From REW@age2.age.uiuc.edu Thu Feb 2 05:47:32 1995 Received: from argus.cso.uiuc.edu (argus.cso.uiuc.edu [128.174.5.58]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id FAA24810 for ; Thu, 2 Feb 1995 05:47:32 -0800 Received: from sugar.age.uiuc.edu (sugar.age.uiuc.edu [128.174.141.26]) by argus.cso.uiuc.edu (8.6.9/8.6.9) with SMTP id HAA21945 for ; Thu, 2 Feb 1995 07:47:30 -0600 Received: from AGE-NEWAGE/TEMPQ by sugar.age.uiuc.edu (Mercury 1.13); Thu, 2 Feb 95 7:47:32 GMT+6 Received: from TEMPQ by AGE-NEWAGE (Mercury 1.13); Thu, 2 Feb 95 7:47:08 GMT+6 From: "Robert Wolf" To: wps-forum@are.Berkeley.EDU Date: Thu, 2 Feb 1995 07:47:02 CST Subject: Re: Relevance of chickens to WPS Priority: normal X-mailer: Pegasus Mail/Windows (v1.22) Message-ID: <1C2259A6DA0@sugar.age.uiuc.edu> This note is in support of those who feel that this forum should stick to WPS relevant material. I've been away from my office for a long enough period of time conducting PAT, WPS, and numerous pesticide application seminars that I cetainly do not have to worry about having email to read (125 messages over the last 2-3 weeks). So with nonrelevant items to sort through it just complicates the effort. I enjoy the forum for the most part and will continue to participate. Not seeing any email messages on my machine just means I can get to other items of work much quicker. Thanks for giving a few lines of your time! Date: Mon, 9 Jan 1995 21:51:15 -0800 Reply-to: wps-forum@are.Berkeley.EDU From: Bob Roach <73507.555@compuserve.com> To: Multiple recipients of list Subject: Relevance of chickens to WPS Amy, Allow me to explain myself. After returning from a long weekend I checked my mail and found that the box was empty! I just thought the forum needed a jump start. As for the relevance to the Worker Protection Standard, my point is that federal standards are sometimes absurd. I was voicing frustration at having a federal bureaucracy impose upon the states rules that are bad. Members may come and members may go but every time I hear the latest subscriber count, it is higher than the last. > Dear forum users -- > > Bob Roach's recent communication on poultry was somewhat interesting but I > fail to see its tie-in with WPS issues. There have been similar postings in > the past. Those of us out-of-staters who are members of the forum are willing > to wade through the stuff that's unique to California regulations for the sake > of the occasional useful discussion. However, when forum users stray from > the central issue of WPS some of us get frustrated. I know a number of > people who have reluctantly quit the forum because of this. > Bob Roach 73507.555@compuserve.com Thank you. --------------------------------------------------------------------------------------------------------------- Robert E. Wolf, Extension Specialist Agriculutral Engineering, Pesticide Applicator Training, University of Illinois, Department of Agricultural Engineering, 360-Q AESB, 1304 W. Pennsylvania Ave. , Urbana, IL 61801 Phone: (217) 333-9418, FAX: (217) 244-0323 Email: rew@age2.age.uiuc.edu; cellular: (217)493-1184 From MGALLO@cdprsmtp.cdpr.ca.gov Thu Feb 2 11:04:17 1995 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id LAA02378 for ; Thu, 2 Feb 1995 11:04:14 -0800 From: MGALLO@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Thu, 02 Feb 1995 11:02:52 -0800 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Thu, 02 Feb 1995 10:23:17 -0800 To: REW@age2.age.uiuc.edu, wps-forum@are.Berkeley.EDU Subject: Re: Relevance of chickens to WPS -Reply I'm not coming to Bob R's defense. However, I can see his point regarding the fresh/frozen/fresh chicken analogy of the WPS. Common sense and my taste buds, dictate that once a chicken, or any other food commodity has been frozen, it can not be considered fresh. But the feds, and the courts, disregard common sense and consider a thawed chicken as fresh. The feds made it so. Even though the WPS is well intended, much of it lacks common sense, but that makes no difference to the feds. They will make it so. I too, get very frustrated with the WPS regulations and EPA's proposals. But up to this point I've restrained myself from taking up people's time and forum space to vent my frustrations and lob rocks at a beast that I cannot control. I try not to spend energy and time trying to change what I cannot change or control what I cannot control. I prefer to spend my work time studying the WPS and DPR regulations and trying to understand them to the best of my ability so that I can answer questions from the growers, PCA's, and other folk when they ask me. If I be of any assistance to anyone, please don't hesitate to call or net me. Thanks for your time. Adolfo R. MarvinGallo Senior Pesticide Use Specialist California Department of Pesticide Regulation 916.445.3895 From acooke@moore.ces.ncsu.edu Fri Feb 3 06:36:46 1995 Received: from bigbad.ces.ncsu.edu (bigbad.ces.ncsu.edu [152.1.45.4]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id GAA14454 for ; Fri, 3 Feb 1995 06:36:46 -0800 Received: by bigbad.ces.ncsu.edu (5.59/25-eef) id AA15913; Fri, 3 Feb 95 09:39:10 EST Received: by moore.ces.ncsu.edu (NCCES-2.6) id AA05385; 2 Feb 95 15:54:06 EST (Thu) Subject: Central Posting To: wps-forum@are.Berkeley.EDU Date: Thu, 2 Feb 1995 15:54:06 -0500 (EST) From: "Al Cooke" X-Mailer: ELM [version 2.4 PL23] Content-Type: text Content-Length: 1050 Message-Id: <9502021554.AA05385@moore.ces.ncsu.edu> Any regulatory requirement tends to put an increased burden on the employer. Sometimes there are things we can turn to our advantage. What if a worker goes to court and insists s/he was never told what PPE to wear. Who will the court believe? As long as you've got this central posting with all the info there, require the workers to initial a statement that they have read the information and agree to comply. Every day. Just like punching a clock or signing in. It becomes part of going to work. It's no excuse for shabby compliance, but if an employer is making a good effort the employee's initials are evidence that he had access to the information on a daily basis. I realize that this is more workable for 20 workers than for 200. Any other information you need workers to know. You've got their attention for a moment. This burden might also work for the employer. Al ---^^^-- + 0 \ ''~'' -- Al Cooke E-Mail : acooke@moore Internet: acooke@moore.ces.ncsu.edu Phone : 910-947-3188 From howardr@are.Berkeley.EDU Fri Feb 3 10:47:56 1995 Received: from [128.32.251.100] (gia5mac20.Berkeley.EDU [128.32.251.100]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id KAA04560 for ; Fri, 3 Feb 1995 10:47:54 -0800 X-Sender: howardr@are.berkeley.edu Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Fri, 3 Feb 1995 10:48:27 -0800 To: wps-forum From: wps-forum@are.Berkeley.EDU (by way of howardr@are.berkeley.edu (Howard R. Rosenberg)) Subject: Re: Relevance of chickens to WPS [forwarding message that got hung up in ListProc error checker] ----------------------------------------------------------------------------- This Forum is for Those who don't Dread the onslaught of WPS mail. If you're recieving much more than you can "read or respond to", skip over the obvious extremist message. Read those that intrest you. ****************************************************************************** apesa@freenet.columbus.oh.us A. Patrick Pesa apesa@metrodata.com ****************************************************************************** On Thu, 2 Feb 1995, Robert Wolf wrote: > This note is in support of those who feel that this forum should > stick to WPS relevant material. I've been away from my office for > a long enough period of time conducting PAT, WPS, and numerous > pesticide application seminars that I cetainly do not have to worry > about having email to read (125 messages over the last 2-3 weeks). > So with nonrelevant items to sort through it just complicates the > effort. I enjoy the forum for the most part and will continue to > participate. Not seeing any email messages on my machine just means I > can get to other items of work much quicker. > > Thanks for giving a few lines of your time! > > Robert E. Wolf, Extension Specialist Agriculutral Engineering, Pesticide Applicator Training, > University of Illinois, Department of Agricultural Engineering, 360-Q AESB, > 1304 W. Pennsylvania Ave. , Urbana, IL 61801 From howardr@are.Berkeley.EDU Fri Feb 3 14:23:05 1995 Received: from [128.32.251.100] (gia5mac20.Berkeley.EDU [128.32.251.100]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id OAA10104 for ; Fri, 3 Feb 1995 14:23:03 -0800 X-Sender: howardr@are.berkeley.edu Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Fri, 3 Feb 1995 14:23:35 -0800 To: wps-forum From: GROUP PRESS 202-260-4355 (by way of howardr@are.berkeley.edu (Howard R. Rosenberg)) Subject: EPA/OSHA Publication on Ag Worker Heat Stress FOR RELEASE: FRIDAY, FEBRUARY 3, 1995 EPA AND OSHA JOINTLY PUBLISH GUIDE TO HEAT STRESS FOR AGRICULTURAL WORKERS EPA and the Occupational Safety & Health Administration (OSHA) have jointly published a guide to help employers protect workers in agriculture against heat-related illnesses, particularly workers who must wear protective gear. "A Guide to Heat Stress in Agriculture" offers practical, step-by-step guidance to managers on how to set up and operate a heat stress control program. The guide was developed in response to requests from agricultural employers and others. EPA's Worker Protection Standard for agricultural pesticides became fully effective on Jan. 1, l995. It requires employers to protect workers (particularly those who must wear protective gear) from illnesses due to heat. OSHA views the new guide as useful to other industries including hazardous waste sites and emergency response units. Copies of the guide are available from the U.S. Government Printing Office (document number 055-000-00474-9) by calling 202-512-1800 or writing GPO, Superintendent of Documents, Washington, D.C. 20402. Copies from GPO are $3.50, with a 25 percent discount for orders of l00 or more. A summary of the guide in both English and Spanish currently is in preparation and will be available soon. R-21# # # From howardr@are.Berkeley.EDU Mon Feb 6 10:07:25 1995 Received: from [128.32.251.100] (gia5mac20.Berkeley.EDU [128.32.251.100]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id KAA21546 for ; Mon, 6 Feb 1995 10:07:22 -0800 X-Sender: howardr@are.berkeley.edu Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Mon, 6 Feb 1995 10:07:57 -0800 To: wps-forum From: wps-forum@are.Berkeley.EDU (by way of howardr@are.berkeley.edu (Howard R. Rosenberg)) Subject: Inventing the future [from WILLIAMR@BCC.ORST.EDU] --------------------------------------------------------------------------- Bob Roach cites Carol Browner's comments in US News & World Rpt regarding what's wrong with government regulations (WPS Digest 186:1). In a recent WPS Digest (169:2), we learned that 88 pages were being considered as additions to current law. Do we wonder why citizens express concern about universities and agencies? Are we experiencing an exponential growth of regulations? What if we explored ways to improve regulatory relationships, common sense improvements, and a balance with compliance? Here's several things we've discovered. First, farmers and workers representing safety committees express lots of common sense ideas. Our experience suggests that asking, LISTENING, and respecting elicites lots of great ideas. Second, recognizing systemic patterns has helped us identify thinking habits and to see unintended consequences occurring over time (delays). Senge (Fifth Discipline, 1990) and others describe growth curves, fixes that fail, shifting the burden, and tragedies of the commons. Osborne and Gaebler (Reinventing Govt., 1992) describe 100 years of increasing regulations and dependency. Flood and Jackson (Total Systems Intervention, 1991) encourage listening to people's stories as a way to associate metaphors and selection of appropriate improvement processes. Instead of a machine metaphor and quick-fix mentality, people are searching for brain metaphors or ways we can learn and act systemically (relationally). As Senge says, "slow is fast". Third, recent learning research and organizational learning literature suggests dynamic and fundamental improvements can be achieved when people with diverse views and values explore common interests and invent ways to achieve their vision. A year ago, a worker representative (3 were invited), 2 agencies, and 7 farmers explored ways to improve WPS. Although the ideas fit outside current law, they seemed simple and common sense. Everyone expressed the same common interest, ie., worker safety. Farmers wanted facts to focus their actions. Since then, many more ideas have been generated. On March 1, 100 or so diverse people will meet to explore "great ideas" in small group discussions. Judgements about whether the ideas fit within current regulatory process will be postponed until the invention phase is achieved. Possible consequences from multiple perspectives and over-time will be considered. Each group will report back to the larger group for greater creativity and critique. A basic premise of this approach involves diverse people entering into a learning and action process that focuses on fundamental improvement. This approach represents a learning and action or brain metaphor. Fourth, we've discovered that communication across learning/action style preferences and cultures requires careful and respectful LISTENING. Although we often use the same word, relational and reductionist thinkers (Kolb, 1984; Myers-Briggs, 1985) interpret the meaning differently. People within an agency, farming, or ethnic culture interpret meanings differently. Thus, one ponders Carol Browner's words about shutting out humanity, about regulatory precision, and about a legal system that cannot be known. So what ideas pop into your mind? Why not ask workers and farmers about their ideas to improve safety? (Be patient; some of these people have a lot of baggage to release before they can be creative). How can we