From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Tue Jun 7 08:51:05 1994 Received: from nak.berkeley.edu (nak.Berkeley.EDU [128.32.136.21]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id IAA21512 for ; Tue, 7 Jun 1994 08:51:05 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id IAA06758; Tue, 7 Jun 1994 08:51:04 -0700 Message-Id: <199406071551.IAA06758@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 2794; Tue, 07 Jun 94 08:51:12 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 4477; Tue, 07 Jun 94 08:51:11 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 8171; Tue, 07 Jun 94 11:03:26 EDT Date: Tue, 07 Jun 94 11:01:58 EDT From: Al French Subject: Potential problem with WPS training verification To: WPS-FORUM X-Acknowledge-To: I'd like to bring to your attention a potential problem in some states regarding WPS training verification. To maintain the integrity of the WPS training verification cards, EPA requires that a state entity (other than the Extension Service) be responsible for issuing blank cards to eligible trainers and maintaining a list of the workers trained and their verification card numbers. This system will be important to many workers in order to be eligible to begin work (particularly if EPA proceeds to reduce or eliminate the training grace period) or where employers require job applicants to provide proof of training. It will also be important to employers who are not qualified to provide the required training or who desire to avoid the cost of repetitious training. A few states have indicated to EPA that they do not intend to issue EPA training verification cards. Some states, primarily those with training requirements that exceed the WPS, indicate they plan to issue their own cards --which may or may not be relied upon by employers in other states for training verification purposes. At the least, this would cause confusion among workers and employers. EPA officials indicate a willingness, where state officials agree to maintain the WPS training standards, to permit a statement to be printed on a state card indicating that the trainee has met the EPA requirements. As of 6/1/94, states that have indicated an intention not to issue WPS training verification cards include: California (workers yes, handlers no), Ohio, Pennsylvania, Wisconsin, and Hawaii. States that have indicated an intention to issue state cards only include: Mississippi, Oregon, Tennessee, and Washington. Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench%ers.bitnet@vtbit.cc.vt.edu From dana@are.Berkeley.EDU Tue Jun 7 15:49:02 1994 Received: from [128.32.251.38] (gia3mac28.Berkeley.EDU [128.32.251.38]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id PAA02457 for ; Tue, 7 Jun 1994 15:49:00 -0700 Message-Id: <199406072249.PAA02457@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Tue, 7 Jun 1994 15:49:02 -0800 To: wps-forum From: dana@are.Berkeley.EDU (Dana E. Keil) Subject: A reply from Pat Krauss ================================================== Note from Dana Keil, list manager The following is the content of a reply by Pat Krauss in response to Al French's message with the subject: Potential problem with WPS training verification. (The message, when first submitted, was incorrectly ignored by the mailing list software.) ================================================== My understanding was that EPA cards are not yet ready. We, at the New York State Agricultural Experiment Station, Geneva, have been issuing a certificate that includes the name of the person, the category level trained to (worker, handler), the department in which the person is located, the date on which they were trained, the date when they must be retrained,the Cornell University logo and Geneva Experiment Station indicia, and the names and signatures of the trainers. We have told all of our people to carry a wallet-sized copy of this certificate with them in case they are ever questioned should they be doing work on other than an experiment station field. -- Dana From howardr@are.Berkeley.EDU Wed Jun 8 01:25:15 1994 Received: from DialupEudora (eudora@are.Berkeley.EDU [128.32.175.17]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id BAA09626 for ; Wed, 8 Jun 1994 01:25:01 -0700 Date: Wed, 8 Jun 1994 01:25:01 -0700 Message-Id: <199406080825.BAA09626@are.Berkeley.EDU> To: wps-forum From: howardr@are.Berkeley.EDU (Howard Rosenberg) Subject: news for use A few notes on forum development. 1. There are now 164 subscribers to WPS-Forum. To find out who they are, send to ListProc@are.berkeley.edu the message: recipients wps-forum 2. The welcome message (received by each new subscriber) has been revised to include a list of files in the archive, more complete instructions on how to retrieve these files, and several other refinements. We will continue to update the welcome occasionally. To get a copy of the most current welcome statement at any time, send to Listproc the message: info wps-forum To get only a list of files in archive, send the message: index wps-forum 3. A small snag has delayed acquisition of the EPA "How to Comply" manual for the archive. We will not have it until next week at the earliest. 4. We have, however, received the full text of the WPS final rule as published in the August 1992 Federal Register. This document includes substantial discussion of the public comments that EPA received and considered after issuing its proposed regulaton. Along with the final rule and discussion are (1) the original request for exception to reentry prohibitions in cut flower and cut fern production, and (2) a lengthy comment on the proposed regulation from USDA, which comment was not published in the Federal Register until three weeks after the WPS. The whole package is a monstrous 600k bundle of joy. It will enter the archive, probably by the end of this week, in two forms. One form will be the whole works, as received, in a single WordPerfect file. The other will be a set of nine or ten ASCII files, each containing a clearly bounded portion of the whole document and generally easier for most of our systems to handle. Even if you already have a paper copy of the full WPS as published, you may find it worthwhile to have the material on hand in a computer file for quickly searching, extracting sections of special interest, or just clogging up your hard disk. When ready for placement in the archive, the files will be named and described in a posted message. Howard From gebillikopf@ucdavis.edu Wed Jun 8 11:30:31 1994 Received: from ucdavis.ucdavis.edu (ucdavis.edu [128.120.250.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id LAA18353 for ; Wed, 8 Jun 1994 11:30:31 -0700 From: gebillikopf@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by ucdavis.ucdavis.edu (8.6.8/UCD2.50) id LAA09359; Wed, 8 Jun 1994 11:30:18 -0700 Date: Wed, 8 Jun 1994 11:30:18 -0700 Message-Id: <199406081830.LAA09359@ucdavis.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: Instructor's Materials Dear EPA netters: A free copy of Melanie Zavala's game for teaching pesticide safety to Spanish-speaking farm workers is available through me, as is a free copy of an Instructor's Manual containing cases, role-plays, and other teaching materials. Because of the limited number of games and manuals, we are first making copies available to those who give workshops, teach, or consult in Ag Human Resource Management or Farm Safety, as well as those who have an interest in incorporating into their workshops and teaching such topics as employee selection, promotion, performance appraisals, wages & benefits, supervision, communication, conflict resolution, training (especially pesticide safety training), discipline, turnover, and family farm issues. Please request your free copy on your university or consultant letterhead and clearly indicate if you want a copy of the game, the manual, or both. If you have any questions please do not hesitate to call, write or e-mail me. Gregorio *********************************************************************** Gregorio Billikopf Encina (209) 525-6654 University of California FAX (209) 525-4969 733 County Center 3 e-mail gebillikopf@ucdavis.edu Modesto, CA 95357 ************************************************************************* From 73507.555@CompuServe.COM Wed Jun 8 22:16:33 1994 Received: from dub-img-1.compuserve.com (dub-img-1.compuserve.com [198.4.9.