1 Worker Protection Standard (WPS) Pesticide Inspector Training Helena, Montana November 30, 2011 Richard Pont U.S. Environmental Protection Agency Office of Pesticide Programs Certification & Worker Protection Branch

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 2 Introduction - Why are we here?  Training Objectives: Learn WPS Requirements Understand WPS Program Goals ANSWER YOUR QUESTIONS! Meet your expectations

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 3 WPS Overview  Background/History  Regulatory Goals  WPS Framework  Summary of Key Definitions/Provisions

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 4 WPS Overview - Background  Basis for Current WPS Regulation Court case involving 40 CFR Part 170 OSHA Hazard Communication Standard Legislative and regulatory actions

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 5 WPS Overview - Background *7/08/88 - EPA Issued Notice of Proposed Rulemaking to Revise 40 CFR part 170 (53 FR 25970) *8/21/92 - Worker Protection Standard Final Rule Issued (57 FR 38102) *4/06/94 - Pesticide Safety Act (Public Law ) [S. 1913]

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 6 WPS Overview - Background *4/10/95 - Guidance on Issuance of WPS Enforcement Actions (60 FR 18100) *5/03/95 - Agency Granted Exceptions to Early Entry (60 FR 21954) *5/03/95 - Requirements for Crop Advisors (60 FR 21948) *5/03/95 - Grace Period for Providing Safety Training (60 FR 21943)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 7 WPS Overview - Background *12/14/95 - Labeling Revisions Required for Pesticide Products Within the Scope of the WPS: Policy Statement/Final Rule (60 FR 64281) *6/26/96 - Language and Size Requirement for Warning Sign (61 FR 33201)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 8 WPS Overview - Background *6/26/96 - Decontamination Requirements (61 FR 33207) *5/07/98 - Labeling Requirements for Pesticides: Respirator Compliance Policy (63 FR 25168) *9/01/ Glove Requirements: Final Rule (69 FR 53341)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 9 WPS Overview - Regulatory Goals  Protect agricultural workers and pesticide handlers from occupational exposure to pesticides and prevent pesticide incidents and illnesses.  WPS strategy relies on 3 main components: Information Protection Mitigation

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 10 WPS Overview - Regulatory Goals  Information Pesticide safety training Safety poster Access to pesticide application and hazard information (with notable exception)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 11 WPS Overview - Regulatory Goals  Protection Protections during applications Restricted-entry intervals (REIs) Early entry protections Handler protections (PPE, etc.)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 12 WPS Overview - Regulatory Goals  Mitigation Decontamination supplies Emergency Assistance

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 13 WPS Overview - WPS Framework  WPS implemented through labeling Labeling requirements contained in 40 CFR part 156, subpart K (Labeling Requirements for Pesticides and Devices/Worker Protection Statements) 40 CFR Part 170 reference statement serves to incorporate full WPS requirements by reference so that full 40 CFR Part 170 text of WPS provisions did not need to be included on every label

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 14

Agricultural Use Requirements Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170. This Standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. It also contains specific instructions and exceptions pertaining to the statements on this label about personal protective equipment (PPE), notification-to-workers, and restricted-entry intervals. The requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard.

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 16 WPS Label Requirements  40 CFR Part 170 (WPS) incorporation by reference established concept of “off-label” requirements: Training requirements Decontamination requirements Additional notification and pesticide safety information display requirements Emergency assistance requirements

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 17 WPS Label Requirements  “On-label” WPS requirements: Restricted entry statements ( ) Notification-to-workers statements ( ) Personal protective equipment (PPE) statements ( ) Includes handler PPE and early entry PPE Note that handler PPE is not contained in "Ag Use Box"

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 18

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 19 WPS Label Requirements  General Statements ( ) Application restrictions statement 40 CFR Part 170 reference statement Product-type identification (for organophosphates, N-methyl carbamates and fumigants) State restrictions Spanish warning statements

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 20 WPS Label Requirements *Generic approach versus product-specific approach for WPS label requirements –Part 156 and original PR Notices based on generic approach of establishing general WPS label requirements based on broader toxicity groupings and tables, etc. –Reregistration is resulting in product specific label requirements based on product specific data (longer REIs, special PPE and/or special posting and notification requirements, etc.)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 21 WPS Overview - Key Definitions  Agricultural establishment - means any farm, forest, nursery, or greenhouse  Agricultural plant - means any plant grown or maintained for commercial or research purposes and includes, but is not limited to, food, feed, fiber plants, trees, turf-grass, flowers, shrubs, ornamentals, and seedlings