blend and balance compliance education and learning paradigms or brain metaphors within the WPS Digest to achieve both immediate requirements and fundamental improvements? ************************************************************************** The best way to predict the future is to invent it. Alan Kay ************************************************************************** Ray D. William Horticulture Dept. Oregon St. Univ. ALS 4017 Corvallis, OR 97331 From PMARER@ucipm.ucdavis.edu Mon Feb 6 14:54:23 1995 Received: from ucipm.ucdavis.edu (prime.ipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id OAA05639 for ; Mon, 6 Feb 1995 14:54:22 -0800 From: PMARER@ucipm.ucdavis.edu Message-Id: <199502062254.OAA05639@are.Berkeley.EDU> Received: (from user PMARER) by ucipm.ucdavis.edu; 06 Feb 95 14:53:00 PST To: wps-forum@are.Berkeley.EDU Date: 06 Feb 95 14:53:00 PST UPCOMING INSTRUCTOR TRAINING PROGRAMS FOR WORKER PROTECTION STANDARD (California) Our next round of instructor training programs will begin in March. We have 10 sessions scheduled and these are listed below. We will be holding additional sessions throughout the year and throughout the state, based on survey results sent to us by local Cooperative Extension offices, Agricultural Commissioner offices, and Farm Bureau offices. People attending these train-the-trainer programs will receive certificates which they can use to obtain the "Worker Verification Cards" to issue to fieldworkers they train. We submit the names of people attending train-the-trainer programs to the Department of Pesticide Regulation. There are two categories of programs: one for trainers of pesticide handlers and fieldworkers; the other for trainers of fieldworkers. To register for any of these meetings (except March 1) contact IPM Education and Publications - (916)752-7691 (for March 1 meeting contact Sharon Bock at the number listed below). Space is limited at each location, so anyone planning to attend should register early to be sure they get in. MARCH PROGRAMS FOR TRAINERS OF HANDLERS/FIELDWORKERS (8-hour program): March 1 - Sacramento (7th Annual America West Safety and Health Expo, Sacramento Convention Center) $40 plus Expo registration - contact Sharon Bock at (916)944-4950 March 9 - Fresno (Fresno County Farm Bureau) $100 March 21 - Lakeport (Clear Lake Grange Hall) $100 March 29 - Salinas (Salinas Community Center) $100 MARCH PROGRAMS FOR TRAINERS OF FIELDWORKERS - IN SPANISH (4-hour program): March 10 - Fresno (Fresno County Farm Bureau) $40 March 22 - Lakeport (Clear Lake Grange Hall) $40 March 30 - Salinas (Salinas Community Center) $40 MARCH PROGRAMS FOR TRAINERS OF FIELDWORKERS - IN ENGLISH (4-hour program): March 10 - Fresno (Fresno County Farm Bureau) $40 March 22 - Lakeport (Clear Lake Grange Hall) $40 March 30 - Salinas (Salinas Community Center) $40 Patrick J. Marer Pesticide Training Coordinator IPM Education and Publications University of California, Davis From SMITH.JUDY@epamail.epa.gov Mon Feb 6 15:13:00 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id PAA06309 for ; Mon, 6 Feb 1995 15:12:57 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HMQKJD9A9S8WWENM@epavax.rtpnc.epa.gov>; Mon, 06 Feb 1995 17:47:46 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HMQKIKVPNK8WW3QV@mail.rtpnc.epa.gov>; Mon, 06 Feb 1995 17:47:14 -0500 (EST) Received: with PMDF-MR; Mon, 6 Feb 1995 17:44:26 EST MR-Received: by mta PYXIS; Relayed; Mon, 06 Feb 1995 17:44:26 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Mon, 06 Feb 1995 17:32:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: Request for Comments on EPA Proposals To: wps-forum@are.Berkeley.EDU Message-id: <01HMQKJ0BDIA8WW3QV@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.berkeley.edu MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Mon, 06 Feb 1995 17:44:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;62447160205991/2418155@MAIL] A1-type: MAIL Hop-count: 1 On January 11, 1995, the Environmental Protection Agency (EPA) released five documents for public comment. The Agency addressed subject areas and solicited public comment for the following: 1. Proposed Training Rule - NOTE: Comment Period closes 2/10/95 This rule proposes shortening the grace period from 15 days to 0, 3, or 5 days. It also shortens the retraining period from 5 years to 3 years. 2. Proposed Crop Advisor Rule - NOTE: Comment Period closes 2/10/95 This rule proposes to exempt crop advisors from many WPS provisions. 3. Proposed Irrigation Exception - NOTE: Comment Period closes 2/27/95 This exception proposes to reduce the early entry restrictions on certain irrigation activities. 4. Proposed Limited Contact Exception - NOTE: Comment Period closes 2/27/95 This exception proposes to reduce the requirements that apply to workers having limited contact with pesticides when entering restricted areas; and, 5. Reduced Reentry Intervals for certain lower risk pesticides - NOTE: Comment Period closes 2/27/95 For certain lower risk pesticides (approximately 75 Active Ingredients), this would allow registrants to reduce label REIs from 12 hours to 4 hours. Interested parties are encouraged to provide EPA with both supportive and critical discussions and information con- cerning these proposals. Of particular interest are comments describing the potential impact of these proposals on operations engaged in the production of agricultural plants. Comments are also sought concerning the potential impact of these proposals on safety protections intended for agricultural workers or handlers involved in such operations. For further details, please contact the Certification, Training, and Occupational Safety Branch (EPA) at 703-305-7371. From 75222.2562@compuserve.com Mon Feb 6 16:18:59 1995 Received: from dub-img-3.compuserve.com (dub-img-3.compuserve.com [198.4.9.3]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id QAA00335 for ; Mon, 6 Feb 1995 16:18:58 -0800 Received: by dub-img-3.compuserve.com (8.6.9/5.941228sam) id TAA02383; Mon, 6 Feb 1995 19:17:53 -0500 Date: 06 Feb 95 19:16:23 EST From: Doug Edwards <75222.2562@compuserve.com> To: Subject: CENTRAL LOCATION Message-ID: <950207001623_75222.2562_GHI83-1@CompuServe.COM> On January 31st, Jeff Woodard said... >stuff deleted...< >As for accessibility of the central posting, many growers have found with< >outdoor bulletin boards that dew and rain and wind tend to make the< >posters/re-entry sheets wet, soggy, missing, and hard to read. Our state< >enforcement personnel have stated that the posting may be located in the< >central farm office that will likely be locked up at night, provided that a< >contact phone number is displayed on the door. This seemed to meet the< >'accessibility' requirement.< >What about growers without central farm offices? The ones that I've seen< >have adopted a briefcase in which all the wps related stuff goes. The< >workers generally ride in the same pickup as the manager, and he shows them< >the briefcase and allows them access, and they have his phone number for< >after-hours access. I think this may get a little sticky, but I'd be< >interested to see anyone else's solutions.< >stuff deleted...< This is interesting that Florida officials would accept that material be accessible INSIDE a farm office, or kept within a vehicle. This is pre- cisely the same standard currently in force under California's hazard communication program for accessibility to hazard communication information, and a source of debate between DPR and USEPA as to whether this information is accessible enough. I think the Florida approach to this issue is a reasonable solution. Doug Edwards Deputy Agricultural Commissioner Fresno County, California From eharwood@cce.cornell.edu Mon Feb 6 20:15:27 1995 Received: from cce.cornell.edu (EMPIRE.CCE.CORNELL.EDU [132.236.89.2]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id UAA09260 for ; Mon, 6 Feb 1995 20:15:26 -0800 Received: by cce.cornell.edu (Smail3.1.28.1 #4) id m0rbhMY-0003VDC; Mon, 6 Feb 95 23:17 EST Date: Mon, 6 Feb 1995 23:15:56 -0500 (EST) From: Ed Harwood Subject: Re: CENTRAL LOCATION To: wps-forum@are.Berkeley.EDU In-Reply-To: <950207001623_75222.2562_GHI83-1@CompuServe.COM> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII HI Wondered why the notices couldn't be laminated. Most Insty-Print places will do this and many schools can. Just a thought. See ya EDH +!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+!+ Ed Harwood (607) 255-3131 FAX: 255-0788 HOME: 257-3996 Program Leader, Agricultural Competitiveness and Profitability Cornell Cooperative Extension 340 Roberts Hall Ithaca, NY 14850-4203 ed_harwood@cce.cornell.edu From k.underwood@genie.geis.com Tue Feb 7 10:49:04 1995 Received: from relay1.geis.com (relay1.geis.com [192.77.188.2]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id KAA06443 for ; Tue, 7 Feb 1995 10:49:01 -0800 From: k.underwood@genie.geis.com Received: by relay1.geis.com (1.37.109.11/15.6) id AA252692930; Tue, 7 Feb 1995 18:48:50 GMT Message-Id: <199502071848.AA252692930@relay1.geis.com> Date: Tue, 7 Feb 95 18:20:00 UTC To: wps-forum@are.Berkeley.EDU Subject: Re: CENTRAL LOCATION X-Genie-Id: 8614173 X-Genie-From: K.UNDERWOOD Schools, institutions may have capabilities of lamination, I will wager that most farming and other operations that would need this done cannot secure it for a "reasonable" price. Here in my operation I would have to take two to three hours of my field time to drive to the nearest town to get this done. This would again be additional expenses for Agriculture that is only created by buracratic gobble, not practicality! Our profit margin is tight enough. Keith Underwood K.Underwood@genie.geis.com From woodard@igc.apc.org Tue Feb 7 14:13:16 1995 Received: from mail.igc.apc.org (mail.igc.apc.org [192.82.108.38]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id OAA11495 for ; Tue, 7 Feb 1995 14:13:13 -0800 Received: from igc2.igc.apc.org (igc2.igc.apc.org [192.82.108.39]) by mail.igc.apc.org (8.6.9/Revision: 1.57 ) with SMTP id OAA22831 for ; Tue, 7 Feb 1995 14:13:44 -0800 Received: from ppp9.igc.org (ppp9.igc.org [198.94.6.9]) by igc2.igc.apc.org (8.6.9/Revision: 1.7 ) with SMTP id OAA26705 for ; Tue, 7 Feb 1995 14:13:40 -0800 Date: Tue, 7 Feb 1995 14:13:40 -0800 Message-Id: <199502072213.OAA26705@igc2.igc.apc.org> X-Sender: woodard@igc.apc.org (Unverified) X-Mailer: Windows Eudora Version 1.4.4 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: woodard@igc.apc.org (Woody) Subject: Re: CENTRAL LOCATION and cost of implementation Ed Harwood Says: >Wondered why the notices couldn't be laminated. Most Insty-Print places >will do this and many schools can. Just a thought. And a good thought, but I don't think that's very feasable. We run a 'central posting' service by fax, where the grower faxes in what they plan to spray, and we fax back the WPS formatted re-entry sheets. Although different growers spray very differently, we've sent over 200 pages of re-entry sheets to one grower in the worst case, and 40 or so in the best case. This is with a 4 month vegetable crop, on close to 200 acres. I shudder to think of the cost of laminating each of these pages, as well as the cost of sending someone the 20-80 miles into town to get it done 'before the application takes place'. On another note, Florida's enforcement personnel told me that the EPA at the federal level estimated the average cost of compliance for growers would be about $47. It doesn't take many .5-1hour training sessions to reach that cost. I wonder if there are any bright economists out there who have done any independent analysys of WPS compliance costs to growers? C 'ya Woody /**************************************************************************/ Jeff Woodard Glades Crop Care voice: 407-746-3740 949 Turner Quay fax: 407-746-3775 Jupiter, FL 33478 e-mail: woodard@igc.apc.org - jwoodard@crl.nmsu.edu - woody@taipan.nmsu.edu woody@ios.com woody0@aol.com -My opinions are my own- /*************************************************************************** *****/ From RDSHS@aol.com Tue Feb 7 15:47:13 1995 Received: from mail04.mail.aol.com (mail04.mail.aol.com [152.163.172.53]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id PAA13962 for ; Tue, 7 Feb 1995 15:47:12 -0800 From: RDSHS@aol.com Received: by mail04.mail.aol.com (1.37.109.11/16.2) id AA117050600; Tue, 7 Feb 1995 18:43:20 -0500 Date: Tue, 7 Feb 1995 18:43:20 -0500 Message-Id: <950207184032_15503309@aol.com> To: wps-forum@are.Berkeley.EDU Subject: extremist message A. Patrick Pesa apesa@metrodata.com responded on Fri, Feb 3 to Re: Relevance of chickens to WPS ************** You bring to light an important point, that being: The ongoing perpetration of anything other than political correctness as an "obvious extremist message". Did it occur to you that it might just be these individuals frustration at EPA's lack of common sense. e.g., Frozen chicken policy is precisely relevant to WPS. Both RULES are derived from pure raw politics, not science or common sense. There are those who not only "Dread the onslaught of WPS mail" but "Dread the onslaught of WPS" itself. Before I decide how fast I am going to dance, I first decide "if" I am going to dance at all. If someone were to cause EPA to place the supporting documents (data and calculations) "on the table" for the justification of the published WPS RULE, one might find the table bare. Also, for those of you from states other than California who trivialize California's traumas. I suggest you pay attention. If this RULE gets enforced, you will have traumas too, except you may not have 20 years of state pesticide policy infrastructure as a head-start. From ROYR@cdprsmtp.cdpr.ca.gov Wed Feb 8 08:58:25 1995 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id IAA08167 for ; Wed, 8 Feb 1995 08:58:24 -0800 From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Wed, 08 Feb 1995 08:57:15 -0800 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Wed, 08 Feb 1995 08:56:48 -0800 To: wps-forum@are.Berkeley.EDU, k.underwood@genie.geis.com Subject: There has been considerable recent discussion about "central posting" on the forum. There has