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id WAA02366 for ; Wed, 8 Jun 1994 22:16:32 -0700 Received: from localhost by dub-img-1.compuserve.com (8.6.4/5.940406sam) id BAA13851; Thu, 9 Jun 1994 01:16:01 -0400 Date: 09 Jun 94 01:11:35 EDT From: BOB ROACH <73507.555@CompuServe.COM> To: Subject: California equivalency issues Message-ID: <940609051135_73507.555_HHB33-1@CompuServe.COM> Can anybody tell me how the equivalency negotiations are going between California and the U.S. EPA? It was my understanding that in the beginning, U.S. EPA was unyielding but that later some signs of hope were evident. Now I have not heard a word for some few months. What are we going to have to deal with in about seven months? Some of the notification and record keeping requirements proposed are not very practical and would replace a system that does work and was designed for California. The approach of the Worker Protection Standard is that of the old command-and-control paradigm that has been successfully used by regulators to solve many problems. Now that we have solved the easy problems, some of the more difficult ones need a fresh approach. Each additional diminishment of risk is smaller and smaller and comes with a greater and greater cost and complexity. I think the proper approach will be to work together cooperatively, acknowledge what needs to be accomplished and empower competent states to develop solutions that work. A one-size-fits-all regulation is not going to be successful because agriculture in this country is too diverse. Bob Roach 73507.555@Compuserve.com From Zax0114@aol.com Thu Jun 9 13:18:41 1994 Received: from mail02.prod.aol.net (mail02.prod.aol.net [192.203.190.97]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id NAA21632 for ; Thu, 9 Jun 1994 13:18:40 -0700 From: Zax0114@aol.com Received: by mail02.prod.aol.net (1.38.193.5/16.2) id AA06913; Thu, 9 Jun 1994 16:18:09 -0400 X-Mailer: America Online Mailer Sender: "Zax0114" Message-Id: <9406091618.tn1016682@aol.com> To: wps-forum@are.Berkeley.EDU Date: Thu, 09 Jun 94 16:18:06 EDT Subject: Worker Notification Anything new on the notification for pesticide applications? Last I read, the notification could be oral or with signs unless the material is a category 1 pesticide (signs only). Any practical advice on oral warnings? Often in vineyards partial blocks are treated, either for pest control purposes or the application for a day ended in the middle of a block. How is posting/notification handled in this case? Also, how will the inconsistances between California posting regulations and EPA notification regulations play out? Zach Berkowitz Domaine Chandon From SAMULIS@aesop.rutgers.edu Fri Jun 10 08:42:24 1994 Received: from aesop.rutgers.edu (aesop.rutgers.edu [128.6.59.6]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id IAA07202 for ; Fri, 10 Jun 1994 08:42:23 -0700 From: SAMULIS@aesop.rutgers.edu Date: Fri, 10 Jun 1994 11:42:21 -0400 (EDT) To: wps-forum@are.Berkeley.EDU Message-Id: <940610114221.29b94@aesop.rutgers.edu> Subject: Posting This is a response to the note from Berkowitz & Domaine Chandon Here in New Jersey our state pesticide codes requirw us to orally notify workers of all reentry times. Because of this, we have to post only when the label specifically says to. Concern exists however because of the type of agriculture we have. One large nursery I work with needs over 1,700 different signs due to the fact that they have many small blocks of different species which are all treated differently. I also work with many sweet corn growers that follow a TIGHT SPRAY SCHEDULE late in the season on possibly a 3 day schedule which would mean that the fields would have to be perpetually posted. Still another problem we have to address relates to day haul workers. Training is fesable provided the workers are the same individuals day in and day out, but what about situations where workers come on a daily basis from the city and most are not repeats on any type of regular basis? One blueberry growers uses 2,700 pickers daily which must be nothing short of a nightmare to deal with. Over the past two years I have personally trained over 400 workers in English, Spanish, and even one Cambodian program. I jumped the gun in order to get growers used to the idea of training workers long before it was required. Interestingly, both myself and the growers felt the traing would be only tolerated by workers when in fact most workers were sincerely interested, and asked many good questions. In fact most programs went 45 minutes to an hour longer than scheduled because of the questions. As an added bonus we also covered ticks and Lymes Disease for their use. While this program will be difficilt to do, I feel we in extension can do a lot to foster participation and cooperation if we have a positive attitude toward WPS. I tell my growerws that happy healthy workers mean good workers thats translates into profit potential. Ray Samulis Rutgers Cooperative Extension of Burlington County Please excuse my marginal typing skills. From palacios@unixg.ubc.ca Sun Jun 12 00:00:16 1994 Received: from unixg.ubc.ca (root@unixg.ubc.ca [137.82.27.7]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id AAA16610 for ; Sun, 12 Jun 1994 00:00:15 -0700 Received: from netinfo.ubc.ca by unixg.ubc.ca (4.1/1.14) id AA06330; Sat, 11 Jun 94 23:59:12 PDT Received: by netinfo.ubc.ca id AA27538; Sun, 12 Jun 94 00:00:13 -0700 Date: Sun, 12 Jun 1994 00:00:12 -0700 (PDT) From: Alejandro Palacios Subject: Re: Potential problem with WPS training verification To: wps-forum@are.Berkeley.EDU In-Reply-To: <199406071551.IAA06758@nak.berkeley.edu> Message-Id: Mime-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII to whom it may concern I would like to be withdrawn from the system Thank you Alejandro Palacios e-mail address: palacios@unixg.ubc.ca From 73507.555@CompuServe.COM Sun Jun 12 13:51:30 1994 Received: from arl-img-1.compuserve.com (arl-img-1.compuserve.com [198.4.7.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id NAA02594 for ; Sun, 12 Jun 1994 13:51:29 -0700 Received: from localhost by arl-img-1.compuserve.com (8.6.4/5.940406sam) id QAA08998; Sun, 12 Jun 1994 16:50:58 -0400 Date: 12 Jun 94 16:49:02 EDT From: BOB ROACH <73507.555@CompuServe.COM> To: Subject: WPS Problems in Veg Growing Area Message-ID: <940612204902_73507.555_HHB54-1@CompuServe.COM> COMMENTS ON THE FEDERAL WORKER PROTECTION STANDARD AS IT AFFECTS MONTEREY COUNTY, CALIFORNIA Fact: California currently prohibits field activities that involve substantial contact with plants during an REI. Irrigation by protected employees is allowed without time restrictions. The early entry workers have to be informed and protected. Under the federal standards, activities that involve substantial contact continue to be prohibited and activities that involve no contact continue to be allowed. Other activities, such as irrigation, are permitted by workers wearing the required Personal Protective Equipment. Entry is limited to one hour in any 24 hour period. No entry may occur until 4 hours have elapsed from the end of the application. PPE (all applicator needs except respiratory protection) and fieldworker training must be provided. all pesticides will have a restricted entry interval of at least 12 hours. Comment: The one hour limit effectively eliminates most irrigation during a Restricted Entry Interval. This is clearly an unacceptable situation, especially when no foliage is present. What is the risk in this case and why can it not be mitigated by using PPE? Some soil-applied herbicide labels require immediate incorporation by irrigation. Failure to incorporate may result in wind transport and resultant contamination of non-target areas and photodegradation of the product resulting in reduced efficacy. Uneven germination of seeds or mortality of transplants is certain to occur if water cannot be applied after seeding or transplanting. To allow irrigation after transplanting it will be necessary to apply the herbicide the day before planting. This could result in more worker exposure for transplanters. It will also result in lower efficacy since the soil will be disturbed after the application and weeds sprout right next to the plants where they are difficult to hoe. Fact: Current requirements require notice to those who are likely to enter a treated area during a REI. Under the new standards any person on a growers