IRREVERSIBLE EYE damage.
WHEN?? LABEL SAYS:
DANGER
DANGER POISON
NOT ACCEPTABLE
AT THE MIX SITE

21. OR-OSHA Pesticide Requirements General Use - Notes
Electrical wiring must comply with Division 4/S
When dispensing a flammable or combustible liquid must comply with Division 4/H
Chemical storage must comply with appropriate state and local fire codes, NFPA 34 & Division 4/H

22. OR-OSHA Pesticide Requirements Restricted Use Pesticides
Lock the storage area to prevent access by unauthorized employees.

23. RESTRICTED USE PESTICIDE REQUIREMENTS
Fungicide, Insecticide, herbicide Captec 4L (the first one) is an example of Danger- that is corrosive & will cause irreversible eye damage, so, is an eyewash required when mixing??
RESTRICTED USE PESTICIDE REQUIREMENTS
Store by category, not by the alphabet!

24. RESTRICTED USE REQUIREMENTS
Restricted use pesticides were inside the Vanguard box. When the wood is contaminated it will most likely fall in the hazardous waste category.
RESTRICTED USE REQUIREMENTS
Seal floors and shelves to prevent the absorbtion of hazardous chemicals

25. Pesticide Storage Regulations Restricted Use
When the storage area contains enough chemicals that a leak or
spill could cause material to leave the confines of the building, there
must be methods or means to contain
the material.

26. SPILLS: Prepare in Advance – Spills in Storage are Concentrates!
TRAIN
PRACTICE
LIMITS
ECONOMIC
IMPACT
Cleanup of some chemical spills may fall under Division 4/H (Haz Waste Op & Emergency Response)

27. Spills
Containers can be damaged in transit and can leak, dissolve or be ripped.
Receivers should be aware of these problems.
Is there a plan for addressing these issues?

28. Control - Contain - Clean up
Pesticide Spills
PPE requirements vary depending on the type of spill.
Growers need to know their limit: when is the spill too big to clean up safely.
Do they have an outside contractor for cleanup?
WA Ecology
The 3 C’s
Control - Contain - Clean up

29. Good Stewardship?

30. Confine Empty Containers
Encourage this:
Confine Empty Containers

31. When your travels reveal……

32. Find an Event Near Them

33. Find an Event Clackamas event: 18,351 pounds from 51 individuals
Pesticides with the following ingredients will be accepted at no charge*
Chlorpyrifos (Dursban, Lorsban) 2, 4, 5-Trichlorphenol (Silvex, Fenoprop) Dicofol (Kelthane) Dinoseb (Dinitro, Premerge) Dyfonate (Fonofos) Bendiocarb (Ficam, Dycarb, Seedox) Azinphos methyl (Guthion) Chlorfenvinphos Carbofuran (Furadan) DDT Aldrin (Aldrex) Dieldrin (Dieldrite) Endosulfan (Thiodan, Thionex) Endrin (Endrix) Heptachlor (Chlorodane) Hexachlorobenzene Lead Arsenate (Gypsine, Security) Lindane (hexachlorocyclohexane, gamma-BHC) (Agrocide, Benexane) Mercury-based pesticides (e.g. mercurous chloride, mercuric chloride) Methoxychlor (Marlate, Chemform, Double-M) Mirex Phosphamdion (Dimecron) Toxaphene *The first 200 pounds of other pesticides will also be accepted at no charge. Additional quantities of other pesticides are accepted at $1.10 per pound.
Clackamas event: 18,351 pounds from 51 individuals
This is from the event on the previous page.

34. Site Security
Is important if the location of the pesticide storage area is vulnerable to theft.
Encourage inventory awareness to report theft immediately of DANGER/POISON products.
Encourage pesticide storage areas to be in a secure location, report suspicious activity.
Keep the storage area locked.
Inform growers that they don’t want a product from their farm to be implicated in someone’s death.

35. Plan ahead:
WA Ecology

36. After a Fire Contact the Pesticide Manufacturer For Assistance!
Not all Haz Mat
Contractors are familiar with pesticides!
After a grain elevator fire that engulfed the pesticides stored for sale, the clean up contractor was instructed by the company to salvage what they could. Approximately 37 aluminum phosphide containers were placed inside an unlabeled 55 gallon drum and was stored unsecured between a neighborhood and the high school tract. Over a year later an employee was instructed to check to see if the product was still usable. The employee lifted the lid slightly, saw a silver fog, shut the lid and was tigfhtening the bung nut when a spark was generated. The drum exploded, the lid hitting the employee in the head resulting in serious injuries.

37. Resources:

38. RESOURCES*
Designing Pesticide Storage buildings: see the order form in your handout.
Fire Codes: State Fire Marshal
Protecting groundwater: DEQ, Soil & Water Conservation Districts
Employee safety & Health: Oregon OSHA –call for a FREE consultation!
Old chemicals:
ODA, DEQ, Soil & Water Conservation Districts

39. Photo Credits Garnet Cooke, Pesticide Coordinator, OR-OSHA
National Pesticide Applicator Core Manual, Washington State University Extension: Chapter 8.
Virginia Tech Pesticide Program