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 22 WPS Overview - Key Definitions  Agricultural employer - means any person who hires workers, for any type of compensation, to perform activities related to the production of agricultural plants - or is responsible for the management of an agricultural establishment that uses such workers

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 23 WPS Overview - Key Definitions  Owner – means any person who has a present possessory interest in an agricultural establishment covered by the WPS  Immediate family - includes only spouse, children, stepchildren, foster children, parents, stepparents, foster parents, brothers, and sisters

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 24 WPS Overview - Key Definitions  Handler - means any person, including a self- employed person, who is employed for any type of compensation by a covered agricultural establishment or commercial handling establishment and who is doing any of the following tasks:

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 25 WPS Overview - Key Definitions  Handler tasks: Mixing, loading, transferring, or applying pesticides Disposing of pesticides or pesticide containers Handling opened containers of pesticides Flagging

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 26  Handler tasks: (continued) Cleaning, adjusting, handling, or repairing any part of pesticide equipment that may contain pesticide residues Assisting with the application of pesticides Entering a greenhouse or other enclosed area… Assisting with soil fumigation Performing tasks as crop advisor WPS Overview - Key Definitions

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 27 WPS Overview - Key Definitions  Worker - means any person, including a self- employed person, who is employed for any type of compensation and is performing activities relating to the production of agricultural plants (such as harvesting, weeding, watering, suckering, etc.) on a covered establishment

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 28 WPS Overview - Key Definitions  Hand labor - means any agricultural activity performed by hand or with hand tools that causes a worker to have substantial contact with surfaces (such as plants, plant parts, or soil) that may contain pesticide residues

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 29 WPS Overview - Key Definitions  Hand labor activities include, but are not limited to, harvesting, detasseling, thinning, weeding, topping, planting, sucker removal, pruning, disbudding, roguing, and packing produce into containers in the field

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 30 WPS Overview - Key Definitions  Hand labor DOES NOT include operating, moving, or repairing irrigation or watering equipment or performing the tasks of crop advisors

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 31 WPS Overview - Key Definitions  Treated area - means any area to which a pesticide is being directed or has been directed  Restricted Entry Interval (REI) - means the time after the end of a pesticide application during which entry into the treated area is restricted

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 32 WPS Overview - Key Provisions  General Duties and Prohibited Actions (170.7) Establishes primary responsibility of agricultural and/or handler employer for compliance and prohibits retaliation by employers

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 33 WPS Overview - Key Provisions  Violations (170.9) For the purposes of 40 CFR part 170, EPA interprets the term “use” to include: –Pre-application activities (storage, mixing and loading, training, preparation for application, etc.) –Application of the pesticide –Post-application activities (training, notification, decontamination, etc.)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 34 WPS Overview - Key Provisions  Applicability ( & ) The WPS applies when any covered pesticide product is used on an agricultural establishment in the production of agricultural plants

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 35 WPS Overview - Key Provisions  Exceptions ( & ) Pasture applications Livestock applications Rodent pest control Post-harvest uses Mosquito abatement, government sponsored “wide-area” public pest control programs Home gardens and greenhouses Landscaping of ornamental plants Non-cropland uses (right of way, wood preservation) Research uses of unregistered uses

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 36 WPS Overview - Key Provisions  Exemptions ( & ) Exemption for Owner & Immediate Family Crop Advisor Exemption

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 37 WPS Requirements Applicable for Worker Employers  Restrictions During Application  Restricted-Entry Intervals (REIs)  Notice About Applications Providing oral warnings and/or posting WPS warning signs

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 38 WPS Requirements Applicable for Both Worker and Handler Employers  Anti-Retaliation  Information at a Central Location  Pesticide Safety Training  Decontamination Supplies  Emergency Assistance  Employer Information Exchange

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 39 WPS Requirements Applicable for Handler Employers  Application Restrictions and Monitoring  Specific Instructions for Handlers  Equipment Safety  Duties Related to PPE

