From 73414.252@compuserve.com Mon Jul 3 12:51:00 1995 Received: from arl-img-4.compuserve.com (arl-img-4.compuserve.com [198.4.7.4]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id MAA07550 for ; Mon, 3 Jul 1995 12:50:58 -0700 Received: by arl-img-4.compuserve.com (8.6.10/5.950515) id PAA21015; Mon, 3 Jul 1995 15:50:21 -0400 Date: 03 Jul 95 15:46:59 EDT From: Judith Houswirth <73414.252@compuserve.com> To: wps-forum Subject: Crop Advisor Confusion and Labeling Message-ID: <950703194659_73414.252_DHS87-1@CompuServe.COM> In light of all of the confusion regarding crop advisor specific statements on labels or labeling and whether the crop advisor exemption overrides those statements, let me add the following. I doubt it will clarify a confused situation but here goes. The crop advisor exemption clearly exempts crop advisors from complying with 40 CFR 170.232 (a) which is knowledge of labeling information. Questions have arisen as to whether statements outside the WPS Ag Use box are covered under the exemption of labeling knowledge. Let me refer to the definition of labels and labeling. The definition is found in FIFRA Section 2 Definitions, (p) Label and Labeling. (1) Label - The term label means the written, printed, or graphic matter on, or attached to, the pesticide or device or any of its containers or wrappers. (2) Labeling - The term labeling means all labels and all other written, printed, or graphic matter - (A) accompanying the pesticide or device at any time; or (B) to which reference is made on the label or in literature accompanying the pesticide or device, except to current official publications of the EPA, USDA, Interior Dept., HHS, state experiment stations, state ag colleges, and other similar Federal or State institutions or agencies authorized by law to conduct research in the field of pesticides. Therefore, FIFRA provides a very broad and encompassing legal definition of labeling. I am not sure that the crop advisor exemption is limited to knowledge of parts of the labeling (i.e. within the WPS box) or all of the labeling since neither the WPS or the exemption get any more restrictive than just "knowledge of the labeling". How this exemption conflicts with the requirements of FIFRA Section 12 Unlawful Acts (a) (2) (G) is a interesting question. That FIFRA requirement states IN GENERAL - It shall be unlawful for any person - to use any registered pesticide in a manner inconsistent with its labeling. Does anyone in Enforcement have an answer to these contradictions on whether one can be exempt from knowledge of the labeling while having to use the pesticide according to the labeling - IN GENERAL? Curt Lunchick From smcdonld@freenet.columbus.oh.us Tue Jul 4 06:02:54 1995 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id GAA10696 for ; Tue, 4 Jul 1995 06:02:52 -0700 Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.6.10/4.940426) id JAA27514; Tue, 4 Jul 1995 09:02:22 -0400 Received: by acme.freenet.columbus.oh.us (8.6.10) id JAA27197; Tue, 4 Jul 1995 09:03:36 -0400 Date: Tue, 4 Jul 1995 08:37:38 -0400 (EDT) From: Sally McDonald Subject: Re: Crop Advisor Confusion -Reply To: wps-forum@are.Berkeley.EDU cc: wps-forum@are.Berkeley.EDU, 73507.555@compuserve.com In-Reply-To: Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII While I don't understand EPA's recent reply that implies that only statements inside the Ag Use Requirements box are "federal" requirements, I may be able to answer questions about where the box came from and why it is a box, rather than just a section on the labeling. In order to avoid placing the rather lengthy exceptions to PPE, REIs, and double notification actually on the label, EPA decided to state the basic requirement on the label and alert users to the existence of the WPS exceptions to those statements using a standard reference statement. For example, a sentence in the Ag Use box states: "Do not enter or allow workers to enter the treated area for 48 hours." Another statement in that box states, in part: "It (the WPS) also contains specific instructions and exceptions pertaining to the statements on this label about PPE, notification to workers, and REIs. The requirements in this box only apply to uses of this product that are covered by the WPS." The "box" was created for those labels that contain both WPS and nonWPS uses, such as many ornamental and turf labels and labels that contain forestry uses as well as rights-of-way and pasture/rangeland uses. Since EPA needed to limit the REI, early-entry PPE, and double notification requirements to ONLY uses within the scope of the WPS, and wanted to allow for other entry restrictions (sprays dried) to apply to nonWPS uses, a means of limiting certain label requirements to just WPS uses or just nonWPS uses was sought. EPA decided to group the WPS entry-related statements together with the WPS reference statements and enclose all the statements in a box and likewise group all nonWPS entry restrictions in a separate box, so there would be no question about which labeling requirements pertained only to WPS uses, which pertained only to nonWPS uses and which labeling requirements pertained to every use on the label. FYI: For handler PPE, EPA decided that only very rarely would different handler PPE be appropriate for WPS uses versus nonWPS uses. Therefore, the handler PPE requirements were left in their traditional location near the label precautionary statements in a section of the label titled: "Hazards to Humans (and domestic animals)." Almost all labels have one set of PPE requirements for handlers and don't differentiate between WPS handlers and nonWPS handlers. So, that's "Why the box?" -- it doesn't, however, explain why EPA now believes that entry restriction statements located outside the box are not federally enforceable. In fact, as a more basis question, why in the world is the crop-advisor entry restriction located outside the Ag Use box? Sally PS. The Forum was too quiet lately anyhow! -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From alfrench@mailbox.econ.ag.gov Thu Jul 6 11:12:45 1995 Received: from mailbox.econ.ag.gov (MAILBOX.econ.ag.gov [151.121.64.123]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id LAA28334 for ; Thu, 6 Jul 1995 11:12:40 -0700 Received: from ECONSMTP-Message_Server by mailbox.econ.ag.gov with Novell_GroupWise; Thu, 06 Jul 1995 14:10:22 -0400 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Thu, 06 Jul 1995 15:12:49 -0400 From: Al French To: wps-forum@are.Berkeley.EDU Subject: Crop Advisor Confusion and Labeling -Reply To add even more to the labeling confusion: Although FIFRA permits States to more stringently regulate federally registered pesticides through a State registration program, Sec. 24(b) states "Such State shall not impose or continue in effect any requirements for labeling or packaging in addition to or different from those required under this Act." Does this mean that a State may not augment the label requirements for crop advisors? For that matter, since the WPS itself is an extension of the label, does this mean that States may not augment _any_ provision of the WPS? Al French USDA Coordinator of Agricultural Labor Affairs alfrench@sies.wsc.ag.gov 202/720-4737 From ROYR@cdprsmtp.cdpr.ca.gov Thu Jul 6 13:44:31 1995 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id NAA02203 for ; Thu, 6 Jul 1995 13:44:27 -0700 From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Thu, 06 Jul 1995 13:44:58 -0700 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Thu, 06 Jul 1995 13:47:07 -0700 To: wps-forum@are.Berkeley.EDU, alfrench@mailbox.econ.ag.gov Subject: Crop Advisor Confusion and Labeling -Reply -Reply On 7/6/95 Al French wrote in part: "Although FIFRA