been considerable recent discussion about "central posting" on the forum. As I understand it there are two things that have to be centrally posted (displayed) under the WPS. The safety information and the application specific information (ASI). I am not sure just which is being addressed by all the talk about laminating and such. There may be some value in providing this kind of protection for the safety information which has some on-going value, but the ASI can be thrown away after 30 days. Why invest all this time and effort in these documents? There is nothing that I have heard of that says the documents have to be exposed to the weather. The word I have from the EPA is that the standard for the display, posting, unimpeded access, etc. is that "the employee must be able to approach and handle or read the documents without having to make a request of anyone". I have read some postings that seem to imply that a different standard may be in place in some other parts of the country. Can anyone verify this for me? This has been a point of some considerable intense discussion in California. Particularly the timing of the display. My understanding is that the information doesn't have to actually be thumb tacked (posted) to a wall or board to meet the standard of "displayed" as long as the definition cited above is met relative to the access. California intends to incorporate the safety information into documents that are already required to be "displayed" so growers will be in compliance without noting any real difference. Use of the big EPA poster is entirely their option, after all it is their property so they can put up almost anything they want. California is trying to allow flexibility in how to comply with the ASI. EPA says that our current use record/report system developed over the last 25 years won't make it. That's real unfortunate as it has other uses such as helping growers comply with the 1990 farm bill requirement for private applicators to keep records of RUP use for 2 years and by processors checking up on potential residues. From SMITH.JUDY@epamail.epa.gov Fri Feb 10 05:32:41 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id FAA12784 for ; Fri, 10 Feb 1995 05:32:40 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HMVM4VPL5S8WY5IL@epavax.rtpnc.epa.gov>; Fri, 10 Feb 1995 08:27:24 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HMVM43HN348WX5AR@mail.rtpnc.epa.gov>; Fri, 10 Feb 1995 08:27:19 -0500 (EST) Received: with PMDF-MR; Fri, 10 Feb 1995 08:26:19 EST MR-Received: by mta PYXIS; Relayed; Fri, 10 Feb 1995 08:26:19 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Fri, 10 Feb 1995 07:55:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: LAST DAY FOR COMMENTS To: wps-forum@are.Berkeley.EDU Message-id: <01HMVM56XCA48WX5AR@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: Fri, 10 Feb 1995 08:26:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;91628001205991/2444503@MAIL] A1-type: MAIL Hop-count: 1 Members of the Forum: Today, February 10th, is the last day to submit comments for the following two EPA proposals: 1. Pesticide Safety Training for Workers and Handlers ** Please reference docket number: OPP-250097, in your comment about the training proposal ** 2. Pesticide Worker Protection Standard: Requirements for Crop Advisors. ** Please reference docket number: OPP-250100, in your comments about the crop advisor proposal ** You are encouraged to submit comments to the EPA Docket electronically. The email address for the Docket is: Docket-OPPTS@epamail.epa.gov Athough there were several comments concerning crop advisors on WPS-Forum, the Agency has received only a few electronic comments concerning these actions. If you are influenced by these proposals, this is the last opportunity to express your concerns and indicate how you and/or your operations may be influenced by these proposed actions. You may also FAX your comments to the Agency. Indicate "Docket -Comments/Attention: J. Smith" on your cover page. Make certain that your comments reference the appropriate docket number (Docket No. indicated above for each proposal). You may FAX comments to 703-308-2962. If you have questions, please contact me at 703-305-7666. Judy Smith Certification, Training, and Occupational Safety Branch From woodard@igc.apc.org Fri Feb 10 05:56:27 1995 Received: from mail.igc.apc.org (root@mail.igc.apc.org [192.82.108.38]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id FAA12917 for ; Fri, 10 Feb 1995 05:56:26 -0800 Received: from igc2.igc.apc.org (igc2.igc.apc.org [192.82.108.39]) by mail.igc.apc.org (8.6.9/Revision: 1.57 ) with SMTP id FAA04412 for ; Fri, 10 Feb 1995 05:57:32 -0800 Received: from ppp6.igc.org (ppp6.igc.org [198.94.6.6]) by igc2.igc.apc.org (8.6.9/Revision: 1.7 ) with SMTP id FAA06733 for ; Fri, 10 Feb 1995 05:57:28 -0800 Date: Fri, 10 Feb 1995 05:57:28 -0800 Message-Id: <199502101357.FAA06733@igc2.igc.apc.org> X-Sender: woodard@igc.org (Unverified) X-Mailer: Windows Eudora Version 1.4.4 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: woodard@igc.apc.org (Woody) Subject: Re: There has been considerable recent discussion about "central ROYR says: >in these documents? There is nothing that I have heard of that says the documents >have to be exposed to the weather. Many growers (and me too) have made the interpretation that the WPS central posting must be outside, or at least in an unlocked shed for 24 hour accessability reasons, but on re-reading the How to Comply manual section, it's not as strict as I once thought. I noticed that the illustration on this section does show an outdoor bulletin board (or what appears to me to be so). >will be in compliance without noting any real difference. Use of the big EPA poster is >entirely their option, after all it is their property so they can put up almost anything >they want. Woah, careful, the requirements of the safety poster are pretty specific. It says either the EPA safety poster, or one that meets the requirements detailed on p. 101.... In all honesty, all of the posters I've seen meet the requirements, but I think an inspector would probably tend to be happier with something he was familiar with. /**************************************************************************/ Jeff Woodard Glades Crop Care voice: 407-746-3740 949 Turner Quay fax: 407-746-3775 Jupiter, FL 33478 e-mail: woodard@igc.apc.org - jwoodard@crl.nmsu.edu - woody@taipan.nmsu.edu woody@ios.com woody0@aol.com -My opinions are my own- /*************************************************************************** *****/ From ROYR@cdprsmtp.cdpr.ca.gov Tue Feb 14 09:17:00 1995 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id JAA07979 for ; Tue, 14 Feb 1995 09:16:59 -0800 From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Tue, 14 Feb 1995 09:15:48 -0800 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Tue, 14 Feb 1995 09:15:43 -0800 To: wps-forum@are.Berkeley.EDU, woodard@igc.apc.org Subject: Jeff Woodward says: Jeff Woodward says: The requirements for the safety poster are pretty specific. I agree. The actual regulation doesn't say anything about the EPA poster. that's just a nice way to comply. The How to Comply Manual is NOT regulation, one must go back to the actual text of the regulation for the basic requirement. The Manual is quotes as stating on page 101 that EITHER the EPA poster or . . . . In CA we are taking the "either" option because we have other stuff we want available to workers. We are incorporating the new EPA stuff into an existing document that is already required to be posted. I repeat, growers will notice little difference in this one item. The basic purpose of the WPS is not to make inspectors happy but to provide protection to workers. Too often government loses sight of the basic intent of laws and favors form over function. That is part of the reason we had such a revolution last November. People are fed up with unworkable laws and regulations. Roy R From RUDOLPH.KAY@EPAMAIL.EPA.GOV Tue Feb 14 10:10:30 1995 Received: from merlin.rtpnc.epa.gov (merlin.rtpnc.epa.gov [134.67.208.148]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id KAA11783 for ; Tue, 14 Feb 1995 10:10:29 -0800 From: RUDOLPH.KAY@EPAMAIL.EPA.GOV Received: from lancelot.rtptok.epa.gov by merlin.rtpnc.epa.gov (8.6.9/1.34) id NAA10781; Tue, 14 Feb 1995 13:09:20 -0500 Received: from cc:Mail by lancelot.rtptok.epa.gov id AA792796169; Tue, 14 Feb 95 10:00:00 EST Date: Tue, 14 Feb 95 10:00:00 EST Message-Id: <9501147927.AA792796169@lancelot.rtptok.epa.gov> To: wps-forum@are.Berkeley.EDU Subject: The How to Comply Manual vs the Regulation To clarify an issue raised in an earlier message, compliance with the How to Comply manual DOES equate to compliance with the 1992 WPS. As the printed manual states, " This manual, in its official Federal format, provides the information necessary to comply with the requirements of the 1992 Federal Worker Protection Standard." So you don't have to go back the text of the regulation to find out what the law is. Now, that introductory paragraph also goes on to state that "EPA may issue additional guidance about the Worker Protection Standard and the Worker Protection Standard may be amended in the future. Check with your State or Tribal agency responsible for pesticides for further information and updates." As you have heard, EPA has proposed five amendments to the WPS, and has issued guidance in the form of interpretive Questions and Answers. Also, some states and tribes may have additional worker protection regulations. So while I recommend the HTC, I also encourage employers to contact their local pesticide regulatory agency for this additional information. Kay Rudolph US-EPA, Region 9, San Francisco From ROYR@cdprsmtp.cdpr.ca.gov Tue Feb 14 11:03:59 1995 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id LAA15688 for ; Tue, 14 Feb 1995 11:03:58 -0800 From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Tue, 14 Feb 1995 11:02:34 -0800 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Tue, 14 Feb 1995 11:02:35 -0800 To: wps-forum@are.Berkeley.EDU, RUDOLPH.KAY@epamail.epa.gov Subject: Kay Rudolp;h states, compliance with the Kay Rudolp;h states, compliance with the How to Comply manual DOES equate to compliance with the 1992 WPS. I certainly agree, but my point is that the HTC manual may not include all of the ways an employer may chose to comply with the WPS. The HTC is the "easy way out" where practical. If not practical the employer may want to go back to the regs to see is there is latitude for other ways to comply. Am I wrong in stating that the regulation does not mention the EPA poster? I understand it to simply require the "safety information". Of course, in most cases, simply putting up the poster, big as it is, is the easiest way to comply, I will readily admit that, but it is not the only way to comply. Another point posted recently implied that the information might have to be available 24 hours a day. I can't find any reference for that requirement, unless workers are on the establishment for 24 hours a day. The information must be available whenever workers or handlers are on the establishment and . . . . From ams@cftnet.com Tue Feb 14 12:52:56 1995 Received: from renoir.cftnet.com (renoir.cftnet.com [163.125.1.2]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id MAA22790 for ; Tue, 14 Feb 1995 12:52:48 -0800 Received: (ams@localhost) by renoir.cftnet.com (8.6.9/8.6.4) id PAA23608; Tue, 14 Feb 1995 15:50:53 -0500 Date: Tue, 14 Feb 1995 15:50:52 -0500 (EST) From: Marc Donovan X-Sender: ams@renoir To: wps-forum@are.Berkeley.EDU Subject: AMS Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII We have a solution for most of the problems experienced by growers in complying with the WPS. If you are spending alot of time preparing your reentry postings by hand, or notifying your workers about PPEs, then our Application Management System will help. This is a complete pesticide management program that is presently being used by over 100 growers in Florida alone. If you would like a free copy to try, just e-mail or call us. This free copy may be passed around and duplicated for evaluation. Marc Donovan ams@renoir.cftnet.com Commercial Computer Systems Inc. ag chemical management software home of the 1-800-340-7525 Application Management System St Pete FL From RUDOLPH.KAY@EPAMAIL.EPA.GOV Tue Feb 14 16:50:39 1995 Received: from merlin.rtpnc.epa.gov (merlin.rtpnc.epa.gov [134.67.208.148]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id QAA00280 for ; Tue, 14 Feb 1995 16:50:37 -0800 From: RUDOLPH.KAY@EPAMAIL.EPA.GOV Received: from lancelot.rtptok.epa.gov by merlin.rtpnc.epa.gov (8.6.9/1.34) id TAA19716; Tue, 14 Feb 1995 19:49:19 -0500 Received: from cc:Mail by lancelot.rtptok.epa.gov id AA792820166; Tue, 14 Feb 95 16:42:00 EST Date: Tue, 14 Feb 95 16:42:00 EST Message-Id: <9501147928.AA792820166@lancelot.rtptok.epa.gov> To: wps-forum@are.Berkeley.EDU Subject: Re: Kay Rudolph states, compliance with the Let me repeat: the How to Comply manual contains ALL the information you will need to comply with the 1992 Federal Worker Protection Standard. On the specific issue of the safety poster, page 23 of the HTC requires, under item 3 under What Information Must Be Displayed: "A pesticide safety poster, which must be either the WPS safety poster developed by EPA or an equivalent poster that contains the concepts listed in Criteria for Pesticide Safety Poster, p. 101." The criteria on page 101 of the printed HTC are the criteria listed in the regulation, nothing more. As I said before, there have been amendments proposed, and EPA has provided interpretive guidance, so you should contact your local pesticide regulatory agency for this information and to learn about any additional local regulations. As for when the application list information has to be posted, I quote from p. 24 of the HTC: display it before the application takes place if you have workers or handlers on the establishment, or no later than the beginning of the first work period if workers and handlers were not present at the start of the application, then "Continue to display