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 40 Restrictions During Applications ( ) During the application of any pesticide on an ag establishment, the ag employer shall not allow or direct ANY PERSON, other than an appropriately trained and equipped handler, to enter or to remain in the treated area Entry-restricted areas in greenhouses and nurseries Entry-Restricted Area is NOT the same as an REI

Summary of Entry-Restricted Areas in Nurseries During Pesticide Applications (b) During application of a pesticide:Workers are prohibited in: (1) a- Applied: (i) Aerially, or (ii) In an upward direction, or (iii) Using a spray pressure > 150 psi, or (2) b- Applied as a: (i) Fumigant, or (ii) Smoke, or (iv) Mist, or (v) Fog, or (vi) Aerosol Treated area ft in all directions on the nursery (2) a- Applied downward using: (i) A height > 12 in. from the plant medium, or (ii) A fine spray, or (iii) A spray pressure > 40 psi. and < 150 psi. b- Not as 1 or 2 (a) described above but for which a respiratory protection device is required for application by the product labeling. Treated area + 25 ft in all directions on the nursery (3) Applied otherwise Treated area

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance Entry-Restricted Areas in Nurseries *This diagram depicts a treated area plus 100 or 25 ft. entry-restricted area in all directions on the nursery 42 Nursery Treated Area 100 ft 25 ft 100 ft 25 ft 100 ft 25 ft

Summary of Greenhouse Entry-Restricted Areas Associated With Pesticide Applications (C) (4) A. When a pesticide is applied: B. Workers are prohibited in: C. Until:D. After the expiration of time in Column C until the Restricted-Entry Interval Expires Area is: (1) As a fumigantEntire greenhouse plus any adjacent structure that cannot be sealed off from the treated area The ventilation criteria of paragraph (c) (3) of this section are met No entry restrictions after criteria in column C are met (2) As a (i) Smoke, or (ii) Mist, or (iii) Fog, or (iv) Aerosol Entire enclosed areaThe ventilation criteria of paragraph (c) (3) of this section are met Entire enclosed area is the treated area (3) Not in 1 or 2 above, and for which a respiratory protection device is required for application by the product labeling Entire enclosed areaThe ventilation criteria of paragraph (c) (3) of this section are met Pesticide treated area (4) Not in 1,2, or 3 above and: (i) From a height of > 12 in from plant medium, or (ii) As a fine spray, or (iii )Using a spray pressure > 40 psi. Treated area plus 25 ft. in all directions in the enclosed area Application is complete Pesticide treated area (5) OtherwisePesticide treated areaApplication is complete Pesticide treated area

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 44 Post-Application Entry Restrictions (REIs) ( ) After the application of any pesticide on an ag establishment, the ag employer shall not allow or direct any worker to enter or to remain in the treated area before the REI specified on the pesticide labeling has expired, except as provided in the various exceptions

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 45 Exceptions to the Entry Restrictions Exception for activities with “no contact” Exception for short term activities Exception for an agricultural emergency

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 46 Exception requiring Agency approval Current, valid Agency granted exceptions include: Irrigation exception Limited contact exception Exceptions to the Entry Restrictions

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 47 Notice of Applications ( ) The ag employer shall notify workers of any pesticide application on the establishment Purpose is to notify workers about areas where pesticide applications are taking place or where REI’s are in effect Some labels may require both oral notification and posting of treated areas with warning signs

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance WPS Field Posting Sign

49 Fumigant Treated Area Posting Sign

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 50 Notice of Applications ( ) Farms, Forestry Operations and Nurseries –Workers may be notified either orally or by posting of warning signs Greenhouses –Must post all treated areas (and provide oral notification if both are required)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 51 Notice of Applications ( ) Notice of applications need not be given if: –Worker will not enter, work in, remain in, or pass through on foot: the treated area any area within 1/4 mile of the treated area during the application

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 52 –Worker will not enter, work in, remain in, or pass through on foot (continued): any area within 1/4 mile of the treated area during the REIWorker applied the pesticide and is aware of information required –Note difference for greenhouses Notice of Applications ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 53 Notice of Applications ( ) *Timing of Warning Signs –Must be posted 24 hours or less before application –Remove the signs within 3 days after the REI has expired –Keep signs legible and visible while they are posted –Remove sign prior to entry by workers

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 54 Notice of Applications ( ) *Timing of Oral Warnings –If workers are present they must be warned before application takes place –If they are not present they must be warned orally at the beginning of the next work period if the application is taking place or if the REI is still in effect