permits States to more stringently regulate federally registered pesticides through a State registration program, Sec. 24(b) states "Such State shall not impose or continue in effect any requirements for labeling or packaging in addition to or different from those required under this Act." Do you mean State regulation program? Section 24(c) allows for States to register additional uses of a EPA registered pesticide. Section 24(b) prohibets from imposing any labeling or packaging requirements that are different from EPA. The industry used this section in the mid 1970s to stop California from establishing standard container and closure requirements to implement its neq closed system requirements. Section 24(a) allows a State to adopt more stringent requirements, presumably through statute or regulation, since it can't be done through labeling. SO. How did California end up with all those special crop advisor requirements on labels that have been the topic of so much recent Forum discussion? If pressed, we would say with a straight face that we didn't require that language, it was offered by registrants to mitigate exposure concerns uncovered during our risk assessment process. Registrants put that language on "federal" labeling and when we reviewed the new labeling - what do you know, we no longer had any concerns and the product could be registered in California. It seems like a sloppy process on the surface but once both sides learned how to use it, it seems to work pretty well to meet some of the staturory provisions we have to deal with out here. If individual registrants choose not to challenge it, what's the harm? Section 24(b) was put there to protect registrants from having to produce 50 different labels. Probably a reasonable protection. RoyR From 73414.252@compuserve.com Fri Jul 7 10:22:48 1995 Received: from dub-img-3.compuserve.com (dub-img-3.compuserve.com [198.4.9.3]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id KAA20359 for ; Fri, 7 Jul 1995 10:22:43 -0700 Received: by dub-img-3.compuserve.com (8.6.10/5.950515) id NAA12750; Fri, 7 Jul 1995 13:22:12 -0400 Date: 07 Jul 95 12:25:20 EDT From: Judith Houswirth <73414.252@compuserve.com> To: wps-forum Subject: FIFRA 24(b) and WPS Message-ID: <950707162519_73414.252_DHS77-1@CompuServe.COM> In regards to FIFRA section 24(b) and also 24(a) as raised by Al French. The intent of these sections was to permit states to enact by regulation or law more stringent requirements than those imposed Federally (24a) but not permit the states to impose on the registrants requirements that would appear on the labeling (24b). A purpose is uniformity through one national label that is approved and registered by EPA. As Roy Rutz responded, states are getting around 24(b) by "requesting" the registrant to seek a Federal label amendment that addresses state concerns. It is doubtful that Congress envisioned this process when FIFRA was amended. As Roy stated, the process works so what is the harm. If EPA did not like a "request" from California that the registrant seeks to add to the Federal label through an amendment, EPA could reject the label amendment request. My read on the state requirements on pesticide labels is - Its on a Federal label and therefore covered by Federal regulations or Federal exemptions from Federal regulations. If the state requirement is enacted in state regulations, then my guess would be that the Federal exemptions would not overide the state's more stringent regulations. For example: If at California's request, the pesticide Megakill has on the label "Crop advisors may not enter until 48 hours after application" the WPS crop advisor exemption against knowledge of the labeling may make the statement inoperative. But if the California code of regulations state that crop advisors may not enter until 48 hours after application because Megakill is a Minimal Exposure Pesticide, than crop advisors in California only must stay out for 48 hours. Remember, this is my opinion and read on FIFRA and the implementing regs. Ask two lawyers and you will get six opinions. Washington has lots of lawyers. Curt Lunchick From agcom15@chiba.netxn.com Tue Jul 18 14:57:06 1995 Received: from chiba.netxn.com (agcom15@chiba.netxn.com [199.172.49.10]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA05046 for ; Tue, 18 Jul 1995 14:57:01 -0700 Received: (from agcom15@localhost) by chiba.netxn.com (8.6.12/8.6.9) id PAA10806; Tue, 18 Jul 1995 15:20:03 -0700 Date: Tue, 18 Jul 1995 15:20:02 -0700 (PDT) From: Kern County Agricultural Comissioner To: wps-forum@are.Berkeley.EDU Subject: Agency Information Collection Activities Under OMB Review (fwd) Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII I wouldn't usually forward something like this to the forum, but it has been so slow lately, I just wanted to see if the thing was still working... Besides, I found the averages and estimates utilized in this "ICR" rather interesting.... Jim.... ---------- Forwarded message ---------- Date: Mon, 17 Jul 1995 10:28:46 -0400 From: S001627@swais.access.gpo.gov To: Multiple recipients of list Subject: Agency Information Collection Activities Under OMB Review [Federal Register: July 17, 1995 (Volume 60, Number 136)] [Notices] [Page 36413-36414] >From the Federal Register Online via GPO Access [wais.access.gpo.gov] ======================================================================= ----------------------------------------------------------------------- ENVIRONMENTAL PROTECTION AGENCY [FRL-5259-3] Agency Information Collection Activities Under OMB Review AGENCY: Environmental Protection Agency (EPA). ACTION: Notice. ----------------------------------------------------------------------- SUMMARY: In compliance with the Paperwork Reduction Act (44 U.S.C. 3501 et seq.), this notice announces that the Information Collection Request (ICR) abstracted below has been forwarded to the Office of Management and Budget (OMB) for review and comment. The ICR describes the nature of the information collection and its expected cost and burden. DATES: Comments must be submitted on or before August 16, 1995. FOR FURTHER INFORMATION OR A COPY CALL: Sandy Farmer at EPA, (202) 260- 2740, please refer to EPA ICR #1759.01. SUPPLEMENTARY INFORMATION: Office of Prevention, Pesticides and Toxic Substances Title: Worker Protection Standards. (ICR No: 1759.01). This is a request for the approval of burden hours for requirements under the Worker Protection Standard (WPS). This action seeks approval for requirements no longer exempt by the Paperwork Reduction Act of 1995. Abstract: EPA is charged under 40 CFR parts 156 and 170 for protection of agricultural workers and pesticide handlers from hazards of pesticides used on farms, in forests, in nurseries and in greenhouses. The WPS workplace practices are designed to reduce or eliminate exposure to pesticides and establish procedures for responding to exposure-related emergencies. The practices include prohibitions against applying pesticides in a way that would cause exposure to workers and others; a waiting period before workers can return to areas treated with pesticides; basic training and distribution and posting of information about pesticide hazards, as well as pesticide application information; arrangements in case of pesticide exposure; and provisions for emergency assistance. The information burden is primarily that of third party notifications to inform agricultural workers and pesticide handlers of basic safety practices. Burden statement: The public burden for this collection of information is estimated to average \1/4\ hour per respondent. Less than 1 percent of the total burden is recordkeeping. Respondents: The potential respondents are agricultural