University of Missouri Extension

G857, Reviewed December 1995

Worker Protection: An Employer's Guide to Worker Protection Standard Compliance

David E. Baker
Food Science and Engineering Unit

The U. S. Environmental Protection Agency (EPA) has issued final rules governing the protection of employees on farms and in forests, nurseries and greenhouses from occupational exposure to agricultural pesticides. The new Worker Protection Standard (WPS) covers two types of employees:

Employers are responsible for making sure that workers and handlers receive the protections required by the pesticide labeling and the WPS. The standard defines two types of employers:

Other terms you need to know

These additional definitions will help you determine whether you are affected by the Worker Protection Standard and will help you understand the standard.

This publication provides a general overview of specific duties that employers of handlers and workers must perform to be in compliance with the standard. It is important to note that there is a difference between how workers and handlers are regulated under the WPS. Depending on the tasks being performed, you may need to provide the same employee (including yourself) with worker protection on some occasions and pesticide handler protection on other occasions.

The WPS covers pesticides that are used in the production of agricultural plants on farms and in forests, nurseries and greenhouses. Both general-use and restricted-use pesticides are covered by the WPS. The WPS does NOT cover pesticides applied:

Duties for all employers

Some of the WPS requirements with which employers must comply are really the same whether the employees are workers or handlers. Following are descriptions of some requirements.

Information at a central location
For the benefit of all employees, information must be posted at an easily seen, central location on each agricultural establishment (for example, on the farm, not at the retailer dealer or custom applicator location). This information includes:

Workers and handlers must be told where the information is posted and allowed access to it. They also must be told of emergency facility information changes. Furthermore, the posted information must be kept legible and current.

Pesticide safety training
Unless the workers or handlers are certified applicators or possess a valid EPA-approved training card, they must be trained. Handlers must be trained before they begin work and at least once each five years. Workers, however, must be trained by the sixth day (16th day until October 1997) of entering an area that has been treated or has been under an REI in the last 30 days.

Training may be conducted by a certified applicator or by someone who has completed a train-the-trainer program. The training must be presented orally, from written materials or audiovisually. The training must be conducted in a manner and language that the employees can understand, using easily understood terms; the trainer must be able to respond to questions.

Decontamination site
Employers must provide a site where workers and handlers can wash pesticides and residue from their hands and body. A decontamination site should supply:

Water for emergency eye flushes must be immediately available if the pesticide label calls for protective eye wear.

Employers also must provide water that is safe and cool enough for washing, eye flushing and drinking. Employers may not use tank-stored water that also is used for mixing pesticides.

A decontamination site must be within one-fourth mile of the employees' work site. If the work site is more than one-fourth mile from the nearest point of vehicular access, the decontamination site may be located at the nearest access point.

Employers must provide handlers with the previously mentioned supplies at each mixing site and at the place where personal protective equipment is removed at the end of a task. Worker decontamination sites may not be in areas being treated or under an REI. Handler decontamination sites may be in the treated area in which the handler is working, as long as the materials are stored in enclosed containers.

Employer information exchange

An agricultural employer must be informed when a pesticide is to be applied on his/her agricultural establishment by a commercial applicator. The agricultural employer is responsible for providing all WPS protections to his or her employees, including oral notification or posting, training, decontamination and emergency assistance. The commercial handler's employer must provide the agricultural employer with the following information:

Operators of agricultural establishments must make sure that the commercial pesticide applicator and his or her employer are aware of all areas on the establishment where pesticides will be applied and where an REI may be in effect while the commercial handler is on the establishment, and of any restrictions on entering those areas.

Emergency assistance
When there is any possibility that any handler or worker has been poisoned or injured by pesticides, an employer must promptly make transportation available to an appropriate medical facility. Additionally, upon request, the employer must provide to the victim and medical personnel the following information:

Worker employer's duties

Restrictions during application
In areas being treated with pesticides, allow entry only to appropriately trained and equipped handlers. Keep nursery workers at least 100 feet away from nursery areas being treated. Allow only handlers in greenhouses during pesticide application and until air concentration levels listed on the label are met or, if there is no such level, until the area has been fan-ventilated for at least two hours.