pesticide-specific information when workers or handlers are on your establishment UNTIL: at least 30 days after the restricted-entry interval expires, or at least 30 days after the end of the application, if there is no restricted-entry interval for the pesticide. Kay Rudolph US-EPA Region 9, San Francisco From raflashi@facstaff.wisc.edu Wed Feb 15 07:23:08 1995 Received: from audumla.students.wisc.edu (students.wisc.edu [144.92.104.66]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id HAA09234 for ; Wed, 15 Feb 1995 07:23:07 -0800 Received: from servroger by audumla.students.wisc.edu; id JAA15032; 8.6.9W/42; Wed, 15 Feb 1995 09:23:04 -0600 Date: Wed, 15 Feb 1995 09:23:04 -0600 Message-Id: <199502151523.JAA15032@audumla.students.wisc.edu> X-Sender: raflashi@facstaff.wisc.edu Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: raflashi@facstaff.wisc.edu (Roger Flashinski) Subject: Re: AMS X-Mailer: Marc, I'd be interested in getting a copy of your AMS. > >We have a solution for most of the problems experienced by growers in complying with the WPS. If you >are spending alot of time preparing your reentry postings by hand, or notifying your workers about PPEs, >then our Application Management System will help. This is a complete pesticide management program >that is presently being used by over 100 growers in Florida alone. If you would like a free copy to try, >just e-mail or call us. This free copy may be passed around and duplicated for evaluation. > > Marc Donovan ams@renoir.cftnet.com >Commercial Computer Systems Inc. ag chemical management software > home of the 1-800-340-7525 > Application Management System St Pete FL > > > > > > > > > Roger Flashinski, Program Mgr Phone: 608-263-6358 Pesticide Applicator Training Fax: 608-262-5217 Dept of Agronomy e-mail: raflashi@facstaff.wisc.edu 1575 Linden Dr Madison WI 53706-1597 From 73507.555@compuserve.com Wed Feb 15 22:47:28 1995 Received: from arl-img-3.compuserve.com (arl-img-3.compuserve.com [198.4.7.3]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id WAA08900 for ; Wed, 15 Feb 1995 22:47:27 -0800 Received: by arl-img-3.compuserve.com (8.6.9/5.941228sam) id BAA07625; Thu, 16 Feb 1995 01:44:19 -0500 Date: 16 Feb 95 01:40:13 EST From: Bob Roach <73507.555@compuserve.com> To: wps-forum Subject: HTC Manual Message-ID: <950216064012_73507.555_HHB63-1@CompuServe.COM> Kay, I had an attorney call me today. She had read the HTC manual and was not satisfied. But then she read the text of the rule and was not satisfied. That is because she was looking to answers to some of the questions of liability that have not yet been resolved. I find the rule itself easier to deal with than the HTC manual. Perhaps that is because I am used to dealing with regulations. The manual is not the law. We are not going to enforce the manual but the law. It would be arrogant of the U.S. EPA to think that they have produced a manual that contains everything anybody needs to know about as complex a rule as the WPS. It is simply beyond human ability to foresee all the situations that will develop in the real world in relation to any rule. What does the HTC manual say about the "central location?" That has been the subject of lengthy debate on the forum. Perhaps we should have just read the manual. Isn't that what they say, "When all else fails, read the manual"? When that fails I guess we should read the interpretive guidance. > To clarify an issue raised in an earlier message, compliance with >the How to Comply manual DOES equate to compliance with the 1992 WPS. >As the printed manual states, " This manual, in its official Federal >format, provides the information necessary to comply with the >requirements of the 1992 Federal Worker Protection Standard." So you >don't have to go back the text of the regulation to find out what >the law is. ****************************************************************** "Men hate the truth. They would rather meet a tiger in the road." - Robinson Jeffers Bob Roach 73507.555@compuserve.com ****************************************************************** From NLSSROL@ADMIN.BAS.NCSU.EDU Thu Feb 16 05:15:29 1995 Received: from romulus.cc.ncsu.edu (romulus.cc.ncsu.edu [152.1.10.19]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id FAA03472 for ; Thu, 16 Feb 1995 05:15:24 -0800 Received: from admin.bas.ncsu.edu by romulus.cc.ncsu.edu (5.65b/SYSTEMS Dec 28 15:30:00 EDT 1992) id AA02094; Thu, 16 Feb 95 08:15:23 -0500 Posted-Date: Thu, 16 Feb 1995 08:16:04 EST Received: from ADMIN/MAILQUEUE by admin.bas.ncsu.edu (Mercury 1.13); Thu, 16 Feb 95 8:16:07 EST Received: from MAILQUEUE by ADMIN (Mercury 1.13); Thu, 16 Feb 95 8:16:05 EST From: "Roger Lewis" Organization: N.C. State University To: wps-forum@are.Berkeley.EDU Date: Thu, 16 Feb 1995 08:16:04 EST Subject: Re: AMS Priority: normal X-Mailer: Pegasus Mail/Windows v1.11 Message-Id: <767362720E@admin.bas.ncsu.edu> Marc, I would like a copy of the manual, please send to: Roger Lewis NC State University Environmental Health & Safety Center Box 7222 Raleigh, NC 27695 Thanks! I'm the industrial hygienist here and we have several research-type farm units. The manual will be helpful. From PMARER@ucipm.ucdavis.edu Thu Feb 16 08:39:01 1995 Received: from ucipm.ucdavis.edu (prime.ipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id IAA13354 for ; Thu, 16 Feb 1995 08:39:00 -0800 From: PMARER@ucipm.ucdavis.edu Message-Id: <199502161639.IAA13354@are.Berkeley.EDU> Received: (from user PMARER) by ucipm.ucdavis.edu; 16 Feb 95 08:39:52 PST To: wps-forum@are.Berkeley.EDU Date: 16 Feb 95 08:39:52 PST POSITION AVAILABLE FOR PESTICIDE EDUCATOR PROGRAM REPRESENTATIVE III VL# 0184 - Program Representative III - $2691-$4016/month Final Filing Date: 2-24-95 This position is located in the Statewide Integrated Pest Management Project, Pesticide Education Program, and is not covered by a collective bargaining unit. RESPONSIBILITIES: Develop educational and informational materials and programs for instructors, pesticide handlers, fieldworkers, and community agency personnel to inform them about the agricultural use of pesticides, aspects of pesticide safety for farm workers, ways farm workers and their families avoid pesticide exposure, and what workers and their families do if exposure occurs; develop specific materials and programs related to pesticide safety for agricultural workers and their families. REQUIREMENTS: Excellent writing and public speaking skills with proficiency in both English and Spanish; good teaching skills with ability to develop innovative teaching methods for non-readers; familiarity with concepts of pest management, especially as it relates to the use of pesticides; expertise in principles of pesticide safety; familiarity with community social service agencies and rural health clinics desirable; familiarity with methods used to test and evaluate training programs and educational materials; ability to use wordprocessor. SPECIAL REQUIREMENTS: A valid Driver's License is required. CONDITIONS OF EMPLOYMENT: California Department of Pesticide Regulation Qualified Applicator Certificate (QAC) required, but may be obtained after employment; frequent travel throughout the state with occasional overnight stays; occasional variable hours required to accommodate for travel and training schedules; work in non-smoking area. APPLICATION PROCESS: Apply to UC Davis Employment Office, TB 122, Davis, California, 95616. Applications must be received on or before 5:00 pm February 24, 1995 for consideration (postmarks are not acceptable). Required application materials are available at the UCD Employment Office or the UCDMC Personnel/Applicant Services Office, 2525 Stockton Boulevard, Room 1019, Sacramento, California. You may also call (916)752-1760. Detailed job descriptions are on file (and available for copying) at the UCD Employment Office. For further information, please contact Irene Day, Recruitment Specialist, at (916)752-6287. UCD is an equal opportunity/affirmative action employer. From k.underwood@genie.geis.com Fri Feb 17 10:26:05 1995 Received: from relay1.geis.com (relay1.geis.com [192.77.188.2]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id KAA13128 for ; Fri, 17 Feb 1995 10:26:02 -0800 From: k.underwood@genie.geis.com Received: by relay1.geis.com (1.37.109.11/15.6) id AA152525557; Fri, 17 Feb 1995 18:25:57 GMT Message-Id: <199502171825.AA152525557@relay1.geis.com> Date: Fri, 17 Feb 95 07:01:00 UTC To: wps-forum@are.Berkeley.EDU Subject: Residue testing info? X-Genie-Id: 9465461 X-Genie-From: K.UNDERWOOD Had an individual ask me a question today that was an interesting one. Does anyone have an answer: He understood that there was a rule, law, requirement or whatever being proposed and soon to be implemented that would require a grower to have his/her employees that are applicators for their business tested for exposure after every 10 hours of work applying chemicals. Is this a truth or rummor? If it is a truth, where can we get more information and reply to the silliness of this kind of regulation! Also what a waste of money if the individual is wearing proper PPE. Keith Underwood K.Underwood@Genie.geis.com From NLSSROL@ADMIN.BAS.NCSU.EDU Fri Feb 17 12:44:49 1995 Received: from romulus.cc.ncsu.edu (romulus.cc.ncsu.edu [152.1.10.19]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id MAA17304 for ; Fri, 17 Feb 1995 12:44:47 -0800 Received: from admin.bas.ncsu.edu by romulus.cc.ncsu.edu (5.65b/SYSTEMS Dec 28 15:30:00 EDT 1992) id AA02665; Fri, 17 Feb 95 15:44:46 -0500 Posted-Date: Fri, 17 Feb 1995 15:45:14 EST Received: from ADMIN/MAILQUEUE by admin.bas.ncsu.edu (Mercury 1.13); Fri, 17 Feb 95 15:45:32 EST Received: from MAILQUEUE by ADMIN (Mercury 1.13); Fri, 17 Feb 95 15:45:17 EST From: "Roger Lewis" Organization: N.C. State University To: wps-forum@are.Berkeley.EDU Date: Fri, 17 Feb 1995 15:45:14 EST Subject: Re: Residue testing info? Priority: normal X-Mailer: Pegasus Mail/Windows v1.11 Message-Id: <95F0D70F1E@admin.bas.ncsu.edu> In reply to Mr. Underwood's question on medical surveillance for pesticide exposure. OSHA does not require medical monitoring for all pesticides, which includes the organophosphorus pesticides. However, cholinesterase monitoring should be evaluated for some pesticide exposure situations. This is an area that needs to be addressed. From cuadros@uclink2.berkeley.edu Fri Feb 17 17:02:30 1995 Received: from uclink2.berkeley.edu (uclink2.Berkeley.EDU [128.32.136.72]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id RAA24819 for ; Fri, 17 Feb 1995 17:02:30 -0800 Received: by uclink2.berkeley.edu (8.6.8/1.33(web)-OV2) id RAA26710; Fri, 17 Feb 1995 17:02:29 -0800 Date: Fri, 17 Feb 1995 17:02:28 -0800 (PST) From: Eric Berg Cuadros Subject: Re: Residue testing info? To: wps-forum@are.Berkeley.EDU cc: Multiple recipients of list In-Reply-To: <95F0D70F1E@admin.bas.ncsu.edu> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII OSHA does not require testing for organophosphate peticides? I don't understand that since they are responsible for most of the reported acute poisoning cases. Is risk categorized from data on lab animal experiments or on data from acutal human illness? Of the 26 pesticides accounting for the largest number of worker poisonings, less than half are restricted to certified applicators and less than one quarter are subject to strong warning requirements or handling restrictions. (Info from Preventing Pesticide-relatedted illness in Calfironia Agriculture, Center for Occupational and Environmental Health) -Eric Berg On Fri, 17 Feb 1995, Roger Lewis wrote: > In reply to Mr. Underwood's question on medical > surveillance for pesticide exposure. OSHA does > not require medical monitoring for all pesticides, > which includes the organophosphorus pesticides. > However, cholinesterase monitoring should be > evaluated for some pesticide exposure situations. > This is an area that needs to be addressed. > From NLSSROL@ADMIN.BAS.NCSU.EDU Mon Feb 20 12:57:33 1995 Received: from romulus.cc.ncsu.edu (romulus.cc.ncsu.edu [152.1.10.19]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id MAA23634 for ; Mon, 20 Feb 1995 12:57:32 -0800 Received: from admin.bas.ncsu.edu by romulus.cc.ncsu.edu (5.65b/SYSTEMS Dec 28 15:30:00 EDT 1992) id AA07796; Mon, 20 Feb 95 15:57:30 -0500 Posted-Date: Mon, 20 Feb 1995 15:57:55 EST Received: from ADMIN/MAILQUEUE by admin.bas.ncsu.edu (Mercury 1.13); Mon, 20 Feb 95 15:58:19 EST Received: from MAILQUEUE by ADMIN (Mercury 1.13); Mon, 20 Feb 95 15:58:02 EST From: "Roger Lewis" Organization: N.C. State University To: wps-forum@are.Berkeley.EDU Date: Mon, 20 Feb 1995 15:57:55 EST Subject: Re: Residue testing info? Priority: normal X-Mailer: Pegasus Mail/Windows v1.11 Message-Id: I would be interested to know if other institutions have developed guidelines on medical monitoring for pesticide exposure. Of special interest is the use of the RBC Cholinesterase test for organophos- phate pesticide exposure. From kaiser@ssnet.com Mon Feb 20 13:37:00 1995 Received: from marlin.ssnet.com (ssnet.com [165.113.8.3]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id NAA24360 for ; Mon, 20 Feb 1995 13:36:57 -0800 Received: by marlin.ssnet.com (4.1/SMI-4.1) id AA09356; Mon, 20 Feb 95 16:32:53 EST Date: Mon, 20 Feb 1995 16:32:52 -0500 (EST) From: Roger Kaiser To: wps-forum@are.Berkeley.EDU Subject: Residue testing organ-phos Message-Id: Mime-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII Dr. Lewis, Please explain your request for testing of residues for organo-phosphates. Many companies have regular monitoring programs set up for people who are exposed to this class of chemistry. It is expensive however, and mass screening of the general population would not make sense. A narrow group is already monitored. If you are suggesting that food should be monitored, please remember the small number of cases that are reported. Would it not give society a much better return on investment to screen smokers with chest X-rays, or blood for HIV? From NLSSROL@ADMIN.BAS.NCSU.EDU Tue Feb 21 05:31:07 1995 Received: from romulus.cc.ncsu.edu (romulus.cc.ncsu.edu [152.1.10.19]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id