Worker Protection Standard EPA’s requirements for workers and handlers of pesticides

Worker Protection Standard Regulations issued by the EPA Took effect January 1995 Included specific language to require protection of workers and handlers of pesticides Added duties to the w&h jobs Required new signing & w&h notification

Worker Protection Standard Not all forestry applications are affected by this Standard, but compliance with the standard is mandatory where the Standard applies

Worker Protection Standard The WPS applies only to those personnel applying pesticides as part of the processes of commodity production

Worker Protection Standard It applies only to workers and handlers of pesticides Does not apply to visitors or other persons not involved in commodity production

Worker Protection Standard “Handlers” are personnel whose jobs require that they mix, load, or apply pesticides “Workers” are defined as persons whose job requires that they work in a treated area prior to the expiration of the REI or during the 30 day period subsequent to a treatment

Worker Protection Standard Applies to: Herbicide release of seedlings for fiber production Agricultural applications performed under special use permit Greenhouse or nursery operations

Worker Protection Standard Does NOT Apply to: Improvement of wildlife habitat Treatments for “general forest protection” (such as a Bacillus thuringiensis application to combat gypsy moth) Pasture or range improvement or right-of-way maintenance Research activities

Worker Protection Standard There are two basic parts to the Standard: Information required to be included on labels issued by the manufacturer Required personnel protective equipment (PPE) for workers and handlers who must enter the treated area prior to the expiration of the REI

Worker Protection Standard Label requirements The regulations require that all pesticides have at least a 12 4 hour REI (restricted entry interval) required by the label The REI is an interval of worker and handler exclusion unless specific protective equipment is worn Labels must specify special PPE for entry into treated areas in less than the REI

Worker Protection Standard Label Requirements By requiring that this information be included on the label –Failure to comply with the WPS requirements has been made a violation of FIFRA Which in turn enables the assessing of severe penalties for that failure

Worker Protection Standard Employer responsibilities WPS requires several things of the employers of handlers and workers

Worker Protection Standard Employer Responsibilities Pesticide information must be provided at a central location including –an appropriate EPA WPS safety warning poster – the name, address, and telephone number of the nearest medical facility –specific information about the location, pesticide(s) applied, and timing of each application completed more recently than the REI plus 30 days Information must be current and legible, and both handlers and workers must be told where to find it

Worker Protection Standard Employer Responsibilities For the purpose of F.S. applications the central location should be a bulletin board in the district office or the work center – or both

Worker Protection Standard Employer Responsibilities Pesticide safety training must be provided to all handlers Training must follow certain specifications Training must be renewed at least every five years

Worker Protection Standard Employer Responsibilities A decontamination site must be provided within ¼ mile of where the handlers are working At the site, the employer must provide soap, wash water, and towels for personnel clean- up; clean coveralls to replace work clothes in the event of accidental contamination And drinking water (separate container from the wash water)

Worker Protection Standard Employer Responsibilities At least one pint of eyeflush water must be available for the handler at the actual work site (The decontamination site may be the crew vehicle, but the eyewash water must be with the crew)

Worker Protection Standard Employer Responsibilities The easiest way to fulfill the eyewash requirement for Force Account crews is to provide each handler with a belt mounted eyewash bottle holster and an eyewash bottle containing at least one pint of water and have additional water on the crew vehicle or at a site within ¼ mile of the work site

Worker Protection Standard Employer Responsibilities In the event that a handler is injured or poisoned by a pesticide Transportation to an appropriate medical facility must be made available immediately Label and MSDS, and the nature of the injury or exposure, must be provided to the attending physician

Worker Protection Standard Employer Responsibilities Employer must insure that pesticide is applied only in such a way that it does not contact, either directly or via drift, any worker or handler not equipped with appropriate PPE

Worker Protection Standard Employer Responsibilities Before beginning a pesticide application, handlers must be given specific, clear, and understandable instructions on how the pesticide is to be applied operation of application equipment applicator safety requirements the REI applicable to the project area

Worker Protection Standard Employer Responsibilities Application areas must either be posted with specified warning signs, or workers and handlers must be orally warned of entry restrictions In most forestry applications oral warnings will be adequate In areas where worker entry is likely, EPA warning signs may need to be posted Some labels will require BOTH signs and oral warnings

Worker Protection Standard Employer Responsibilities In Region 8, ALL areas treated with pesticide will be posted Signing must be adequate to remain in place for at least 30 days from the expiration of the REI

Worker Protection Standard Employer Responsibilities Application equipment must be inspected and repaired as needed before each use If equipment contains pesticides or residues, only trained handlers may clean, adjust, or repair it

Worker Protection Standard Employer Responsibilities PPE specified on the label must be provided to handlers (by the contractor for all members of a contract crew; or by the F.S. for Force Account work crews) Steps must be taken to avoid heat injury resulting from PPE use

Worker Protection Standard Employer Responsibilities A pesticide-free area for storage of PPE and personal clothing must be provided Handlers may not take or wear PPE home. PPE must be stored and washed separately from other clothing Persons who clean PPE must be informed of proper cleaning procedures and of the potential for contamination with, and possible harmful effects of pesticides

Worker Protection Standard F. S. Responsibilities Insure that contractors do not become lax in fulfilling WPS requirements regarding training and PPE Do not assume liability for handler safety (properly placed with the employer (contractor))

Worker Protection Standard F. S. Responsibilities Most forestry herbicides fall into EPA toxicity categories III and IV (slightly toxic and relatively nontoxic) Minimum PPE is long-sleeved shirt, long pants, shoes, socks, and gloves Under WPS handlers are not allowed to take or wear PPE home

Worker Protection Standard F. S. Responsibilities Simplest solution: Wear coverall over clothes in the field which will be taken off at the end of the day prior to going home Coveralls must either be reusable and cleaned before re-use, or disposable and discarded after a single use

Worker Protection Standard There may be state, local, or Tribal requirements which are more restrictive than those in the WPS Enforcement authority for WPS lies with the State Lead Agency specified by EPA in each state State Lead Agencies are listed on the internet at vttp.ext.vt.edu/htmldocs/ srpchome.html

Worker Protection Standard Forest Service has been operating under the basic principles of WPS for many years Current pesticide projects in compliance with all of the mitigations required in the Vegetation Management EIS Records of Decision are already very close to being in full compliance with the WPS

Worker Protection Standard What to do Double check your projects and ensure that they continue to comply with the applicable R-8 Vegetation Management FEIS Ensure that crews have 1 pint of eyewash water for each handler in the field

Worker Protection Standard What to do: Be sure that a copy of the label and the MSDS go to the field with each crew Post EPA/WPS posters in each District or Supervisor's Office and one in each work center where pesticides are being used Maintain a current listing of all pesticide treated sites on the district which are within 30 days of the completion of the REI

Worker Protection Standard What to do Choose coverall use versus washer/drier facilities for cleaning applicator's clothing Incorporate into contract language (a requirement that the contractor shall insure that all provisions of the WPS will be met by his/her handlers and workers