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 55 Providing Specific Information About Applications and Posting Pesticide Safety Information ( and ) If a worker whom they employ is on their establishment; and A covered pesticide has been applied or a REI has been in effect within the last 30 days

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 56 Providing Specific Information About Applications and Posting Pesticide Safety Information ( and ) List of recent pesticide applications –Location and description of treated area, product name, EPA Reg. No., active ingredients, time and date of application, REI for the pesticide applied/to be applied Local emergency medical information –Name, phone number, and address WPS safety poster (or equivalent)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 57 Providing Specific Information About Applications and Posting Pesticide Safety Information ( and ) Inform workers where information is located Allow access to the location Information must remain legible Shall be displayed until 30 days after the expiration of the last REI

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 58 Notice of Applications to Handler Employers ( ) Ag employers must provide handler employers with information about treated areas on their ag establishments if hiring commercial pesticide handlers that may be in or near treated areas – Specific location and description of any such areas –Restrictions on entering areas

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 59 Pesticide Safety Training for Workers ( ) The ag employer shall assure that each worker required to be trained has been trained according to the requirements in the WPS during the last 5 years

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 60 Pesticide Safety Training for Workers ( ) Who can legally conduct worker training? Certified applicators Trainers of certified applicators EPA or State-approved designated trainers Trained WPS handlers

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 61 Pesticide Safety Training for Workers ( ) Other training criteria: –Train before 6 th day (unless early entry) –Training must be presented orally from written materials or audio-visually –In manner/language understood by workers

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 62 Use EPA/State approved training materials (videos, flip charts, manuals, slides) or assure coverage of points in WPS Respond to questions Pesticide Safety Training for Workers ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 63 Decontamination Supplies for Workers ( ) The ag employer must provide decontamination supplies when workers will be working in an area: –where a covered pesticide has been applied or –an REI has been in effect within last 30 days and the worker will have contact with treated surfaces (except where products with an REI of 4 hours or less are only pesticides that were used)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 64 Decontamination Supplies for Workers ( ) General conditions for decontamination supplies: –Soap and single-use towels in quantities sufficient to meet worker’s needs –Enough water for routine washing/emergency eye-flushing –Water must be of quality and temperature not to cause illness or injury when it contacts skin or eyes or if swallowed (anti-siphon req. for mix water)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 65 Decontamination Supplies for Workers ( ) *General conditions for decontamination supplies: (continued) –Location must be reasonably accessible –Not more than 1/4 mile from work site –Cannot be in area being treated with pesticides –Exceptions for remote sites –Additional requirements for early entry sites

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 66 Emergency Assistance ( ) If there is reason to believe that a worker has been poisoned or injured by exposure to pesticides in connection with worker duties on the establishment, the employer shall provide emergency medical assistance: –Provide prompt emergency transportation

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 67 …the employer shall provide emergency medical assistance: (continued) –Provide information: Product name, EPA Reg. No., active ingredients Statement of practical treatment from labeling Circumstances of the application Circumstances of exposure of the person involved Emergency Assistance ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 68 Restrictions During Applications ( ) The handler employer and the handler shall assure that no pesticide is applied so as to contact, either directly or through drift, any worker or OTHER PERSON, other than an appropriately trained and equipped handler

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 69 Restrictions During Applications ( ) Other restrictions: –The handler employer must assure that handlers using skull & cross-bone products are monitored visually or by voice communication at least every two hours; and –Fumigant handling/application in greenhouses must be monitored continuously Monitor must have access to PPE

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 70 Providing Specific Information About Applications and Posting Pesticide Safety Information ( and ) If a handler whom they employ is on their establishment; and A covered pesticide has been applied or a REI has been in effect within the last 30 days

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 71 Providing Specific Information About Applications and Posting Pesticide Safety Information ( and ) List of recent pesticide applications –Location and description of treated area, product name, EPA Reg. No., active ingredients, time and date of application, REI for the pesticide applied/to be applied

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 72 Local emergency medical information –Name, phone number, and address WPS safety poster (or equivalent) Providing Specific Information About Applications and Posting Pesticide Safety Information ( and )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 73 Providing Specific Information About Applications and Posting Pesticide Safety Information ( and ) Inform handlers where information is located Allow access to the location Information must remain legible Shall be displayed until 30 days after the expiration of the last REI