FAA03881 for ; Tue, 21 Feb 1995 05:31:06 -0800 Received: from admin.bas.ncsu.edu by romulus.cc.ncsu.edu (5.65b/SYSTEMS Dec 28 15:30:00 EDT 1992) id AA03297; Tue, 21 Feb 95 08:31:04 -0500 Posted-Date: Tue, 21 Feb 1995 08:31:48 EST Received: from ADMIN/MAILQUEUE by admin.bas.ncsu.edu (Mercury 1.13); Tue, 21 Feb 95 8:31:54 EST Received: from MAILQUEUE by ADMIN (Mercury 1.13); Tue, 21 Feb 95 8:31:50 EST From: "Roger Lewis" Organization: N.C. State University To: wps-forum@are.Berkeley.EDU Date: Tue, 21 Feb 1995 08:31:48 EST Subject: Re: Biological Monitoring Priority: normal X-Mailer: Pegasus Mail/Windows v1.11 Message-Id: We are in the very early stages of developing guidelines for biological monitoring for pesticide exposure. I am in agreement that mass screening for cholinesterase levels among all workers who apply pesticides in the field would be expensive and not readily received by all workers, since the test is a bit invasive. I would be very interested in how other institutions are dealing with this. Roger Lewis 919-515-6862 Fax: 919-515-6307 From PMARER@ucipm.ucdavis.edu Tue Feb 21 11:04:37 1995 Received: from ucipm.ucdavis.edu (prime.ipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id LAA09785 for ; Tue, 21 Feb 1995 11:04:36 -0800 From: PMARER@ucipm.ucdavis.edu Message-Id: <199502211904.LAA09785@are.Berkeley.EDU> Received: (from user PMARER) by ucipm.ucdavis.edu; 21 Feb 95 11:05:13 PST To: wps-forum@are.Berkeley.EDU Date: 21 Feb 95 11:05:13 PST In response to Roger Lewis' question about medical monitoring for pesticide exposure: Most people probably realize that California has required medical monitoring of certain pesticide handlers for many years. The requirements apply to anyone who handles Category I or II organophosphate or N-methyl carbamate insecticides for more than 6 days in any 30 day period. Employers are responsible for sending these employees to a clinic or physician for a baseline cholinesterase determination and then having periodic tests made. The California Department of Health Services has a publication titled "Medical Supervision of Pesticide Workers: Guidelines for Physicians" that provides information about the testing requirements. A researcher here at the UC Davis campus has been evaluating the various methods of testing cholinesterase levels and is extremely knowledgeable with the process and its application to pesticide workers. I would suggest anyone wanting more information about this to contact: Barry W. Wilson Department of Environmental Toxicology University of California Davis, CA 95616 (916)752-3519 From PMARER@ucipm.ucdavis.edu Tue Feb 21 11:29:33 1995 Received: from ucipm.ucdavis.edu (prime.ipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id LAA10571 for ; Tue, 21 Feb 1995 11:29:32 -0800 From: PMARER@ucipm.ucdavis.edu Message-Id: <199502211929.LAA10571@are.Berkeley.EDU> Received: (from user PMARER) by ucipm.ucdavis.edu; 21 Feb 95 11:30:12 PST To: wps-forum@are.Berkeley.EDU Date: 21 Feb 95 11:30:12 PST Here is some further information on biological monitoring of pesticide handlers: INFORMATION BOOKLET ON CHOLINESTERASE TESTING. California law requires that agricultural employees who handle organophosphate or N-methyl carbamate pesticides for more than 6 days in any 30-day period receive regular monitoring of their blood and plasma cholinesterase levels. This procedure provides early detection of pesticide exposure so an employer can remove an employee from a potentially hazardous situation before any injury occurs. The procedure requires an initial blood test to establish the handler's baseline, then periodic tests, usually on a monthly basis, during times when the handler is using cholinesterase-inhibiting pesticides. Being required to go to a clinic to have blood samples drawn is often a frightening experience, especially for Hispanic workers who are unfamiliar with the reasons for cholinesterase monitoring. The Pesticide Education Program of the UC Statewide Integrated Pest Management Project has developed a booklet that explains the cholinesterase testing process to pesticide handlers. This has been a collaborative project between Melanie Zavala and the Ag Health and Safety Center at UC Davis investigator Barry Wilson. It is based on the video produced by Melanie Zavala and released in late 1994. The publication is a Fotonovela (a story using photographs of actors portraying events) written in both English and Spanish. The booklet is available through the University of California ANR Publications office in Oakland (telephone (800)994-8849) or through local UC Cooperative Extension offices (Publication Number 21507). The video can be obtained from Visual Media, University of California, Davis, CA 95616. Telephone (916)757-8980. From PMARER@ucipm.ucdavis.edu Tue Feb 21 11:30:34 1995 Received: from ucipm.ucdavis.edu (prime.ipm.ucdavis.edu [128.120.83.1]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id LAA10614 for ; Tue, 21 Feb 1995 11:30:33 -0800 From: PMARER@ucipm.ucdavis.edu Message-Id: <199502211930.LAA10614@are.Berkeley.EDU> Received: (from user PMARER) by ucipm.ucdavis.edu; 21 Feb 95 11:31:14 PST To: wps-forum@are.Berkeley.EDU Date: 21 Feb 95 11:31:14 PST EPA-APPROVED VIDEOS FOR OUTDOOR NURSERY WORKERS A set of Worker Protection Standard pesticide safety videos, approved by the US Environmental Protection Agency, is available for training workers and pesticide handlers employed in outdoor nurseries. These videos were produced by the UC Statewide IPM Project and directed by Melanie Zavala. Funding for the videos was provided by the Region 10 office of the US Environmental Protection Agency. The set includes English and Spanish versions of two separate videos. Part I is intended for workers and handlers; Part II is aimed specifically at pesticide handlers. The four videos are available separately, but both Part I and Part II should be used when training pesticide handlers. These videos can be ordered from the UC Cooperative Extension Visual Media Office on the Davis Campus telephone (916)757-8980. Catalog Numbers are: Part I (English) - V/95-A; Part I (Spanish) - V/95-B; Part II (English) - V/95-C; and Part II (Spanish) - V/95-D. These videos will also be available through Gemplers. From SMITH.JUDY@epamail.epa.gov Wed Feb 22 14:33:46 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id OAA11669 for ; Wed, 22 Feb 1995 14:33:44 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HNCWKAK5M88WX6O3@epavax.rtpnc.epa.gov>; Wed, 22 Feb 1995 17:29:22 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HNCWJM79BK8Y5KCR@mail.rtpnc.epa.gov>; Wed, 22 Feb 1995 17:28:53 -0500 (EST) Received: with PMDF-MR; Wed, 22 Feb 1995 17:25:19 EST MR-Received: by mta CARINA; Relayed; Wed, 22 Feb 1995 17:25:19 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Wed, 22 Feb 1995 17:09:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: WPS Materials Listing TO BE ARCHIVED SOON To: wps-forum@are.Berkeley.EDU Message-id: <01HNCWJRVOI88Y5KCR@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: Wed, 22 Feb 1995 17:23:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;91527122205991/2516503@MAIL] A1-type: MAIL Hop-count: 1 To meet the needs of the public and the overwhelming demand for the Worker Protection Standard (WPS) pesticide safety and training materials, the Certification, Training and Occupational Safety Branch is providing a resource listing of WPS materials. These will be sent to Howard Rosenberg and he will archive this listing on WPS-Forum. In a few days, Howard will provide a notice of availability, plus provide file names, and indicate you can access the information you may desire. Content of Listing: This listing identifies pesticide safety, training and informational materials that were developed or produced by the Environmental Protection Agency (EPA), States, and other establishments, organizations or associations. The materials in this listing are organized under categories. The "type" categories include books, posters, leaflets, bulletins, fact sheets, videos, slides, field warning signs and kits. Each entry may be identified by title, followed by, a short summary; date, description (size, length and product identification number) and source name. The full address, telephone and fax number are located in Appendix A. Pricing information is not included. This listing is updated quarterly and, to the best of our knowledge, the items listed here should be available upon request or for purchase. We welcome information regarding the availability of additional WPS materials and where they can be obtained. Please contact Allie Fields at 703-305-7666. For inclusion on this list, please send information and one copy of your product to: Ms. Allie Fields, U.S. Environmental Protection Agency, Office of Pesticide Programs (7506C), 401 M Street, S.W., Washington, D.C. 20460 If you have additional questions, please feel free to contact me at 703-305-7666. Judy Smith US EPA Certification, Training and Occupational Safety Branch From dbreth@cce.cornell.edu Thu Feb 23 05:33:25 1995 Received: from cce.cornell.edu (EMPIRE.CCE.CORNELL.EDU [132.236.89.2]) by are.Berkeley.EDU (8.6.9/8.6.5) with SMTP id FAA29358 for ; Thu, 23 Feb 1995 05:33:24 -0800 Received: by cce.cornell.edu (Smail3.1.28.1 #4) id m0rhdhL-0003WRC; Thu, 23 Feb 95 08:35 EST Date: Thu, 23 Feb 1995 08:32:15 -0500 (EST) From: Deborah Breth Subject: Re: WPS-FORUM digest 199 To: wps-forum@are.Berkeley.EDU cc: Multiple recipients of list In-Reply-To: <199502161718.JAA14466@are.Berkeley.EDU> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII Marc, I am an Area Extension Specialist with an interest in different recordkeeping systems for pesticide applications availible to growers. Please send me a copy of the AMS for review. Thank you, Deborah I. Breth, Cornell Cooperative Extension PO Box 150 20 S. Main St. Albion, NY 14411 Phone: 716-589-5561 FAX: 716-589-0665 From 70730.3261@compuserve.com Thu Feb 23 09:19:55 1995 Received: from arl-img-3.compuserve.com (arl-img-3.compuserve.com [198.4.7.3]) by are.Berkeley.EDU (8.6.9/8.6.5) with ESMTP id JAA05942 for ; Thu, 23 Feb 1995 09:19:52 -0800 Received: by arl-img-3.compuserve.com (8.6.9/5.941228sam) id MAA22032; Thu, 23 Feb 1995 12:19:21 -0500 Date: 23 Feb 95 12:13:02 EST From: Ted Olson <70730.3261@compuserve.com> To: WPS Forum Subject: ChemTrak, computer software Message-ID: <950223171302_70730.3261_CHK44-1@CompuServe.COM> Since one of last week's forum messages seems not to have aroused a protest over commercialism on the net (!), we're assuming there may be some interest in computer software to manage pesticide applications, record keeping, reporting where required, and full WPS compliance. ChemTrak(tm) has been available for several years now and we're based in California where, believe me, we know about regulation. ChemTrak is currently used in about 20 different states, and includes support for all 50 states to manage evolving requirements. It is modular and tailors easily to growers, crop advisors, applicators, farm management companies, nurseries and greenhouses, landscape maintenance services, municipalities, golf courses (etc), and even the complexities of university farms and research centers. We have a complete information package which includes a working demonstration copy of the program, a mini-manual (complete manual is $25), product brochure and literature, and a set of sample reports. ChemTrak runs on DOS machines, with Windows available this summer and PowerMac to follow. The demo kit is free of charge through any of the following contact methods: OCS Software Email 70730.3261@compuserve.com Product Information (800)781-4123 Customer Service (209)781-4123 FAX (209)781-3718 From SMITH.JUDY@epamail.epa.gov Thu Feb 23 14:45:29 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA15892 for ; Thu, 23 Feb 1995 14:45:24 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HNE9HNNZEO8WXN33@epavax.rtpnc.epa.gov>; Thu, 23 Feb 1995 16:50:36 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HNE9GT05R48Y5RRU@mail.rtpnc.epa.gov>; Thu, 23 Feb 1995 16:49:57 -0500 (EST) Received: with PMDF-MR; Thu, 23 Feb 1995 16:45:44 EST MR-Received: by mta CARINA; Relayed; Thu, 23 Feb 1995 16:45:44 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Thu, 23 Feb 1995 16:00:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: Comment Period Closes 2/27/95 To: wps-forum@are.Berkeley.EDU Message-id: <01HNE9GVH3X28Y5RRU@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.berkeley.edu MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Thu, 23 Feb 1995 16:43:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;44546132205991/2524237@MAIL] A1-type: MAIL Hop-count: 1 Forum Members: The comment period closes for the following three WPS proposed actions on February 27, 1995: 1. Early Entry Exception for Irrigation (reference Docket No. OPP-250098 in comments) 2. Exception for Limited Contact (reference Docket No. OPP-250101 in comments) 3. Reduced Entry Intervals for Certain Low Risk Pesticides (reference Docket No. OPP-00399 in comments) Each of these actions are archived and available to you through WPS-FORUM also. You are encouraged to comment on each document and provide the Agency with data, i.e. projected impact on your operations, etc., concerning the above proposals. You may send your comments directly to the OPP Docket office. Please remember to reference the docket number of the document also. The email address for the OPP Docket is: docket-OPPTS@epamail.epa.gov If you prefer to submit your comments via fax, you may send them to me at 703-308-2963 and I will deliver your fax to the Docket office. If you have questions, please feel free to call me at 703-305-7666 or 703-305-7371. Judy Smith U.S. EPA Certification, Training, and Occupational Safety From SMITH.JUDY@epamail.epa.gov Thu Feb 23 14:58:10 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA16725 for ; Thu, 23 Feb 1995 14:58:06 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HNEB362A9C8WXN33@epavax.rtpnc.epa.gov>; Thu, 23 Feb 1995 17:36:10 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HNEB31Z74G8Y5NWL@mail.rtpnc.epa.gov>; Thu, 