4 Pesticide Storage Violations 2009 – 38 out of 394 pesticide related violationsout of 479 pesticide related violationsout of 352 pesticide related violationsout of 275 pesticide related violations2005 – 23 out of 272 pesticide related violationsFrom 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 JurisdictionA universal seal of approval is not availableResources not readily accessibleThe belief that a good storage facility will cost lots of moneyDifficulties finding solutionsFear of calling attention to their facilityDon’t know who to askBecause 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 MarshalOregon Department of Environmental QualityOregon Department of AgricultureOregon OSHALocal Building CodesUS Environmental Protection AgencyUS Department of Homeland Security
7 Multiple Agency Jurisdiction Fire Marshal- Fire – exposures to responders, neighborsDEQ- Spills on land, into water, up in smokeODFW & US Fish & WildlifeODA- Use not consistent with the labelOregon OSHA- employee exposuresBuilding codes- tied to fire codesUS EPA – following labelUS Homeland Security – not abetting terroristsEach agency has different areas of expertise.
8 Financial Costs & Pesticide Storage Crop loss from inadvertent contamination in storageLoss of pesticides due to fireEnvironmental cleanup costs > $1000/hourLoss of pesticides due to theftLiability to neighborsEquipment & structure lossInsurance costsWhen 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 categoryFor 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 MSDSGranted 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, degradeUse exhaust fans to reduce temperature, remove dust and vapor to the outsideKeep storage area cool well-ventilated, and dryAzinphos-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 candlesFor reading labeling, spotting leaks, and cleaning up spillsUse 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 PesticidesDo NOT store with pesticidesThis requirement is found in the Worker Protection Standard in Division 4, or in Subdivision I under Personal Protective Equipment.
19 DecontaminationIf pesticides are mixed adjacent to the pesticide storage area:SoapWaterPaper towelsChange of coveralls15 minute emergency eyewash when mixing Danger or Danger Poison pesticides.WPS and First Aid requirments
20 Emergency Eyewash AT MIX SITE ACCEPTABLEACCEPTABLE / PORTABLEIf the label carries the signal word “Danger” it means the product is CORROSIVE and will produce IRREVERSIBLE EYE damage.WHEN?? LABEL SAYS:DANGERDANGER POISONNOT ACCEPTABLEAT THE MIX SITE
21 OR-OSHA Pesticide Requirements General Use - Notes Electrical wiring must comply with Division 4/SWhen dispensing a flammable or combustible liquid must comply with Division 4/HChemical 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 REQUIREMENTSStore 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 REQUIREMENTSSeal 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 orspill could cause material to leave the confines of the building, theremust be methods or means to containthe material.
26 SPILLS: Prepare in Advance – Spills in Storage are Concentrates! TRAINPRACTICELIMITSECONOMICIMPACTCleanup of some chemical spills may fall under Division 4/H (Haz Waste Op & Emergency Response)
27 SpillsContainers 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 SpillsPPE 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 EcologyThe 3 C’sControl - Contain - Clean up
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 individualsThis is from the event on the previous page.
34 Site SecurityIs 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.
36 After a Fire Contact the Pesticide Manufacturer For Assistance! Not all Haz MatContractors 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.
38 RESOURCES*Designing Pesticide Storage buildings: see the order form in your handout.Fire Codes: State Fire MarshalProtecting groundwater: DEQ, Soil & Water Conservation DistrictsEmployee 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