employers, including employers in farms as well as nursery, forestry, and greenhouse establishments. Estimated No. of Respondents: 1,000,000. Estimated No. of Responses per Respondent: 8. Estimated Total Annual Burden on Respondents: 2,100,000 hours. Frequency of Collection: On occasion. Send comments regarding the burden estimate, or any other aspect of the information collection, including suggestions for reducing the burden (please refer to EPA ICR #1759.01) to: Sandy Farmer, EPA ICR #1759.01, U.S. Environmental Protection Agency, Information Policy Branch--2136, 401 M Street SW., Washington, DC 20460 and Tim Hunt, Office of Management and Budget, Office of Information and [[Page 36414]] Regulatory Affairs, 725 17th Street NW., Washington, DC 20503. Dated: July 10, 1995. Richard Westlund, Acting Director, Regulatory Information Division. [FR Doc. 95-17478 Filed 7-14-95; 8:45 am] BILLING CODE 6560-50-M From 73507.555@compuserve.com Tue Jul 18 17:04:19 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 RAA08143 for ; Tue, 18 Jul 1995 17:04:16 -0700 Received: by dub-img-2.compuserve.com (8.6.10/5.950515) id UAA27608; Tue, 18 Jul 1995 20:03:45 -0400 Date: 18 Jul 95 20:01:36 EDT From: Bob Roach <73507.555@compuserve.com> To: wps-forum Subject: Work Clothing vs. PPE Message-ID: <950719000136_73507.555_HHB83-1@CompuServe.COM> All pesticide labels seem to have statements to the effect of "do not get on skin, in eyes or on clothing." Labels also specify work clothing to be worn, such as long sleeved shirt, long pants, shoes and socks. This work clothing is obviously required to provide protection to the applicator by serving as a barrier to the pesticide and therefore it is to be expected that the material will get on the clothing. My question to the U.S. EPA is, how do we reconcile these contradictory label statements? Are the boilerplate "do not get on/in..." statements just relics? Are they merely advisory and not to be taken literally? Are additional measures required comply with these general statements? I do recognize situations where the work clothing specified on the label is not adequate. For example, a crew hand-spraying strawberries wearing long pants, shoes and socks would be soaked to the skin in no time. They need chemical resistant suits and boots. On the other hand, an applicator standing on a bed sprayed with diazinon (soil applied) wearing his shoes and socks is not being dangerously exposed yet he is getting it on his clothing. At what point is the label violated? Bob Roach 73507.555@Compuserve.com From MGALLO@cdprsmtp.cdpr.ca.gov Wed Jul 19 08:13:01 1995 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id IAA17447 for ; Wed, 19 Jul 1995 08:13:00 -0700 From: MGALLO@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Wed, 19 Jul 1995 08:16:13 -0700 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Wed, 19 Jul 1995 08:08:45 -0700 To: wps-forum@are.Berkeley.EDU, 73507.555@compuserve.com Subject: Work Clothing vs. PPE -Reply Bob, regarding your question about label statements that direct pesticide users to keep the pesticide off clothing. Perhaps what is meant is that the pesticide is to be kept off clothing other than clothing deemed PPE. Clothing, such as long legged pants, short sleeved shirts, shoes, and socks are included in the PPE definition in 170.240 WPS. ?What say ye, EPA? Adolfo DPR, California. "Such is life in the fur, fur West , where nobody's happy, but everyone's glad." From kickraack@agvax2.ag.ohio-state.edu Wed Jul 19 09:48:21 1995 Received: from agvax2.ag.ohio-state.edu (agvax2.ag.ohio-state.edu [128.146.140.101]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id JAA19550 for ; Wed, 19 Jul 1995 09:48:14 -0700 Date: Wed, 19 Jul 1995 09:48:14 -0700 Message-Id: <199507191648.JAA19550@are.Berkeley.EDU> Received: from kh237.ag.ohio-state.edu by agvax2.ag.ohio-state.edu (MX V4.1 VAX) with SMTP; Wed, 19 Jul 1995 12:45:35 +500 X-Sender: kickraack@agvax2.ag.ohio-state.edu 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: kickraack@agvax2.ag.ohio-state.edu (Joanne Kick-Raack) Subject: Re: Work Clothing vs. PPE -Reply Adolfo, It is my understanding that long pants, long-sleeved shirt, shoes and socks are NOT defined as PPE under WPS. This is referenced on page 82 of the How-to-Comply manual. Joanne Kick-Raack >Bob, regarding your question about label >statements that direct pesticide users to keep the >pesticide off clothing. Perhaps what is meant is >that the pesticide is to be kept off clothing other >than clothing deemed PPE. Clothing, such as long >legged pants, short sleeved shirts, shoes, and >socks are included in the PPE definition in 170.240 >WPS. >?What say ye, EPA? >Adolfo >DPR, California. >"Such is life in the fur, fur West , where nobody's >happy, but everyone's glad." > > From D_GRAY@OJC.Colorado.EDU Wed Jul 19 10:12:27 1995 Received: from vaxf.Colorado.EDU (vaxf.Colorado.EDU [128.138.129.9]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id KAA20446 for ; Wed, 19 Jul 1995 10:12:26 -0700 Received: from DECNET-MAIL (D_GRAY@OJC) by VAXF.COLORADO.EDU (PMDF V5.0-3 #8140) id <01HT1VW2FG9S000MJE@VAXF.COLORADO.EDU> for wps-forum@are.Berkeley.EDU; Wed, 19 Jul 1995 11:03:31 -0600 (MDT) Date: Wed, 19 Jul 1995 11:03:31 -0600 (MDT) From: DEBBIE GRAY Subject: Re: WPS-FORUM digest 295 To: wps-forum@are.Berkeley.EDU Message-id: <01HT1VW2H25E000MJE@VAXF.COLORADO.EDU> X-VMS-To: VAXF::IN%"wps-forum@are.Berkeley.EDU" X-VMS-Cc: D_GRAY MIME-version: 1.0 Content-transfer-encoding: 7BIT Please don't send any more notices. We requested to unsubcribe. From MGALLO@cdprsmtp.cdpr.ca.gov Wed Jul 19 10:14:46 1995 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id KAA20665 for ; Wed, 19 Jul 1995 10:14:43 -0700 From: MGALLO@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Wed, 19 Jul 1995 10:17:21 -0700 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Wed, 19 Jul 1995 10:09:50 -0700 To: kickraack@agvax2.ag.ohio-state.edu, wps-forum@are.Berkeley.EDU Subject: Re: Work Clothing vs. PPE -Reply -Reply >>>>>>>>>>>>>>> Received: from localhost (server@localhost.Berkeley.EDU [127.0.0.1]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id JAA19620; Wed, 19 Jul 1995 09:49:09 -0700 Received: from agvax2.ag.ohio-state.edu (agvax2.ag.ohio-state.edu [128.146.140.101]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id JAA19550 for ; Wed, 19 Jul 1995 09:48:14 -0700 Received: from kh237.ag.ohio-state.edu by agvax2.ag.ohio-state.edu (MX V4.1 VAX) with SMTP; Wed, 19 Jul 1995 12:45:35 +500 Reply-To: wps-forum@are.Berkeley.EDU Sender: owner-wps-forum@are.Berkeley.EDU Precedence: bulk MIME-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-Sender: kickraack@agvax2.ag.ohio-state.edu X-Mailer: Windows Eudora Version 1.4.4 X-Listprocessor-Version: 7.1 -- ListProcessor by CREN Adolfo, It is my understanding that long pants, long-sleeved shirt, shoes and socks are NOT defined as PPE under WPS. This is referenced on page 82 of the How-to-Comply manual. Joanne Kick-Raack >Bob, regarding your question about label >statements that direct pesticide users to keep the >pesticide off clothing. Perhaps what is meant is >that the pesticide is to be kept off clothing other >than clothing deemed PPE. Clothing, such as long >legged pants, short sleeved shirts, shoes, and >socks are included in the PPE definition in 170.240 >WPS. >?What say ye, EPA? >Adolfo >DPR, California. >"Such is life in the fur, fur West , where nobody's >happy, but everyone's glad." > > <<<<<<<<<<<<<<< Joanne, You're right; as Roy Rutz also pointed out, I missed a very important word while typing my response to Bob Roach's message. The clothing mentioned in my response is NOT considered PPE as per 170.240(b)(2). I've attached an edited version of my first response to Bob, for clarification. Thank you for the message. I'm still interested in feed back from EPA to Bob's question and to Roy's comments. 