23 Feb 1995 17:36:06 -0500 (EST) Received: with PMDF-MR; Thu, 23 Feb 1995 17:32:11 EST MR-Received: by mta PYXIS; Relayed; Thu, 23 Feb 1995 17:32:11 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Thu, 23 Feb 1995 17:14:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: Limited Contact - Fact Sheet To: wps-forum@are.Berkeley.EDU Message-id: <01HNEB334GH28Y5NWL@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.berkeley.edu MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Thu, 23 Feb 1995 17:29:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;11237132205991/2524699@MAIL] A1-type: MAIL Hop-count: 1 Background On January 11, 1995, EPA published in the Federal Register a proposed exception to the Worker Protection Standard (WPS) that would allow, under specified conditions, workers to enter pesticide treated areas during a restricted entry interval (REI) to perform early entry limited contact tasks. To address practical concerns raised by a number of interested groups, the Agency is soliciting public comment on this proposal. The proposal seeks further information and comment to assist the Agency in determining whether the conditions of entry under the proposed exception would pose unreasonable risk to workers performing the permitted limited contact tasks during a restricted entry interval. Summary of Proposal Under the proposed exception to early entry restrictions for limited contact tasks, a worker may enter a treated area during an REI to performed limited contact tasks if the agricultural employer ensures that: 1. The workers' only contact with treated surfaces is to the feet, lower legs, hands, and forearms; 2. The pesticide product does not have a statement in the labeling requiring double notification, i.e. workers must be notified both verbally and by posting); this requirement affects the more toxic pesticides; 3. Personal protective equipment (PPE) for early entry is provided to the worker and must either conform with the label requirements or include at least coveralls, chemical resistant gloves, socks, and chemical resistant footwear; 4. No hand labor activity is performed; 5. The time in treated areas under a REI for any worker does not exceed 3 hours in any 24 hr period. In addition, the agricultural employer must ensure that certain other requirements are met, including provisions for the selection, use, and maintenance of PPE, prohibition from entry into a treated area during an REI unless ventilation and inhalation criteria have been met, and a requirement for decontamination site. EPA proposes that this exception would expire 24 months after the effecctive date to allow the Agency to review and revise the terms of the exception based on experience during the two years. For more information, call 703-305-7371 or 703-305-7666. Judy Smith US EPA Certification, Training and Occupational Safety From SMITH.JUDY@epamail.epa.gov Thu Feb 23 14:58:16 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA16739 for ; Thu, 23 Feb 1995 14:58:12 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HNEBGWQJVK8WXMNE@epavax.rtpnc.epa.gov>; Thu, 23 Feb 1995 17:47:18 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HNEBGSJ6EO8Y5RPY@mail.rtpnc.epa.gov>; Thu, 23 Feb 1995 17:47:14 -0500 (EST) Received: with PMDF-MR; Thu, 23 Feb 1995 17:44:38 EST MR-Received: by mta PYXIS; Relayed; Thu, 23 Feb 1995 17:44:38 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Thu, 23 Feb 1995 17:30:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: FACT SHEET-Early Entry Exception To: wps-forum@are.Berkeley.EDU Message-id: <01HNEBGW010G8Y5RPY@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.berkeley.edu MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Thu, 23 Feb 1995 17:43:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;83447132205991/2524852@MAIL] A1-type: MAIL Hop-count: 1 Background To address practical concerns raised by a number of interested groups, EPA has published a proposed exception to the 1992 Worker Protection Standard (WPS) that would allow workers, under specified conditions, to perform early entry irrigation tasks for more than 1 hour per day during a restricted entry interval (REI). The Agency is soliciting public comment on this proposal. Additional information and comment will assist the Agency in determining whether the conditions of entry under the proposed exception would pose unreasonable risks to workers performing the permitted irrigation tasks during a REI. Summary of Proposal A worker may enter a treated area during a REI to perform tasks related to operating, moving, or repairing irrigation or watering equipment, if the agricultural employer ensures that: 1. The worker's only contact with treated surfaces is to the feet, lower legs, hands, and forearms; 2. The pesticide product does not have a statement in the labeling requiring double notification (workers must be notified both verbally and by posting); this requirement affects the more toxic pesticides; 3. The tasks could not be delayed until after expiration of the REI; 4. Personal protective equipment (PPE) for early entry is provided to the worker and shall either conform with the label requirements or include at least coveralls, chemical resistant gloves, socks, and chemical resistant footwear; 5. No hand labor activity is performed; 6. The time in treated areas under a REI for any worker does not exceed 8 hours in any 24 hour period. In addition, the agricultural employer shall ensure that: the requirements of 40 CFR 170.112 (c) (3) through (9) are met and label-specified inhalation exposure level has been reached; PPE requirements are met; label-specific instructions are followed; heat-related illness avoidance measures are taken; decontamination requirements are met; and a prohibition against wearing home or taking home PPE is conveyed. This exception shall expire 24 months after the effective date to allow the Agency to review and revise the terms of the exception based upon experience during the two years. For more information call 703-305-7371 or 703-305-7666. *** The comment period closes on 2/27/95 for this proposal*** Judy Smith US EPA Certification, Training, and Occupational Safety Branch From SMITH.JUDY@epamail.epa.gov Fri Feb 24 06:04:26 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id GAA09607 for ; Fri, 24 Feb 1995 06:04:25 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HNF7CZ4ANK8WYBS3@epavax.rtpnc.epa.gov>; Fri, 24 Feb 1995 09:00:38 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HNF7CRB8ZK8Y5ZD2@mail.rtpnc.epa.gov>; Fri, 24 Feb 1995 09:00:26 -0500 (EST) Received: with PMDF-MR; Fri, 24 Feb 1995 08:58:34 EST MR-Received: by mta CARINA; Relayed; Fri, 24 Feb 1995 08:58:34 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Fri, 24 Feb 1995 08:29:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: Fact Sheet-Reduced REI for Low Risk Pesticides To: wps-forum@are.Berkeley.EDU Message-id: <01HNF7D3ABW28Y5ZD2@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: Fri, 24 Feb 1995 08:56:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;43858042205991/2528367@MAIL] A1-type: MAIL Hop-count: 1 Background To address practical concerns raised by a number of agricultural groups, the Agency has published a Federal Register Notice that would reduce the restricted entry intervals (REIs) for certain low risk pesticides covered by the WPS. The Agency is interested in receiving comments concerning this proposed action. This proposal has been archived on WPS-Forum. DEADLINE for submitting comments to the OPP docket is February 27, 1995. Summary of Proposal This proposed notice would allow pesticide registrants to: 1. Reduce the interim WPS REIs from 12 to 4 hours for certain low risk pesticides. 2. Revise their labeling to reflect the reduced REI though simply notifying EPA; and, 3. Have one year to make label changes for the REI using the notification process. 4. After August 1995, label amendments must be submitted to the Agency's regular label change process. 5. Registrants have six months to propose additions to the candidate active ingredient list. Discussion The proposed notice applies to: Products subject to WPS labeling requirements; Products containing one or more of the active ingredients listed on the candidate list; Currently registered end-use products with INTERIM REIs. The proposed notice does NOT apply to: Products not on the published candidate list; New and pending registrations (these will be evaluated using the criteria outlined in the notice during the regular registration process) Nearly 500 active ingredients covered by WPS were screened using toxicological criteria for the candidate list. Active ingredients eligible for the four hour REI were screened using the following criteria: classified as toxicity category III or IV for acute dermal toxicity, primary skin irritation, and primary eye irritation; were not known to be a sensitizer or have known reports of hypersensitivity; had no associated adverse health effects, i.e. mutagenicity, carcinogenicity, developmental effects, reproductive effects, etc. Of these active ingredients, 75 were determined to be eligible for REI reduction. If you have questions, please contact the Agency at 703-305-7371 or 703-305-7666. Judy Smith US EPA Certification, Training & Occupational Safety Branch From SMITH.JUDY@epamail.epa.gov Fri Feb 24 08:13:40 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id IAA10776 for ; Fri, 24 Feb 1995 08:13:38 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HNFBTJ3J348WY1JJ@epavax.rtpnc.epa.gov>; Fri, 24 Feb 1995 11:08:31 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HNFBRXWKSG8Y5XWV@mail.rtpnc.epa.gov>; Fri, 24 Feb 1995 11:07:13 -0500 (EST) Received: with PMDF-MR; Fri, 24 Feb 1995 11:04:34 EST MR-Received: by mta PYXIS; Relayed; Fri, 24 Feb 1995 11:04:34 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Fri, 24 Feb 1995 10:53:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: EPA Response to Coalition RE:WPS Enforcement Guidance To: wps-forum@are.Berkeley.EDU Message-id: <01HNFBSAMG768Y5XWV@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: Fri, 24 Feb 1995 11:03:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;43401142205991/2529579@MAIL] A1-type: MAIL Hop-count: 1 Forum Members: On February 13, Lynn Goldman issued the following letter to the Coalition for Sensible Farmworker Protection. The enclosure referenced in this communication is in a separate FORUM posting. Please see the posting entitled, "Summary Guidance-Enforcement." Judy Smith US EPA Certification, Training and Occupational Safety Branch 703-305-7666 Feb 13, 1995 (date stamped) Mr. Mark Nestlen, Coordinator Coalition for Sensible Farmworker Protection 1156 15th Street, N.W., Suite 1020 Washington, D.C. 2005 Dear Mr. Nestlen: The Coalition for Sensible Farm Worker Protection requested that EPA "clarify its interpretation of the responsibility and liability provisions of the WPS regulations to take the same case-by-case approach as the other major Federal laws protecting the interests of farm workers." Consistent with our letter to NASDA of October 7, 1994, we recommend to the States that accountability for compliance be decided on a common sense, case-by-case basis. In response to your request for additional clarification, we have enclosed the Agency's "Guidance on Issuance of WPS Enforcement Actions," issued February 13, 1995. This guidance identifies ten factors which EPA recommends be considered by States when they need to determine the appropriate recipient(s) of an enforcement action. We appreciate the Coalition's contributions in discussions with the Agency during development of this guidance. We look forward to continued dialogue with members of the Coalition as implementation of the Worker Protection Standard progresses. Sincerely, Lynn R. Goldman, M.D. Assistant Administrator Office of Prevention, Pesticides, and Toxic Substances Steven A. Herman Assistant Administrator Office of Enforcement and Compliance Assurance Enclosure From SMITH.JUDY@epamail.epa.gov Fri Feb 24 08:22:26 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id IAA10963 for ; Fri, 24 Feb 1995 08:22:22 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HNFC09QYAO8WY1JJ@epavax.rtpnc.epa.gov>; Fri, 24 Feb 1995 11:12:57 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HNFBYH8YKG8Y5ZYB@mail.rtpnc.epa.gov>; Fri, 24 Feb 1995 11:12:21 -0500 (EST) Received: with PMDF-MR; Fri, 24 Feb 1995 11:09:39 EST MR-Received: by mta PYXIS; Relayed; Fri, 24 Feb 1995 11:09:39 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Fri, 24 Feb 1995 11:03:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: Summary Guidance-Enforcement To: wps-forum@are.Berkeley.EDU Message-id: <01HNFBYNOZ7E8Y5ZYB@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: Fri, 24 Feb 1995 11:09:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;93901142205991/2529646@MAIL] A1-type: MAIL Hop-count: 1 Forum members: The following guidance was issued by the Office of Regulatory Enforcement and provides factors for State Lead Agency consideration in determining the recipient(s) of an enforcement action. Judy Smith US EPA Certification, Training, and Occupational Safety Branch 703-305-7371 or 305-7666 February 13 1995 (date stamp) MEMORANDUM SUBJECT: Summary Guidance on Issuance of WPS Enforcement Actions FROM: Jessie Baskerville, Director Toxics and Pesticides Enforcement Office of Regulatory Enforcement TO: Regional Toxics and Pesticides Division Directors Regional Counsels Phil Benedict, Chairman, SFIREG Mary Ellen Setting, President, AAPCO The Agency recently received a request to clarify its interpretation of the responsibility and liability provisions of the Worker Protection Standard (WPS) regulations and to take the same case by case approach as the other major Federal laws protecting the interests of farm workers. In response to this request, we have attached a summary of ten factors which EPA recommends be considered by States as they make determinations of who should be held accountable for a given WPS violation. Please provide the attached "Summary Guidance on Issuance of WPS