From dana@are.Berkeley.EDU Thu Sep 1 08:01:57 1994 Received: from [128.32.251.16] (gia3mac6.Berkeley.EDU [128.32.251.16]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id IAA11883 for ; Thu, 1 Sep 1994 08:01:55 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Thu, 1 Sep 1994 08:01:56 -0800 To: wps-forum From: dana@are.Berkeley.EDU (Dana E. Keil) Subject: C. Coffman's email address It's come to my attention that the message I forwarded from Charlotte Coffman the other day mentioned that she could be contacted and then, because I had forwarded the message, did not have her email address in it. Here it is: CHARLOTTE_COFFMAN@QMRELAY.MAIL.CORNELL.EDU ____ Dana E. Keil Department of Agricultural and Resource Economics dana@are.Berkeley.EDU University of California, Berkeley From gebillikopf@ucdavis.edu Thu Sep 1 12:24:40 1994 Received: from ucdavis.ucdavis.edu (ucdavis.ucdavis.edu [128.120.1.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id MAA19721 for ; Thu, 1 Sep 1994 12:24:34 -0700 From: gebillikopf@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by ucdavis.ucdavis.edu (8.6.9/UCD2.50) id MAA16696; Thu, 1 Sep 1994 12:22:49 -0700 Date: Thu, 1 Sep 1994 12:22:49 -0700 Message-Id: <199409011922.MAA16696@ucdavis.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: Free Pesticide Game cc: hrnet@cornell.edu WPS net--Free copies of Spanish Pesticide Game still available If you are a consultant, agency, government, University, or clinic, free copies of Melanie Zavala's game "La Loteria de los Pesticidas" is still available. It is a great training tool to break up a longer training session, and is well received by farm workers. Get your free copy by sending a written request on your letterhead to the Modesto address below. Farmers--Can purchase Spanish Pesticide Game for $15 Purchase from ANR publications, 510-642-2431 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 pearson@vegmail.ucdavis.edu Thu Sep 1 14:31:16 1994 Received: from ucdavis.ucdavis.edu (ucdavis.ucdavis.edu [128.120.1.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id OAA24037 for ; Thu, 1 Sep 1994 14:31:16 -0700 Received: from vegmail.ucdavis.edu by ucdavis.ucdavis.edu (8.6.9/UCD2.50) id OAA01571; Thu, 1 Sep 1994 14:31:07 -0700 Received: by vegmail.ucdavis.edu with Microsoft Mail id <2E6648F7@vegmail.ucdavis.edu>; Thu, 01 Sep 94 14:34:47 PDT From: "Pearson, G." To: wps-forum Subject: RE: WPS Poll Date: Thu, 01 Sep 94 14:28:00 PDT Message-ID: <2E6648F7@vegmail.ucdavis.edu> Encoding: 40 TEXT X-Mailer: Microsoft Mail V3.0 4 ---------- From: wps-forum To: Multiple recipients of list Subject: WPS Poll Date: Tuesday, August 30, 1994 4:47PM WPS-EPA In your opinion, if a farmer provides WPS training for his/hers Farm Labor Contractor's field workers, does his/hers FLC lose independent contractor status? 1. Definitively 2. Quite likely 3. Unsure 4. Unlikely 5. Definitively not 6. No opinion as I do not know much about independent contractor regulations Please hit reply button, and quickly anwer this question and I will sumarize answers. The more votes the better, so please do this now. 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 gebillikopf@ucdavis.edu Thu Sep 1 14:33:25 1994 Received: from ucdavis.ucdavis.edu (ucdavis.ucdavis.edu [128.120.1.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id OAA24130 for ; Thu, 1 Sep 1994 14:33:24 -0700 From: gebillikopf@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by ucdavis.ucdavis.edu (8.6.9/UCD2.50) id OAA01819; Thu, 1 Sep 1994 14:33:11 -0700 Date: Thu, 1 Sep 1994 14:33:11 -0700 Message-Id: <199409012133.OAA01819@ucdavis.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: RESULTS-WPS POLL Original question: In your opinion, if a farmer provides WPS training for his/hers Farm Labor Contractor's field workers, does his/hers FLC lose independent contractor status? Responses: 1. Definitevely (none) 2. Quite likely (2) 3. Unsure/depends (2) 4. Unlikely (2) 5. Definitively not (1) 6. No opinion as I (11) do not know much about independent contractor regulations. I have also been asking this question of labor attorneys and labor management specialists. The wording for them was slightly different. From a scale of 1 to 5, where 1 means that a FLC would definitively lose independent contractor status and 5 the FLC would definitively not lose independent contractor status. REsults from this informal survey showed a range from a 2 to a 4, with a slight tendency toward a 2. Additional explanation about Independent Contractor status and Joint Employer issues: It all boils down to who is the employer. Under the ALRA (ag labor relations act for California) the FLC cannot be an employer, so the grower becomes the employer. For the purpose of I-9 recordkeeping and liability for hiring undocumented workers, the burden falls on the FLC only if the FLC is an independent contractor. With a few exceptions, no one factor will make a FLC lose his independent contractor status with a grower. Factors considered include: does this FLC work for other employers; who provides the tools, who provides supervision, etc. THe IRS has a list of 20 items it uses in making independent contractor evaluations. The issue of independent contractor applies to the relationship with a particular grower, such that a FLC may be considered an independent contractor when carrying out duties for one grower but not for another. Joint employer status can shift liability to growers when it can be shown both grower and FLC shared responsibilities. So, while some laws are very specific as to who is the employer, it may be argued that certain actions can affect a grower-FLC relationship status in other areas. "It is a balancing test, and an issue of control" as one attorney who asked not to be identified explained. My opinion: While I realize that this is a balancing act, with many factors considered, I voted a 2, and feel that when a grower trains the employees of a FLC it may be hard to defend the argument that the FLC is the sole employer. It is easy to see how someone might say that the FLC and grower are joint employers in this case. An interesting comment: Al French writes, "FLCs are seldom found to be independent contractors by the courts. Farmers who believe they have an independent contractor arrangement frequently hold a different view than enforcement agencies, particularly the Department of Labor's Wage & Hour Division (DOL). The Nactional Council of Agricultural Employers (NCAE) has recently issued a memo that disucsses recent litigation on this subject. DOL's FLC compliance office can be reached at 1-800-800-0235; NCAE at 202-728-0300." I tried the 800 number but will have to try again as I got not answer. It is too late in the day to get an answer from the 202 number. So, I do not know why there is a discrepancy between DOL and growers in this area, and what effect, if any, might a grower training his or hers FLCs employees have on the issue. Why is this important? If I hired a FLC, I would want to encourage the FLC to become a trainer so the FLC can provide his or her own training. Along with the state and federal FLC proof of registration, I would want proof that the workers had been trained. Of course, someone else can train the workers, and it would matter little if the FLC or someone else provide the training. But, realistically, I am sure FLCs have enough turnover that it would be hard for them to have an outside trainer every time a new worker is hired. UC IPM sponsored training for field workers and handlers. In California UC IPM will be conducting train-the-trainer classes for field workers (in Spanish) and for handlers (in English) in multiple locations throughout the state. For more information call: 916-752-7691. Workshops begin September 20, 1994 Your comments and viewpoints are welcome. Send them directly to the net so others can benefit from your opinions. 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 rugge@lifesci.lscf.ucsb.edu Thu Sep 1 14:55:57 1994 Received: from lifesci.lscf.ucsb.edu (root@lifesci.lscf.ucsb.edu [128.111.226.5]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id OAA26062 for ; Thu, 1 Sep 1994 14:55:56 -0700 Received: from [128.111.226.92] (greenhouse.lscf.ucsb.edu) by lifesci.lscf.ucsb.edu (4.1/LSCF.UCSB-v1.3R) id AA08656; Thu, 1 Sep 94 14:57:30 PDT Date: Thu, 1 Sep 94 14:57:28 PDT Message-Id: <9409012157.AA08656@lifesci.lscf.ucsb.edu> To: wps-forum@are.Berkeley.EDU From: rugge@lifesci.lscf.ucsb.edu (Barron Rugge) Subject: RE: WPS Poll >4Poll-#6 > ---------- >From: wps-forum >To: Multiple recipients of list >Subject: WPS Poll >Date: Tuesday, August 30, 1994 4:47PM > > >WPS-EPA > >In your opinion, if a farmer provides WPS training for his/hers Farm Labor >Contractor's field workers, does his/hers FLC lose independent contractor >status? > >1. Definitively >2. Quite likely >3. Unsure >4. Unlikely >5. Definitively not >6. No opinion as I do not know much about independent contractor >regulations > > >Please hit reply button, and quickly anwer this question and I will sumarize > >answers. The more votes the better, so please do this now. > >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 > >************************************************************************ ***************************************************************** * Barron Rugge E-Mail rugge@lifesci.lscf.ucsb.edu * * Department of Biology * * Greenhouse Office Phone (805) 893-2867 * * University of California * * Santa Barbara, CA 93106 FAX (805) 893-4724 * ***************************************************************** From LOWEN@galaxy.gov.bc.ca Thu Sep 1 16:40:37 1994 Received: from VENUS.GOV.BC.CA (VENUS.GOV.BC.CA [142.32.2.21]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id QAA02805 for ; Thu, 1 Sep 1994 16:40:37 -0700 Received: from mr.gov.bc.ca by VENUS.GOV.BC.CA (PMDF V4.2-15 #6803) id <01HGLS4R1V1C8WX6WV@VENUS.GOV.BC.CA>; Thu, 1 Sep 1994 16:40:16 PDT Received: with PMDF-MR; Thu, 1 Sep 1994 16:35:32 PDT MR-Received: by mta MARS; Relayed; Thu, 01 Sep 1994 16:35:32 -0700 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Thu, 01 Sep 1994 16:26:00 -0700 (PDT) From: Lorne Owen 852-5211 Subject: Re: WPS Poll To: "wps-forum@are.Berkeley.EDU" Message-id: <01HGLS5EW9TM8WX6WV@mr.gov.bc.ca> MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Thu, 01 Sep 1994 16:28:00 -0700 (PDT) Importance: normal Priority: normal X400-MTS-identifier: [;23536110904991/2328740@GALAXY] A1-type: MAIL Hop-count: 0 6 Just thought I would let you know I'm still reading what is going on. It seems like a great discussion group for you folks. I have suggetssted that some of our AES people who are doing training gain access to this discussion group. Lorne From howardr@are.Berkeley.EDU Thu Sep 1 17:48:36 1994 Received: from [128.32.251.98] (gia5mac18.Berkeley.EDU [128.32.251.98]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id RAA04738 for ; Thu, 1 Sep 1994 17:48:34 -0700 Message-Id: <199409020048.RAA04738@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Thu, 1 Sep 1994 17:49:13 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: NASDA petition now in forum archive Ray Mcallister has graciously provided us with a computer file containing the full text of the (11-page) petition submitted 7/8/94 by the National Association of State Departments of Agriculture to EPA Administrator Carol M. Browner, asking for specific revisions in the WPS. The NASDA news release summarizing this petition was posted here last month. The full petition is now available in the forum archive. To obtain a copy, send to ListProc@are.berkeley.edu (**not** to wps-forum) the message: GET WPS-FORUM nasda.pet Thank you very much, Ray. Howard From ZIMMERMAN_TOM/OMGATE_OA@gate.us.ohio-state.edu Thu Sep 1 19:32:34 1994 Received: from gate.us.ohio-state.edu (gate.us.ohio-state.edu [128.146.15.5]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id TAA06576 for ; Thu, 1 Sep 1994 19:32:33 -0700 From: ZIMMERMAN_TOM/OMGATE_OA@gate.us.ohio-state.edu Received: from by gate.us.ohio-state.edu with SMTP (1.38.193.5/15.6) id AA20434; Thu, 1 Sep 1994 22:30:02 -0400 X-Openmail-Hops: 2 Date: Thu, 1 Sep 94 23:34:00 -0400 Message-Id: In-Reply-To: <"199408302347.QAA*"@MHS> Subject: WPS Poll To: wps-forum@are.Berkeley.EDU #6 -- Don't know much about contractor regulations. Tom Zimmerman The Ohio State University Wooster, Ohio 44691 zimmerman.4@osu.edu From <@cmsa.Berkeley.EDU:JRUNYAN@ERS.BITNET> Fri Sep 2 03:59:28 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 DAA10691 for ; Fri, 2 Sep 1994 03:59:27 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id DAA14634; Fri, 2 Sep 1994 03:59:26 -0700 Message-Id: <199409021059.DAA14634@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 8382; Fri, 02 Sep 94 03:59:21 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 8776; Fri, 02 Sep 94 03:59:21 PDT Received: from ERS (JRUNYAN) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 5734; Fri, 02 Sep 94 06:59:14 EDT Comments: Converted from PROFS to RFC822 format by PUMP V2.2X Date: Fri, 2 Sep 94 06:59:13 EDT From: Subject: RE: WPS Poll In-Reply-To: note of 09/01/94 17:57 To: Jack Runyan ARED-FRE/FS Room 224, 219-0932 3 Thank You From gebillikopf@ucdavis.edu Fri Sep 2 08:57:46 1994 Received: from ucdavis.ucdavis.edu (ucdavis.ucdavis.edu [128.120.1.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id IAA13447 for ; Fri, 2 Sep 1994 08:57:45 -0700 From: gebillikopf@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by ucdavis.ucdavis.edu (8.6.9/UCD2.50) id IAA20522; Fri, 2 Sep 1994 08:57:33 -0700 Date: Fri, 2 Sep 1994 08:57:33 -0700 Message-Id: <199409021557.IAA20522@ucdavis.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: AG-HRnet cc: hrnet@cornell.edu Reply to gregorio Please excuse the multiple posting under both the Worker Protection Standards net (wps-forum@are.berkeley.edu) Human Resource Management net-Academy of Management (hrnet@cornell.edu) WOULD YOU BE INTERESTED IN JOINING AN AGRICULTURAL HUMAN RESOURCE NET? This is a preliminary inquiry to determine if the formation of such a net would be worthwhile. This would work much like Howard R. Rosenberg's WPS net, but it would not have the benefit of such a concentrated focus. Topics to be discussed: 1. Human resource management within agriculture (e.g., employee selection, pay, discipline, worker motiation, conflict management, etc.) 2. Labor law compliance issues in agriculture (e.g., OSHA regulations, workers' compensation, posting requirements, etc.) 3. Labor law policy issues (e.g., immigration reform, etc.) ONCE AGAIN, THIS IS ONLY A PRELIMINARY INQUIRY, SO LET US KNOW IF YOU ARE INTERESTED. If there is enough interest, we will look further into creating a AG-HRnet. Reply to 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 <@cmsa.Berkeley.EDU:JRUNYAN@ERS.BITNET> Fri Sep 2 10:15:28 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 KAA15150 for ; Fri, 2 Sep 1994 10:15:27 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id KAA13025; Fri, 2 Sep 1994 10:15:26 -0700 Message-Id: <199409021715.KAA13025@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 5044; Fri, 02 Sep 94 10:15:17 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 8999; Fri, 02 Sep 94 10:14:45 PDT Received: from ERS (JRUNYAN) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 7911; Fri, 02 Sep 94 13:14:30 EDT Comments: Converted from PROFS to RFC822 format by PUMP V2.2X Date: Fri, 2 Sep 94 13:14:27 EDT From: Subject: AG-HRnet In-Reply-To: note of 09/02/94 11:59 To: Jack Runyan ARED-FRE/FS Room 224, 219-0932 Yes. Thank You From howardr@are.Berkeley.EDU Fri Sep 2 11:14:45 1994 Received: from [128.32.251.98] (gia5mac18.Berkeley.EDU [128.32.251.98]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id LAA16851 for ; Fri, 2 Sep 1994 11:14:43 -0700 Message-Id: <199409021814.LAA16851@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Fri, 2 Sep 1994 11:15:23 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: our forum Very sorry to clog the lines again with non-substantive stuff, but conversations with two netters have persuaded me that this message is worth posting. In his post this morning Gregory referred to wps-forum as "Howard R. Rosenberg's WPS net". Want to make clear that I do not share this notion and am extremely uncomfortable about what it may imply. The forum is a network of, by, and for all its subscribers. As the welcome message says, it is a UC public service, not moderated, and will be maintained as long as there is an evident need. Howard From LSNDVL@ucipm.ucdavis.edu Fri Sep 2 14:06:21 1994 Received: from ucipm.ucdavis.edu (ucipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id OAA21343 for ; Fri, 2 Sep 1994 14:06:21 -0700 From: LSNDVL@ucipm.ucdavis.edu Message-Id: <199409022106.OAA21343@are.Berkeley.EDU> Received: (from user LSNDVL) by ucipm.ucdavis.edu; 02 Sep 94 14:09:51 PDT Subject: re: WPS Poll To: wps-forum@are.Berkeley.EDU Date: 02 Sep 94 14:09:51 PDT Here's my vote for #5 send OA$$ '$OA$ From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Tue Sep 6 05:14:43 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 FAA25662 for ; Tue, 6 Sep 1994 05:14:42 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id FAA22422; Tue, 6 Sep 1994 05:14:42 -0700 Message-Id: <199409061214.FAA22422@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 6220; Tue, 06 Sep 94 05:14:35 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 3786; Tue, 06 Sep 94 05:14:35 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 8076; Tue, 06 Sep 94 08:14:18 EDT Date: Tue, 06 Sep 94 07:29:16 EDT From: Al French Subject: Howard's net To: WPS-FORUM@are.Berkeley.EDU X-Acknowledge-To: All disclaimers aside, I think Howard is doing a great job managing "our" net. It takes a lot of work and the results of his effort are evident. So despite the risk of making him even more uncomfortable, I'd say "WELL DONE, HOWARD." Al French USDA Coordinator, Agricultural Labor Affairs 202-720-4737 afrench@ers.bitnet From siebert Tue Sep 6 08:45:32 1994 Received: from localhost (siebert@localhost) by are.Berkeley.EDU (8.6.5/8.6.5) id IAA27384 for wps-forum@are.Berkeley.EDU; Tue, 6 Sep 1994 08:45:32 -0700 From: Jerry Siebert Message-Id: <199409061545.IAA27384@are.Berkeley.EDU> Subject: Re: our forum To: wps-forum@are.Berkeley.EDU Date: Tue, 6 Sep 1994 08:45:31 -0700 (PDT) In-Reply-To: <199409021814.LAA16851@are.Berkeley.EDU> from "Howard R. Rosenberg" at Sep 2, 94 11:15:07 am X-Mailer: ELM [version 2.4 PL23] MIME-Version: 1.0 Content-Type: text/plain; charset=US-ASCII Content-Transfer-Encoding: 8bit Content-Length: 54 Howard: I think you're over reacting. Jerry Siebert From dana@are.Berkeley.EDU Tue Sep 6 09:16:16 1994 Received: from [128.32.251.16] (gia3mac6.Berkeley.EDU [128.32.251.16]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id JAA28166; Tue, 6 Sep 1994 09:16:13 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Tue, 6 Sep 1994 09:16:14 -0800 To: wps-forum From: dana@are.Berkeley.EDU (Dana E. Keil) Subject: A common listproc error message I have received questions like this from a number of subscribers now, so I'm sending the answer to the whole group thinking there may be others interested in the explanation. >Hi Dana, >>I'm confused about an error message I have received, twice now. I >requested a copy of the Petition for Worker Protection Standard >Rulemaking. I received a message back saying "unrecognized >request" but I also received the Petition. I am signed up for the WPS >forum, and am receiving information, but I also received an error >message after signing up for that list. The error message said >unrecognized request. > >I'm not sure what I am doing incorrectly, and am somewhat of a >novice on internet. You're not really doing anything incorrectly, the error message comes from the fact that requests sent to listproc@are.berkeley.edu are processed by an automated software procedure that is set up to read each line of an email message as a command. When it comes to something in a message that is not one of the commands that it is programmed to recognize, it stops processing the message and returns an error message to the sender. In the requests you have sent to the listproc address, your name or address is tacked on to the end of the message. This generates an error message that is somewhat confusing because it says "unrecognized request" and then lists your name or address. It's confusing because the error message is not saying "Hey, Dana Keil, you sent me an unrecognized request" but rather "The line that I didn't recognize started with the words Dana Keil." But any valid commands on previous lines have already been processed successfully, so you do get what you were really requesting. There is a way to prevent getting these error messages. The listproc software is programmed to stop looking for requests when it encounters a line that contains just two hyphens. So all you need to do is to put two hyphens before your "signature" as I have done with the signature on this message. If you have an automatic signature that your email software puts in, you would have to either edit the contents of the automatic signature or simply end your message with a line containing two hyphens. It would be great if everyone sending requests to listproc@are.berkeley.edu would either turn off their signature line or make sure that their signature begins with a line containing just two hyphens; that would greatly reduce the number of erroneous error messages that the list manager and list owners have to deal with. -- Dana E. Keil Department of Agricultural and Resource Economics dana@are.Berkeley.EDU University of California, Berkeley From Zax0114@aol.com Tue Sep 6 16:05:29 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 QAA10584 for ; Tue, 6 Sep 1994 16:05:29 -0700 From: Zax0114@aol.com Received: by mail02.prod.aol.net (1.38.193.5/16.2) id AA04687; Tue, 6 Sep 1994 19:04:52 -0400 X-Mailer: America Online Mailer Sender: "Zax0114" Message-Id: <9409061904.tn415105@aol.com> To: wps-forum@are.Berkeley.EDU Date: Tue, 06 Sep 94 19:04:52 EDT Subject: Re: RESULTS-WPS POLL It sounds like farmers should stay away from training FLC employees. This is pretty clear. What about the content of the training? We have work rules and codes of safe practices that we constantly review with our workers. If we hire a FLC to perform a task or operate a ranch, to what extent can we encourage them to practice our rules. The reasons to even explore this are: 1. how do we explain to our workers and field supervisors that it's alright if FLC workers are performing a job in a way that would be considered unsafe according to our rules. 2. if an accident took place - who is liable. We assume that we would be involved in some way and if so, do we have the right to determine work rules for the FLC? Pesticide related safety is a little more black and white than areas such as harvest activities or tractor driving but even pesticide safety has some gray areas. How much say does the farmer have in assuring that FLC employees are properly trained? From TOLAND.WAYNE@EPAMAIL.EPA.GOV Wed Sep 7 05:53:40 1994 Received: from ARTHUR.RTPTOK.EPA.GOV (arthur.rtptok.epa.gov [134.67.212.29]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id FAA24771 for ; Wed, 7 Sep 1994 05:53:39 -0700 From: TOLAND.WAYNE@EPAMAIL.EPA.GOV Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with WordPerfect_Office; Wed, 07 Sep 1994 08:43:36 -0400 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Wed, 07 Sep 1994 08:51:37 -0400 To: wps-forum@are.Berkeley.EDU Subject: WPS-FORUM digest 76 -Reply "Unsubscribe WPS-Forum" From gebillikopf@ucdavis.edu Wed Sep 7 08:20:49 1994 Received: from ucdavis.ucdavis.edu (ucdavis.ucdavis.edu [128.120.1.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id IAA26091 for ; Wed, 7 Sep 1994 08:20:49 -0700 From: gebillikopf@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by ucdavis.ucdavis.edu (8.6.9/UCD2.50) id IAA21135; Wed, 7 Sep 1994 08:20:40 -0700 Date: Wed, 7 Sep 1994 08:20:40 -0700 Message-Id: <199409071520.IAA21135@ucdavis.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: RESULTS-WPS POLL Regarding your question (attached) about FLCs, I would say that while there is a line to be drawn between specifying safety procedures that need to be followed and doing the training yourself, I feel you would be well within safety to give your FLC clear safety guidelines that need to be followed. If these guidelines are being broken by one of the employees, talk to the FLC and ask her or him to speak to the employee. Gregorio > It sounds like farmers should stay away from training FLC employees. This is > pretty clear. What about the content of the training? We have work rules > and codes of safe practices that we constantly review with our workers. If > we hire a FLC to perform a task or operate a ranch, to what extent can we > encourage them to practice our rules. The reasons to even explore this are: > 1. how do we explain to our workers and field supervisors that it's alright > if FLC workers are performing a job in a way that would be considered unsafe > according to our rules. > 2. if an accident took place - who is liable. We assume that we would be > involved in some way and if so, do we have the right to determine work rules > for the FLC? > > Pesticide related safety is a little more black and white than areas such as > harvest activities or tractor driving but even pesticide safety has some gray > areas. How much say does the farmer have in assuring that FLC employees are > properly trained? > > > *********************************************************************** 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 dana@are.Berkeley.EDU Wed Sep 7 08:28:33 1994 Received: from [128.32.251.16] (gia3mac6.Berkeley.EDU [128.32.251.16]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id IAA26251 for ; Wed, 7 Sep 1994 08:28:31 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Wed, 7 Sep 1994 08:28:34 -0800 To: wps-forum From: dana@are.Berkeley.EDU (Dana E. Keil) Subject: another reminder In order to fend off a flurry of messages sent to the wrong address, I must once again remind the group that unsubscribe messages should be sent to listproc@are.berkeley.edu. Do not send your unsubscribe requests to the forum address, please. Dana Keil, mailing list manager -- Dana E. Keil Department of Agricultural and Resource Economics dana@are.Berkeley.EDU University of California, Berkeley From charlie@hpirs.stjohn.hawaii.edu Wed Sep 7 20:00:45 1994 Received: from relay1.Hawaii.Edu (relay1.Hawaii.Edu [128.171.41.53]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id UAA27616 for ; Wed, 7 Sep 1994 20:00:44 -0700 Received: from uhunix.uhcc.Hawaii.Edu ([128.171.44.54]) by relay1.Hawaii.Edu with SMTP id <11405>; Wed, 7 Sep 1994 17:00:36 -1000 Received: from hpirs.stjohn.hawaii.edu by uhunix.uhcc.Hawaii.Edu (4.1/Sun690) id AA16511; Wed, 7 Sep 94 16:58:53 HST Date: Wed, 7 Sep 1994 16:58:53 -1000 Received: from HPIRS/MAILQUEUE by hpirs.stjohn.hawaii.edu (Mercury 1.11); Wed, 7 Sep 94 16:41:44 -1000 Received: from MAILQUEUE by HPIRS (Mercury 1.11); Wed, 7 Sep 94 16:41:36 -1000 Received: from [128.171.243.14] by hpirs.stjohn.hawaii.edu (Mercury 1.11); Wed, 7 Sep 94 16:41:34 -1000 To: WPS-Forum@are.Berkeley.EDU From: charlie@hpirs.stjohn.hawaii.edu Subject: Gloves, Linings, Sweat & Dermatitis Cc: barry@hpirs.stjohn.hawaii.edu Message-Id: <177AD95F88@hpirs.stjohn.hawaii.edu> >>> A grower asked me to post the following problem & question. <<< "We are encountering a problem with section 170.240c5. It prohibits the use of linings with waterproof gloves unless specifically allowed on the label. >>> 170.240c5 Gloves shall be of the type specified by the product labeling. Gloves or glove linings made of leather, cotton, or other absorbent material shall not be worn for handling activities unless such materials are listed on the product labelin as acceptable for such use. <<< "The pesticides being used are herbicides. Applicators apply the material using backpack sprayers 8 hours/day. In the past, applicators had used cotton glove with a rubber-like coating. It does breathe, and therefore, their hands remain dry throughout the day. Liquids would "bead" off the glove. If there was exposure, they would know since their hands would get wet, and corrective actions could be taken immediately. "Due to the new standard, rubber gloves were issued since linings are not allowed. The applicators' hands get totally soaked within an hour, and thereafter, are working in a "pool" of water. We have tried skin protection creams and other protectants but they do not hold up with the excessive moisture. Within days, some applicators hands started to turn red, indicating the start of dermatitis problems. "It appears to that the past practice protected the applicators adequately. It allowed early notification if there was exposure to the hands from leaks. The new requirement results in a condition that can expose the applicator to pesticide without his/her knowledge. Changing the glove frequently is not practical since on hot days, the hands get water soaked within minutes. The hands would need time to dry before being placed into another pair of gloves. The amount of time spent on a "break" during an eight hour day would be prohibitive. "How have other users handled this issue?" >>> fromCHARLIE NAGAMINE, University of Hawaii <<< From PMARER@ucipm.ucdavis.edu Thu Sep 8 08:42:12 1994 Received: from ucipm.ucdavis.edu (ucipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id IAA05050 for ; Thu, 8 Sep 1994 08:42:11 -0700 From: PMARER@ucipm.ucdavis.edu Message-Id: <199409081542.IAA05050@are.Berkeley.EDU> Received: (from user PMARER) by ucipm.ucdavis.edu; 08 Sep 94 08:46:19 PDT Subject: Charlie's Question About Rubber Gloves To: wps-forum@are.Berkeley.EDU Date: 08 Sep 94 08:46:19 PDT Unlined rubber gloves can be hot, sweaty, and very unconfortable, especially in hot and humid weather. The problem can be lessened if the applicator wears cotton glove liners under the unlined rubber gloves. These are loosly woven gloves that will absorb perspiration and keep the hands drier and more comfortable. They should only be used once, then thrown away, eliminating the need for cleaning and preventing chances of contamination. They are very cheap and can be bought in large quantities. Glove liners also work when someone is applying pesticides in extremely cold weather and the gloves radiate heat away from the hands. From personal experience, I've used them under these conditions and they really work! Pat Marer IPM Education and Publications UC Davis From 72760.1152@compuserve.com Thu Sep 8 09:05:50 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 JAA05357 for ; Thu, 8 Sep 1994 09:05:49 -0700 Received: from localhost by dub-img-1.compuserve.com (8.6.4/5.940406sam) id MAA16637; Thu, 8 Sep 1994 12:05:17 -0400 Date: 08 Sep 94 12:00:52 EDT From: "Roy A. Motter" <72760.1152@compuserve.com> To: WPS Forum Subject: Restricted-Entry, Chemigation Message-ID: <940908160051_72760.1152_FHG95-1@CompuServe.COM> 1. If a pre-emergent herbicide is applied to the top of the planted bed, would it be considered a "non-contact early entry" if a worker walked in the untreated furrow so as they "will not touch or be touched by any pesticide residues..."? 2. If a pesticide is applied through a sprinkler system, would the entire sprinkler system be considered "chemigation equipment" or would only the injection equipment be considered as such? If the whole sprinkler system is considered "chemigation equipment" is there any time limit or would this equipment always require special handling? 3. If a pesticide lable has the following language - "Use this produce only in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170" - what exactly does this mean? If this means that we have to comply with all parts of the WPS now, how is this possible at this time? Roy A. Motter Brawley, Ca. From gkinro@hinc.hawaii.gov Thu Sep 8 10:03:13 1994 Received: from hinc.hinc.hawaii.gov ([166.122.246.2]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id KAA06878 for ; Thu, 8 Sep 1994 10:03:11 -0700 Received: by hinc.hawaii.gov (5.0/SMI-4.1) id AA04611; Thu, 8 Sep 1994 06:59:01 +1000 Date: Thu, 8 Sep 1994 06:59:01 +38835 (HST) From: "Gerald Y. Kinro" Subject: Re: Gloves, Linings, Sweat & Dermatitis To: wps-forum@are.Berkeley.EDU Cc: Multiple recipients of list In-Reply-To: <177AD95F88@hpirs.stjohn.hawaii.edu> Message-Id: Mime-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII content-length: 2713 On Wed, 7 Sep 1994 charlie@hpirs.stjohn.hawaii.edu wrote: > >>> A grower asked me to post the following problem & question. <<< > > "We are encountering a problem with section 170.240c5. It prohibits the > use of linings with waterproof gloves unless specifically allowed on the > label. > > >>> 170.240c5 Gloves shall be of the type specified by the product labeling. Gloves or glove linings made of leather, cotton, or other absorbent material shall not be worn for handling activities unless such materials are listed on the product labelin > as acceptable for such use. <<< > > "The pesticides being used are herbicides. Applicators apply the material > using backpack sprayers 8 hours/day. In the past, applicators had used > cotton glove with a rubber-like coating. It does breathe, and therefore, > their hands remain dry throughout the day. Liquids would "bead" off the > glove. If there was exposure, they would know since their hands would get > wet, and corrective actions could be taken immediately. > > "Due to the new standard, rubber gloves were issued since linings are not > allowed. The applicators' hands get totally soaked within an hour, and > thereafter, are working in a "pool" of water. We have tried skin > protection creams and other protectants but they do not hold up with the > excessive moisture. Within days, some applicators hands started to turn > red, indicating the start of dermatitis problems. > > "It appears to that the past practice protected the applicators adequately. > It allowed early notification if there was exposure to the hands from > leaks. The new requirement results in a condition that can expose the > applicator to pesticide without his/her knowledge. Changing the glove > frequently is not practical since on hot days, the hands get water soaked > within minutes. The hands would need time to dry before being placed into > another pair of gloves. The amount of time spent on a "break" during an > eight hour day would be prohibitive. > > "How have other users handled this issue?" > > >>> fromCHARLIE NAGAMINE, University of Hawaii <<< > > Grower did contact us for guidance. PR Notice 93-11, Supplement A (Deviations from the label), page 4 states:, "In addition, registrants are instructed to call EPA if they believe that applying Main Labeling Guidance to their current product would lead to a label that is not protective enough, unreasonably protective, or otherwise unreasonable for the product." We will advise grower to work with the registrant in this regard. While it may not present an immediate solution, there appears to be a legal vehicle for a long-term one. Gerald, Hawaii Department of Agriculture From PMARER@ucipm.ucdavis.edu Thu Sep 8 11:15:02 1994 Received: from ucipm.ucdavis.edu (ucipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id LAA08761 for ; Thu, 8 Sep 1994 11:15:01 -0700 From: PMARER@ucipm.ucdavis.edu Message-Id: <199409081815.LAA08761@are.Berkeley.EDU> Received: (from user PMARER) by ucipm.ucdavis.edu; 08 Sep 94 11:19:19 PDT Subject: More response to Charlie and Gerald To: wps-forum@are.Berkeley.EDU Date: 08 Sep 94 11:19:19 PDT My reply to the problem of the unlined gloves may not have been clear. The regulation applies to gloves with a built-in lining of cloth or flocking material. It does not address disposable glove liners. I don't see how wearing a pair of cotton, disposable glove liners is in violation of this regulation. It would be no different, in my opinion, than saying that if waterproof cloting hing is required, the applicator couldn't wear underwear. The intent of the law is to protect the applicator from pesticide exposure. Lined gloves like those on the market can become contaminated with pesticides. These are difficult or ipmmpossible to clean, therefore could cause contamination the next time they are used. This makes perfect sense and explains why the regs say not to use lined gloves. Glove liners are separate from the gloves, and are disposable, therefore do not have to be cleaned after use. If they are not reused, they cannot expose the applicator to any more potential pesticide exposure thqan the use of unlined gloves. We encourage applicators to wear cotton clothing and glove liners under waterproof personal protective equipment to make the use of these items more compfortable and acceptable. Forcing someone to keep their hands in unlined gloves for 8 hours is rediculridiculous and unnecessary. Pat Marer IPM Education and Publications University of California - Davis From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Thu Sep 8 12:04:03 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 MAA10080 for ; Thu, 8 Sep 1994 12:04:02 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id MAA23184; Thu, 8 Sep 1994 12:04:02 -0700 Message-Id: <199409081904.MAA23184@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 7400; Thu, 08 Sep 94 12:03:54 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 8801; Thu, 08 Sep 94 12:03:53 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 6634; Thu, 08 Sep 94 15:03:49 EDT Date: Thu, 08 Sep 94 15:02:36 EDT From: Al French Subject: Gloves, dermatitis, and regulation To: WPS-FORUM@are.Berkeley.EDU X-Acknowledge-To: Pat Marer's advice about using cotton glove liners is good for avoiding heat-related illness, but if I understand correctly, the problem Charlie Nagamine raised is that the WPS prohibits the use of glove liners with the particular herbicide. WPS section 170.240(c)(5) (page 38163) states: "Gloves or glove linings made of leather, cotton, or other absorbent material shall not be worn for handling activities unless such materials are listed on the product labeling as acceptable for such use." If workers are experiencing dermatitis, Charlie's grower may be caught between the prohibition of glove liners and WPS section 170.240(g) (page 38165) which states that "the handler employer shall assure that no handler is allowed or directed to perform the handling activity unless appropriate measures are taken, if necessary, to prevent heat-related illness." Charlie, is their an appropriate alternative herbicide that would allow glove liners to be worn? Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench@ers.bitnet or afrench%ers.bitnet@vtbit.cc.vt.edu From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Thu Sep 8 12:08:28 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 MAA10201 for ; Thu, 8 Sep 1994 12:08:28 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id MAA23500; Thu, 8 Sep 1994 12:08:26 -0700 Message-Id: <199409081908.MAA23500@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 7449; Thu, 08 Sep 94 12:08:13 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 9098; Thu, 08 Sep 94 12:07:35 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 6670; Thu, 08 Sep 94 15:07:26 EDT Date: Thu, 08 Sep 94 15:05:56 EDT From: Al French Subject: Independent? Contractors To: WPS-FORUM@are.Berkeley.EDU X-Acknowledge-To: I believe part of the difficulty in discussing independent contractor relationships is that they can not be determined in the abstract but only with respect to a particular law. A FLC may be independent in one case but not in another. For example, even in uncommon cases where FLCs are independent contractors under the Federal minimum wage law or MSPA, the employees of that contractor are considered to be the employees of the farmer or owner for WPS purposes. Part 170.3 (page 38151) of the WPS provides: "Agricultural employer means any person who hires OR CONTRACTS for the services of workers, for any type of compensation, to perform activities related to the production of agricultural plants, OR ANY PERSON WHO IS AN OWNER of or is responsible for the management or condition of an agricultural establishment that uses such workers. (emphasis added)" Thus, under WPS, it is the responsibility of the farmer (or owner) to assure worker training and workers' compliance with work rules. One way the farmer may assure that the WPS training requirements are met without jeopardizing an independent contractor relationship is to specify to the FLC that all workers must have WPS training verification cards. This is another reason why it is important to get going with training and card issuance. I agree with Gregorio that, if an independent contractor relationship is to be preserved, a farmer should avoid direct supervision and management of workers and deal with the contractor (and also consult a labor lawyer). Zax0114 asked: > What about the content of the training? . . . If we hire a FLC to perform a > task or operate a ranch, to what extent can we encourage them to practice > our rules? . . . do we have the right to determine work rules for the FLC? > . . . How much say does the farmer have in assuring that FLC employees are > properly trained? Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench@ers.bitnet or afrench%ers.bitnet@vtbit.cc.vt.edu From sgrower1@rain.org Thu Sep 8 12:32:08 1994 Received: from rain.org (sgrower1@rain.org [198.68.144.2]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id MAA10756 for ; Thu, 8 Sep 1994 12:32:05 -0700 Received: by rain.org (4.1/25-eef) id AA20865; Thu, 8 Sep 94 12:28:59 PDT Date: Thu, 8 Sep 1994 12:28:58 -0700 (PDT) From: Phil Soderman Subject: Re: Charlie's Question About Rubber Gloves To: wps-forum@are.Berkeley.EDU Cc: Multiple recipients of list In-Reply-To: <199409081542.IAA05050@are.Berkeley.EDU> Message-Id: Mime-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII Even with the cotton liners workers hands get wet and stay wet for the entire shift. If you do this for one day your hands survive. If hands stay wet with sweat for 5 days of 8 hours each the worker often gets some type of dermatitis. You can change the cotton inner glove during the day but in the field it can be just another problem. Phil Soderman sgrower1@rain.org On Thu, 8 Sep 1994 PMARER@ucipm.ucdavis.edu wrote: > Unlined rubber gloves can be hot, sweaty, and very unconfortable, > especially in hot and humid weather. > > The problem can be lessened if the applicator wears cotton glove > liners under the unlined rubber gloves. These are loosly woven > gloves that will absorb perspiration and keep the hands drier and > more comfortable. They should only be used once, then thrown > away, eliminating the need for cleaning and preventing chances of > contamination. They are very cheap and can be bought in large > quantities. > > Glove liners also work when someone is applying pesticides in > extremely cold weather and the gloves radiate heat away from the > hands. From personal experience, I've used them under these > conditions and they really work! > > Pat Marer > IPM Education and Publications > UC Davis > > From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Thu Sep 8 13:21:00 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 NAA11631 for ; Thu, 8 Sep 1994 13:20:59 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id NAA00222; Thu, 8 Sep 1994 13:20:59 -0700 Message-Id: <199409082020.NAA00222@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 8679; Thu, 08 Sep 94 13:20:50 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 3935; Thu, 08 Sep 94 13:20:50 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 7381; Thu, 08 Sep 94 16:20:26 EDT Date: Thu, 08 Sep 94 15:41:57 EDT From: Al French Subject: FLCs To: wps-forum@are.Berkeley.EDU X-Acknowledge-To: I've received a private inquiry that perhaps should be answered to the net. A FLC is a farm labor contractor and it generally means a FLC as defined by MSPA--the Migrant and Seasonal Agricultural Worker Protection Act. Such a mouthful is why it is tempting to use acronyms! MSPA regulates FLCs, requires a certificate of compliance with insurance requirements, vehicle inspections, disclosure to workers of the terms and conditions of employment, etc.. MSPA provides for workers' private right of action to sue for $500 statutory damages per worker per violation. Very large claims under MSPA are not unusual. Since FLCs pockets may not be that deep, lawyers sue farmers, too, claiming joint liability and denying that the FLC is an independent contractor. Courts frequently rule that FLCs are not independent contractors and hold the farmer liable. Thus, farmers concern for maintaining an independent contractor relationship. The WPS cuts across some of the normal boundaries between farmers and contractors and folks on the WPS-FORUM are trying to sort it out. Al French USDA Coordinator of Farm Labor Affairs 202-720-4737 afrench@ers.bitnet From PMARER@ucipm.ucdavis.edu Thu Sep 8 15:13:56 1994 Received: from ucipm.ucdavis.edu (ucipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id PAA14117 for ; Thu, 8 Sep 1994 15:13:56 -0700 From: PMARER@ucipm.ucdavis.edu Message-Id: <199409082213.PAA14117@are.Berkeley.EDU> Received: (from user PMARER) by ucipm.ucdavis.edu; 08 Sep 94 15:18:14 PDT Subject: Response to Al French re glove liners To: wps-forum@are.Berkeley.EDU Date: 08 Sep 94 15:18:14 PDT Al: I think there is a difference in the regulations between glove linings (...ings) and glove liners (...ers). Alt least I hope there is. The way I read the regulation you cited implies to me that gloves have to be unlined and not made of leather or cloth. It does not say they can be worn wit not be worn wqiith glove liners (...ers). We need to get an "official" interpretation on this. Ireally don't think the people who wrote this were aware of the benefit and use of disposable glover line rs (...ers). Kay Rudolph and Roy Rutz: What are your opininons? Pat Marer IPM Education and Publications University of California - Davis From ROYR@cdprsmtp.cdpr.ca.gov Fri Sep 9 08:35:50 1994 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id IAA23866 for ; Fri, 9 Sep 1994 08:35:50 -0700 From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Fri, 09 Sep 1994 08:38:05 -0700 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Fri, 09 Sep 1994 08:37:24 -0700 To: wps-forum@are.Berkeley.EDU, PMARER@ucipm.ucdavis.edu Subject: RE. Glove linings vs liners RE. Glove linings vs liners I think this is splitting hairs, but if this is whit it takes so be it. In our experience, the only inherent problem with absorbent linings is that special attention must be paid to cleaning because the linings are more prone to absorb pesticide. As long as the user is aware of this traot, no problem This is what we were getting at when we developed the regulations on gloves in Title 3, CCR, section 6738. There is specific reference to cleaning both inside and outside to address this issue. The WPS position does not give adequate weight to wearer comfort and its impact on "wearability". Lined gloves are somewhat more comfortable to wear which increases the likelihood they will be worn a greater percentage of the time. We cannot forget human nature when writing regulations- but we often do, I don't know about USEPA position but I for one, would support your position on "ers vs 'ings'. However, dealing with two layers is a nuisance that will decrease use,; which is not the intent. By the way all the above is based on handlers. For fieldworkers our experience is that the glove material males little difference. We do not agree with the USEPA position on this. Fieldworker exposure is different from handler exposure. Something the WPS doesn't seem to recognize. From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Mon Sep 12 13:12:22 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 NAA13276 for ; Mon, 12 Sep 1994 13:12:21 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id NAA28493; Mon, 12 Sep 1994 13:12:21 -0700 Message-Id: <199409122012.NAA28493@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 0024; Mon, 12 Sep 94 12:50:10 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 4857; Mon, 12 Sep 94 12:28:02 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 4341; Mon, 12 Sep 94 15:28:02 EDT Date: Mon, 12 Sep 94 15:26:29 EDT From: Al French Subject: Glove liners/linings To: WPS-FORUM@are.Berkeley.EDU X-Acknowledge-To: Response to Pat: I agree that disposable glove liners should be considered as different from absorbent glove linings; however, I'm not certain everyone involved in WPS enforcement will see it that way. Perhaps the best thing to do would be to seek an "interpretive guidance" from EPA. Can anyone on the net point me to PPE studies in the literature that would apply? Direct response is good for me and probably better for those who may have little interest in the minutiae of glove linings/liners. I'll be glad to post a summary of responses. Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench@ers.bitnet or afrench%ers.bitnet@vtbit.cc.vt.edu From pbaker@ag.Arizona.EDU Mon Sep 12 17:34:30 1994 Received: from ag.Arizona.EDU (Ag.Arizona.EDU [128.196.42.70]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id RAA20953 for ; Mon, 12 Sep 1994 17:34:29 -0700 Received: by ag.Arizona.EDU (5.0/SMI-SVR4) id AA08768; Mon, 12 Sep 1994 17:29:45 +0700 Date: Mon, 12 Sep 1994 17:29:44 -0700 (MST) From: Paul B Baker Subject: RE: WPS Poll To: wps-forum@are.Berkeley.EDU In-Reply-To: <2E6648F7@vegmail.ucdavis.edu> Message-Id: Mime-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII content-length: 1356 number 5 Paul Baker (602) 621-4012 Pesticide Coordinator's Office (602) 621-4013 FAX Department of Entomology pbaker@ag.arizona.edu University of Arizona Tucson, Arizona 85721 On Thu, 1 Sep 1994, Pearson, G. wrote: > > 4 > ---------- > From: wps-forum > To: Multiple recipients of list > Subject: WPS Poll > Date: Tuesday, August 30, 1994 4:47PM > > > WPS-EPA > > In your opinion, if a farmer provides WPS training for his/hers Farm Labor > Contractor's field workers, does his/hers FLC lose independent contractor > status? > > 1. Definitively > 2. Quite likely > 3. Unsure > 4. Unlikely > 5. Definitively not > 6. No opinion as I do not know much about independent contractor > regulations > > > Please hit reply button, and quickly anwer this question and I will sumarize > > answers. The more votes the better, so please do this now. > > 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 rugge@lifesci.lscf.ucsb.edu Tue Sep 13 08:11:14 1994 Received: from lifesci.lscf.ucsb.edu (root@lifesci.lscf.ucsb.edu [128.111.226.5]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id IAA00628 for ; Tue, 13 Sep 1994 08:11:13 -0700 Received: from [128.111.226.92] (greenhouse.lscf.ucsb.edu) by lifesci.lscf.ucsb.edu (4.1/LSCF.UCSB-v1.3R) id AA07573; Tue, 13 Sep 94 08:12:55 PDT Date: Tue, 13 Sep 94 08:12:54 PDT Message-Id: <9409131512.AA07573@lifesci.lscf.ucsb.edu> To: wps-forum@are.Berkeley.EDU From: rugge@lifesci.lscf.ucsb.edu (Barron Rugge) Subject: RE: WPS Poll >>My vote is #6 ***************************************************************** *-- Barron Rugge E-Mail rugge@lifesci.lscf.ucsb.edu * * Department of Biology * * Greenhouse Office Phone (805) 893-2867 * * University of California * * Santa Barbara, CA 93106 FAX (805) 893-4724 * ***************************************************************** From gebillikopf@ucdavis.edu Tue Sep 13 08:49:28 1994 Received: from ucdavis.ucdavis.edu (ucdavis.ucdavis.edu [128.120.1.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id IAA01283 for ; Tue, 13 Sep 1994 08:49:27 -0700 From: gebillikopf@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by ucdavis.ucdavis.edu (8.6.9/UCD2.50) id IAA11271; Tue, 13 Sep 1994 08:48:55 -0700 Date: Tue, 13 Sep 1994 08:48:55 -0700 Message-Id: <199409131548.IAA11271@ucdavis.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: Poll Results--Final WPS Poll--final results Question: In your opinion, if a farmer provides WPS training for his/hers Farm Labor Contractor's field workers, does his/hers FLC lose independent contractor status? Responses: 1. Definitively (0) 2. Quite likely (2) 3. Unsure, it depends (3) 4. Unlikely (3) 5. Definitively not (3) 6. No opinion as I do not know much about independent contractor regulations. (13) Total responses: 24 Comments: Thank you all for your responses. Net participants tended a bit toward the view that a farmer would not jeopardize a FLC's independent contractor status by providing training to the workers of the FLC. In an informal survey of attorneys and labor management specialists there was a slight tendency the opposite direction. My own view is that a farmer who provides training to the workers of a FLC may be considered a joint employer (jointly liable). If I were a farmer I would ask my FLC to attest that workers he/she brings have been trained according to EPA requirements. It will be interesting if any cases arise out of this issue. Once again, thanks for all your interesting comments and opinions. 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 RUDOLPH.KAY@epamail.epa.gov Tue Sep 13 16:57:58 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 QAA19031 for ; Tue, 13 Sep 1994 16:57:57 -0700 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-7 #5309) id <01HH2QJ3ZDU890MVQI@epavax.rtpnc.epa.gov>; Tue, 13 Sep 1994 19:57:33 EDT Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-7 #5309) id <01HH2QFSK3J48YB8V2@mail.rtpnc.epa.gov>; Tue, 13 Sep 1994 19:54:51 EDT Received: with PMDF-MR; Tue, 13 Sep 1994 19:50:33 EDT MR-Received: by mta CARINA; Relayed; Tue, 13 Sep 1994 19:50:33 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Tue, 13 Sep 1994 19:37:00 -0400 (EDT) From: KAY RUDOLPH 510-733-1065 Subject: RE: Reentry Intervals To: wps-forum Message-id: <01HH2QFTDAUU8YB8V2@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, 13 Sep 1994 19:45:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;33059131904991/1653596@MAIL] A1-type: MAIL Hop-count: 1 Quick clarification on REI's: Under EPA's reregistration process, only certain chemicals will require occupational exposure data and product-specific REIs. These are Tox 1 chemicals or chemicals that have a history that indicates the need for closer scrutiny. Other registrants may voluntarily provide the occupational exposure data and have product-specific REIs set. That is not necessarily the only scenario for reducing REIs, though. This is not my area of expertise, but I understand that in some cases, as when the toxicity of a chemical is widely understood to present low risk, the REI can be reduced without the occupational exposure studies. If you are working with a pesticide that you believe falls into this category, please contact your EPA Regional Worker Protection Contact and ask them to call me for more information. --Kay Rudolph US EPA R9 Worker Protection Prog. Mgr. From RUDOLPH.KAY@epamail.epa.gov Tue Sep 13 17:10:40 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 RAA20809 for ; Tue, 13 Sep 1994 17:10:40 -0700 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-7 #5309) id <01HH2QVMYPAO90MVTC@epavax.rtpnc.epa.gov>; Tue, 13 Sep 1994 20:07:42 EDT Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-7 #5309) id <01HH2QSDE4LS8Y9P84@mail.rtpnc.epa.gov>; Tue, 13 Sep 1994 20:05:07 EDT Received: with PMDF-MR; Tue, 13 Sep 1994 20:00:49 EDT MR-Received: by mta CARINA; Relayed; Tue, 13 Sep 1994 20:00:49 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Tue, 13 Sep 1994 19:54:00 -0400 (EDT) From: KAY RUDOLPH 510-733-1065 Subject: RE: In response to questions on california's intentions re. the To: wps-forum Message-id: <01HH2QSJKRNM8Y9P84@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, 13 Sep 1994 19:56:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;94000231904991/1653634@MAIL] A1-type: MAIL Hop-count: 1 EPA Training cards are in the mail to California Department of Pesticide Regulation. --Kay Rudolph US EPA R9, WPS Prog. Mgr. From howardr@are.Berkeley.EDU Wed Sep 14 17:53:23 1994 Received: from [128.32.251.102] (gia5mac22.Berkeley.EDU [128.32.251.102]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id RAA17717 for ; Wed, 14 Sep 1994 17:53:21 -0700 Message-Id: <199409150053.RAA17717@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Wed, 14 Sep 1994 17:54:04 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: list of WPS materials from EPA A few posts earlier this summer mentioned an annotated list, available from Allie Fields of EPA in Washington, of WPS training materials and other compliance resources. Kay Rudolph has provided a computer file of this document (June 1994 version), and it now resides in the WPS-Forum archive as "tr-mats.lst". This compilation includes items produced by the EPA itself, state agencies, and other organizations. Its table of contents sorts materials according to audience (employers, handlers, workers, general). Item descriptions are grouped by "type" (books, posters, leaflets, bulletins, fact sheets, videos and slides, field warning signs, and kits) and include title, short summary, date of publication, size, identification number, and source name. Full addresses and phone numbers of sources are listed at the end. There is no price information. To obtain a copy (size is 38857 bytes), send to ListProc@are.berkeley.edu the message: GET WPS-FORUM TR-MATS.LST Howard Rosenberg From 73507.555@compuserve.com Wed Sep 14 22:30:55 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 WAA20217 for ; Wed, 14 Sep 1994 22:30:48 -0700 Received: from localhost by dub-img-1.compuserve.com (8.6.4/5.940406sam) id BAA28252; Thu, 15 Sep 1994 01:30:12 -0400 Date: 15 Sep 94 01:26:25 EDT From: BOB ROACH <73507.555@compuserve.com> To: Subject: Roy Motter's questions Message-ID: <940915052625_73507.555_HHB55-1@CompuServe.COM> Ray, You posted some good questions and I would like to have a go at answering them. None of the other regulatory folks are forthcoming. Wouldn't it be something if the Ca. Dept. of Pesticide Regulation had a bulletin board where people could ask questions like this? They might find themselves drinking from the firehose. <1. If a pre-emergent herbicide is applied to the top of the > < planted bed, would it be considered a "non-contact early entry" if > < touch or be touched by any pesticide residues..."