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 74 Notice of Applications to Agricultural Employers ( ) Before the application of any pesticide on or in an ag establishment, the handler employers must provide ag employers with information about pesticide applications or assure the ag employer is aware of such information Specific location and description of areas to be treated Product name, EPA Reg. No., active ingredient(s)

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 75 Time and date of application REI Notification requirements Any other restrictions Notice of Applications to Agricultural Employers ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 76 Pesticide Safety Training for Handlers ( ) Before any handler performs any handling task, the handler employer shall assure that the handler has been trained according to the requirements in the WPS during the last 5 years

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 77 Pesticide Safety Training for Handlers ( ) Who can legally conduct handler training? Certified applicators Trainers of certified applicators EPA or State-approved designated trainers

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 78 Pesticide Safety Training for Handlers ( ) Other training criteria: Train before any handling tasks performed Training must be presented orally from written materials or audio-visually In manner/language understood by handlers

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 79 Other training criteria (continued): Use EPA/State approved training materials (videos, flip charts, manuals, slides) or assure coverage of points in WPS Respond to questions Pesticide Safety Training for Handlers ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 80 Knowledge of Labeling and Site- Specific Information ( ) The handler employer shall assure that the handler: –has either read the product labeling or has been informed in a manner the handler can understand all of the labeling requirements related to safe use of the pesticide

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 81 The handler employer shall assure that the handler: (continued) –has access to the product labeling information during handling activities –is aware of information about treated areas on the ag establishment Knowledge of Labeling and Site- Specific Information ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 82 Safe Operation of Equipment ( ) The handler employer shall assure that before the handler uses any equipment for mixing, loading, transferring, or applying pesticides, the handler is instructed in the safe operation of such equipment –Inspect and maintain equipment before each use –Remove residues before repair; or –Inform person of potential risks

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 83 PPE Requirements ( ) Any person who performs tasks as a pesticide handler shall use the clothing and personal protective equipment (PPE) specified on the labeling for use of the product

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 84 PPE Requirements ( ) Handler employer is responsible for: –Providing clean and properly operating PPE to the handler –Assuring proper use of PPE by handler –Care and maintenance of PPE –Preventing heat-related illness Note PPE exceptions

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 85 Decontamination Supplies for Handlers ( ) *During any handling activity, the handler employer must provide for handlers, decontamination supplies for washing off pesticides and pesticide residues

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 86 Decontamination Supplies for Handlers ( ) General conditions for decontamination supplies : –Soap and single-use towels in quantities sufficient to meet handler’s needs (plus clean change of clothing) –Enough water for routine washing, emergency eye-flushing and washing entire body in case of emergency

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 87 General conditions for decontamination supplies: (continued) –Water must be of quality and temperature not to cause illness or injury when it contacts skin or eyes or if swallowed (anti-siphon req. for mix water) Decontamination Supplies for Handlers ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 88 General conditions for decontamination supplies: (continued) –Location must be reasonably accessible –Not more than 1/4 mile from work site –Exceptions for remote sites Decontamination Supplies for Handlers ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 89 Decontamination Supplies for Handlers ( ) Additional conditions for handler decontamination supplies: –Decontamination supplies must be at mixing/loading sites –Emergency eyeflush water must be immediately available when label requires protective eyewear

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 90 Additional conditions for handler decontamination supplies: (continued) –Decontamination supplies may be in treated area (but covered) –Decontamination supplies must be at site for removing PPE and washing thoroughly at end of exposure period –End-of-day site may use clean towels Decontamination Supplies for Handlers ( )

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 91 Emergency Assistance ( ) If there is reason to believe that a handler has been poisoned or injured by exposure to pesticides in connection with handling duties on the establishment, the employer shall provide emergency medical assistance:

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 92 Emergency Assistance ( )...the employer shall provide emergency medical assistance: – Provide prompt emergency transportation –Provide information: Product name, EPA Reg. No., active ingredients Statement of practical treatment from labeling Circumstances of the application Circumstances of exposure of the person involved

Richard Pont- Legislative History; Label and Use Requirements; Interpretative Guidance 93 Interpretive Guidance Workgroup *The Interpretive Guidance Workgroup (IGW) was established to address WPS policy questions. Existing IGW policies can be found on EPA’s worker safety website: