Part one: Overview of the WPS and changes in training and record-keeping
by Sally Colby
Dr. Mary Ann Rose, director of Pesticide Safety Education Program for Ohio State University extension, says that the Worker Protection Standard (WPS) was established to reduce the risk of pesticide related injuries to workers and handlers in agricultural production facilities. “It’s focused on plant production – nursery, greenhouse, forests and farms,” she said.
EPA estimates that the new WPS will reduce exposures incidents and related illnesses by half, and will save an estimated 10 to 15 million dollars annually in healthcare costs related to acute illnesses associated with pesticides.
“The Worker Protection Standard is invoked by the pesticide label,” said Rose. “You have to follow the WPS as a farm or nursery when you use products that have the WPS labeling. You will see on the pesticide label, under directions for use section in the agricultural use requirements box, that the entire rule is invoked.”
The two main groups under protection by the rule are agricultural workers and handlers and early entry workers and crop advisors. Agricultural workers and handlers are those who do actual work – the people who mix, load and apply pesticides. The designation ‘handler’ includes anyone performing a task that requires direct contact with pesticides, such as handling open containers or cleaning equipment contaminated with residue.
Rose says that worker protection extends past the point of the application for a full 30 days after the restricted entry interval (REI) expires. “The WPS is designed to reduce the risks from occupational exposure to pesticides.”
The WPS requires employers to offer employees information about exposure to pesticides, protection against exposure and mitigating the effects if exposed. “The new revision will require full safety training,” said Rose, explaining that workers and handlers will have to receive annual training – records verifying training must be maintained for two years, as well.
“Previously, trained handlers or workers could do the training,” said Rose, “That’s no longer the case unless they are licensed pesticide applicators.” Training must include new EPA-approved written and audiovisual materials, and a qualified individual will have to be present during the entire training – not just during the question period.
Rose says a lot of the changes are designed to limit take-home exposure to the family. “Removing work shoes before entering your home, bathing after work before contact with family members, laundering work clothing separately from the family laundry, pesticide education about potential pesticide exposure hazards to young children and pregnant women, and keeping children and non-working family members away from pesticide-treated areas.”
The new rule also includes a directive that requires explicit instructions about the location of all information workers should have access to. Rose explained that the revised WPS also includes changes to record keeping, starting with the requirement to maintain records for two years.
Handlers must receive training on all of the same material that workers will be trained on. “There’s a new minimum age requirement for handlers – 18,” said Rose. “They have to be informed about the new requirements for respirator use and revised posting requirements.”
The central posting area must include pesticide application-specific information with some minor content changes. “They loosened up the timing for when that must be displayed – no later than 24 hours after the application has been completed or before any worker enters a treated area,” said Rose. “The information still remains posted for 30 days after the REI expires. What’s new is the addition of safety data sheets (SDS) for pesticides being posted.”
The EPA will be providing a new pesticide safety poster that includes additional information, which must also be present at all decon sites. Also required at central posting is posting of emergency medical facility contact information including for state or tribal agency. “Another new record-keeping requirement is that all the information that you have been posting about pesticide application now has to be kept as a record for two years,” said Rose. “The SDS sheets will have to kept for the same period.” Workers and worker advocates must also have access to this information; signed consent is required for advocates.