? > No. It would only be no-contact if he or she were in a tractor and prevented from having contact by operator placement or other physical means. Only irrigators would be likely to enter a field during a REI after such an application and they are addressed specifically. They are limited to one hour in 24 and this is a problem. That pre-emergent herbicide is going to blow away in the wind and be degraded by the sun until the expiration of the REI. <2. If a pesticide is applied through a sprinkler system, would > The whole sprinkler system is the application equipment until it is no longer contaminated. I cannot see that the WPS changes anything in regard to handling equipment that has contained pesticides. Generally, workers have to be informed and told what precautions to take to prevent exposure. Perhaps some labels will address it. <3. If a pesticide label has the following language - "Use this > Implementation of most of the WPS was postponed until 1995. At present, everything explicitly stated on the label is enforced. All the referenced 40 CFR Part 170 requirements are not. I suppose that U.S. EPA is technically enforcing those parts of the WPS that are in effect. The county agricultural commissioners are enforcing the labels and existing California regulations. Until California adopts new regulations, we are neither here nor there. This is creating an interesting mish-mash for growers and enforcement personnel to work with. California DPR will not have new regulations in place by the first of next year unless they are adopted on an emergency basis. The final draft has not yet been formally noticed and put up for comment. This means that I, A deputy county agricultural commissioner, do not know exactly what the regulations will be. This is unfortunate because many counties issue permits at the turn of the year. Many start in November, as we will do. I have to get material to the printer in October and I am pretty sure that I will still not know what the final version will be. I hope this prolonged gestation period will bring much improvement over the last draft of June 28, 1994. Bob Roach 73507.555@compuserve.com From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Thu Sep 15 12:28:06 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 MAA13122 for ; Thu, 15 Sep 1994 12:28:06 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id MAA16545; Thu, 15 Sep 1994 12:28:04 -0700 Message-Id: <199409151928.MAA16545@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 0962; Thu, 15 Sep 94 12:27:51 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 4625; Thu, 15 Sep 94 12:27:50 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 7298; Thu, 15 Sep 94 15:27:46 EDT Date: Thu, 15 Sep 94 15:25:41 EDT From: Al French Subject: Response to Ray To: WPS-FORUM@are.Berkeley.EDU X-Acknowledge-To: On 9/8 Ray Motter said: < 1. If a pre-emergent herbicide is applied to the top of the planted > < bed, would it be considered a "non-contact early entry" if a worker > < walked in the untreated furrow so as they "will not touch or be touched > < by any pesticide residues..."? > Ray, the WPS provides an exception for early entry to treated areas, without personal protective equipment (PPE) or time limitation, if there will be no contact with the pesticide or its residues and if any inhalation exposure level or ventilation criteria have been met. See 170.112(b). Note, however, that PPE can not be used to prevent the contact under this exception. EPA issued an interpretive guidance on irrigation February 23, 1994 that seems to apply to your question: "(The no contact) exception may apply to a variety of irrigation situations, e.g., . . . --Workers walking or performing other tasks in furrows after the pesticides are applied to the soil surface in a narrow band on beds and there is no contact with those treated surfaces." < 2. If a pesticide is applied through a sprinkler system, would the > < entire sprinkler system be considered "chemigation equipment" or would > < only the injection equipment be considered as such? If the whole > < sprinkler system is considered "chemigation equipment" is there any time > < limit or would this equipment always require special handling? > Whatever part of the irrigation equipment was used in the application of a pesticide would be considered chemigation equipment and the "chemigator" must be an applicator. However, handlers may (and workers may not) perform the irrigation tasks where the pesticide label requires or advises watering-in. I find nothing in the rule or interpretive guidances as to whether at some time chemigation equipment would no longer be contaminated. Perhaps a clarification should be sought from EPA. I would think that applying the restricted-entry interval would be appropriate for that part of the system which contained dilute materials or perhaps it would be deemed clean after a certain amount of water had passed through it. < 3. If a pesticide label has the following language - "Use this product > < only in accordance with its labeling and with the Worker Protection > < Standard, 40 CFR part 170" - what exactly does this mean? If this means > < that we have to comply with all parts of the WPS now, how is this possible > < at this time? > After Congress delayed implementation parts of the WPS, EPA issued an interpretive guidance on the 1994 Legislative Changes which is in the WPS- FORUM archives. (Use gopher or send e-mail message "GET WPS-FORUM EPA.Q-A" (without the quotes) to LISTPROC@ARE.BERKELEY.EDU). In summary, during 1994 employers (except rose growers) must comply with the WPS requirements that are spelled out on the label and they do not need to comply with the "referenced" requirements (that you quoted) until January 1, 1995. I hope this helps you. Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench@ers.bitnet or afrench%ers.bitnet@vtbit.cc.vt.edu From GEYER@VTVM1.CC.VT.EDU Fri Sep 16 05:33:04 1994 Received: from VTVM1.CC.VT.EDU (vtvm1.cc.vt.edu [128.173.4.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id FAA26471 for ; Fri, 16 Sep 1994 05:33:03 -0700 Message-Id: <199409161233.FAA26471@are.Berkeley.EDU> Received: from VTVM1.CC.VT.EDU by VTVM1.CC.VT.EDU (IBM VM SMTP V2R2) with BSMTP id 8330; Fri, 16 Sep 94 08:30:12 EDT Received: from VTVM1 (NJE origin GEYER@VTVM1) by VTVM1.CC.VT.EDU (LMail V1.2a/1.8a) with BSMTP id 6722; Fri, 16 Sep 1994 08:30:12 -0400 Date: Fri, 16 Sep 94 08:28:57 EDT From: Leon Subject: Re: AG-HRnet To: wps-forum@are.Berkeley.EDU In-Reply-To: Message of Fri, 2 Sep 1994 08:58:04 -0700 from wHAT A SPLENDID IDEA. i WOULD LOVE TO JOIN AND WILL SEND MESSAGE TO GEORGE. LEON From howardr@are.Berkeley.EDU Fri Sep 16 16:28:56 1994 Received: from [128.32.251.96] (gia5mac16.Berkeley.EDU [128.32.251.96]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id QAA12105 for ; Fri, 16 Sep 1994 16:28:54 -0700 Message-Id: <199409162328.QAA12105@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Fri, 16 Sep 1994 16:29:37 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: PPE guide and the chemical resistance cat. chart Following the double-line below is a copy of the EPA chemical resistance category selection chart that Bob Roach first asked about last month. This ASCII version was typed and sent to WPS-Forum this week by a contributor, identified only as "Tommy the Tourist," who tried to post it through an anonymous mailer system (ListProc rejected it as a post but sent copy to me in an error message). If you're still gophering and/or listening out there, Tommy, stand up and take a bow. The contributor states that the chart was copied from a pamphlet produced by the Cornell Cooperative Extension entitled: "Personal Protective Equipment Guide: Choosing Chemical-Resistant PPE," the same one that Charlotte Coffman mentioned in responding to Bob. Serendipity is in evidence here. Just a few hours earlier, Kay Rudolph had provided a document entitled DRAFT "Personal Protective Equipment Guide: Choosing Chemical-Resistant PPE," including a word-processor version of The Chart that was pulverized by e-mail software. So Tommy's gift fit right in. Though it bears no reference to Cornell, Kay's file appears to hold the content of the Cornell pamphlet, perhaps in preliminary form. Section headings are: Chemical Resistance, Chemical Resistance Of PPE Materials, Choosing Chemical-Resistant PPE, and Using The Chemical-Resistance Category Selection Chart. The full document, with readable chart spliced in, is now available in the archive as "guide.ppe". To obtain a copy (size is 13024 bytes), send to ListProc@are.berkeley.edu the message: GET WPS-FORUM GUIDE.PPE The chart alone is below. -- Howard Rosenberg ======================================================================== EPA CHEMICAL RESISTANCE CATEGORY SELECTION CHART For use when PPE section on pesticide label lists a chemical resistance cat. ----------------------------------------------------------------------------- |SELECTION| | |CATEGORY | | |LISTED ON| TYPE OF PERSONAL PROTECTIVE MATERIAL | |PESTICIDE| | |LABEL | | ----------------------------------------------------------------------------- | |Barrier |Butyl |Nitrile|Neoprene|Natural|Poly- |Poly- |Viton | | |Laminate|Rubber|Rubber | Rubber |Rubber*|ethylene|vinyl |> or =| | | |> or =|> or = | > or = |> or = | > or = |Chloride|14 mil| | | |14 mil|14 mils| 14 mils|14 mils| 14 mils| (PVC) | | | | | | | | | | | | | | | | | | | | | | ----------------------------------------------------------------------------- | A | | | | | | | | | |(dry and | | | | | | | | | | water- | high | high | high | high | high | high | high | high | | based | | | | | | | | | |formulat)| | | | | | | | | ----------------------------------------------------------------------------- | B | high | high | slight| slight | none | slight | slight |slight| ----------------------------------------------------------------------------- | C | high | high | high | high | mod. | mod. | high | high | ----------------------------------------------------------------------------- | D | high | high | mod. | mod. | none | none | none |slight| ----------------------------------------------------------------------------- | E | high |slight| high | high | slight| none | mod. | high | ----------------------------------------------------------------------------- | F | high | high | high | mod. | slight| none | slight | high | ----------------------------------------------------------------------------- | G | high |slight| slight| slight | none | none | none | high | ----------------------------------------------------------------------------- | H | high |slight| slight| slight | none | none | none | high | ----------------------------------------------------------------------------- * includes natural rubber blends and laminates HIGH: Highly chemical-resistant. Clean or replace PPE at end of each day's work period. Rinse off pesticides at rest breaks. MOD.: Moderately chemical-resistant. Clean or replace PPE within an hour or two of contact. SLIGHT: Slightly chemical-resistant. Clean or replace PPE within 10 minutes of contact. NONE: No chemical-resistance. Do not wear this type of material as PPE when contact is possible. From 73507.555@compuserve.com Sun Sep 18 18:50:29 1994 Received: from dub-img-2.compuserve.com (dub-img-2.compuserve.com [198.4.9.2]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id SAA00980 for ; Sun, 18 Sep 1994 18:50:28 -0700 Received: from localhost by dub-img-2.compuserve.com (8.6.4/5.940406sam) id VAA25990; Sun, 18 Sep 1994 21:49:57 -0400 Date: 18 Sep 94 21:46:14 EDT From: BOB ROACH <73507.555@compuserve.com> To: Subject: Early reentry for Irrigators Message-ID: <940919014613_73507.555_HHB61-1@CompuServe.COM> On 9/8 Ray Motter asks: <<1. If a pre-emergent herbicide is applied to the top of the >> << planted bed, would it be considered a "non-contact early entry" if>> <> << touch or be touched by any pesticide residues..."