Restricted-entry intervals
As stated earlier, the REI is the time immediately after a pesticide application when entry into the treated area is limited. The interval is based on the most toxic active ingredient in the pesticide. The restricted-entry intervals should be listed on the label as follows:

  Signal word Restricted-entry interval
Toxicity category I Danger — Poison 48 hours
Toxicity category II Warning 24 hours
Toxicity category III Caution 12 hours

Other REIs may apply. Follow the REI on the label. During an REI, do not allow workers to enter a treated area or contact anything treated with the pesticide to which the REI applies.

Notice about applications
Employers must notify workers about pesticide applications on the establishment. In most cases, employers may choose between oral warnings or posted warning signs, but they must tell workers which warning method is in effect. For some pesticides, however, employers have to do both. Pesticides requiring both oral and posted warnings will state this on the label.

Posted warning signs must be:

Oral warnings must be delivered in a manner understood by workers, using an interpreter if necessary. Oral warnings must contain the following information:

Handler employer's duties

Application restrictions and monitoring
Employers must not allow handlers to apply a pesticide so that it contacts anyone, directly or through drift, other than trained and properly equipped handlers. Employers also must make visual or voice contact at least every two hours with anyone handling pesticides labeled with a skull and crossbones (signal word: Danger — Poison). In addition, the employer must make sure that a trained handler equipped with label-specific personal protective equipment maintains constant visual or voice contact with any handler in a greenhouse who is performing fumigant-related tasks such as applications or air level monitoring.

Specific instructions for handlers
Employers must inform handlers of all pesticide labeling instructions for safe use before they perform any handling tasks. In addition, employers must keep pesticide labels accessible to each handler during the entire handling task and inform handlers of how to use any assigned handling equipment safely before they use it. When commercial handlers will be on an agricultural establishment, the employer must inform them beforehand of areas on the establishment where pesticides will be applied or where an REI will be in effect, and of any entry restrictions on these areas.

Equipment safety
Employers of handlers must make sure that equipment used for mixing, loading, transferring or applying pesticides is inspected and repaired or replaced as needed.

Only appropriately trained and equipped handlers may repair, clean or adjust pesticide handling equipment that contains pesticides or pesticide residues.

Personal protective equipment (PPE)
Employers must provide handlers with the PPE required for the task by the pesticide labeling and be sure it is clean, in operating condition, worn and used correctly, inspected before each day of use, and repaired or replaced as needed. In addition, employers must ensure that respirators fit correctly, and they must take steps to prevent heat illness. Employers must provide handlers with a pesticide-free work area for storing personal clothing not in use, putting on PPE at the start of the task and taking off PPE at the end of each task. They must not allow any handler to wear or take home any PPE used for handling activities.

Cleaning PPE
The employer must make sure that:

Replacing respirator purifying elements
Dust/mist filters must be replaced when breathing becomes difficult, if the filter is damaged or torn, when respirator label or pesticide label requires it, or at the end of each day's work period in the absence of any other instructions or indications. Vapor-removing cartridges or canisters must be replaced when odor, taste or irritation is noticed, when respirator label or pesticide label requires it, or at the end of each day's work period in the absence of any other instructions or indications.

Disposal of PPE
Coveralls and other clothing that are heavily contaminated with an undiluted pesticide having a DANGER or WARNING signal word must be discarded. Federal, state and local laws must be adhered to when disposing of PPE that cannot be cleaned correctly.

Instructions for people who clean PPE
Employers must inform people who clean or launder PPE that it may be contaminated with pesticides. They must inform them of the potentially harmful effects of exposure to pesticides and show them how to protect themselves and how to clean PPE correctly.

Additional information

For more information about or assistance with Worker Protection Standard compliance, contact

 

G857 Worker Protection: Employer’s Guide to Worker Protection Standard Compliance | University of Missouri Extension

Order publications online at http://extension.missouri.edu/explore/shop/ or call toll-free 800-292-0969.

University of Missouri Extension - print indicia