Enforcement Actions" to the State Lead Agencies for their consideration and use, consistent with the States' enforcement response policies. We will continue to work with the Regions and States on any enforcement related questions which they may have. Please do not hesitate to call us if you have any questions or comments concerning the attached summary guidance. Attachment cc: Steven Herman Lynn Goldman Michael Stahl Scott Fulton Jim Aidala Robert Van Heuvelen Elaine Stanley Dan Barolo Regional Toxics and Pesticide Branch Chiefs Attachment February, 1995 Summary Guidance on Issuance of Worker Protection Standard Enforcement Actions This document provides summary guidance to clarify EPA's interpretation of the responsibility and liability provisions of the FIFRA Worker Protection Standard (WPS) regulations. Under FIFRA, the principal agricultural owner, as well as operator and employer agents, all may be liable for a given WPS violation. Agricultural establishment owners, operators, and employers are jointly responsible for providing WPS protections to workers and for ensuring compliance with WPS requirements. During WPS implementation, however, EPA recommends that a common sense, case- by-case approach be used in determining the appropriate recipient(s) of a WPS enforcement action. To provide further clarification and assistance in determining the appropriate recipient(s) of a WPS enforcement action, the Agency recommends that State Lead Agencies consider the following ten factors: 1) Who has control over pesticide use; 2) Who directs pesticide use; 3) Who has control over the agricultural establishment for posting and other WPS-related responsibilities; 4) Who gives direction on the agricultural establishment for posting and other WPS-related responsibilities; 5) Who has control over the practices used by agricultural workers on the establishment; 6) Who directs the practices used by the agricultural workers on the establishment; 7) Measures taken to comply with provisions of the WPS; 8) Actions taken in response to incidents of noncompliance; 9) History of prior violations; and 10) Ability to assure continuing compliance with the WPS. The totality of the circumstances should be considered in each case. The above factors are not listed in any order of priority; each factor should be appropriately considered in every case. Documentation by agricultural owners/operators/ employers could assist them in demonstrating to State regulatory officials, their efforts to comply and their responses to instances of noncompliance. From SMITH.JUDY@epamail.epa.gov Fri Feb 24 14:31:33 1995 Received: from VAXTM1.RTPNC.EPA.GOV (vaxtm1.rtpnc.epa.gov [134.67.208.95]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA20894 for ; Fri, 24 Feb 1995 14:31:32 -0800 Received: from pyxis.rtpnc.epa.gov by epavax.rtpnc.epa.gov (PMDF V4.3-10 #5309) id <01HNFOQ3FI4W8WYJC7@epavax.rtpnc.epa.gov>; Fri, 24 Feb 1995 17:17:29 -0500 (EST) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01HNFOQ1CR688Y5Z4J@mail.rtpnc.epa.gov>; Fri, 24 Feb 1995 17:17:29 -0500 (EST) Received: with PMDF-MR; Fri, 24 Feb 1995 17:15:47 EST MR-Received: by mta PYXIS; Relayed; Fri, 24 Feb 1995 17:15:47 -0500 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Fri, 24 Feb 1995 16:45:00 -0500 (EST) From: JUDY SMITH 703-305-6605 Subject: Response to EPA Proposals To: wps-forum@are.Berkeley.EDU Message-id: <01HNFOQC9SHA8Y5Z4J@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: Fri, 24 Feb 1995 17:15:00 -0500 (EST) Importance: normal Priority: normal X400-MTS-identifier: [;74517142205991/2532891@MAIL] A1-type: MAIL Hop-count: 1 Forum members: For those of you that have provided comments to the Agency concerning the 5 proposed actions, we appreciate receiving your concerns, comments, and suggestions. For those sending faxes to me for delivery to the OPP docket, please indicate an internet address on your cover page and I will send you a notice of fax receipt and delivery to the OPP docket. Judy Smith US EPA Certification, Training and Occupational Safety Branch 703-305-7371 or 305-7666 FAX: 703-308-2962 From gebillikopf@ucdavis.edu Fri Feb 24 15:16:42 1995 Received: from nic.cerf.net (root@nic.cerf.net [192.102.249.3]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id PAA22203 for ; Fri, 24 Feb 1995 15:16:41 -0800 Received: from (dial-800.cerf.net [134.24.11.2]) by nic.cerf.net (8.6.10/8.6.9) with SMTP id PAA08758; Fri, 24 Feb 1995 15:16:33 -0800 Date: Fri, 24 Feb 1995 15:16:33 -0800 Message-Id: <199502242316.PAA08758@nic.cerf.net> X-Sender: szbillik@peseta.ucdavis.edu Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: hrnet@cornell.edu From: gebillikopf@ucdavis.edu (Gregorio Billikopf-Encina) Subject: Position announcement Cc: wps-forum@are.Berkeley.EDU X-Mailer: How about a job with all the advantages of being part of the academic community plus the advantages of setting your own research and workshop schedule? This job opening as a farm advisor for the University of California Agricultural Extension allows for exactly that flexibility. One day you may be making a farm visit and helping an agricultural enterprise design a more effective selection process; the next day you may be giving a one-day workshop for farmers on setting up incentive and pay systems; the next you may be working on a research project; and the next you may be writing an article for a trade journal on the management of a seasonal work force. Rather than working with the regular university or college population, your education and research efforts are carried out directly with those farmers and farm managers who are hungry for the information and who can use it within their agricultural corporation. You would deal with farm employers who hire only a few people (and sometimes family members) to those who have large work forces. You would be evaluated on the amount and quality of your education and research programs as well as demonstrated professional competence. But while you are expected to have a balanced program and respond to local clientele needs, there is much room for your individual interests and personality to help shape the contents and style of your program. For instance, I began (1981) with a large emphasis on employee selection and the use of practical tests, as well as establishing incentive pay programs. >From there I began work on employee discipline and performance appraisals. Today, I have rounded up my program and put on workshops on supervision also, including interpersonal relations and conflict management. Even though I come from a farm background, I feel that a thorough knowledge of the field of human resource management is much more important than knowledge about the particular settings within which it gets applied (vineyards, orchards, dairies, etc.). If you do not have much knowledge about agriculture I feel you will pick it up as you go with minimal effort. This position is part of the Cooperative Extension which is part of the US Land Grant College system, to which the University of California belongs. Minimum qualifications are Master in Human Resource Management, Industrial Psychology or a related field. Knowledge of Spanish would come in very useful. The right to work in the United States is a requirement. The position opening is for northern California. Please do not hesitate to give me a call or to write if you wish to discuss this position with me. To obtain the official job announcement, please call Debbie Maha at the University of California (916) 754-8495 or e-mail her at: damaha@ucdavis.edu Best wishes, Gregorio *************************************************** Gregorio Billikopf Encina (Gregory Encina Billikopf) University of California 733 County Center 3 Modesto, CA 9535 gebillikopf@ucdavis.edu (209) 525-665 (209) 525-4969 FAX *************************************************** From 73507.555@compuserve.com Sun Feb 26 15:37:05 1995 Received: from dub-img-2.compuserve.com (dub-img-2.compuserve.com [198.4.9.2]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id PAA21921 for ; Sun, 26 Feb 1995 15:37:04 -0800 Received: by dub-img-2.compuserve.com (8.6.9/5.941228sam) id SAA16753; Sun, 26 Feb 1995 18:36:34 -0500 Date: 26 Feb 95 14:38:57 EST From: Bob Roach <73507.555@compuserve.com> To: wps-forum Subject: Culture of Safety Message-ID: <950226193856_73507.555_HHB68-2@CompuServe.COM> One approach to safety is to develop detailed rules for people to follow. The problem with this approach is that people don't always follow rules well. Many problems are caused by human error, misunderstanding or noncompliance. Creating a culture of safety is another perhaps more effective approach to decreasing risk. When combined with sensible rules, a culture of safety creates a best case for reducing risk. This is the situation I believe now exists in California where for years solid regulations combined with effective education and enforcement have been in effect. The fear of liability due to negligence also plays a part. The main problem I have had with the WPS is that some parts of it are not well suited to certain agricultural situations. When we have a rule with which it is nearly impossible to comply, we create a culture of scofflaws. Precise, objective rules satisfy our desire for certainty but they can also rule out common sense. ****************************************************************** "Men hate the truth. They would rather meet a tiger in the road." - Robinson Jeffers Bob Roach 73507.555@compuserve.com ****************************************************************** From ellara@ucdavis.edu Mon Feb 27 07:49:14 1995 Received: from bullwinkle.ucdavis.edu (bullwinkle.ucdavis.edu [128.120.8.167]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id HAA29418 for ; Mon, 27 Feb 1995 07:49:13 -0800 Received: from [128.120.250.69] by bullwinkle.ucdavis.edu (8.6.10/UCD3.0) id HAA12680; Mon, 27 Feb 1995 07:49:21 -0800 Date: Mon, 27 Feb 1995 07:49:21 -0800 Message-Id: <199502271549.HAA12680@bullwinkle.ucdavis.edu> X-Sender: szlara@bullwinkle.ucdavis.edu Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: ellara@ucdavis.edu (Elias Lopez) Subject: Re: Job Position Dear Mr. Billikopf-Encina, The job you describe sounds very interesting and I will be giving you a call to know more about it. My name is Elias Lopez and I just got my Ph.D. from the Agricultural Economics department from UC Davis, in September of 1994. My interests is in how does one create a learning environment in the workplace for Agricultural workers, despite their low levels of educational attainment. So far in terms of jobs, I have interviewed at Michigan State University in their Agricultural Economics department, and at Cal Poly, San Luis Obispo, in their Ethnic Studies program. I have been offered a job to go to Michigan State University. The position is a tenure-track position and it requires me to do 50% Extension, 30% Teaching, and 20% Research. If I go over there I will work with both farmers and farmworkers in the human resource management area. With Cal Poly, San Luis Obispo, I just came back from the interview, and I won't know if they offer me that position until the middle of March. Everything well in the interviews. I got along well with the Director of the program, the search committee, and the dean of the college, and so I think I will get an offer there too. Despite these offers, the position you announced sounds very interesting since I would like to do Extension work. At the same time, I would like to continue doing research. My research would focus on documenting the learning environment in the workplace and how this affects productivity. I have a heavy quantitative background that would be used toward this end. Moreover, the announced position sounds good because my family and my wife's family live already around this area (Davis and Concord). In fact, some of my wife's family still work in agriculture around Davis. Also, my wife already works for UC Davis as a Clinical Social Worker for the Alzheimer's Disease Center. She has a good job and enjoys the setting in which she works. In short, the position sounds interesting. I called Howard Rosenberg about two months ago (before I went to interview at Michigan State) to make his acquaintance. He told me about a similar position. However, the closing date had passed and I never followed up on it. Now, I have this opportunity and I want to take advantage of it. And I have heard so much about the quality programs that you, Steve Sutter, and Howard Rosenberg, put out, that it is a very appealing opportunity for me. Muchas Gracias. Elias S. Lopez Phone: (916) 758-2209 From BAUMGARTNER.DONALD@EPAMAIL.EPA.GOV Mon Feb 27 08:29:23 1995 Received: from ARTHUR.RTPTOK.EPA.GOV (arthur.rtptok.epa.gov [134.67.212.29]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id IAA00315 for ; Mon, 27 Feb 1995 08:29:22 -0800 From: BAUMGARTNER.DONALD@EPAMAIL.EPA.GOV Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with WordPerfect_Office; Mon, 27 Feb 1995 11:26:00 -0500 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Mon, 27 Feb 1995 11:14:19 -0500 To: wps-forum@are.Berkeley.EDU Subject: Cholinesterase Testing and the WPS In response to the inquiry from Keith Underwood dated Febr. 17, asking if there was a regulation requiring regular Cholinesterase testing of applicators, I know of no such requirement under FIFRA or the WPS, although several Forum subscribers recently have noted such requirements exist under California law. Related to the WPS, as you may be aware, cholinesterase testing was indeed a topic considered during the 1985 negociated rulemakeing of WPS and a summary of some considerations and opinions has been published in the Federal Register (vol. 57 (163), Aug. 21, 1992; pages 38130-38131) as part of the preamble to the Rule. EPA determined that even though a blood-level cholinesterase monitoring program may be prudent for some handlers, the Agency had determined that imposing a nationwide requirement is not justified at this time. The Agency did state that it intends to reconsider the need for, and the appropriate form of, exposure moniotoring after the WPS has been