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Rosenberg) Subject: Ag Employer Training Program A developer of pesticide education and resource tools has informed me of a comprehensive training program that he has designed to support detailed instruction for agricultural employers about their obligations under the WPS. "WPS--Agricultural Employer Training Program," produced by Pesticide Training Resources (PTR, based in Tucson), uses computer-generated text slides, illustration slides and support literature to explain all material in the EPA's "How to Comply" manual. This program is specifically designed for use by educators/trainers providing instruction to ag employers on their obligations under WPS (not for training handlers or workers). The program is divided into five sections, each approximately one hour in length. Each section comes with a set of suggested review questions and handouts to distribute and discuss with participants. Recommendations for supplemental teaching aids are offered. PTL believes that after receiving instruction from this program, ag employers should have a thorough understanding of WPS requirements. PTR is keeping up with WPS developments and, for a nominal fee, plans to provide upgraded training materials if the rule is changed or new regulations come into effect. Price of the five-part Agricultural Employer Training Program is $349.00 plus $12.95 for shipping and handling. Inquiries should be directed to: Dr. Michael Pfeiffer, Pesticide Training Resources, 2525 East Seneca, Tucson, Arizona, 85716-3018; phone (520) 323-3135. --Howard Rosenberg From cefresno@ucdavis.edu Thu Jul 20 15:15:07 1995 Received: from franc.ucdavis.edu (root@franc.ucdavis.edu [128.120.8.183]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id PAA23290 for ; Thu, 20 Jul 1995 15:15:05 -0700 From: cefresno@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by franc.ucdavis.edu (8.6.12/UCD3.4) id PAA12572; Thu, 20 Jul 1995 15:13:34 -0700 Date: Thu, 20 Jul 1995 15:13:34 -0700 Message-Id: <199507202213.PAA12572@franc.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: news from fresno Cc: cefresno@ucdavis.edu This is Steve Sutter, UC Area Personnel Management Farm Advisor, Fresno ... It was simply a matter of time. At my Central California Farm Labor Contractor Advisory Group meeting today, I learned EPA's worker training certificates or "blue cards" are available at local swap meets... "Fresno Clear." From ROYR@cdprsmtp.cdpr.ca.gov Fri Jul 21 08:43:09 1995 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id IAA03910 for ; Fri, 21 Jul 1995 08:43:08 -0700 From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Fri, 21 Jul 1995 08:43:42 -0700 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Fri, 21 Jul 1995 08:43:42 -0700 To: wps-forum@are.Berkeley.EDU Cc: cefresno@ucdavis.edu Subject: news from fresno -Reply On the issue of the EPA training verification cards being available at swap meets: My response is a great big yawn and a SO WHAT! Was there anyone who didn't think that it was going to happen? I feel that government has no responsibility to prevent a worker who will go to these lengths from continuing to work in ignorance! This is yet another example of government believing that it must go to the extreme to protect people from themselves. If a worker wants to relieve an employer from responsibility by presenting a forged card, that's their business and their neck. My only concern would be if certain employers are buying them and issuing them after giving substandard training. This is a lot of risk for very little gain in my estimation. Workers could protect themselves from this by making sure the card issued to them is completely and accurately filled out. That would, I believe, divert the responsibility back to whoever gave the training and issued the card. while this situation shouldn't be completely ignored, I don't see it as a problem that should divert resources from more important tasks; and there are many. RoyR From 73507.555@compuserve.com Mon Jul 24 07:01:42 1995 Received: from dub-img-1.compuserve.com (dub-img-1.compuserve.com [198.4.9.1]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id HAA12515 for ; Mon, 24 Jul 1995 07:01:40 -0700 Received: by dub-img-1.compuserve.com (8.6.10/5.950515) id KAA11359; Mon, 24 Jul 1995 10:50:47 -0400 Date: 24 Jul 95 10:49:24 EDT From: Bob Roach <73507.555@compuserve.com> To: wps-forum Subject: The Label Paradox Message-ID: <950724144923_73507.555_HHB39-1@CompuServe.COM> A few people jumped on Adolfo for apparently forgetting to read his How To Comply Manual (I know you know that work clothing is not PPE) but nobody else made any attempt to untie this Gordian knot. The paradox remains: the labels say to wear work clothing to protect the handler and they also demand that one not get the pesticide on the clothing. Is there no Alexander out there? ; Mon, 24 Jul 1995 12:20:07 -0700 Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with Novell_GroupWise; Mon, 24 Jul 1995 15:20:15 -0400 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Mon, 24 Jul 1995 15:05:44 -0400 From: DONALD BAUMGARTNER To: wps-forum@are.Berkeley.EDU Subject: WPS Training Videos See below for a recent list of EPA-approved WPS training videos. This list was recently prepared for all EPA Region and all State Departments of Agriculture participants at the EPA Pesticide Regulatory Education Program offered in East Lansing, Michigan last July 11-14. If you have any questions or additions to this list, please feel free to contact me directly via Internet, or 312/886-7835. Donald Baumgartner EPA Region 5 (Chicago) **************************************************** ************************************************* July 1995 WORKER PROTECTION STANDARD PESTICIDE REGULATORY EDUCATION PROGRAM EPA-APPROVED TRAINING VIDEOS AVAILABLE Title; Producer(s); EPA-Approved 1) You Can Do It - How to Teach Pesticide Health & Safety to Farmworkers & Their Families; Workgroup on Pest. Health & Safety (Wash.); NOT Appr. for training (EPA funded, good for train-the-trainer programs) (1991) 2) Shedding Some Light on Pesticide Protection; EPA Off. Res. & Develop.; NOT Appr. for training (EPA funded, good for train-the-trainer programs) (1994) 3) Pesticide Safety - Worker Protection (worker/handler); Univ. of Idaho; Yes (1993) 4) The Playing Field; Natl. Migrant Res. Prog.; NOT approved for training (good for train-the-trainer programs) 5) WPS for Greenhouses & Nurseries (worker/handler); Iowa State Univ.; NOT appr. for training (1994) (employer education tool) 6) Pesticide Handlers and the WPS (handler); Michigan State Univ.; Yes (1994) 7) Chasing the Sun (worker); Natl. Migrant Res. Prog.; Yes (1994) 8) Protect Yourself from Pesticides (worker); SOS Communications; Yes (1994) 9) Greenhouse Pesticide Safety Training (worker/handler); Floriculture Greenhouse Ind. Alliance; Yes (1995) 10) Pesticide Safety for You & Your Family's Health (worker); Kent Co. CES/Mich. State Univ.; Yes (1995) 11) Safe Use of Pesticides in Outdoor Nurseries (worker/handler); Visual Media (Univ. CA); Yes (1995) 12) Pesticide Safety - Help Workers Protect Themselves; St. Joseph Co. CES/MI State Univ. Ext.; Yes (1995) 13) Pest. Safety Training for Ag. & Early-Entry Workers; W. VA Univ. CES; Yes (1995) 14) Pesticide Training for Agricultural Employees (worker/handler); Farm Employers Labor Service (Calif.); Yes (1995) From howardr@are.Berkeley.EDU Mon Jul 24 14:32:05 1995 Received: from [128.32.251.104] (gia5mac24.Berkeley.EDU [128.32.251.104]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id