property who will be within 1/4 mile of any field under a REI must receive oral and/or written warning. If the field is posted this notice is not required unless oral notification is specifically required by the label (Category I acute dermal toxicity or skin irritation products.) Those required to receive notification include: grower employees; PCO employees; PCAs; and labor contractor employees. Oral warnings must include: the location and description of the treated area, the time of the REI and instructions not to enter the area. The posting sign is 14 inches by 16 inches and consists of the stern face and upraised hand. Comment: Why should field posting not suffice in all cases? The sign says "stop, do not enter here." Field posting is a better solution than oral warnings that are impossible to deliver to the many independent parties that may be found on the ranch. Workers may forget a warning or be mistaken about which location was meant. A sign is clear. The logistics of accomplishing oral notification in vegetable production situations are very difficult. Monterey County, California has approximately 23,000 sites on 1500 ranches operated by 600 growers. There are approximately 100,000 applications a year. It is hard to know how to accomplish the notification. Field sizes are small and our ranches are nearly always less than 1/4 mile across. There are many different people are in the fields. All of those listed above will be found. There are usually many points of entry to any ranch. Growers sometimes do not have a lot of control over when labor contractors show up. Communications with crews in the field is a problem. A crew may work on several ranches in a day. Short of having a fence and a gate with a guard to issue the warnings of the day, I do not see how to accomplish this. The EPA slide show shows their concept of a farm. There is a little red house, a big red barn, a silo and a field of corn. Around here the situation is much more dynamic. They show the grower giving oral warning to a few employees and showing them a calender with the REI days crossed out. A grower here might have 10 REIs on the ranch and 10 crews or other workers to notify. That would require the transfer of 100 pieces of information that day. How would a worker remember all the locations they are not supposed to enter? How are we supposed to identify the lots? They would need a map. It is easy to get lots confused. Is giving notice to the farm labor contractor sufficient? If the FLC then does not inform the crew of the REI, the grower is still responsible under another provision of the WPS. Fact: Currently growers have to keep application records and MSDS sheets for two years. Workers must be told where the information is kept and that they have the right to access it. Access must be provided within 48 hours. Under the federal standards a notice that includes the identity of the active ingredient must be posted (access cannot be impeded in any way) at a central location before the application begins and until 30 days after the expiration of the REI. Comment: California's hazard communication regulations provide a higher standard of protection in cases where the amount on information is large, as in vegetable production areas. Under the federal system there is no provision for access to labels and MSDSs. Under the California system the information is available for at least two years and not just 30-plus days. Nobody will be able to glean any useful information under the proposed system because it is not organized. With many lots and applications on a ranch locating the desired information will be difficult. The information is not under control. Once a worker finds the desired application what will they do? They will probably tear it off and put it in their pocket. The grower is still responsible for maintaining the information yet they are forced to put it in an area where they cannot control it. Growers should not have to face the burden of maintaining two systems to provide information for workers, especially when one is useless. The Agricultural Commissioner's Office also has the information, since use reports are public information and labels and MSDS sheets are generally available. Labor contractors, PCOs and PCAs do not usually report to any central location when the arrive at a ranch. They normally go directly to the worksite. How are they going to see the information posted at the central location? From 73507.555@CompuServe.COM Mon Jun 13 21:29:28 1994 Received: from dub-img-1.compuserve.com (dub-img-1.compuserve.com [198.4.9.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id VAA14554 for ; Mon, 13 Jun 1994 21:29:28 -0700 Received: from localhost by dub-img-1.compuserve.com (8.6.4/5.940406sam) id AAA01093; Tue, 14 Jun 1994 00:28:56 -0400 Date: 14 Jun 94 00:25:22 EDT From: BOB ROACH <73507.555@CompuServe.COM> To: Subject: WPS IN U.S. TERRITORIES Message-ID: <940614042522_73507.555_HHB28-1@CompuServe.COM> Does anyone know how the Worker Protection Standards are going to be implemented and enforced in U.S. Territories? I am specifically interested in Puerto Rico, where I will be travelling in about ten days. Bob Roach 73507.555@compuserve.com From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Tue Jun 14 12:25:49 1994 Received: from nak.berkeley.edu (nak.Berkeley.EDU [128.32.136.21]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id MAA00722 for ; Tue, 14 Jun 1994 12:25:49 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id MAA16146; Tue, 14 Jun 1994 12:25:07 -0700 Message-Id: <199406141925.MAA16146@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 3074; Tue, 14 Jun 94 12:25:47 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 5204; Tue, 14 Jun 94 12:11:47 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 3492; Tue, 14 Jun 94 15:11:09 EDT Date: Tue, 14 Jun 94 15:08:58 EDT From: Al French Subject: Posting (Reply to Zach Berkowitz & Domaine Chandon) To: WPS-FORUM X-Acknowledge-To: In reply to Zach Berkowitz & Domaine Chandon who asked: This question was considered during the development of the WPS. It was decided that since there was no prohibition for over-posting the area treated, and there would be no increase in risk to workers by over-posting, the employer could elect to post either the actual portion of a field that had been treated or the entire field. EPA officials speak of this as an undefined area within a defined area. However posted, the workers' oral notification must be consistent with the posting, and reentry restrictions would apply to the area posted. This procedure could also apply where contract researchers must keep test plots confidential. By posting the entire field, the test plot within it could not be identified. I checked this with an appropriate EPA official in DC today and was told that the policy still holds. I believe there could be a change in policy if over-posting was abused or if multiple fields were unnecessarily posted because this could make posting less meaningful to workers. Incidentally, the WPS limits over-posting with respect to time. An area may not be posted more than 24 hours in advance of the scheduled application and the posting must be removed within 3 days after the end of the restricted-entry interval. Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench@ers.bitnet or afrench%ers.bitnet@vtbit.cc.vt.edu From howardr@are.Berkeley.EDU Tue Jun 14 20:03:50 1994 Received: from DialupEudora (eudora@are.Berkeley.EDU [128.32.175.17]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id UAA10047 for ; Tue, 14 Jun 1994 20:03:30 -0700 Date: Tue, 14 Jun 1994 20:03:30 -0700 Message-Id: <199406150303.UAA10047@are.Berkeley.EDU> To: wps-forum From: howardr@are.Berkeley.EDU (Howard Rosenberg) Subject: Documents from Federal Register Added to Archive Now playing in the WPS-Forum archive are (1) the full text of the WPS final rule as published in the August 1992 Federal Register, (2) a proposed companion rule, published with the final WPS, on communication of pesticide hazard information, (3) a proposed exception to the early entry prohibition in cut flower and cut fern production, also published with the final WPS, and (4) a lengthy March 1992 letter from USDA commenting on EPA's draft WPS of June 1991. The first three of these items officially appeared together in the Federal Register on Friday, August 21, 1992 (Vol. 57, No. 163), pp. 38102-38176, a reprint of which has been widely circulated. The USDA comment was published in the Federal Register on September 14, 1992. The WPS text has been split into six ASCII files for the archive, and the other three items are in one file each. Names and contents of the nine files total are listed below. The first 44 pages (38102-38146) of the WPS are explanatory and are contained in the files wps.fr1 through wps.fr4. The rule proper begins on page 38146 and is contained in files wps.fr5 and wps.fr6. Please remember to address requests for any of these files to ListProc, not to WPS-Forum. The form is: GET WPS-Forum filename. For example, to get the USDA Comment, send to ListProc@are.berkeley.edu the message: GET WPS-Forum wps.fr9 FILENAME CONTENT wps.fr1 ---- Summary and Prefatory Information I. Background II. Organization and Summary of the Final Rule [pp. 38102-38106 in FR] wps.fr2 ---- III. Provisions of the Final Rule (incl. discussion of comments) [pp. 38106-38132] wps.fr3 ---- IV. Labeling Statements (incl. discussion of comments) V. Statutory Review (incl. discussion of comments) [pp. 38132-38139] wps.fr4 ---- VI. Implementation VII. Public Docket VIII. Regulatory Requirements [pp. 38139-38146] wps.fr5 ---- Part 156--Labeling Requirements for Pesticides and Devices [pp. 38146-38151] wps.fr6 ---- Part 170--Worker Protection Standard [pp. 38151-38166] wps.fr7 ---- Proposed Rule on WPS Hazard Information [pp. 38167-38174] wps.fr8 ---- Proposed Exeception to WPS Entry Entry Prohibition for Hand Labor Tasks Performed on Cut Flowers and Cut Ferns [pp. 38175-38176] wps.fr9 ---- USDA Comment on Draft WPS Regulations [pp. 42472-42480] Forum participants who are not yet acquainted with these fundamental references will find them quite informative. Having the material in computer-readable (and searchable) form ought to prove useful for many of us, regardless of prior familiarity with it. We are indebted to Noreen Wong for meticulously reformatting source text in these ASCII files. Howard From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Wed Jun 15 08:32:44 1994 Received: from nak.berkeley.edu (nak.Berkeley.EDU [128.32.136.21]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id IAA16536 for ; Wed, 15 Jun 1994 08:32:44 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id IAA20774; Wed, 15 Jun 1994 08:31:49 -0700 Message-Id: <199406151531.IAA20774@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 2567; Wed, 15 Jun 94 08:32:31 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 6557; Wed, 15 Jun 94 08:28:17 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 8504; Wed, 15 Jun 94 11:28:04 EDT Date: Wed, 15 Jun 94 11:25:49 EDT From: Al French Subject: Rose exception issued To: WPS-FORUM X-Acknowledge-To: EPA has published a limited exception for the harvesting of greenhouse-grown roses in the Federal Register of June 10, 1994, pages 30264-30273. The exception is narrower than proposed for roses and will expire after 2 years. No exception was granted to other cut flowers or ferns as was proposed August 21, 1992. Generally, the conditions of the exception include no entry for 4 hours after application, a limit of 3 hours work in any 24-hour period during the balance of the restricted entry interval, early entry personal protective equipment requirements, heat stress protection, decontamination and change areas, emergency assistance, and training and label information notification. The exception does not permit early entry for watering, pruning, or disbudding roses. The 1994 legislation does not affect the terms of the exception and the exception does not apply where product labels prohibit entry--including that which would otherwise be permitted under the WPS and this exception. The explanatory portion of the rule describes factors considered by EPA in granting the exception and includes an analysis of the comments received. This explanation should be of great interest to others who may be considering an application for an exception to WPS reentry restrictions. Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench%ers.bitnet@vtbit.cc.vt.edu From PETERSEN@aesop.rutgers.edu Wed Jun 15 08:50:14 1994 Received: from aesop.rutgers.edu (aesop.rutgers.edu [128.6.59.6]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id IAA17790 for ; Wed, 15 Jun 1994 08:50:13 -0700 From: PETERSEN@aesop.rutgers.edu Date: Wed, 15 Jun 1994 11:50:12 -0400 (EDT) To: wps-forum@are.Berkeley.EDU Message-Id: <940615115012.31c42@aesop.rutgers.edu> Subject: RE: Rose exception issued Doesn't this exemption open a big can of worms? Now everyone will be trying to come up with an exemption for their commodity. If EPA grants too many of them, the regulations will be impossible to follow, don't you think? Everyone should be playing on the same field. **************************************************************** Kenneth S Petersen Fruit IPM Program Associate Rutgers Cooperative Extension 4 Gauntt Place Flemington, NJ 08822 908-788-1339 internet: petersen@aesop.rutgers.edu FAX 908-806-4735 **************************************************************** From 73507.555@CompuServe.COM Thu Jun 16 21:13:07 1994 Received: from arl-img-2.compuserve.com (arl-img-2.compuserve.com [198.4.7.2]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id VAA25436 for ; Thu, 16 Jun 1994 21:13:06 -0700 Received: from localhost by arl-img-2.compuserve.com (8.6.4/5.940406sam) id AAA23113; Fri, 17 Jun 1994 00:12:35 -0400 Date: 17 Jun 94 00:08:38 EDT From: BOB ROACH <73507.555@CompuServe.COM> To: Subject: Posting in Ca, reply to Z.B. Message-ID: <940617040838_73507.555_HHB85-1@CompuServe.COM> Reply to Zach Berkowitz regarding posting in California: Under the WPS, oral warnings will be the minimum requirement. Additional field posting is required for more dermally toxic materials. California is likely to propose regulations that say that field posting is the equivalent of oral warnings. The truth is that in many cases, oral warnings are difficult to deliver. A posting sign works better. Oral warnings may work fine in a major-crop situation with few workers and large fields but in the opposite case, with easy ranch access and many different crews, it is a logistical nightmare. So in some areas, nearly everything will be posted. The problem will remain when both oral and written warnings are required by a label. Grape growers will have an easier time of it than vegetable growers. It will be interesting to see how this plays out. I understand that the first pre-draft California regulation proposal released last year is changed substantially. I would expect the Department of Pesticide Regulation to release another draft soon for comments. I hope that they do. Implementation is supposed to be just over six months away and it will take several months to go through the process of adopting the regulations. It would be good if the new regulations were out several months before January so that the implementation could coincide with the issuance of restricted material permits in the state. Bob Roach 73507.555@compuserve.com From 73507.555@CompuServe.COM Thu Jun 16 21:14:51 1994 Received: from arl-img-1.compuserve.com (arl-img-1.compuserve.com [198.4.7.