? >> My reply was: Al French provided the following response: < Ray, the WPS provides an exception for early entry to treated areas, > <170.112(b). Note, however, that PPE can not be used to prevent the > < > < EPA issued an interpretive guidance on irrigation February 23, 1994 > < that seems to apply to your question: > < > < "(The no contact) exception may apply to a variety of irrigation > < situations, e.g., . . . --Workers walking or performing other > < tasks in furrows after the pesticides are applied to the soil > < surface in a narrow band on beds and there is no contact with > < those treated surfaces." > We are of two differing opinions. I arrived at my answer by looking at the draft California regulations governing field reentry and discussion with a DPR Senior Pesticide Use Specialist. It seems quite clear to me that in California, irrigators will be considered limited-contact workers. Clarification is needed here. I hope that U.S. EPA and Cal-EPA will address this question. The subject of reentry requirements for irrigators has come up before in many comments and discussions with DPR staff. Irrigation work has been discussed as a limited-contact activity and I have never heard it suggested that it may be considered a no-contact activity. That would solve many problems. Since the interpretive guidance suggests that only certain irrigation tasks may be considered no-contact activities, we need to know what those tasks are. Setting irrigation pipe involves more than walking down the furrow. Some contact with the bed tops seems unavoidable. Also, if 25% to 50% of the area of the field is sprayed in a band treatment, some drift to the furrows is also unavoidable. Setting of irrigation pipe is in my opinion a very-low-contact activity and exposure is prevented through the use of appropriate boots and gloves. The one hour in 24 hour limit for this type of work seems unnecessary. It is going to prevent rapid incorporation of soil-applied herbicides and cause more ill effects than it prevents. If some irrigation tasks are considered no-contact activities and others are limited-contact activities, how are the regulations going to be enforced? If each different situation must be considered and evaluated, we have a real mess on our hands. One should be able to ask a simple question and get a simple answer. We seem to be getting into endless "how many angels can dance on the head of a pin" discussions in which any definitive answer is elusive. Bob Roach 73507.555@compuserve.com From <@cmsa.Berkeley.EDU:AFRENCH@ERS.BITNET> Tue Sep 20 12:30:23 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 MAA03818 for ; Tue, 20 Sep 1994 12:30:23 -0700 Received: from cmsa.Berkeley.EDU by nak.berkeley.edu (8.6.8.1/1.40) id MAA23524; Tue, 20 Sep 1994 12:30:17 -0700 Message-Id: <199409201930.MAA23524@nak.berkeley.edu> Received: from cmsa.Berkeley.EDU by cmsa.Berkeley.EDU (IBM VM SMTP V2R2) with BSMTP id 0271; Tue, 20 Sep 94 12:29:24 PDT Received: from ERS.BITNET by cmsa.Berkeley.EDU (Mailer R2.08 R208004) with BSMTP id 5690; Tue, 20 Sep 94 12:28:51 PDT Received: from ERS (AFRENCH) by ERS.BITNET (Mailer R2.08 R208004) with BSMTP id 6569; Tue, 20 Sep 94 15:28:42 EDT Date: Tue, 20 Sep 94 15:22:51 EDT From: Al French Subject: Other handlers To: WPS-FORUM@are.Berkeley.EDU X-Acknowledge-To: It has come to my attention that some employers and trainers may have overlooked a provision of the WPS that requires farm mechanics and vehicle service and maintenance personnel to qualify as handlers if they attend to spray rigs, the tractors that pull them, the nurse trucks that supply them; or chemigation equipment that may contain pesticide residues. The WPS states (page 38151): Section 170.3 _Definitions._ _Handler_ means any person, including a self-employed person: (1) Who is employed for any type of compensation by an agricultural establishment or commercial pesticide handling establishment to which subpart C of this part applies and who is: (i) . . . . (v) Cleaning, adjusting, handling, or repairing the parts of mixing, loading, or application equipment that may contain pesticide residues. -------------- 9/3 Gators 77 New Mexico State 21 9/10 Gators 73 Kentucky 7 9/17 Gators 31 Tennessee 0 Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 afrench@ers.bitnet or afrench%ers.bitnet@vtbit.cc.vt.edu From dana@are.Berkeley.EDU Tue Sep 20 13:10:21 1994 Received: from [128.32.251.39] (gia3mac29.Berkeley.EDU [128.32.251.39]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id NAA05243 for ; Tue, 20 Sep 1994 13:10:19 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Tue, 20 Sep 1994 13:10:31 -0800 To: wps-forum From: dana@are.Berkeley.EDU (Dana E. Keil) Subject: message on WPS training from G. Billikopf A glitch in the UC Davis email system caused this message to the WPS-Forum to be rejected so I am re-sending it. Dana Keil Listproc Mailing List Manager Department of Agricultural and Resource Economics -------------------- re-sent message follows -------------- A farmer, in response to a recent newsletter on WPS training being held in Modesto (see below), called to say he does his own training. "I tell the worker to just drive the tractor," the farmer explained. My training consists of telling the worker to stay away from the herbicides and let me handle that. "I do all the mixing and spraying myself while he drives the tractor." If I understood this farmer correctly, and the worker is driving the tractor while herbicides are applied (how they are applied seems irrelevant), would not this tractor driver have to be trained as a handler, rather than a field worker? I agreed to get back to him on this question. ******* ******* Meetings that may be of interest: ******** ******* October 11, 1994 Train the trainers of field workers UC IPM Modesto, Contact (916) 752-7691--$40 (Spanish) (trainer certification provided--especialy recommended for Farm Labor Contractors and providers of training in Spanish who are not already qualified trainers under EPA regulations.) Novermber 10, 1994 Train the trainers of handlers UC IPM Modesto, Contact (916) 752-7691--$100 (English) (trainer certification provided) December 1, 1994 EPA regs + pesticide containers + Methyl bromide UCCE & Ag Comm. Office, Modesto, Contact Melynda Ange (209) 525-6654 4 hours continuing education hours in Laws and Regs. (English) Free December 7-9, 1994 Supervisory Training Skills for Farm Supervisors & for Farm Labor Contractors (FLCs). (In Spanish) 2 days on supervisory skills plus 1 day on WPS train the trainer of field workers (trainer certification provided). Stockton, UCCE, $45 for 3 days. Contact Melynda Ange (209) 525-6654. December 14, 1994 WPS field worker training for workers. Stockton, UCCE, free, Contact Melynda Ange (209) 525-6654. EPA Certification. January 17, 1994 WPS field worker training for workers. Merced, UCCE, free, Contact Melynda Ange (209) 525-6654. EPA Certification. January 17, 1994 WPS field worker training for workers. Modesto, UCCE, free, Contact Melynda Ange (209) 525-6654. EPA Certification. February 28, 1995 Farm Labor Contractor Training Location: TBA (Spanish) UCCE & Employment Development Department (EDD) --------------------------------------------------------------------- Wheelchair facilities. For Special accomodations please call Melynda Ange at (209) 525-6654. --------------------------------------------------------------------- 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 charlie@hpirs.stjohn.hawaii.edu Tue Sep 20 16:22:26 1994 Received: from relay1.Hawaii.Edu (relay1.Hawaii.Edu [128.171.41.53]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id QAA12155 for ; Tue, 20 Sep 1994 16:22:23 -0700 Received: from uhunix.uhcc.Hawaii.Edu ([128.171.44.54]) by relay1.Hawaii.Edu with SMTP id <11334>; Tue, 20 Sep 1994 13:21:19 -1000 Received: from hpirs.stjohn.hawaii.edu by uhunix.uhcc.Hawaii.Edu (4.1/Sun690) id AA25838; Tue, 20 Sep 94 13:19:42 HST Date: Tue, 20 Sep 1994 13:19:42 -1000 Received: from HPIRS/MAILQUEUE by hpirs.stjohn.hawaii.edu (Mercury 1.11); Tue, 20 Sep 94 13:02:09 -1000 Received: from MAILQUEUE by HPIRS (Mercury 1.11); Tue, 20 Sep 94 13:01:46 -1000 Received: from [128.171.243.14] by hpirs.stjohn.hawaii.edu (Mercury 1.11); Tue, 20 Sep 94 13:01:38 -1000 To: WPS-Forum@are.Berkeley.EDU From: charlie@hpirs.stjohn.hawaii.edu Subject: Nurseries on golf courses, resorts, shopping malls Cc: barry@hpirs.stjohn.hawaii.edu Message-Id: <14BD9C64875@hpirs.stjohn.hawaii.edu> QUESTION: Aren't nurseries on operations such as golf courses, resorts, and shopping malls exempt from WPS regulations if treated plants are not resold but are used on their premises? 170.3 states definition of NURSERY: any operation engaged in the outdoor production of any agricultural plant to produce cut flowers and ferns or plants that will be used in their entirety in another location. Such plants include, but are not limited to: flowering and foliage plants or trees; tree seedlings; live Christmas trees; vegetable, fruit, and ornamental transplants; and turfgrass produced for sod. The plants in question are not be used in another location. They are used on the operation's premises. WPS does not apply when a pesticide is applied on an agricultural establishment in 10 circumstances. 170.102 (b) Exception (3) On plants grown for other than commercial or research purposes, which may include plants in habitations, home fruit and vegetable gardens and home greenhouses. Exception (4) On plants that are in ornamental gardens, parks, and public or private lawns and grounds that are intended only for aesthetic purposes or climatic modification. The plants in question are not used in commerce (resale). They are used in the landscape for aesthetic or climatic modifcation purposes. The Agency, in their summary of public comments and Agency response, has stated the following: Public areas and residential uses: The Agency proposed to exempt pesticide uses in malls, atria, or office buildings where agricultural plants are present primarily for aesthetic or climatic modifications and in and around habitations or non-commercial crop or ornamnetal gardens, in non-commercial greenhouses, or on lawns, shrubs or trees. Although there were no comments that addressed these exemptions specifically, there were many comments that stated that all pesticide handlers should be covered by these regulations. The Agency is concerned that the use of pesticides under such conditions, including use by homeowner, may vary substantially from those in agriculture and therefore require the development of different standards. The Agency will gather information on the worker exposures related to these uses and assess the merits of Including these uses in part 170 or in a separate regulatlon, at a later time. Until that time non-commercial crops and greenhouses, etc. look to be exempt. Charles Nagamine Environmental Biochemistry Dept. Dept. mail: 1800 East-West Rd. HENKE Hall, Rm. 329 Honolulu, HI 96822 My desk: St. John , Rm. 017 ph. 808/956-6007 From howardr@are.Berkeley.EDU Tue Sep 20 16:55:10 1994 Received: from [128.32.251.96] (gia5mac16.Berkeley.EDU [128.32.251.96]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id QAA12767 for ; Tue, 20 Sep 1994 16:55:08 -0700 Message-Id: <199409202355.QAA12767@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Tue, 20 Sep 1994 16:55:52 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: letter from NASDA to Sen. Thad Cochran A copy of the following letter was provided to WPS-Forum by Mark C. Nestlen, Manager of Legislative and Regulatory Affairs, National Association of State Departments of Agriculture. ------------------------------------------------------------------------ National Association of State Departments of Agriculture 1156 15th Street, NW, Suite 1020 Washington, DC 20005 202/296-9680 September 8, 1994 The Honorable Thad Cochran Also sent to Reps. de la Garza, 326 Russell Senate Office Building Roberts, Stenholm, Smith, Washington, DC 20510 and Boehner Dear Senator Cochran: As you are aware, the National Association of State Departments of Agriculture (NASDA) and eighteen other organizations submitted a petition to the Environmental Protection Agency (EPA) on July 8, 1994 calling for a rulemaking to correct the serious flaws with the Worker Protection Standard (WPS) for Agricultural Pesticides. You will recall that earlier this year Congress delayed enforcement of the WPS due to the lack of educational materials available to farmers and regulators and because of the practical problems associated with the regulation. As provided by that legislation, January 1, 1995 is the new date upon which the regulation will be enforceable. While EPA has done a good job in providing the educational materials, the Agency appears to lack the resolve to address the issues the agricultural community has raised. During negotiations on how long the delay should be, EPA assured Congress that an eight and one-half-month delay would provide sufficient time to address the serious problems. Despite EPA's assurance to Members, NASDA is very concerned with the lack of action by EPA. Although, the NASDA et. al. petition was submitted two months ago today, EPA has yet to officially acknowledge receipt of the petition. Agency officials continue to indicate that no decisions have been made with regard to how the Agency will address the petition or the problems. In meetings with EPA officials they have indicated that at least two significant problems -- low contact personal protective equipment requirements and the reentry interval -- will take at least 18 months to resolve. EPA's actions indicate that resolving the issues prior to January 1, 1995 is doubtful. There have been a number of personnel changes in the Agency with regard to WPS. Some agricultural organizations that have spent months educating staff on their industry's specific problems are now having to start all over with "get acquainted" meetings with the new staff. Recently James Willis, Technical and Land Services Manager of Chesapeake Forest Products, said it appears to him that the only redress the forest industry has with EPA with regard to the WPS and how those standards relate to the industry "is in the courts or in seeking [a] legislative exemption for forestry herbicides." In a letter to the American Forest and Paper Association, Willis said that he was "personally unwilling to invest any more time in talking to anyone from the Agency. They have not listened to us when we presented research showing the safety of forestry herbicide use, they have refused to come out to the field and see how the work is done, and they have not given us any guidance on how to achieve compliance with the standards." Willis said he had read a "much belated letter" from EPA's Office of Field Operations Director with "considerable disappointment and consternation. EPA appears to have changed its definition of forestry workers since our April 8 meeting and has not answered the other items they promised to 'get back to us on.' In essence, it appears to me that we have no answers for dealing with forestry problems in the Worker Protection Standards," he said. We are very concerned with these events and felt you should be advised of EPA's inaction. What will happen to farmers, ranchers, foresters, regulators, and others affected by WPS on January 1, 1995 if EPA has continued to ignore the concerns raised in the NASDA et. al. petition? Congress will not be in session, and on this issue in the past the Agency has shown a tremendous lack of flexibility. Congress had to act this year on the delay because EPA refused to even consider delaying enforcement so that the problems could be addressed. You may find it necessary to turn the NASDA et. al. petition into legislative language to once again impress upon EPA the serious nature of agriculture's concerns. NASDA appreciates your concern with this issue and thanks you in advance for your attention to this continuing problem with implementation of the WPS. If you have any questions or concerns, please feel free to contact me or the NASDA staff in Washington. We continue to hope that a worker protection program can be put in place which truly protects farmworkers, allows farmers to produce profitably in a world market, and permits regulators to enforce the provisions fairly and accurately. Sincerely, Rick Perry Chairman, NASDA WPS Task Force Commissioner, Texas Department of Agriculture From charlie@hpirs.stjohn.hawaii.edu Tue Sep 20 18:36:57 1994 Received: from relay1.Hawaii.Edu (relay1.Hawaii.Edu [128.171.41.53]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id SAA17694 for ; Tue, 20 Sep 1994 18:36:56 -0700 Received: from uhunix.uhcc.Hawaii.Edu ([128.171.44.54]) by relay1.Hawaii.Edu with SMTP id <11333>; Tue, 20 Sep 1994 15:36:50 -1000 Received: from hpirs.stjohn.hawaii.edu by uhunix.uhcc.Hawaii.Edu (4.1/Sun690) id AA01355; Tue, 20 Sep 94 15:35:08 HST Date: Tue, 20 Sep 1994 15:35:08 -1000 Received: from HPIRS/MAILQUEUE by hpirs.stjohn.hawaii.edu (Mercury 1.11); Tue, 20 Sep 94 15:17:37 -1000 Received: from MAILQUEUE by HPIRS (Mercury 1.11); Tue, 20 Sep 94 15:17:24 -1000 Received: from [128.171.243.14] by hpirs.stjohn.hawaii.edu (Mercury 1.11); Tue, 20 Sep 94 15:17:23 -1000 To: WPS-Forum@are.Berkeley.EDU From: charlie@hpirs.stjohn.hawaii.edu Subject: Looking for a PR notice Cc: barry@hpirs.stjohn.hawaii.edu Message-Id: <14E1C8F454C@hpirs.stjohn.hawaii.edu> Am looking for date & page # of a Federal Register in which is supposed to be published a PR notice re: reduced REI's for biological & less risky pesticides. Read same in minutes & report of AAPCO 8/94 Seattle annual mtng. Charles Nagamine Environmental Biochemistry Dept. Dept. mail: 1800 East-West Rd. HENKE Hall, Rm. 329 Honolulu, HI 96822 My desk: St. John , Rm. 017 ph. 808/956-6007 From rmcallis@fieldofdreams.ceris.purdue.edu Thu Sep 22 07:24:41 1994 Received: from fieldofdreams.ceris.purdue.edu (fieldofdreams.ceris.purdue.edu [128.210.64.11]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id HAA29090 for ; Thu, 22 Sep 1994 07:24:40 -0700 Received: by fieldofdreams.ceris.purdue.edu (5.65+/1.34) id AA23854; Thu, 22 Sep 94 09:24:16 -0500 From: rmcallis@fieldofdreams.ceris.purdue.edu (Ray McAllister) Message-Id: <9409221424.AA23854@fieldofdreams.ceris.purdue.edu> Subject: EPA provides access to documents electronically To: wps-forum@are.Berkeley.EDU, rmcallis@fieldofdreams.ceris.purdue.edu (Ray McAllister) Date: Thu, 22 Sep 94 9:24:15 EST EPA has established the Pesticide Special Review and Reregistration Information System (PSRRIS-BBS), to provide public electronic access to significant prgram document files. Now available are recent RED documents, RED fact sheets, the Rainbow Report, selected PR Notices, and more. Access is by modem to 703-308-7224 (to 14,400 bps) or via Internet (telnet fedworld.gov, log on, select gateway system #11). Contact Eric Feris (703-308-8048) for more details, or just log on! This is a big step up from the Pesticide Information System (PIN) bulletin board some of you may be familiar with. From ROYR@cdprsmtp.cdpr.ca.gov Thu Sep 22 08:21:49 1994 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id IAA29727; Thu, 22 Sep 1994 08:21:35 -0700 From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Thu, 22 Sep 1994 08:24:05 -0700 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Thu, 22 Sep 1994 08:23:51 -0700 To: dana@are.Berkeley.EDU, wps-forum@are.Berkeley.EDU Subject: Response to "Farmer's question"- Yes, the employee is an applicator (handler) and must be trained an Response to "Farmer's question"- Yes, the employee is an applicator (handler) and must be trained and provided the protections required by the pesticide product labeling and the laws and regulations. You are correct, the method of application is not relevant. Royr From millert@oes.orst.edu Fri Sep 23 09:43:37 1994 Received: from OES.ORST.EDU (OES.ORST.EDU [128.193.124.2]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id JAA25800 for ; Fri, 23 Sep 1994 09:43:36 -0700 Received: by OES.ORST.EDU id AA19616 (5.65b/IDA-1.4.3); Fri, 23 Sep 94 09:41:53 -0700 Date: Fri, 23 Sep 1994 09:41:52 -0700 (PDT) From: Terry Miller Subject: WPS 'Starter Kit' To: WPS Forum Cc: Terry Miller Message-Id: Mime-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII In Oregon, I've heard many complaints from folks affected by the WPS that the rule is too complicated, and that they just do not have the time to read the How To Comply manual. I am considering developing something you might call the "WPS 'Starter Kit'", which I vision to be a simplified overview of the rule by broad subject area, with ample cross-references to the HTC manual. The subjects highlighted might help the reader to hone in on the part of WPS that they are interested in at the moment - in some ways it might be an annotated guide to the WPS. My hope would be that this "Starter Kit", if appropriately done, would help "break the ice" for those relucant to get into the rule in the depth necessary for compliance. Has anyone developed such an approach? What is your reaction to the idea? Terry Miller Oregon State University From 73163.3106@compuserve.com Sat Sep 24 16:14:28 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 QAA21637 for ; Sat, 24 Sep 1994 16:14:27 -0700 Received: from localhost by dub-img-1.compuserve.com (8.6.4/5.940406sam) id TAA02279; Sat, 24 Sep 1994 19:13:56 -0400 Date: 24 Sep 94 19:10:22 EDT From: Tom Kraemer <73163.3106@compuserve.com> To: "INTERNET:wps-forum@are.Berkeley.EDU" Subject: WPS-FORUM digest 90 Message-ID: <940924231021_73163.3106_DHI31-2@CompuServe.COM> Terry I'm from Oregon and yes it would help to have such a kit. Although we have dealt with chemical applications and their regs for a number of years. We have never had anything like this to deal with. Our biggest problem is going to be tracking who's had training and who has not. At the peak of our season we may have 250 or 300 people working each day and making sure each one of them has had training could be a problem. It would help if there was some type of card we could hand out but as far as I know neither the state nor the feds are going to issue such a card. Tom Kraemer Kraemer Farms From 73507.555@compuserve.com Sun Sep 25 11:59:18 1994 Received: from dub-img-2.compuserve.com (dub-img-2.compuserve.com [198.4.9.2]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id LAA28843 for ; Sun, 25 Sep 1994 11:59:17 -0700 Received: from localhost by dub-img-2.compuserve.com (8.6.4/5.940406sam) id OAA16520; Sun, 25 Sep 1994 14:58:46 -0400 Date: 25 Sep 94 14:56:03 EDT From: BOB ROACH <73507.555@compuserve.com> To: Subject: NASDA Letter Message-ID: <940925185603_73507.555_HHB90-2@CompuServe.COM> I would just like to say amen to that. I am afraid that implementation of the WPS as planned in California will lead to the creation of a new class of criminal. These will be the employers who are in compliance now but will find compliance with some of the hazard communication requirements under the new standards require heroic efforts to eliminate very little risk. It can even be quite difficult to determine what is in compliance and what is not. They will also be very much more difficult to enforce criminally. This is a real concern in California where enforcement is taken very seriously. I am afraid of eventual loss of respect for the California pesticide regulatory system if parts of it are unreasonable or too difficult to comply with and enforce. Based on the draft California regulations now on the table and the lack of apparent progress toward settling many important issues, I conclude that things are not going very well in the negotiations with U.S. EPA. The proposed regulations should be out now in order to be implemented on January 1, 1995. They are probably going around and around in tight little circles about issues of equivalency. I think the U.S. EPA needs to accept a broader notion of what is equivalent and allow California to have a system that is effective, workable and enforceable. I think California has such a system now and that Department of Pesticide Regulation should not accept anything that will degrade the program here. DPR should consider eliminating some of California's higher standards and coming down to the federal Worker Protection Standard in the interest of simplicity. I realize that this is election time and doing anything drastic with such a hot-button issue as pesticide regulation is difficult. Perhaps after November when things settle down, the state will find the resolve to deal with the matter. Robert A. Roach 73507.555@compuserve.com From tzimmerm@magnus.acs.ohio-state.edu Mon Sep 26 06:52:35 1994 Received: from beauty.magnus.acs.ohio-state.edu (beauty.magnus.acs.ohio-state.edu [128.146.216.26]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id GAA15615 for ; Mon, 26 Sep 1994 06:52:27 -0700 Received: from [128.146.211.24] by beauty.magnus.acs.ohio-state.edu (8.6.4/4.940426) id JAA10684; Mon, 26 Sep 1994 09:52:04 -0400 X-NUPop-Charset: English Date: Mon, 26 Sep 1994 09:52:22 -0600 (CST) From: "Tommy L. Zimmerman" Sender: tzimmerm@magnus.acs.ohio-state.edu Message-Id: <35560.tzimmerm@magnus.acs.ohio-state.edu> To: wps-forum@are.Berkeley.EDU Subject: RE: WPS 'Starter Kit' In message Fri, 23 Sep 1994 09:43:53 -0700, Terry Miller writes: > > In Oregon, I've heard many complaints from folks affected by the > WPS that the rule is too complicated, and that they just do not have the > time to read the How To Comply manual. I am considering developing > something you might call the "WPS 'Starter Kit'", which I vision to be a > simplified overview of the rule by broad subject area, with ample > cross-references to the HTC manual. The subjects highlighted might help > the reader to hone in on the part of WPS that they are interested in at > the moment - in some ways it might be an annotated guide to the WPS. My > hope would be that this "Starter Kit", if appropriately done, would > help "break the ice" for those relucant to get into the rule in the > depth necessary for compliance. > > Has anyone developed such an approach? What is your reaction to > the idea? > > Terry Miller > Oregon State University > Terry, Go for it! As is the case with most of these kinds of regulations, they do need to be understandable. I would say it would be a great help to those who might not otherwise be able to "wade" through the regulations. Tom Zimmerman Ohio State University Wooster, Ohio From Bob_Bellinger@quickmail.clemson.edu Mon Sep 26 13:09:26 1994 Received: from hubcap.clemson.edu (hubcap.clemson.edu [130.127.8.1]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id NAA24412 for ; Mon, 26 Sep 1994 13:09:22 -0700 Received: from quickmail.clemson.edu (quickmail.clemson.edu [130.127.8.57]) by hubcap.clemson.edu (8.6.7/8.6.4) with SMTP id QAA01823 for ; Mon, 26 Sep 1994 16:08:21 -0400 Message-ID: Date: 26 Sep 1994 14:04:08 -0500 From: "Bob Bellinger" Subject: WPS "Starter Kit" To: "WPS Forum ¥ Berkeley" X-Mailer: Mail*Link SMTP/QM 3.0.0 Subject: Time:1:51 PM OFFICE MEMO WPS "Starter Kit" Date:9/26/94 YO, Terry, RE: the "Starter Kit" Nebraska (Larry Schultz, P.A.T. in Lincoln) rescripted a shortened version of the "How-to-Comply" EPA slide set that might be useful. He got the118 slide "short "version" down to about 50 slides as I recall. A number of states have done leaflets, handouts, etc. which summarize or give highlights of the WPS. Contact Larry Olsen (P.A.T.) at Michigan State, he has some good stuff. Susan Whitney (P.A.T.) in Delaware has some material. I don't mean to slight anyone not listed. Contact John Impson (PAT-ES/USDA, Washington, DC) or Jim Boland (OPP-OS/EPA, Virginia) as they are on top of what folks have out already. Consider, however, that these folks have little time now to be reluctant. If you need to comply you need to get into this reg with both feet--NOW. My advice to those who need to comply is to DO SOMETHING! You may get it wrong the first time, but compliance on some parts of this reg may take more than one try for your operation! There is Compliance, and then there is Compliance and It Works for My Operation TOO. Look at The Delay as practice before the big game. Ain't no time to sit back and scratch your chin on this one! The Delay is very brief. This reg will be with most ag employers literally for the rest of their lives. And for us (trainers, instructors, outreachers, Extension, et al.): when would we get a second shot at getting ag employers information on the WPS at this late date if we "nurse" them first? Tell them it's big, tell them it's complicated, tell them this is the first reg you've ever seen that comes with it's own "logo", and they're that they're really going to have to roll their sleeves up on this one. They