OAA23750 for ; Mon, 24 Jul 1995 14:32:01 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Mon, 24 Jul 1995 14:32:29 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: Re: WPS Training Videos Thank you, Don, for the update on approved training videos. I had been on the verge of posting a request for just such information. Cosmic. Looks like the choices have expanded nicely. By my count from your list, there are currently nine tapes approved for workers and four for handlers. approved--worker: #3, 7, 8, 9, 10, 11, 12, 13, 14 approved--handler: #6, 9, 11, 14 not approved for either worker or handler training: #1, 2, 4, 5 In preparing for a comparative study of worker videos, I could also use to know of any additional ones that are pending review or in an advanced stage of development. If anyone is involved in producing a video that fits this description (for workers, not handlers), please let me know, on or off the net. I'll post a summary of any responses at end of this week. Thanks. --Howard Rosenberg From chessele@acenet.auburn.edu Mon Jul 24 18:26:33 1995 Received: from acenet.auburn.edu (aces1.acenet.auburn.edu [131.204.46.253]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id SAA29653 for ; Mon, 24 Jul 1995 18:26:30 -0700 Received: by acenet.auburn.edu (4.1/SMI-4.1 aces1 1.0) id AA16073; Mon, 24 Jul 95 20:26:28 CDT Date: Mon, 24 Jul 1995 20:26:27 -0500 (CDT) From: Charles Hesselein X-Sender: chessele@aces1 To: wps-forum@are.Berkeley.EDU Subject: Pesticides with 4 hr. REIs? Message-Id: Mime-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII I am trying to find a list of the most recent pesticides approved for 4 hr. REIs. Specifically, I am trying to find out if horticultural oils are on this list and if so if any oil containing products have been relabeled with the new 4 hr. REI. Thanks, Chazz Hesselein Extension Horticulturist, ACES chessele@acenet.auburn.edu Third time's a charm, eh Howard? From SMITH.JUDY@EPAMAIL.EPA.GOV Tue Jul 25 07:43:43 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 HAA05499 for ; Tue, 25 Jul 1995 07:43:41 -0700 From: SMITH.JUDY@EPAMAIL.EPA.GOV Received: from lancelot.rtptok.epa.gov by merlin.rtpnc.epa.gov (8.6.9/1.34) id IAA19145; Tue, 25 Jul 1995 08:59:39 -0400 Received: from cc:Mail by lancelot.rtptok.epa.gov id AA806687518; Tue, 25 Jul 95 08:51:57 EST Date: Tue, 25 Jul 95 08:51:57 EST Message-Id: <9506258066.AA806687518@lancelot.rtptok.epa.gov> To: wps-forum@are.Berkeley.EDU Subject: Re: Pesticides with 4 hr. REIs? Chazz: Please send me your fax number and I will forward the Reduced REI list to you. Mineral oil is on the Candidate List of AIs eligible for the 4 hr REI. Judy Smith EPA 703-305-7666 From: Charles Hesselein To: wps-forum@are.Berkeley.EDU Subject: Pesticides with 4 hr. REIs? Mime-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII X-Sender: chessele@aces1 X-Listprocessor-Version: 7.1 -- ListProcessor by CREN I am trying to find a list of the most recent pesticides approved for 4 hr. REIs. Specifically, I am trying to find out if horticultural oils are on this list and if so if any oil containing products have been relabeled with the new 4 hr. REI. Thanks, Chazz Hesselein Extension Horticulturist, ACES chessele@acenet.auburn.edu Third time's a charm, eh Howard? From aftgoul@gatekeeper.ddp.state.me.us Tue Jul 25 08:05:26 1995 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id IAA06746 for ; Tue, 25 Jul 1995 08:05:24 -0700 Received: from @gatekeeper.ddp.state.me.us by gatekeeper.ddp.state.me.us (8.6.5/1.37) id IAA13811; Tue, 25 Jul 1995 08:22:05 -0400 Date: Tue, 25 Jul 1995 08:22:05 -0400 Message-Id: <199507251222.IAA13811@gatekeeper.ddp.state.me.us> X-Sender: aftgoul@gatekeeper.ddp.state.me.us X-Mailer: Windows Eudora Version 1.4.3 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: aftgoul@gatekeeper.ddp.state.me.us (Tammy Gould) Subject: RE: Training Video List I've got to concur with Howard that this list is great! Thanks, Don. I have just one small request though. Could you or maybe others on the Forum provide information, including a telephone number, on where to purchase the videos? I get calls all the time from growers asking where to buy some videos and I usually send them to Gemplers. I noticed that many of these are not available from Gemplers. Where can we get them from? From aftgoul@gatekeeper.ddp.state.me.us Tue Jul 25 08:05:28 1995 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id IAA06750 for ; Tue, 25 Jul 1995 08:05:26 -0700 Received: from @gatekeeper.ddp.state.me.us by gatekeeper.ddp.state.me.us (8.6.5/1.37) id IAA14296; Tue, 25 Jul 1995 08:27:54 -0400 Date: Tue, 25 Jul 1995 08:27:54 -0400 Message-Id: <199507251227.IAA14296@gatekeeper.ddp.state.me.us> X-Sender: aftgoul@gatekeeper.ddp.state.me.us X-Mailer: Windows Eudora Version 1.4.3 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: aftgoul@gatekeeper.ddp.state.me.us (Tammy Gould) Subject: Re: Pesticides with 4 hr. REIs? The list of 114 active ingredients eligible for reduced REIs is located in the [Federal Register: May 3, 1995]. I've copied the list for you here. It's now up to each registrant to provide the data and make the label changes. I've been telling growers in Maine to expect changes next season. Tammy Gould Maine Board of Pesticides Control >IV. Candidate Active Ingredients Meeting Low Toxicity Criteria > > The following is a list of 114 active ingredients currently subject >to the WPS requirements that meet the lower toxicity criteria. > > Acetylchitin > Agrobacterium radiobacter > Ampelomyces quisqualis isolate M-10 > Azadirachtin (neem extract) > B.t. subsp. aizawai > B.t. subsp. aizawai strain GC-91 > B.t. subsp. israelensis > B.t. subsp. kurstaki > B.t. subsp. kurstaki HD-263 > B.t. subsp. kurstaki strain EG2348 > B.t. subsp. kurstaki strain EG2371 > B.t. subsp. kurstaki strain EG2424 > B.t. subsp. san diego > B.t. subsp. tenebrionis > Bacillus popilliae and B. lentimorbus > Bacillus sphaericus > Bacillus subtilis GB03 > Bacillus subtilis MBI 600 > BNOA (b-naphythoxy acetic acid) > Borax > Calcium hypochlorite > Calcium oxytetracycline > Calcium thiosulfate > Candida oleophila > Capsicum oleoresin > Checkmate peach twig borer pheromone > Chitosan > Chlorsulfuron > Colletotricum gleosporoides > Copper as ammonia complex > Copper salts of fatty acids > Cytokinin > 2,4-DB, isooctyl > Diatomaceous earth > Disodium octaborate tetrahydrate > Disparlure > Ethylene > Ethoxyquin > Farnesol > Fatty acids, C8-12, Methyl esters > Fenridazone-potassium > Fluazifop-butyl > Fluazifop-r-butyl > Gibberellic acid > Gibberellins A4 and A7 > Gliocladium virens G-21 > Glyphosate, ammonium > Glyphosate, isopropylamine > Glyphosate, sodium > Gossyplure: hexadecadien-1-ol acetate > Gypsy moth npv > Heavy aromatic naphtha > Imazethapyr > Imazethapyr, ammonium salt > Indole-3-butyric acid > Lagendidium giganteum, mycelium > Mefluidide, diethanolamine > Mefluidide, potassium salt > Methyl nonyl ketone [[Page 21967]] > Metsulfuron-methyl > Milky spore > Mineral oil > Muscalure, component of (e)-9-tricosene > Muscalure, component of (z)-9-tricosene > N-6-Benzyladenine > NAA, Ethyl ester > Nerolidol > Nicosulfuron > Nosema locustae > Octyl bicycloheptenedicarboxamide > Oxytetracycline hydrochloride > Paradichlorobenzene > Paraffin oils > Periplanone B > Polyhedral inclusion bodies of Autographa californica > Polyhedral inclusion bodies of Heliothis zea NPV or Helicoverpa >zea NPV > Polyhedral inclusion bodies of beet armyworm npv > Polyhedral inclusion bodies, Neodiprion sertifer NVP > Potassium gibberellate > Promalin > Pseudomonas cepacia type wiscons. > Pseudomonas fluorescens > Pseudomonas fluorescens A506 > Pseudomonas fluorescens EG-1053 > Pseudomonas fluorescens strain NCIB 