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id VAA25806 for ; Thu, 16 Jun 1994 21:14:48 -0700 Received: from localhost by arl-img-1.compuserve.com (8.6.4/5.940406sam) id AAA16364; Fri, 17 Jun 1994 00:14:17 -0400 Date: 17 Jun 94 00:10:18 EDT From: BOB ROACH <73507.555@CompuServe.COM> To: Subject: Rose Exception, reply to K.P. Message-ID: <940617041017_73507.555_HHB85-2@CompuServe.COM> Reply to Kenneth Petersen regarding rose cut flower exemption: <> How do you think a one-size-fits-all regulation is going to work across all the diverse agricultural situations in this country? To extend your playing field analogy, the flower growers are not even to be in the game if they cannot harvest their crop. Some parts of the WPS are impossible to follow now and that is the reason that some variances are needed. I do not see this as opening up a can of worms but as allowing reason and common sense to prevail. When the WPS was written it was not possible to foresee all situations, so some adjustments will be necessary. I am only sorry to hear that the decision only applied to roses. In my opinion, one of the big obstacles in implementation has been a rigid, unyielding attitude on the part of U.S. EPA. In California we have the best and most comprehensive pesticide regulation system in the country. Some parts of the WPS have the potential to wreak havoc with it if implemented as written. One benefit of the WPS is that it will level the playing field among the states. Places like New Jersey, where you are from and I was raised, will have some standards that are at least comparable to California. Then I will challenge you to match enforcement capabilities. I suspect that most other states fall far short in that regard. Bob Roach 73507.555@compuserve.com From PETERSEN@aesop.rutgers.edu Fri Jun 17 05:44:52 1994 Received: from aesop.rutgers.edu (aesop.rutgers.edu [128.6.59.6]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id FAA01131 for ; Fri, 17 Jun 1994 05:44:51 -0700 From: PETERSEN@aesop.rutgers.edu Date: Fri, 17 Jun 1994 8:42:40 -0400 (EDT) To: wps-forum@are.Berkeley.EDU Message-Id: <940617084240.23866@aesop.rutgers.edu> Subject: RE: Rose Exception, reply to K.P. Gee, I didn't know one little comment would get such a response! I have received a couple of good responses to my "level playing field" statement. As usual there are no absolutes in life (or regulations!) and it looks like the WPS fits this as well. I realize that the WPS is a blanket covering all of agriculture, and because ag is so diverse that it can't be expected to cover every situation. It just seems silly to put another set of regulations out that probably is the most comprehensive and difficult regulations for producers to deals with, and then say "here are the WPS regs, everybody follow them except for commodities a,b,c,& z." Its tough for growers to keep on top of ever changing regs ************************************************************** Ken Petersen Rutgers Cooperative Extension IPM Program Associate Extension Center 4 Gauntt Place Flemington, NJ 08822-1928 Phone: (908) 788-1338 Internet: petersen@aesop.rutgers.edu FAX: (908) 806-4735 ************************************************************** From chaos02@tmn.com Fri Jun 17 06:14:40 1994 Received: from tmn.com (tmn.com [198.67.13.2]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id GAA02130 for ; Fri, 17 Jun 1994 06:14:38 -0700 Received: by tmn.com (4.1/2.01) id AA17037; Fri, 17 Jun 94 09:16:09 EDT Date: Fri, 17 Jun 94 09:16:09 EDT From: chaos02@tmn.com (Tom Abeles) Message-Id: <9406171316.AA17037@tmn.com> To: wps-forum@are.Berkeley.EDU Subject: Rose Exception, reply to K.P. on the rose exemption- regulations are written because no one has rust in the capabilities of individuals in any position- users and enforces lto make intellegent decsions- until we can build up some level of trust and trust/competency relations this type of crazy reg/exception will go forward to the delight of the legal profession- it also encourages exceptions and violations- somewhere along the line we have to start believing that education does work and that humans have basic intellegence and some larger best interest alternatives- the regs assume guilt until inocensce is proven and then make perople fight to prove inocence business and management has found that it can't work that way- regulators need to fighure out how to do this also somewhere we need to find a solvent which will loosen the gears between people's ears- somewhere we have to figure out where we can establish basic trust instead of dispassionate reg/exception programs From RUDOLPH.KAY@epamail.epa.gov Mon Jun 20 14:27:37 1994 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id OAA08090 for ; Mon, 20 Jun 1994 14:27:36 -0700 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.2-13 #5309) id <01HDRUGK8BHS8WYMYQ@epavax.rtpnc.epa.gov>; Mon, 20 Jun 1994 17:25:48 EDT Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.2-15 #5309) id <01HDRUEYNCR48ZOO9P@mail.rtpnc.epa.gov>; Mon, 20 Jun 1994 17:24:40 EDT Received: with PMDF-MR; Mon, 20 Jun 1994 17:24:25 EDT MR-Received: by mta CARINA; Relayed; Mon, 20 Jun 1994 17:24:25 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Mon, 20 Jun 1994 17:02:00 -0400 (EDT) From: KAY RUDOLPH 510-733-1065 Subject: RE: WPS IN U.S. TERRITORIES To: "wps-forum@are.Berkeley.EDU" Message-id: <01HDRUF9C32C8ZOO9P@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.Berkeley.EDU MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Mon, 20 Jun 1994 17:17:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;52427102604991/1291907@MAIL] A1-type: MAIL Hop-count: 0 In response to the question from the subscriber requesting information about implementation of the WPS in Puerto Rico: Most territories have pesticide programs to enforce federal regulations, and are implementing the Worker Protection Standard in much the same way as states are doing. Puerto Rico is included in EPA Region 2, and the Worker Protection Program Manager in that Region is Teresa Yaegel-Souffront. Her telephone number is (908) 321-6771. The Puerto Rico Department of Agriculture is the lead agency for pesticide enforcment on the island, and Arline R. de Gonzales, director of the Agriculture Materials Laboratory, will be able to assist you. Her telephone number is (809) 796-1775, FAX (809)796-4426. Her address is: Ms. Arline R. de Gonzalez, Director Agriculture Materials Laboratory Puerto Rico Dept. of Agriculture P.O. Box 10163 Santurce, PR 00908 --Kay rudolph Worker Protection Program Management Region 9, San Francisco From RUDOLPH.KAY@epamail.epa.gov Mon Jun 20 14:47:20 1994 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id OAA09469 for ; Mon, 20 Jun 1994 14:47:19 -0700 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.2-13 #5309) id <01HDRV63UVWW8WYM71@epavax.rtpnc.epa.gov>; Mon, 20 Jun 1994 17:46:27 EDT Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.2-15 #5309) id <01HDRV4DNNGG8ZOP2V@mail.rtpnc.epa.gov>; Mon, 20 Jun 1994 17:45:02 EDT Received: with PMDF-MR; Mon, 20 Jun 1994 17:45:19 EDT MR-Received: by mta CARINA; Relayed; Mon, 20 Jun 1994 17:45:19 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Mon, 20 Jun 1994 17:37:00 -0400 (EDT) From: KAY RUDOLPH 510-733-1065 Subject: WPS Training Verification To: wps-forum@are.Berkeley.EDU Message-id: <01HDRV4I85IY8ZOP2V@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.berkeley.edu MIME-version: 1.0 Content-type: MULTIPART/MIXED; BOUNDARY="Boundary (ID Jf82pNnV+Rj0a6G66wdPPg)" Content-transfer-encoding: 7BIT Posting-date: Mon, 20 Jun 1994 17:39:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;91547102604991/1292071@MAIL] A1-type: MAIL Hop-count: 0 --Boundary (ID Jf82pNnV+Rj0a6G66wdPPg) Content-type: TEXT/PLAIN; CHARSET=US-ASCII I've had some problems with my e-mail program--here we go again. --Boundary (ID Jf82pNnV+Rj0a6G66wdPPg) MIME-version: 1.0 Content-type: MESSAGE/RFC822 Date: Mon, 20 Jun 1994 15:40:00 EDT Subject: WPS Training Verification Card Sender: KAY RUDOLPH 510-733-1065 To: wpsforum@berkeley.edu Content-type: TEXT/PLAIN; CHARSET=US-ASCII Posting-date: Mon, 20 Jun 1994 16:56:00 EDT Importance: normal A1-type: MAIL Apologies for being slow to join the system. My e-mail is not as user friendly as some systems, so I have been flailing about a bit. Al French noted last week that some states do not plan on using the EPA training verification card. That is true, and it is true that that may cause some confusion. But the situation may not be as grim as it first appears, however. California will not be accepting the Handler card, as the state has existing requirements for handler training beyond those represented by the card. All handlers who work in California will have to be trained in California. That will mean that handlers who are trained in California will have to be trained again if they go to work in another state. Hawaii will not be using training verification cards because their workforce is mainly permanent workers, and so cards are not necessary. Tennessee wanted cards that could be computer processed. Tennessee could develop a computer card that resembles the EPA card, and EPA would then assign a block of numbers to Tennessee, so the Tennessee cards would, in effect, be part of the EPA system. I have heard that a number of states (perhaps those listed in Al French's message) do not plan to use cards for the same reason noted by Hawaii--that they do not feel there will be a significant demand from employers in their state. Each state has the authority to decide how training will be verified in that state: they may choose to accept the EPA card only, the EPA card and some other types of documentation, or they may allow only their own state card. Employers should contact their state regulatory agency for informantion about what the state will accept for training verification. --Kay Rudolph Worker Protection Program Manager Region 9, San Francisco --Boundary (ID Jf82pNnV+Rj0a6G66wdPPg)-- From howardr@are.Berkeley.EDU Mon Jun 20 18:24:35 1994 Received: from DialupEudora (eudora@are.Berkeley.EDU [128.32.175.17]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id SAA14770 for ; Mon, 20 Jun 1994 18:24:24 -0700 Date: Mon, 20 Jun 1994 18:24:24 -0700 Message-Id: <199406210124.SAA14770@are.Berkeley.EDU> To: wps-forum From: howardr@are.Berkeley.EDU (Howard Rosenberg) Subject: The Question on State Equivalency with U.S. EPA Standards Two weeks ago Bob Roach asked how the equivalency negotiations were going between California and the U.S. EPA, seeking a clue as to "What are we going to have to deal with in about seven months?" He said he hadn't heard anything new about it for some time. Seemed like a fair question that was pretty important to have answered, but no one has yet posted a response. The only thing I have heard lately about equivalency is that the authority to make an agreement with the state Department of Pesticide Regulation (DPR) has been delegated from U.S. EPA headquarters to its Region 9 office in San Francisco. A few WPS-Forum participants from DPR and EPA have subscribed recently enough to have missed Bob's original posting. Since they are most likely able to provide an informed update on this issue, I raise it again. Is there anything that can be divulged yet about differences between the nationwide WPS and its implementation in California? If not, when can we expect some word? With every day that passes at the current level of uncertainty, the preparation of accurate compliance references and programs gets delayed, and the odds grow a little longer against employers and enforcers alike being ready to meet their obligations in January 1995. While we're on the subject, does anyone know of movement toward equivalency in other states? Howard Rosenberg Agricultural and Resource Economics, UC Berkeley From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Tue Jun 21 07:43:11 1994 Received: from nak.berkeley.edu (nak.Berkeley.EDU [128.32.136.21]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id HAA22619 for ; Tue, 21 Jun 1994 07:43:10 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id HAA25711; Tue, 21 Jun 1994 07:43:09 -0700 Message-Id: <199406211443.HAA25711@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 2497; Tue, 21 Jun 94 07:43:11 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 7808; Tue, 21 Jun 94 07:43:10 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 6153; Tue, 21 Jun 94 10:43:00 EDT Date: Tue, 21 Jun 94 10:41:05 EDT From: Al French Subject: Multilingual WPS Training To: WPS-FORUM X-Acknowledge-To: The WPS indicates that EPA will provide approved training materials only in English and Spanish. However, approved materials in other languages are now available from Ms. Allie Fields, U.S. Environmental Protection Agency, Office of Pesticide Programs (7506C), 401 M Street, S.W., Washington, D.C., 20460. 703/305-7666. Languages presently available include Chinese, English, Korean, Laotian, Philippian, Spanish, Tagalog, and Vietnamese. A Hmong version will soon be available. Perhaps someone from Cornell could post information as to the availability of a Polish version which I understand is being developed there. Employers should note that, if they provide WPS training to any employees, it might be deemed a violation of the Equal Employment Opportunities Act or the anti-discrimination provisions of the Immigration Reform and Control Act to refuse to hire applicants because the employer is unable to provide training in a manner that the applicants can understand. The WPS requires: Training programs. General pesticide safety information shall be presented to workers either orally from written materials or audiovisually. The information must be presented in a manner that the workers can understand (such as through a translator) using nontechnical terms. The presenter also shall respond to workers' questions. Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench@ers.bitnet or afrench%ers.bitnet@vtbit.cc.vt.edu From RUDOLPH.KAY@epamail.epa.gov Tue Jun 21 16:28:34 1994 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id QAA07032 for ; Tue, 21 Jun 1994 16:28:30 -0700 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.2-13 #5309) id <01HDTD00CUXC8WYZL8@epavax.rtpnc.epa.gov>; Tue, 21 Jun 1994 19:27:43 EDT Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.2-15 #5309) id <01HDTCYGAVCW8ZPKOT@mail.rtpnc.epa.gov>; Tue, 21 Jun 1994 19:26:28 EDT Received: with PMDF-MR; Tue, 21 Jun 1994 19:23:18 EDT MR-Received: by mta CARINA; Relayed; Tue, 21 Jun 1994 19:23:18 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Tue, 21 Jun 1994 18:52:00 -0400 (EDT) From: KAY RUDOLPH 510-733-1065 Subject: RE: Multilingual WPS Training To: "wps-forum@are.Berkeley.EDU" Message-id: <01HDTCYMAJMS8ZPKOT@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.Berkeley.EDU MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Tue, 21 Jun 1994 19:17:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;81329112604991/1298108@MAIL] A1-type: MAIL Hop-count: 0 As Al French has noted, the EPA manual "Protect Yourself from Pesticides--Guide for Agricultural Workers" is being translated into a variety of languages. EPA is working to get those translations typeset for publication, and would certainly be interested in hearing from organizations that might be able to help in this effort. Al has also raised the point that the WPS requires that information be presented in a manner that the workers and handlers can understand, such as through a translator. Where are employers going to find translators? There are a number of possibilities: churches and schools have strong links to the communities they serve, and may be able to suggest people who could act as translators. Medical facilities, police departments, and courts often need translators, and may be a source of information. Farmworker advocacy organizations may have bilingual staff that would be willing to assist in translating, or may know of others who could assist in translating. If there are any other suggestions out there, please post them. The WPS sets requirements on the qualifications of the trainer: he or she must either be a certified applicator, be a currently designated trainer of RUP applicators, have attended an approved train-the-trainer program, or (for trainers of workers) have completed pesticide safety training for handlers. The translator does not have to be the qualified trainer, though. The translator must simply be able to translate what the trainer is saying and the questions that workers and handlers may ask. --Kay Rudolph Worker Protection Program Manager US EPA Region 9, San Francisco From Amy_E_BROWN@umail.umd.edu Thu Jun 23 06:09:49 1994 Received: from umailsrv1.UMD.EDU (umailsrv1.umd.edu [128.8.10.53]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id GAA05080 for ; Thu, 23 Jun 1994 06:09:48 -0700 Received: by umailsrv1.UMD.EDU (5.57/Ultrix3.0-C) id AA19038; Thu, 23 Jun 94 09:09:45 -0400 Message-Id: <9406231309.AA19038@umailsrv1.UMD.EDU> Date: Thu, 23 Jun 94 09:09 EDT From: Amy_E_BROWN@umail.umd.edu (ab35) Subject: Re: Multilingual WPS Training To: wps-forum@are.Berkeley.EDU In-Reply-To: <199406211443.HAA25711@nak.berkeley.edu> In regard to the matter of training materials available in different languages, the Task Force on Training Materials recommended that EPA keep track of all EPA-approved and EPA-developed materials as well as translations into other languages. Is anyone at EPA following through? State Extension Services need updates on this subject. We need a printed list that we can hand out or mail out that identifies these materials and how to get copies. I have developed a listing for WPS-related materials and their availability, but so far it doesn't list any materials in languages other than Spanish. I'd be glad to send a copy of my publication to someone at EPA so they can see what information is needed in this kind of a reference document. Amy Brown Pesticide Coordinator Maryland From RUDOLPH.KAY@epamail.epa.gov