implemented, but to date the Agency has not addressed this issue. Donald Baumgartner U.S. EPA Region 5 --------------------------------------------------------- Had an individual ask me a question today that was an interesting one. Does anyone have an answer: He understood that there was a rule, law, requirement or whatever being proposed and soon to be implemented that would require a grower to have his/her employees that are applicators for their business tested for exposure after every 10 hours of work applying chemicals. Is this a truth or rummor? If it is a truth, where can we get more information and reply to the silliness of this kind of regulation! Also what a waste of money if the individual is wearing proper PPE. Keith Underwood K.Underwood@Genie.geis.com From BAUMGARTNER.DONALD@EPAMAIL.EPA.GOV Mon Feb 27 10:03:10 1995 Received: from ARTHUR.RTPTOK.EPA.GOV (arthur.rtptok.epa.gov [134.67.212.29]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id KAA06450 for ; Mon, 27 Feb 1995 10:03:05 -0800 From: BAUMGARTNER.DONALD@EPAMAIL.EPA.GOV Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with WordPerfect_Office; Mon, 27 Feb 1995 13:01:38 -0500 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Mon, 27 Feb 1995 12:59:52 -0500 To: wps-forum@are.Berkeley.EDU Subject: WPS and Greenhouse Labeled Products The below Region 5 interpretation was provided to one of our States recently at an in-house WPS meeting and the following message was sent to our other States (Febr. 22) last as well. 40 CFR Part 158 App. A supports our view in that greenhouses are separated as a general use pattern DIFFERENT from terrestrial food crops or indoor uses in terms of data requirements for registration. ------------------------------------------------------------ Questions are continually raised by Extension and State regulatory officials, as well as being addressed in January 1995 through the WPS-Forum, concerning the use of "home" indoor use non-WPS labeled pesticidal products in greenhouses. People question if such home indoor use products without WPS labeling could be legally used inside greenhouses, and if they are, then of course employers need not comply with the WPS. A second issue arises with department stores which may have an attached "greenhouse" to the store and may be using non-greenhouse (home use) products to control insects on plants maintained for sale inside these store greenhouses. Remember, that even department stores must comply with the WPS if they are using WPS labeled products (see question 14.16 of the IGW October 1994 Q&A document). Our opinion is that applicators must use Greenhouse Labeled products inside greenhouses, and that the use of a specific non-greenhouse labeled product (such as one for indoor use and with the same plant labeled but w/o greenhouse labeling) would constitute a misuse of the product (violation) under conditions of commercial production/maintenance. In other words, if the label does not specify that a pesticide may be used in greenhouses, then that pesticide MAY NOT BE USED IN GREENHOUSES, regardless if the specific crop is mentioned the label or not and regardless if the label is silent for this site. Therefore, greenhouse employers MAY NOT use pesticides which are not labeled specifically for greenhouse use. The same technically applies to department stores which have an attached greenhouse for the maintence of plants for sale; they may not use home use products from their store shelves, which would constitute a misuse. Under this latter senario, State inspectors could not cite a violation of the WPS because a WPS labeled product was not even used, but this still would constitute a general misuse and the store employer should then be notified that they should be using greenhouse labeled products with WPS labeling and that they should be complying with the WPS requirements. If the department store does not have a greenhouse but rather has plants on shelves inside the store, then greenhouse labeled products need not be used and general indoor use products would be appropriate. Home use products may be used as well for "hobby" greenhouses where plants are grown for non-commercial purposes. Since this question frequently arises, there is an obvious need for a formal Agency interpretation (perhaps IGW Q&A) to address these questions. Donald Baumgartner U.S. EPA Region 5 From crowley@shep.agsci.colostate.edu Mon Feb 27 10:52:57 1995 Received: from lamar.ColoState.EDU (root@lamar.ColoState.EDU [129.82.103.75]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id KAA07979 for ; Mon, 27 Feb 1995 10:52:56 -0800 Received: from shep.AGSCI.ColoState.EDU by lamar.ColoState.EDU (AIX 3.2/UCB 5.64/4.03) id AA74563; Mon, 27 Feb 1995 11:52:44 -0700 Received: by shep.agsci.colostate.edu (5.59/25-eef) id AA23727; Mon, 27 Feb 95 11:54:33 MST Date: Mon, 27 Feb 95 11:54:33 MST From: Crowley County Message-Id: <9502271854.AA23727@shep.agsci.colostate.edu> Ua-Content-Id: Email-Version: 2 Ua-Message-Id: Phone: (719) 267-4741 Subject: clarification of WPS To: wps-forum@are.Berkeley.EDU Content-Type: Text Content-Length: 1206 The Worker Protection Standard for Agricultural Pesticides - How to Comply Manual states that the standard "covers pesticides that are used in the production of agricultural plants on farms, forests, nurseries, and greenhouses." In areas of Colorado, we have large agricultural operations called ranches. They consist of producers that run either cow-calf or yearling beef cattle on range land. The cattle graze grasses and forbs that grow on the range. These operations are not considered to be farms, but a livestock agribusiness. They produce beef. If one of these producers uses a herbicide(s) to control prickly pear on his/her ranch, do the WPS apply? If so, then do the ranch hands that only work with the cattle have to be trained as workers? I hope that someone can help clarify this to me. ============================================================================== Ron Ackerman ph. (719) 267-4741 Colo. State Un. Coop. Ext. in Crowley County North Main Street, County Annex fax (719) 267-4741 Ordway, CO 81063 e-mail - crowley@shep.agsci.colostate.edu ============================================================================== From RUDOLPH.KAY@EPAMAIL.EPA.GOV Mon Feb 27 14:04:00 1995 Received: from merlin.rtpnc.epa.gov (merlin.rtpnc.epa.gov [134.67.208.148]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA13744 for ; Mon, 27 Feb 1995 14:03:54 -0800 From: RUDOLPH.KAY@EPAMAIL.EPA.GOV Received: from lancelot.rtptok.epa.gov by merlin.rtpnc.epa.gov (8.6.9/1.34) id RAA20608; Mon, 27 Feb 1995 17:02:42 -0500 Received: from cc:Mail by lancelot.rtptok.epa.gov id AA793933289; Mon, 27 Feb 95 13:56:00 EST Date: Mon, 27 Feb 95 13:56:00 EST Message-Id: <9501277939.AA793933289@lancelot.rtptok.epa.gov> To: wps-forum@are.Berkeley.EDU Subject: Re: clarification of WPS Ron Ackerman will probably get a half-dozen responses to his question about whether operations that use pesticides on razing land or pasture are covered by the WPS. That's because this is such a straightforward answer that we'll all want to jump on it. The WPS specifically exempts pesticide applications for pasture and rangeland use. If you don't harvest the hay, then the WPS doesn't apply. The WPS also specifically exempts pesticide applications on livestock or other animals, or in or about animal premises. Kay Rudolph US-EPA San Francisco, Region 9 From SMITH.JUDY@EPAMAIL.EPA.GOV Mon Feb 27 14:11:17 1995 Received: from merlin.rtpnc.epa.gov (merlin.rtpnc.epa.gov [134.67.208.148]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA14110 for ; Mon, 27 Feb 1995 14:11:16 -0800 From: SMITH.JUDY@EPAMAIL.EPA.GOV Received: from lancelot.rtptok.epa.gov by merlin.rtpnc.epa.gov (8.6.9/1.34) id RAA20762; Mon, 27 Feb 1995 17:10:06 -0500 Received: from cc:Mail by lancelot.rtptok.epa.gov id AA793933719; Mon, 27 Feb 95 16:14:52 EST Date: Mon, 27 Feb 95 16:14:52 EST Message-Id: <9501277939.AA793933719@lancelot.rtptok.epa.gov> To: wps-forum@are.Berkeley.EDU Subject: Re: clarification of WPS WPS does not apply to rangeland. For those individuals that apply herbicides for noxious weed control, they should take care to follow all label provisions even though WPS does not apply, i.e. protective equipment, etc. Ranch hands working with the cattle would not be trained as handlers since WPS does not apply to rangelands. Keep in mind that hay IS an agricultural crop, and WPS does apply. Judy Smith US EPA Certification, Training & Occupational Safety Branch 703-305-7666 or 7371 From SMITH.JUDY@EPAMAIL.EPA.GOV Mon Feb 27 14:30:55 1995 Received: from merlin.rtpnc.epa.gov (merlin.rtpnc.epa.gov [134.67.208.148]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA15400 for ; Mon, 27 Feb 1995 14:30:54 -0800 From: SMITH.JUDY@EPAMAIL.EPA.GOV Received: from lancelot.rtptok.epa.gov by merlin.rtpnc.epa.gov (8.6.9/1.34) id RAA21203; Mon, 27 Feb 1995 17:29:47 -0500 Received: from cc:Mail by lancelot.rtptok.epa.gov id AA793934888; Mon, 27 Feb 95 17:22:18 EST Date: Mon, 27 Feb 95 17:22:18 EST Message-Id: <9501277939.AA793934888@lancelot.rtptok.epa.gov> To: wps-forum@are.Berkeley.EDU Subject: LAST CALL FOR COMMENTS LAST CALL FOR COMMENTS Forum members: Today is the last day to comment on the EPA actions. Please take a few moments, if one or more of the actions impacts your establishment, and provide comments. Electronic comments can be forward to the OPP Docket at the following internet address: Docket-OPPTS@epamail.epa.gov You may also fax comments to me at 703-308-2962 Be sure and reference the appropriate docket number in your comments: Irrigation exception OPP-250098 Limited contact exception OPP-250101 Reduced REIs for certain pesticides OPP-00399 Many thanks to those of you that have sent comments via fax during the last few working days. Your input is appreciated. Judy Smith US EPA Certification, Training, and Occupational Safety Branch 703-305-7666 or 7371 From gebillikopf@ucdavis.edu Tue Feb 28 10:25:39 1995 Received: from nic.cerf.net (root@nic.cerf.net [192.102.249.3]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id KAA21624 for ; Tue, 28 Feb 1995 10:25:38 -0800 Received: from (dial-800.cerf.net [134.24.11.2]) by nic.cerf.net (8.6.10/8.6.9) with SMTP id KAA02081 for ; Tue, 28 Feb 1995 10:25:34 -0800 Date: Tue, 28 Feb 1995 10:25:34 -0800 Message-Id: <199502281825.KAA02081@nic.cerf.net> X-Sender: szbillik@peseta.ucdavis.edu Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: gebillikopf@ucdavis.edu (Gregorio Billikopf-Encina) Subject: Idaho WPS tape X-Mailer: A month ago I reported a strong preference by Spanish-speaking trainers for the "Chasing the Sun" WPS video over the "Idaho WPS" video for fieldworker training. I had been showing the "Idaho" tape first and "Chasing the Sun" second. I wondered what would happen if I changed the order. In a well atteded Train-the-trainer workshop yesterday I changed the order, and for some reason this made a major difference. The vast majority now prefered the "Idaho" tape! (I had not gone over the points that require correction of the tape, however, when I asked the question. As most of you know, the Idaho tape is not valid as is. It requires that numerous corrections be made orally after the tape is shown.) This simple "experiment" seems to show that the order of the tapes may have an impact on the viewers. In each case viewers defended their positions vigorously. I still do not recommend the Idaho tape (even though I prefered it over 'Chasing the Sun' at first) because: 1.- It requires a long list of correction--which take almost longer than the showning the tape to go over. 2.- It shows a pinpoint pupil and in Spanish it says "pupila dilatada," or diluted pupil, instead of constricuted or pinpoint pupil. 3.- It shows a pregnant woman who looks as if she will loose her baby--a bit overkill I think. I do hope the Idaho tape will be corrected and updated so it is a viable option to those who want to use it as a WPS fieldworker training tool. At that point I would probably go back and prefer it over "Chasing the Sun." As many of the supervisors and farm labor contractors in my meeting yesterday pointed out, the "Idaho" tape is loaded with a lot more useful information. Gregorio *************************************************** Gregorio Billikopf Encina (Gregory Encina Billikopf) University of California 733 County Center 3 Modesto, CA 9535 gebillikopf@ucdavis.edu (209) 525-665 (209) 525-4969 FAX *************************************************** From 73507.555@compuserve.com Tue Feb 28 22:00:44 1995 Received: from arl-img-3.compuserve.com (arl-img-3.compuserve.com [198.4.7.3]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id WAA11572 for ; Tue, 28 Feb 1995 22:00:43 -0800 Received: by arl-img-3.compuserve.com (8.6.9/5.941228sam) id BAA09698; Wed, 1 Mar 1995 01:00:11 -0500 Date: 01 Mar 95 00:58:32 EST From: Bob Roach <73507.555@compuserve.com> To: wps-forum Subject: WPS Coverage Message-ID: <950301055831_73507.555_HHB64-2@CompuServe.COM> The three passages below are from three separate messages in the same recent digest. I find this to be very interesting. A worker who applies an herbicide to pasture all day (perhaps bromoxynil, a California "minimal exposure" pesticide) is exempt from WPS requirements. Yet a retail nursery that is perhaps part of a department store may fall under the WPS. That raises some further interesting questions. Is the retail nursery an "agricultural establishment?" Do the notification requirements to all on the property within one quarter mile apply to the entire store or just the nursery portion? Of course I do not think this makes much sense. A retail nursery maintaining plants for sale is not involved in production agriculture. All workers handling pesticides deserve proper training and protection. What is the "IGW October 1994 Q&A document?" Is this available in the archive? I would like to refer to question 14.16 as suggested. >The Worker Protection Standard for Agricultural >Pesticides - How to Comply Manual states that the >standard "covers pesticides that are used in the >production of agricultural plants on farms, forests, >nu