12089 > Pseudomonas syringae > Puccinia canaliculata (Schweinitz) > Rimsulfuron DPX-E9636 > Ryania speciosa > Ryanodine > s-Kinoprene > s-Methoprene > Sesame plant, ground > Siduron > Silica gel > Silicon dioxide > Sodium carboxymethylcellulose > Sodium metaborate > Soybean oil > Streptomyces griseoviridis > Streptomycin > Streptomycin sesquisulfate > Sulfometuron-methyl > Thifensulfuron-methyl > Thiobencarb > Tomato pinworm (e)-4-tridecen-1-yl acetate > Tomato pinworm (e)-11-tetradecenyl acetate > Triasulfuron > 1-Triacontanol > Trichoderma harzianum var. rifai (KRL-AG2) > Trichoderma harzianum (ATCC 20476) > Trichoderma polysporum (ATCC 20475) > Tussock moth npv > >I am trying to find a list of the most recent pesticides approved for 4 >hr. REIs. Specifically, I am trying to find out if horticultural oils are >on this list and if so if any oil containing products have been relabeled >with the new 4 hr. REI. > >Thanks, > >Chazz Hesselein >Extension Horticulturist, ACES >chessele@acenet.auburn.edu > >Third time's a charm, eh Howard? > From SIESNET.SIES1.alfrench@SIES.WSC.AG.GOV Tue Jul 25 13:03:52 1995 Received: from SIES.WSC.AG.GOV (sies.wsc.ag.gov [199.128.64.4]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id NAA15563 for ; Tue, 25 Jul 1995 13:03:49 -0700 Received: from USDAHQ-Message_Server by SIES.WSC.AG.GOV with Novell_GroupWise; Tue, 25 Jul 1995 16:03:59 -0500 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Tue, 25 Jul 1995 16:04:52 -0500 From: Al French To: wps-forum@are.Berkeley.EDU Subject: The Label Paradox -Reply Bob Roach says >The paradox remains: the labels say to wear work< >clothing to protect the handler and they also demand< >that one not get the pesticide on the clothing.< It seems to me that if the label requires a minimum of long sleeves/long pants but conditions would result in handlers being "soaked to the skin" then they should wear chemical-resistant PPE if the label also requires "do not get on skin, in eyes or on clothing." If read this way, the "contradiction" or "paradox," and more importantly, contamination disappears. Label requirements are only minimums, not command and control. IMHO, if EPA is expected to issue specific regulations for every possible situation that may occur on a farm, WPS and its interpretive guidances will either be so voluminous as to be incomprehensible or so restrictive that little work could be performed. I believe that trained handlers can figure out that "do not get on skin, in eyes or on clothing" means they should do whatever is needed under the circumstances. Are specific label regulations needed for each product and each commodity at every stage of growth to tell in several languages trained handlers what to wear if spray drifts toward them, if spray drifts away from them, if foliar contact is made with the legs, or with the arms, or with arms and legs, or if it drips on the head, or gets on the shoes, or if it gets on feet and legs but not arms and head, etc. ad infinitum? Doesn't a generic statement such as "don't get it on you or your clothing" suffice? >Is there no Alexander out there?< Will just "Al" suffice? Al French alfrench@usda.gov From norwong@are.Berkeley.EDU Wed Jul 26 11:51:39 1995 Received: from [128.32.251.110] (gia5mac30.Berkeley.EDU [128.32.251.110]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id LAA04706 for ; Wed, 26 Jul 1995 11:51:36 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" Date: Wed, 26 Jul 1995 11:58:12 -0800 To: wps-forum From: norwong@are.Berkeley.EDU Subject: human help on this error message Human help on the error message from MEEDS_C@wpb1.dep.state.fl.us Please excuse this off-topic request. > > Here in Florida, we are working on developing a state sponsored > publication instead of rules for "Best Managment Practices" for > Yard Trash mulch, compost, fuel, etc. > > The BMP is being created by the industry itself under a newly > created association called, Florida Organic Recyclers Association > (F.O.R.A.). > > I hoped you all might know of a group similar to this one for > discussion of composting and yard trash. If anyone knows of one > I'd appreciate hearing about it. > > Thanks and sorry for the intrusion. > > Carol Meeds, meeds_c@wpb1.dep.state.fl.us > > -- Noreen From BAUMGARTNER.DONALD@EPAMAIL.EPA.GOV Wed Jul 26 15:22:29 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 PAA11604 for ; Wed, 26 Jul 1995 15:22:20 -0700 Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with Novell_GroupWise; Wed, 26 Jul 1995 18:23:37 -0400 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Wed, 26 Jul 1995 18:20:01 -0400 From: DONALD BAUMGARTNER To: wps-forum@are.Berkeley.EDU Subject: WPS Training Videos - Order Information In response to several inquiries recently received, asking for more information on the purchase of the various WPS training videos which I itemized last July 24, I provide below the direct contacts and purchase information pertinent to each of the videos previously listed. Please remember to include sales tax for those ordering videos within the same State. Remember also to specify English or Spanish for each video, since some videos are provided in one or the other language for the same price. I trust that this will satisfy the present and any future inquiries. Donald Baumgartner EPA Region 5 ************************************************* July 1995 WORKER PROTECTION STANDARD EPA-APPROVED TRAINING VIDEOS AVAILABLE Title; Producer(s); EPA-Approved; Source 1) You Can Do It - How to Teach Pesticide Health & Safety to Farmworkers & Their Families; Workgroup on Pest. Health & Safety (Wash.); NOT Appr. for training (EPA funded, good for train-the-trainer programs) (1991); Available at $19.00 ea. from Work Group on Pesticide Health and Safety, P.O. Box 801, Vashon Island, Wash. 98070 (206/463-9000). 2) Shedding Some Light on Pesticide Protection; EPA Off. Res. & Develop.; NOT Appr. for training (EPA funded, good for train-the-trainer programs) (1994); Available at $15-20 ea. from Cornell Univ. Audiovisual Center, 7 Business & Technology Park, Ithaca, NY 14850 (607/255-2090) 3) Pesticide Safety - Worker Protection (worker/handler); Univ. of Idaho; Yes (1993); Available at $19.95 ea. (add $3 for postage) from Ag Communications Center, Univ. of Idaho, Moscow, Idaho 83844-2332 (208/885-7945). 4) The Playing Field; Natl. Migrant Res. Prog.; NOT approved for training (good for train-the-trainer programs); Available at $35.00 ea. from Natl. Migrant Resource Program, Inc., 1515 Capital of Texas Hwy. South, Ste. 220, Austin, TX 78746 (512/328-7682). 5) WPS for Greenhouses & Nurseries (worker/handler); Iowa State Univ.; NOT appr. for training (1994) (employer education tool); Available at $20 ea. from Iowa State Univ., Extension Entomololgy, 109 Insectary Building, attn. Julie Honeick, Ames, IA 50011-3140 (515/294-1101). 6) Pesticide Handlers and the WPS (handler); Michigan State Univ.; Yes (1994); Available at $25.00 ea. (VT048) from Michigan State University Bulletin Office, 10-B Agriculture Hall, MSU, East Lansing, MI 48824-1039 (517/355-0240). 7) Chasing the Sun (worker); Natl. Migrant Res. Prog.; Yes (1994); Available at $35.00 ea. from Natl. Migrant Resource Program, Inc., 1515 Capital of Texas Hwy. South, Ste. 220, Austin, TX 78746 (512/328-7682). 8) Protect Yourself from Pesticides (worker); SOS Communications; Yes (1994); Available at $19.95 ea. (add 10% postage) from SOS Communications, 2999 Monterey Salinas Hwy., Suite 4, Monterey, CA 93940 (408/375-2035). 9) Greenhouse Pesticide Safety Training (worker/handler); Floriculture Greenhouse Ind. Alliance; Yes (1995); Available at $49.95 ea. (non-member) (add $5 shipping ea.) from Professional Plant Growers Assoc., P.O. Box 27517, Lansing, MI 48909-0517 (517/694-7700). 