Thu Jun 23 09:30:13 1994 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id JAA08255 for ; Thu, 23 Jun 1994 09:30:08 -0700 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.2-13 #5309) id <01HDVPSF9BQ88WZYBP@epavax.rtpnc.epa.gov>; Thu, 23 Jun 1994 11:55:44 EDT Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.2-15 #5309) id <01HDVPR07ZTS8ZOUU6@mail.rtpnc.epa.gov>; Thu, 23 Jun 1994 11:54:36 EDT Received: with PMDF-MR; Thu, 23 Jun 1994 11:54:13 EDT MR-Received: by mta PYXIS; Relayed; Thu, 23 Jun 1994 11:54:13 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Thu, 23 Jun 1994 11:37:00 -0400 (EDT) From: KAY RUDOLPH 510-733-1065 Subject: Re: Multilingual WPS Training To: "wps-forum@are.Berkeley.EDU" Message-id: <01HDVPR31JAO8ZOUU6@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.Berkeley.EDU MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Thu, 23 Jun 1994 11:46:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;31451132604991/1305935@MAIL] A1-type: MAIL Hop-count: 0 EPA very recently put together a list of WPS materials, titled: "Worker Protection Standard: Materials Developed by EPA, States and Other Organizations." The item is available from : Ms. Allie Fields US EPA Office of Pesticide Programs (7506C) 401 M Street, S.W. Washiington, D.C. 20460 (703) 305-7666 While the worker training manual has been translated into several languages other than Spanish, we have not been able to get these translations typeset for distribution. Allie would be very interested in receiving information about materials that are not on the EPA list. We are also working at getting this EPA list on the WPS-Forum, and hope to have it available within the next couple of weeks. --Kay Rudolph Worker Protection Program Manager US EPA, Region 9, San Francisco From shenkm@BCC.ORST.EDU Thu Jun 23 11:45:38 1994 Received: from BCC.ORST.EDU (ava.BCC.ORST.EDU [128.193.86.4]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id LAA12214 for ; Thu, 23 Jun 1994 11:45:37 -0700 Received: from [128.193.88.177] (Schenk-2036a-I.CORDLEY.ORST.EDU) by BCC.ORST.EDU (4.1/SMI-4.1) id AA18672; Thu, 23 Jun 94 11:45:40 PDT From: "Myron Shenk" Date: Thu, 23 Jun 94 11:48:20 CST Message-Id: <42502.shenkm@bcc.orst.edu> X-Popmail-Charset: English To: wps-forum@are.Berkeley.EDU Subject: Re: Multilingual WPS Training Amy, while not wps training materials, I know that Oregon OSHA published a small booklet on the safe use of pesticides in some nine or ten languages, a few years back. If of interest to you, contact: Marilyn Schuster Manager of Standards and Technical Resources OR OSHA Labor and Industries Building Room 160 Salem, OR 97310 tel. 503/ 378-3272 Cheers, Myron Shenk, Oregon State University FAX 503/ 378-5729 Myron Shenk (503)737-6274 Internet: shenkm@bcc.orst.edu IPPC Cordley Hall, Rm 2040 Oregon State University Corvallis, Oregon 97331-2915 From dana@are.Berkeley.EDU Fri Jun 24 15:26:18 1994 Received: from [128.32.251.27] (gia3mac17.Berkeley.EDU [128.32.251.27]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id PAA05010 for ; Fri, 24 Jun 1994 15:26:16 -0700 Message-Id: <199406242226.PAA05010@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Fri, 24 Jun 1994 15:26:16 -0800 To: wps-forum From: dana@are.Berkeley.EDU (Dana E. Keil) Subject: booklets Steve Sutter, UC Area Farm Advisor, Fresno, writes: I've recently completed an 8-page digest of US EPA's 100-page "Protect Yourself from Pesticides -- Guide for Pesticide Handlers." I omitted each unit's "opening and review questions," to condense the material to a judicious amount that still embodies the essense of required safety information. One opening question in the EPA version is "Do you find that you are more sensitive to some pesticides than you are to others?" EPA's opening questions are evidently intended to stimulate interaction. The trim UC Cooperative Extension "Handler Training Digest" is available for $1.50. Send check, payable to "County of Fresno," to Ag Personnel Management Program, 1720 S. Maple Ave., Fresno, CA 93702. Write "Digest" on the check margin. Also available, for $3.50, is US EPA's set of 8 brochures, a "guidance package" on personal protective equipment and heat stress. I've packaged it as a single booklet to make the material more accessible to WPS handler trainers. From RUDOLPH.KAY@epamail.epa.gov Fri Jun 24 16:20:52 1994 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id QAA06813 for ; Fri, 24 Jun 1994 16:20:44 -0700 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.2-13 #5309) id <01HDXJKZ3HIO8X1C2J@epavax.rtpnc.epa.gov>; Fri, 24 Jun 1994 19:19:34 EDT Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.2-15 #5309) id <01HDXJJHO6IO8ZPS2W@mail.rtpnc.epa.gov>; Fri, 24 Jun 1994 19:18:21 EDT Received: with PMDF-MR; Fri, 24 Jun 1994 19:15:01 EDT MR-Received: by mta CARINA; Relayed; Fri, 24 Jun 1994 19:15:01 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Fri, 24 Jun 1994 19:08:00 -0400 (EDT) From: KAY RUDOLPH 510-733-1065 Subject: EPA's Q&A document for Rose Exception To: wps-forum@are.Berkeley.EDU Message-id: <01HDXJJL4RH68ZPS2W@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.berkeley.edu MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=ISO-8859-1 Content-transfer-encoding: QUOTED-PRINTABLE Posting-date: Fri, 24 Jun 1994 19:13:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;10519142604991/1313116@MAIL] A1-type: MAIL Hop-count: 0 EPA has put together the following brief document to addres= s the=20 major questions the agricultural community may have about t= he=20 Rose Exception. This document will also be available in the= WPS- Forum archive. --Kay Rudolph US EPA Region 9, San Francisco =20 =20 =20 United States Prevention, Pesticides May = 1994 Environmental Protection And Toxic Substances Agency (7506C) =C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4= =C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4= =C4=C4=C4=C4=C4 =20 Questions & Answers =20 =20 Exception To Early Entry Restrictions for Rose Growers =20 =20 =C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4= =C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4=C4= =C4=C4=C4=C4=C4 =20 =20 1. What action is EPA taking and what will the exception= do? =20 EPA is granting an exception to the pesticide Worker Protection Standard (WPS), originally published in the Aug= ust 21, 1992, Federal Register, that allows, for a 2-year peri= od, under specified conditions, early entry into pesticide-trea= ted areas in greenhouses to harvest cut roses. EPA is denying = an exception to other cut flower and cut fern producers at th= is time. The exception will provide the cut rose industry time= to=20 develop and implement safe alternatives to early entry, or = to present data on the risks and benefits of the exception, including possible alternatives, if they determine another= =20 exception is needed. =20 =20 =20 2. Why is EPA taking this action? =20 EPA believes that rose growers could suffer substantia= l losses if compliance with the WPS restricted-entry interva= ls were required at this time because roses must be harvested= 2 times per day, 7 days per week. EPA believes that the cond= itions of the exception will mitigate worker risk. =20 =20 =20 3. Who may take advantage of this exception? =20 Growers of greenhouse-grown cut roses may take advanta= ge of this exception for harvesting roses if each of the conditi= ons of the exception are followed. =20 =20 =20 4. What are the conditions under which a rose grower may= use this exception to harvest roses? =20 Rose growers must observe the requirements listed belo= w for harvesting cut roses under this exception. =20 The generic early-entry conditions outlined in the WPS = must be followed: No entry may take place for the first 4 hours after = an application. =20 PPE is provided, cleaned and maintained for workers, workers are trained in how to use it, and provided = a place to put on and remove PPE. =20 Label-specific information/training is provided to workers. =20 Measures to mitigate heat stress are taken. = =20 Soap, clean towels, and water to wash thoroughly aft= er removing PPE are provided. =20 Two conditions specific to this exception must also be observed: Early-entry workers are informed that the exception = is being used and what the exception conditions are. = =20 Each worker is limited to 3 hours of early entry per 24-hour period. =20 Also, some basic WPS protections, which have been delay= ed for agricultural employers in general by legislation, = must be followed for rose growers using this exception. Th= e following protections, which EPA believes important to early-entry rose harvester safety, must be provided: Basic safety training is provided. =20 The WPS safety poster is displayed. =20 Application information is displayed at a central notification area. =20 A general decontamination site is provided. = =20 Emergency assistance is provided if a worker gets si= ck or injured because of pesticide exposure. =20 =20 5. Can other growers ask for an exception to the early e= ntry restrictions? =20 The Worker Protection Standard (WPS) establishes a pro= cess for EPA to consider requests for exceptions. The WPS stat= es that exception decisions will be based on whether the bene= fits of the exception outweigh the cost, including the value of = the=20 health risks attributable to the exception. The WPS also l= ists the information which should be submitted with exception requests to decide whether to grant the exception.Generally= , the information includes: Crop and pesticide use descriptions.