don't like it, they may not want to hear about it (they may not like you for telling them about it!), but they got to do it. As for not having time to read the How-to-Compy manual, they need to MAKE and TAKE the time to read it. This is so they will have time to read it again. The How-to-Compy manual does a very good job of getting it all down. (Bias here, I had a little imput on it). It's often a tempation for us in Extension to "re-invent the wheel". One of the best things you can do for a grower/producer is to slap a How-to-Comply manual in their hand and tell them to find a comfortable chair! You can only do so much hand-holding. The WPS is serious stuff. I know sound like a real hard-acre on this. I am. You do good work. Bellinger Clemson Univ Entomology bbllngr@clust1.clemson.edu From dbayer@usaid.gov Mon Sep 26 16:41:03 1994 Received: from BASA14001.usaid.gov ([165.13.2.2]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id QAA01788 for ; Mon, 26 Sep 1994 16:41:02 -0700 Received: by BASA14001.usaid.gov; Mon, 26 Sep 94 19:40:53 EDT Date: Mon, 26 Sep 94 19:30:14 EDT Message-ID: From: "David Bayer" To: wps-forum@are.Berkeley.EDU Subject: re: WPS-FORUM digest 93 X-Incognito-SN: 235 X-Incognito-Format: VERSION=2.00 Beta-30 ENCRYPTED=NO Howard, How are you guys doing? Believe it or not I read all these digests which come through but do not have time to reply or participate. Is there any chance that you could send me a copy of the "How to Comply" Manual for the WPS? If yes, this is the address: David Bayer P.O. Box 139 Ica, Peru By the way Mary Louise Flint from the IPM program has been a tremendous help. I shall be getting some of her stuff out to the Ica tomato grower industry. Keep up the good work and say hello to Gary, Greg, etc. Great staying in contact. David From Patric6548@aol.com Mon Sep 26 23:05:14 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 XAA06933 for ; Mon, 26 Sep 1994 23:05:14 -0700 From: Patric6548@aol.com Received: by mail02.prod.aol.net (1.38.193.5/16.2) id AA15680; Tue, 27 Sep 1994 02:04:40 -0400 X-Mailer: America Online Mailer Sender: "Patric6548" Message-Id: <9409270204.tn209739@aol.com> To: wps-forum@are.Berkeley.EDU Date: Tue, 27 Sep 94 02:04:22 EDT Subject: Re: AG-HRnet Gregory--- Hi--- and yes I would be interested in the Ag Human Resources Net. I'm very much interested in this area of our industry. ---Patrick From gebillikopf@ucdavis.edu Tue Sep 27 13:44:36 1994 Received: from ucdavis.ucdavis.edu (ucdavis.ucdavis.edu [128.120.1.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id NAA20857 for ; Tue, 27 Sep 1994 13:44:35 -0700 From: gebillikopf@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by ucdavis.ucdavis.edu (8.6.9/UCD2.50) id LAC03392; Tue, 27 Sep 1994 11:40:44 -0700 Date: Tue, 27 Sep 1994 11:40:44 -0700 Message-Id: <199409271840.LAC03392@ucdavis.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: new labor mgmt book cc: ce-counties@enterprise.ucdavis.edu cc: ce-cdirectors@enterprise.ucdavis.edu cc: danr-spec@enterprise.ucdavis.edu cc: hrnet@cornell.edu Labor Management in Ag[riculture]: Cultivating Personnel Productivity (170 pages, Billikopf) is now available for $10 (includes tax and mailing). Checks payable to "Farm Advisors' Trust Fund," and mail to address below. Audience: Directed to farmers and farm labor contractors. In English. Contents: Chapter 01- Managing People on the Farm Chapter 02- Practical Steps to Employee Selection Chapter 03- Validating the Selection Process Chapter 04- Promotions, Transfers & Layoffs Chapter 05- Helping Workers Acquire Skills Chapter 06- Performance Appraisal Chapter 07- Internal Wage Structure Chapter 08- Incentive Pay Chapter 09- Supervisory Power Chapter 10- Delegation Chapter 11- Conducting Effective Meetings Chapter 12- Interacting With Employees Chapter 13- Conflict Management Skills Chapter 14- Discipline & Termination Chapter 15- Turnover Chapter 01- Personnel Policies *********************************************************************** 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 gebillikopf@ucdavis.edu Wed Sep 28 00:23:04 1994 Received: from ucdavis.ucdavis.edu ([128.120.1.250]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id AAA00734 for ; Wed, 28 Sep 1994 00:23:03 -0700 From: gebillikopf@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by ucdavis.ucdavis.edu (8.6.9/UCD2.50) id JAA00478; Tue, 27 Sep 1994 09:04:05 -0700 Date: Tue, 27 Sep 1994 09:04:05 -0700 Message-Id: <199409271604.JAA00478@ucdavis.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: AG-HRnet ready 1. How to subscribe 2. Information about the Agricultural Human Resources Net 3. E-mail procedures for sending messages, unsubscribing, etc. 1. To subscribe to the AG-HRnet send message as follows: to: listproc@ucdavis.edu subject: (delete the subject line) subscribe ag-hrnet yourfirstname yourlastname -- (add a single line containing just two hyphens if you do not delete your signature) [You will receive a brief subscription acknowledgment via e-mail.] 2.- ************* SAVE THIS E-MAIL MESSAGE FOR FUTURE REFERENCE *********** The AG-HRnet is an open forum on agricultural labor management. Topics include management or legal aspects of employee selection, placement, promotions, transfers, layoffs, training, internal wage structure, incentive pay, benefits, supervision, delegation, performance appraisal, conflict management, negotiation, mediation, arbitration, interpersonal relations, discipline, termination, turnover, personnel policy, farm safety, and labor relations (union-management relations & collective bargaining). Whether your interest is as a farmer, consultant, academic, legal scholar, or other interested party, and regardless of the type of involvement--from a casual to an active participant--you are welcome. Use this net to offer suggestions, ask questions, obtain collaboration on an educational or research project. DELETE button: The success of a net such as this one depends on (1) interest a large number of participants of varied backgrounds and interests; (2) our ability to provide a good description in the "subject" or "re:" line, and (3) our willingness to use the delete button when the topic does not interest us. Do not be shy about sending messages to the whole net. Several subscribers may carry on a conversation on MEDIATION, or on the status of a particular LAW in CANADA, CALIFORNIA, or AUSTRALIA. With such a broad spectrum of subjects it is unlikely that you will be interested in all of them. 3.- ******************************************************** To send message to net >>> to: ag-hrnet@ucdavis.edu subject: (be descriptive) Type in your message. To subscribe >>> to: listproc@ucdavis.edu subject: (delete the subject line) subscribe ag-hrnet yourfirstname yourlastname -- (add a single line containing just two hyphens if you do not delete your signature) [You will receive a brief subscription acknowledgment via e-mail.] To unsuscribe >>> to: listproc@ucdavis.edu subject: (delete the subject line) unsubscribe ag-hrnet [note: don't put your name here when unsubscribing] -- (add a single line containing just two hyphens if you do not delete your signature) To obtain list of ag-hrnet members >>> to: listproc@ucdavis.edu subject: (delete the subject line) recipients ag-hrnet -- (add a single line containing just two hyphens if you do not delete your signature) More help on other commands >>> to: listproc@ucdavis.edu subject: (delete the subject line) help -- (add a single line containing just two hyphens if you do not delete your signature) ******************************************************** Best wishes: 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 charlie@hpirs.stjohn.hawaii.edu Wed Sep 28 13:48:41 1994 Received: from relay1.Hawaii.Edu (relay1.Hawaii.Edu [128.171.41.53]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id NAA22721 for ; Wed, 28 Sep 1994 13:48:40 -0700 Received: from uhunix.uhcc.Hawaii.Edu ([128.171.44.54]) by relay1.Hawaii.Edu with SMTP id <13858>; Wed, 28 Sep 1994 10:48:36 -1000 Received: from hpirs.stjohn.hawaii.edu by uhunix.uhcc.Hawaii.Edu (4.1/Sun690) id AA05820; Wed, 28 Sep 94 09:16:32 HST Date: Wed, 28 Sep 1994 09:16:32 -1000 Received: from HPIRS/MAILQUEUE by hpirs.stjohn.hawaii.edu (Mercury 1.11); Wed, 28 Sep 94 8:57:57 -1000 Received: from MAILQUEUE by HPIRS (Mercury 1.11); Wed, 28 Sep 94 8:57:32 -1000 Received: from [128.171.243.14] by hpirs.stjohn.hawaii.edu (Mercury 1.11); Wed, 28 Sep 94 8:57:22 -1000 To: wps-forum@are.Berkeley.EDU From: charlie@hpirs.stjohn.hawaii.edu Subject: Re: WPS 'Starter Kit' Message-Id: <207CD19353B@hpirs.stjohn.hawaii.edu> Terry, Have developed & twice tried a classroom handout for exercise to introduce the 'basics' of the WPS. Trainees get a copy of the How to Comply (HTC) manual and this 3 col., 10 row ruled handout. (Easy to compose in spread sheet format) Col.1 ROLE: Worker Employer, Handler Employer, Worker, Early-entry Worker, Handler, "other persons", Owner, Crop Advisor, Supervisors. Col. 2 PAGE IN THE HTC MANUAL: p. iii, p. iii, p. 14, p. 59 (paragr. 1 & 2), p. 14, p. 45,51,53, p. 91, p. 13, p. 19. Col. 3 EXAMPLE: [left blank for trainee to write in name of someone he or she knows who fit the role] I know you are looking for ideas that can be put on paper. But phrase in your messge, "hone in on the part of WPS that they are interested in at the moment - in some ways it might be an annotated guide to the WPS," caught my eye. I figured this classroom handout/exercise helps the trainee focus ("home in") on his or her ROLE in the WPS & also give page # references. Good luck. Charles Nagamine Environmental Biochemistry Dept. Dept. mail: 1800 East-West Rd. HENKE Hall, Rm. 329 Honolulu, HI 96822 My desk: St. John , Rm. 017 ph. 808/956-6007 From SMITH.JUDY@epamail.epa.gov Thu Sep 29 03:08:05 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 DAA19823 for ; Thu, 29 Sep 1994 03:08:03 -0700 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-7 #5309) id <01HHOA7TQTS090TFQD@epavax.rtpnc.epa.gov>; Thu, 29 Sep 1994 06:07:43 EDT Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-7 #5309) id <01HHOA4GGTUO8WYDNZ@mail.rtpnc.epa.gov>; Thu, 29 Sep 1994 06:05:01 EDT Received: with PMDF-MR; Thu, 29 Sep 1994 06:03:55 EDT MR-Received: by mta CARINA; Relayed; Thu, 29 Sep 1994 06:03:55 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Thu, 29 Sep 1994 05:48:00 -0400 (EDT) From: JUDY SMITH 703-305-6605 Subject: Re: WPS 'Starter Kit' To: wps-forum Message-id: <01HHOA4HBWOM8WYDNZ@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, 29 Sep 1994 05:57:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;55306092904991/1731555@MAIL] A1-type: MAIL Hop-count: 1 Terry and Charles Nagamine: I just joined WPS Forum a couple of days ago. In terms of handouts, I have a couple of sheets that may be of interest to you and others. The first is a single page handout; there are four column headers, i.e. toxicity category (with signal word), then PPE is outlined for Handlers and Early Entry workers, and WPS REIs are provided. It wouldn't be difficult to reference this sheet back to page numbers in the Handbook. The second handout, also a single page, is a listing of WPS Requirements. This provides a list of requirements, such as REIs, Early Entry Work, PPE for Handlers, Double Notification, Protection for Crop Advisors, Safety Training, etc. Plus, it indicates whether or not these requirements are applicable before or after 1/95, and has attached notes. This sheet would be more appropriate for the trainer or agricultural employer. Please contact me if you would like copies. Judy Smith U.S. EPA Office of Pesticides Occupational & Residential Exposure Branch 703-305-6605 From ONN@gnv.ifas.ufl.edu Thu Sep 29 06:42:44 1994 Received: from gnv.ifas.ufl.edu (gnv.ifas.ufl.edu [128.227.242.11]) by are.Berkeley.EDU (8.6.5/8.6.5) with ESMTP id GAA21315 for ; Thu, 29 Sep 1994 06:42:42 -0700 From: ONN@gnv.ifas.ufl.edu Received: from gnv.ifas.ufl.edu by gnv.ifas.ufl.edu (PMDF V4.2-11 #3240) id <01HHOH4GJKTY934QMU@gnv.ifas.ufl.edu>; Thu, 29 Sep 1994 09:42:10 EST Date: Thu, 29 Sep 1994 09:42:10 -0500 (EST) Subject: WPS Starter Kit To: wps-forum@are.Berkeley.EDU Message-id: <01HHOH4GJKU0934QMU@gnv.ifas.ufl.edu> X-VMS-To: IN%"wps-forum@are.berkeley.edu" MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Terry, I sympathize with growers in their attempt to comprehend the WPS. I think we need to be careful in trying to provide them an abbreviated version. following it. In order to know what they must do to comply, they need to have either How to Comply or the reg. If materials are developed to alert them about the WPS, they should tell the reader that this is not all they may or will need to know about WPS to be in compliance. They will need to have HTC or the reg, itself, in order to know all they need to know about compliance. Norm Nesheim, Unibv niversity of Florida From howardr@are.Berkeley.EDU Thu Sep 29 16:51:17 1994 Received: from [128.32.251.103] (gia5mac23.Berkeley.EDU [128.32.251.103]) by are.Berkeley.EDU (8.6.5/8.6.5) with SMTP id QAA06731 for ; Thu, 29 Sep 1994 16:51:15 -0700 Message-Id: <199409292351.QAA06731@are.Berkeley.EDU> Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Thu, 29 Sep 1994 16:52:01 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: mother of all starter kits? At long last, and perhaps in the nick of time to help colleagues intending to develop simplified 'starter kits', we have in the archive a copy of EPA's official starter kit, aka "The Worker Protection Standard For Agricultural Pesticides -- How to Comply". While this ASCII-format version of HTC does not exhibit the identical layout (i.e., graphics, font variations, blank pages) of the published Federal manual, it does include all the text of the official document in a form clearly representing the original. An explanatory note at the beginning of the archived version specifies its main adaptations from the original format. Like other files in the archive, HTC can now be downloaded through an e-mail command to ListProc and then imported into word processing programs, searched by keyword, extractracted from, edited, reformatted, and so on.