10) Pesticide Safety for You & Your Family's Health (worker); Kent Co. CES/Mich. State Univ.; Yes (1995); Available at $25 ea. (order # VT046) (add $5 postage) from Mich. State Univ. Bulletin Office, 10-B Agriculture Hall, MSU, East Lansing, MI 48824-1039 (517/355-0240). 11) Safe Use of Pesticides in Outdoor Nurseries (worker/handler); Visual Media (Univ. CA); Yes (1995); Available at $40.00 ea. (English & Spanish combined) from Visual Media, Univ. California, Davis 95616 (916/757-8980). 12) Pesticide Safety - Help Workers Protect Themselves; St. Joseph Co. CES/MI State Univ. Ext.; Yes (1995); Available at $30.00 ea. from St. Joseph County Mich. State Univ. Extension, P.O. Box 280, Centreville, MI 49032-0280 (616/467-5511). 13) Pest. Safety Training for Ag. & Early-Entry Workers; W. VA Univ. CES; Yes (1995); Available at $14.00 ea. from West Virginia Univ., Safety & Health Extension, 130 Tower Lane, P.O. Box 6615, Morgantown, WV 26506-6615 (304/293-3096). 14) Pesticide Training for Agricultural Employees (worker/handler); Farm Employers Labor Service (Calif.); Yes (1995); Available at $49 ea. from Farm Employers Labor Service, 1601 Exposition Blvd., FB7, Sacramento, CA 95815-5103 (916/924-4124). ########################################################### From: Wendy C Vance <@hawaii.edu> To: R5SCI.R5ESD(baumgartner-donald) Date: Monday, July 24, 1995 8:02 pm Subject: WPS Videos Thank you for listing the EPA-approved WPS videos on the wps-forum. Do you have procurement details (address, telephone, fax, cost, etc.)? Any assistance would be appreciated. Thank you, Blake Vance wvance@hawaii.edu ------------------------------------------- From: Tammy Gould <.state.me.us> To: "wps-forum@are.Berkeley.EDU","... Date: Tuesday, July 25, 1995 7:22 am Subject: RE: Training Video List I've got to concur with Howard that this list is great! Thanks, Don. I have just one small request though. Could you or maybe others on the Forum provide information, including a telephone number, on where to purchase the videos? I get calls all the time from growers asking where to buy some videos and I usually send them to Gemplers. I noticed that many of these are not available from Gemplers. Where can we get them from? From 73507.555@compuserve.com Wed Jul 26 21:37:17 1995 Received: from arl-img-4.compuserve.com (arl-img-4.compuserve.com [198.4.7.4]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id VAA18755 for ; Wed, 26 Jul 1995 21:37:16 -0700 Received: by arl-img-4.compuserve.com (8.6.10/5.950515) id AAA17689; Thu, 27 Jul 1995 00:36:44 -0400 Date: 27 Jul 95 00:35:18 EDT From: Bob Roach <73507.555@compuserve.com> To: wps-forum Subject: Al The Great Message-ID: <950727043517_73507.555_HHB59-1@CompuServe.COM> Al, Like Alexander The Great, you have cut through this Gordian knot with the sword of common sense. Well done, sir. The Oracle foretells that you shall become the Master of Asia. If common sense were really so common, all users could determine the appropriate protective measures. Unfortunately, they all do not have the wisdom of Crop Advisors. Common sense should tell one to wear the eye protection over the eyes, yet the most common PPE violation I see is the applicator not wearing any eye protection when required, or wearing it on the top of the head, as if expecting some overhead exposure. I agree there are innumerable application situations that will arise and labeling cannot cover everything. We have to draw a line somewhere to give people some guidance. IMHO that line should be contamination of the _person_ and not the _clothing_. ------------------------- King Gordius of Phrygia 73507.555@Compuserve.com ------------------------- >Bob Roach says >>The paradox remains: the labels say to wear work< >>clothing to protect the handler and they also demand< >>that one not get the pesticide on the clothing.< > > It seems to me that if the label requires a minimum of long >sleeves/long pants but conditions would result in handlers >being "soaked to the skin" then they should wear >chemical-resistant PPE if the label also requires "do not get >on skin, in eyes or on clothing." If read this way, the >"contradiction" or "paradox," and more importantly, >contamination disappears. Label requirements are only >minimums, not command and control. > IMHO, if EPA is expected to issue specific regulations for >every possible situation that may occur on a farm, WPS and >its interpretive guidances will either be so voluminous as to >be incomprehensible or so restrictive that little work could be >performed. I believe that trained handlers can figure out that >"do not get on skin, in eyes or on clothing" means they >should do whatever is needed under the circumstances. > Are specific label regulations needed for each product and >each commodity at every stage of growth to tell in several >languages trained handlers what to wear if spray drifts >toward them, if spray drifts away from them, if foliar contact >is made with the legs, or with the arms, or with arms and >legs, or if it drips on the head, or gets on the shoes, or if it >gets on feet and legs but not arms and head, etc. ad >infinitum? Doesn't a generic statement such as "don't get it >on you or your clothing" suffice? > >>Is there no Alexander out there?< > Will just "Al" suffice? > >Al French From PFEITUC@aol.com Thu Jul 27 13:11:53 1995 Received: from mail06.mail.aol.com (mail06.mail.aol.com [152.163.172.108]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id NAA02200 for ; Thu, 27 Jul 1995 13:11:51 -0700 From: PFEITUC@aol.com Received: by mail06.mail.aol.com (1.37.109.11/16.2) id AA173745880; Thu, 27 Jul 1995 16:11:20 -0400 Date: Thu, 27 Jul 1995 16:11:20 -0400 Message-Id: <950727161115_42177468@aol.com> To: WPS-Forum@are.Berkeley.EDU Subject: WPS-Ag Employer Training Program An easy and effective way to instruct Ag Employers on How to Comply with the WPS. Howard R. had listed this instructional program on the Forum -7/19/95.. Basically, this program is cover to cover from the EPA "How to Comply-Manual". The advantage of this program is that the slide presentation is composed of Text and illustration slide which makes it much easier for the audience (Ag Employers) to follow along. It is highly unlike that the average Ag Employer will get the information they need to get into compliance using the How to Comply Manual: They need help; someone needs to explain it to them and answer questions. This program would be the primary method of providing the needed information and the How to Comply Manual would be for reference. I developed this program to conduct "training" in the state of Arizona then decided that there must be others that needed this type of program . If you have questions on this program contact me: Dr. Michael Pfeiffer Pesticide Training Resources 2525 East Seneca Tucson, Arizona 85716 (520) 323-3135 (602 for and area code if 520 doesn't work) OR PFEITUC@aol.com p.s. It is not my intent to turn the forum into a swap meet for new products but think this fits in with the training material motif. Also this is my first time sending anything to the Forum, hope it looks presentable. Thanks Howard! From cefresno@ucdavis.edu Sat Jul 29 11:56:05 1995 Received: from franc.ucdavis.edu (root@franc.ucdavis.edu [128.120.8.183]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id LAA09469 for ; Sat, 29 Jul 1995 11:56:03 -0700 From: cefresno@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by franc.ucdavis.edu (8.6.12/UCD3.4) id LAA10699; Sat, 29 Jul 1995 11:55:19 -0700 Date: Sat, 29 Jul 1995 11:55:19 -0700 Message-Id: <199507291855.LAA10699@franc.