=20 Alternative practices and why each would not be technic= ally or financially viable.=20 Per-acre economic estimates and supporting data for the= crop and area for which the exception is requested.=20 Descriptions or documentation of the safety and feasibi= lity of the exception for each crop task.=20 Descriptions of the costs associated with early entry. =20 =20 6. How does the 1994 Act delaying some of the WPS provis= ions affect this action? =20 Due to the legislation delaying certain provisions of = the WPS until January 1, 1995, EPA has included some of the ba= sic protections in the terms of this exception.EPA believes the= y are necessary to prevent unacceptable worker risk under the= =20 exception. Those provisions include: =20 =20 Basic safety training (under section 170.130).=20 General decontamination (section 170.150).=20 Information displayed at a central notification area (section 170.122).=20 Safety poster display (section 170.135).=20 Emergency assistance (section 170.160). =20 From dana@are.Berkeley.EDU Fri Jun 24 17:25:07 1994 Received: from [128.32.251.27] (gia3mac17.Berkeley.EDU [128.32.251.27]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id RAA08832; Fri, 24 Jun 1994 17:25:04 -0700 Message-Id: <199406250025.RAA08832@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Fri, 24 Jun 1994 17:25:05 -0800 To: wps-forum From: dana@are.Berkeley.EDU (Dana E. Keil) Subject: reformatted K. Rudolph message It looks like the message sent recently by Kay Rudolph with the subject line "EPA's Q&A document for Rose Exception" may have arrived at some of our mailboxes with garbled formatting. Here's my attempt at rectifying it. cheers, Dana Keil, list manager ------original message follows------ EPA has put together the following brief document to address the major questions the agricultural community may have about the Rose Exception. This document will also be available in the WPS- Forum archive. --Kay Rudolph US EPA Region 9, San Francisco United States Prevention, Pesticides May 1994 Environmental Protection And Toxic Substances Agency (7506C) ----------------------------------------------- Questions & Answers Exception To Early Entry Restrictions for Rose Growers ---------------------------------------------- 1. What action is EPA taking and what will the exception do? EPA is granting an exception to the pesticide Worker Protection Standard (WPS), originally published in the August 21, 1992, Federal Register, that allows, for a 2-year period, under specified conditions, early entry into pesticide-treated areas in greenhouses to harvest cut roses. EPA is denying an exception to other cut flower and cut fern producers at this time. The exception will provide the cut rose industry time to develop and implement safe alternatives to early entry, or to present data on the risks and benefits of the exception, including possible alternatives, if they determine another exception is needed. 2. Why is EPA taking this action? EPA believes that rose growers could suffer substantial losses if compliance with the WPS restricted-entry intervals were required at this time because roses must be harvested 2 times per day, 7 days per week. EPA believes that the conditions of the exception will mitigate worker risk. 3. Who may take advantage of this exception? Growers of greenhouse-grown cut roses may take advantage of this exception for harvesting roses if each of the conditions of the exception are followed. 4. What are the conditions under which a rose grower may use this exception to harvest roses? Rose growers must observe the requirements listed below for harvesting cut roses under this exception. The generic early-entry conditions outlined in the WPS must be followed: No entry may take place for the first 4 hours after an application. PPE is provided, cleaned and maintained for workers, workers are trained in how to use it, and provided a place to put on and remove PPE. Label-specific information/training is provided to workers. Measures to mitigate heat stress are taken. Soap, clean towels, and water to wash thoroughly after removing PPE are provided. Two conditions specific to this exception must also be observed: Early-entry workers are informed that the exception is being used and what the exception conditions are. Each worker is limited to 3 hours of early entry per 24-hour period. Also, some basic WPS protections, which have been delayed for agricultural employers in general by legislation, must be followed for rose growers using this exception. The following protections, which EPA believes important to early-entry rose harvester safety, must be provided: Basic safety training is provided. The WPS safety poster is displayed. Application information is displayed at a central notification area. A general decontamination site is provided. Emergency assistance is provided if a worker gets sick or injured because of pesticide exposure. 5. Can other growers ask for an exception to the early entry restrictions? The Worker Protection Standard (WPS) establishes a process for EPA to consider requests for exceptions. The WPS states that exception decisions will be based on whether the benefits of the exception outweigh the cost, including the value of the health risks attributable to the exception. The WPS also lists the information which should be submitted with exception requests to decide whether to grant the exception.Generally, the information includes: Crop and pesticide use descriptions. Alternative practices and why each would not be technically or financially viable. Per-acre economic estimates and supporting data for the crop and area for which the exception is requested. Descriptions or documentation of the safety and feasibility of the exception for each crop task. Descriptions of the costs associated with early entry. 6. How does the 1994 Act delaying some of the WPS provisions affect this action? Due to the legislation delaying certain provisions of the WPS until January 1, 1995, EPA has included some of the basic protections in the terms of this exception.EPA believes they are necessary to prevent unacceptable worker risk under the exception. Those provisions include: Basic safety training (under section 170.130). General decontamination (section 170.150). Information displayed at a central notification area (section 170.122). Safety poster display (section 170.135). Emergency assistance (section 170.160). From rbonanno@coopext.umass.edu Mon Jun 27 19:08:31 1994 Received: from RFD.UCS.UMASS.EDU (rfd.ucs.umass.edu [128.119.175.3]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id TAA09016 for ; Mon, 27 Jun 1994 19:08:30 -0700 Received: from phobos.ucs.umass.edu by rfd.ucs.umass.edu (PMDF V4.3-8 #6523) id <01HE1WDIOS000084NN@rfd.ucs.umass.edu>; Mon, 27 Jun 1994 22:08:28 -0400 Received: from phobos.ucs.umass.edu by phobos.ucs.umass.edu (PMDF V4.3-8 #6523) id <01HE1WDG3MTS8WW6KN@phobos.ucs.umass.edu>; Mon, 27 Jun 94 22:08:24 -0400 Date: Mon, 27 Jun 1994 22:08:24 -0400 From: "A. Richard Bonanno" Subject: Re: reformatted K. Rudolph message To: wps-forum@are.Berkeley.EDU Message-id: <01HE1WDG46428WW6KN@phobos.ucs.umass.edu> X-VMS-To: IN%"wps-forum@are.Berkeley.EDU" MIME-version: 1.0 Content-transfer-encoding: 7BIT delete rbonanno@coopext.umass.edu