by Jon M. Casey
Christmas tree farm worker safety was the featured topic at the Northeast PA Christmas Tree Growers Meeting & Trade Show held earlier this year at the Capriotti’s Catering banquet facility in McAdoo, PA. Penn State Worker Protection Standard Specialist, Jim Harvey, offered detailed explanations on current and future worker safety guidelines covering workers at Christmas tree farms, for both family members and hired workers employed by the tree growers.With updated changes in federal worker regulations due to be implemented through 2018, the upcoming changes are on the minds of Christmas tree growers across the country. Harvey said that while the U.S. EPA in Pennsylvania requires the overall regulations, it is the Pennsylvania Department of Agriculture (PDA) that enforces the regulations. Other states have other enforcement agencies, for example, he said that in New Jersey, the NJ Department of Environmental Protection that enforce the laws.
Harvey began by encouraging growers to familiarize themselves with the current changes to the federal Worker Protection Standards. He said that a training DVD developed by Penn State and the PDA entitled “Safety in the Field – Worker Protection Standard Training for Workers and Handlers on Christmas Tree Farms,” would only be valid through 2018.
At that time, the dvd will be updated and made available as soon as the new script is approved. The videos are available upon request for PA Christmas tree farmers upon request from the Penn State Extension.
Worker Protection Standards – who is covered?
Harvey said that Christmas tree farmers who hire workers from outside the immediate family and are working within a crop area that has been treated with pesticides within the last 30-day window for Restricted Entry Intervals (REI) are covered by the WPS standards. Employees are anyone who is hired to work on the farm. The definition for family exemptions has broadened under the new guidelines. Previously the family exemption covered owners, spouses, siblings, children, stepchildren, foster children, parents, stepparents and foster parents. Today, the rule has expanded to include in-laws, first cousins, aunts, uncles, nephews, nieces, grandchildren and grandparents. The family exemption DOES NOT exclude family members who are using material that requires Personal Protective Equipment (PPE) on the material label and it DOES NOT exclude them from following the REIs.
Regardless, Harvey suggested that everyone be trained according to the WPS standards as a matter of good safety management and family safety in general. Everyone should handle pesticides safely and avoid treated areas for the prescribed duration to protect everyone’s health. Material handlers and early entry workers must be at least 18 years of age with the exception of immediate family members.
Harvey explained that if a farm is under WPS, they need an instructional poster on display at their central location, for use as an ongoing training tool for employee safety. According to guidelines on www.EPA.gov, “An employer must display the required information together in a central location on the agricultural establishment where it is readily accessible and can be easily seen and read by workers and handlers. The information must be displayed whenever: any worker or handler employed by the agricultural establishment is on the agricultural establishment; and in the past 30 days, a pesticide that references the WPS on the labeling has been applied; or a restricted-entry interval has been in effect.” [Editor’s Note: Per EPA guidelines, the pesticide safety poster, must be the EPA Worker Protection Standard (WPS) safety poster, Protect Yourself from Pesticides; or an equivalent poster that includes all of the required elements. To obtain the Protect Yourself from Pesticides poster, order the poster in hard copy or on CD from the National Service Center for Environmental Publications.]
Employee training records should also be stored at the central location for the required time. He said that in the past, farmers have been required to store Material Safety Data Sheets (MSDS) from the pesticide labels, but now, farmers are required to have the approved Safety Data Sheets (SDS) for the materials in use on the farm. These forms are now in a common format and they are easier to read and are more helpful to the medical people who would need to tend to workers who might be affected by pesticides. The SDS should be posted at the Central Location until 30 days after the last application of the material REI and the forms then need to be retained on file, for two years following.
Training must now be done once per year instead of the previous every 5-year regimen. Employees that do not need training are family members, employees who have been trained elsewhere that year or workers with a current PA pesticide certification, however everyone needs to know where the central location and decontamination supplies are located. All appropriate training documentation needs to be kept in a safe place for easy access when needed.
Christmas tree farms will need to keep decontamination supplies in three locations, for pesticide handlers to have easy access in case of contact with the hazardous material. The specified sites are at the area where the material is mixed and loaded, within one-quarter mile of where the material will be applied and at the site where the handler’s PPE is removed when the work is completed. These supplies include three gallons of potable water, paper towels and soap.
In case of an emergency, natural water supplies can be used to decontaminate immediately, but the regular supplies need to be at their designated locations. Additionally, there needs to be a handler eyewash system at the mix and load site. It needs to be able to deliver 0.4 gallons per minute of clean water for 15 minutes or 6 gallons of water that can flow gently for 15 minutes. A hose attached to clean, potable water will serve in this capacity.
Harvey concluded by saying that following pesticide application outdoors, material that has an REI of greater than 48 hours must have “Do Not Enter” signs posted around the affected area. Enclosed spaces with an REI of greater than 4 hours must be posted. Material labels will provide this information.
He closed by reminding attendees that updates and changes take place regularly. The most current information available is on Facebook, and is updated as it becomes available. The Facebook page is Worker Protection Standard-PORH. Harvey’s email address is firstname.lastname@example.org .
Christmas tree farm worker safety takes center stage
by Jon M. Casey