Pesticide Inspectors’ Forum Oregon OSHA Pesticide Storage Garnet R Cooke

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

Some look like this: Then stay tuned.

Pesticide Storage Violations 2009 – 38 out of 394 pesticide related violations 2008 - 58 out of 479 pesticide related violations 2007 - 23 out of 352 pesticide related violations 2006 - 22 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 2000. The annual reports are posted on our web-site to assist growers in complaince.

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.

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

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.

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.

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 437-004-1680 (1-5) Restricted Use: OAR 437-004-1680 (1-9) If restricted use products are present the rule applies to all pesticides in storage (437-004-1680(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.

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.

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

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.

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.

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.

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.

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

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

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.

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

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

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

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

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!

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

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.

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)

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?

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

Good Stewardship?

Confine Empty Containers Encourage this: Confine Empty Containers

When your travels reveal……

Find an Event Near Them

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.

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.

Plan ahead: WA Ecology

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.

Resources:

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

Photo Credits Garnet Cooke, Pesticide Coordinator, OR-OSHA National Pesticide Applicator Core Manual, Washington State University Extension: Chapter 8. Virginia Tech Pesticide Program http://www.pesticidepics.org/main.php