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: news from fresno Cc: cefresno@ucdavis.edu This is Steve Sutter, UC Area Farm Advisor, Fresno ... I just learned from one of my WPS fieldworker train-the-trainer graduates from Calexico (58 miles from Yuma) that, although Arizona accepts WPS "blue cards" issued (or purchased) in California, he wasn't officially qualified to do WPS fieldworker training in Arizona. I've since learned one option for him would be to round up 19 other people for a free WPS train-the-trainer course, offered through Frank Lamudio, AZ Dept. of Ag., Yuma, (520) 343-1177. Such a full-day "refresher" class would legalize his efforts in Arizona! ... "Fresno Clear." From cefresno@ucdavis.edu Sat Jul 29 11:56:08 1995 Received: from franc.ucdavis.edu (root@franc.ucdavis.edu [128.120.8.183]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id LAA09475 for ; Sat, 29 Jul 1995 11:56:07 -0700 From: cefresno@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by franc.ucdavis.edu (8.6.12/UCD3.4) id LAA10701; Sat, 29 Jul 1995 11:55:22 -0700 Date: Sat, 29 Jul 1995 11:55:22 -0700 Message-Id: <199507291855.LAA10701@franc.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: advice please Cc: cefresno@ucdavis.edu >From Steve Sutter, UC Area Personnel Management Farm Advisor, Fresno ... One of my fieldworker train-the-trainer "graduates," employed by a grower-packer, moonlights as a WPS field worker trainer, offering her class to any fieldworker who's interested. Workers view an approved video and receive EPA's Worker Booklet, and are issued EPA's "blue card" (which she laminates on request to help preserve information on it). She advises workers where they can get free (Americorp) WPS training, but many of them (some of whom are seeking work from her regular employer) opt to pay $5 to get her instruction. ... Then calls (following one complaint) a local employment service official, asserting WPS training should be free to workers. ... THE WPS SAYS a "worker" is any person who is "employed" for any kind of compensation for activities related to agricultural plant production. ... Some employers have taken to heart EPA's admonition that they "assure workers have been trained according ! to the WPS" -- by requiring that job APPLICANTS have an EPA-approved WPS training card as a job "qualification." ... Legal discrimination??? ..."Fresno Clear." From alfrench@mailbox.econ.ag.gov Mon Jul 31 05:25:26 1995 Received: from mailbox.econ.ag.gov (MAILBOX.econ.ag.gov [151.121.64.123]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id FAA25799 for ; Mon, 31 Jul 1995 05:25:24 -0700 Received: from ECONSMTP-Message_Server by mailbox.econ.ag.gov with Novell_GroupWise; Mon, 31 Jul 1995 08:22:35 -0400 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Wed, 19 Jul 1995 17:50:03 -0400 From: Al French To: wps-forum@are.Berkeley.EDU Subject: Re: Work Clothing vs. PPE -Reply Wouldn't it make sense to read the label statement "do not get on skin, in eyes or on clothing" to mean that if circumstances would result in Bob Roach's handlers being "soaked to the skin," chemical-resistant clothing or protective eyewear should be worn even if only certain clothing (as distinguished from PPE) is required by the label? "Contradictions" then disappear. Label requirements are only minimums, not command and control. IMHO, if EPA is expected to issue regulations specific to every possible situation that may occur on a farm WPS and its interpretive guidances will either be so voluminous as to be incomprehensible or so restrictive that little work could be performed. I believe that people can figure out that "do not get on skin, in eyes or on clothing" means they should do whatever is necessary under the circumstances. Are specific label regulations needed for each product and each commodity at every stage of growth to tell in several languages trained handlers what to wear if spray drifts toward them, if spray drifts away from them, if foliar contact is made with the legs, or with the arms, or with arms and legs, or if it drips on the head, or gets on the shoes, or if it gets on feet and legs but not arms and head, etc. ad infinitum? Wouldn't a generic statement such as "don't get it on you or your clothing" suffice? Al French alfrench@usda.gov From alfrench@mailbox.econ.ag.gov Mon Jul 31 05:28:01 1995 Received: from mailbox.econ.ag.gov (MAILBOX.econ.ag.gov [151.121.64.123]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id FAA25899 for ; Mon, 31 Jul 1995 05:27:58 -0700 Received: from ECONSMTP-Message_Server by mailbox.econ.ag.gov with Novell_GroupWise; Mon, 31 Jul 1995 08:25:09 -0400 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Tue, 25 Jul 1995 09:20:42 -0400 From: Al French To: wps-forum@are.Berkeley.EDU Subject: Pesticides with 4 hr. REIs? -Reply On July 24 Chazz Hesselein stated: >I am trying to find a list of the most recent pesticides< >approved for 4 hr. REIs.< EPA published in the Federal Register on May 3, 1995, a list of 114 Candidate Active Ingredients Meeting Low Toxicity Criteria for which EPA may allow registrants to reduce WPS REIs from 12 to 4 hours. These are: Acetylchitin Agrobacterium radiobacter Ampelomyces quisqualis isolate M-10 Azadirachtin (neem extract) B.t. subsp. aizawai B.t. subsp. aizawai strain GC-91 B.t. subsp. israelensis B.t. subsp. kurstaki B.t. subsp. kurstaki HD-263 B.t. subsp. kurstaki strain EG2348 B.t. subsp. kurstaki strain EG2371 B.t. subsp. kurstaki strain EG2424 B.t. subsp. san diego B.t. subsp. tenebrionis Bacillus popilliae and B. lentimorbus Bacillus sphaericus Bacillus subtilis GB03 Bacillus subtilis MBI 600 BNOA (b-naphythoxy acetic acid) Borax Calcium hypochlorite Calcium oxytetracycline Calcium thiosulfate Candida oleophila Capsicum oleoresin Checkmate peach twig borer pheromone Chitosan Chlorsulfuron Colletotricum gleosporoides Copper as ammonia complex Copper salts of fatty acids Cytokinin 2,4-DB, isooctyl Diatomaceous earth Disodium octaborate tetrahydrate Disparlure Ethylene Ethoxyquin Farnesol Fatty acids, C8-12, Methyl esters Fenridazone-potassium Fluazifop-butyl Fluazifop-r-butyl Gibberellic acid Gibberellins A4 and A7 Gliocladium virens G-21 Glyphosate, ammonium Glyphosate, isopropylamine Glyphosate, sodium Gossyplure: hexadecadien-1-ol acetate Gypsy moth npv Heavy aromatic naphtha Imazethapyr Imazethapyr, ammonium salt Indole-3-butyric acid Lagendidium giganteum, mycelium Mefluidide, diethanolamine Mefluidide, potassium salt Methyl nonyl ketone [[Page 21967]] Metsulfuron-methyl Milky spore Mineral oil Muscalure, component of (e)-9-tricosene Muscalure, component of (z)-9-tricosene N-6-Benzyladenine NAA, Ethyl ester Nerolidol Nicosulfuron Nosema locustae Octyl bicycloheptenedicarboxamide Oxytetracycline hydrochloride Paradichlorobenzene Paraffin oils Periplanone B Polyhedral inclusion bodies of Autographa californica Polyhedral inclusion bodies of Heliothis zea NPV or Helicoverpa zea NPV Polyhedral inclusion bodies of beet armyworm npv Polyhedral inclusion bodies, Neodiprion sertifer NVP Potassium gibberellate Promalin Pseudomonas cepacia type wiscons. Pseudomonas fluorescens Pseudomonas fluorescens A506 Pseudomonas fluorescens EG-1053 Pseudomonas fluorescens strain NCIB 12089 Pseudomonas syringae Puccinia canaliculata (Schweinitz) Rimsulfuron DPX-E9636 Ryania speciosa Ryanodine s-Kinoprene s-Methoprene Sesame plant, ground Siduron Silica gel Silicon dioxide Sodium carboxymethylcellulose Sodium metaborate Soybean oil Streptomyces griseoviridis Streptomycin Streptomycin sesquisulfate Sulfometuron-methyl Thifensulfuron-methyl Thiobencarb Tomato pinworm (e)-4-tridecen-1-yl acetate Tomato pinworm (e)-11-tetradecenyl acetate Triasulfuron 1-Triacontanol Trichoderma harzianum var. rifai (KRL-AG2) Trichoderma harzianum (ATCC 20476) Trichoderma polysporum (ATCC 20475) Tussock moth npv Al French alfrench@usda.gov