From ALFRENCH@mailbox.econ.ag.gov Wed Nov 8 07:59:49 1995 Received: from mailbox.econ.ag.gov (MAILBOX.econ.ag.gov [151.121.64.123]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id HAA10881 for ; Wed, 8 Nov 1995 07:59:47 -0800 (PST) Received: from ECONSMTP-Message_Server by mailbox.econ.ag.gov with Novell_GroupWise; Wed, 08 Nov 1995 10:59:17 -0500 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Wed, 08 Nov 1995 10:57:06 -0500 From: Al French To: wps-forum@are.berkeley.edu Subject: Research into Pest Management Alternatives Funding for a program implementing a 1994 Memorandum of Understanding between USDA and EPA has been announced. (60 Federal Register 56098 (11/6/95)), designed to develop safer alternatives to pesticides that have been cancelled. EPA and USDA will create a list of pesticides that could affect farmers' control over pests that had been previously contained by recently cancelled pesticides. In the Federal Register notice, the pest management alternatives research program places emphasis on, "current and potential loss of select pesticides due to increased worker and food safety and environmental concerns leading to regulatory review and actions." The memorandum also establishes a grants program at USDA's Cooperative State Research, Education, and Extension Service (CSREES) for state agricultural experiment stations, colleges and universities, private organizations, state and federal agencies, and eligible USDA scientists. Al French alfrench@usda.gov From 71154.2454@compuserve.com Sun Nov 12 18:42:46 1995 Received: from dub-img-1.compuserve.com (dub-img-1.compuserve.com [198.4.9.1]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id SAA25907 for ; Sun, 12 Nov 1995 18:42:43 -0800 (PST) Received: by dub-img-1.compuserve.com (8.6.10/5.950515) id VAA19250; Sun, 12 Nov 1995 21:42:04 -0500 Date: 12 Nov 95 21:37:18 EST From: Carolyn Tryon <71154.2454@compuserve.com> To: WPS Forum Subject: WPS Pocket Guide Message-ID: <951113023717_71154.2454_DHB52-1@CompuServe.COM> Hi WPS Forum members! Many of you helped me as I developed a WPS Pocket Guide. Thanks for your help and comments. The WPS Pocket Guide came off the presses last week. My dealers love it. It contains all (this number changes weekly) EPA approved WPS products currently being sold in the U.S. There is one product per page and we used the EPA approved "Supplemental Labeling" format plus a header with 10 items (EPA#, phone#, REI, manufacturer, A.I. etc.). The body of the text is straight from the label with no editing. We are not calling this "Supplemenat Labeling" because we have not gotten approval from all of the 167 manufacturers with label info in our Guide. The index alone is invaluable with Trade Name, EPA#, manufacture and a page number to find WPS information for that product ( including the Ag Use Requirments box, Engineering Statement, all PPE, etc). Again, the info on each productt appears as it did on the label and not in table or chart form. If their are multiple REIs - we have pulled them from the crop/site and placed them with the REI in the Ag Use Requirments Box. The data in a more comprehensive form (all label info except "Use Directions") is also available for the personal computer. I have several folks with EPA and a state Cooperative Extension Service evaluating the computer system. If you want any more info - EMail or call me at 770-992-5773 Earl H. Tryon From howardr@are.Berkeley.EDU Mon Nov 13 13:29:57 1995 Received: from [128.32.251.103] (gia5mac23.Berkeley.EDU [128.32.251.103]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id NAA16446 for ; Mon, 13 Nov 1995 13:29:49 -0800 (PST) Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Mon, 13 Nov 1995 13:29:57 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: comment on proposed change to warning sign rule In late September, the EPA published two WPS revision proposals. One would shorten the time that decontamination sites for workers are required when certain low-toxicity pesticides are used. The second would allow substitution of another language for Spanish on warning signs, and would allow the use of smaller warning signs in greenhouses and nurseries. Deadline for public comments on both proposals is today, November 13, 1995. Mark Nestlen, Director of Legislative & Regulatory Affairs for the National Association of State Departments of Agriculture, has provided us with a copy of the letter through which the Coalition for Sensible Farmworker Protection (signators are NASDA plus 13 other agricultural organizations) has commented on the sign proposal. Full text of the letter is below. -------------------------------------------------- Coalition for Sensible Farmworker Protection November 7, 1995 Public Response Section Field Operations Division (7506C) Office of Pesticide Programs Environmental Protection Agency 401 M Street, SW Washington, DC 20460 Dear Sir/Madam: The following comments are submitted by the American Association of Nurserymen, the American Corn Growers Association, the American Soybean Association, the Hawaiian Sugar Planters Association, the National Agricultural Aviation Association, the National Association of State Departments of Agriculture, the National Association of State Foresters, the National Association of Wheat Growers, the National Corn Growers Association, the National Cotton Council, the National Council of Agricultural Employers, the National Grange, the Society of American Florists, and the Western Growers Association in response to the Environmental Protection Agency's proposed rule on the language and size requirement for warning signs under the Worker Protect Standard (OPP-250107). On July 8, 1994, 19 agricultural organizations petitioned the Agency to make modifications to the Worker Protection Standard (WPS) for Agricultural Pesticides. One of the points raised in the petition related to the language requirements on field signs. In the petition, the organizations said that the posting and training provisions of the WPS which require agricultural employers to provide workers with certain information in English and Spanish needed modification. The organizations recognized that this requirement enables Spanish-speaking workers to receive and understand crucial information regarding pesticide safety. However, in some areas of the country, Spanish-speaking workers are a rarity and it is difficult to find Spanish-speaking trainers to conduct training sessions. The requirements for conveying information in English and Spanish in these areas is burdensome and a waste of resources. Accordingly, the organizations requested EPA make clear in the context of a rulemaking action that the Spanish language requirements are limited to those areas within which a significant number of Spanish-speaking workers are employed. The proposed rule on warning sign requirements published on September 29, 1995 in Vol. 60, No. 189 of the Federal Register properly addresses the concerns raised in the July 8, 1994 petition. The undersigned organizations support the proposed rule as published and would encourage the Agency to finalize the rule in an expedited fashion. It is appropriate for the Agency to allow growers the option of replacing the Spanish portion of the warning sign with the written language that is most read by the portion of the workforce that does not read English. As proposed, the option should not preclude the continued use of the English/Spanish sign, which should remain acceptable to fulfill requirements in all cases. Further, the requirement should not be changed to require more than two languages -- or "all languages read by workers" -- on a sign. The undersigned organizations also generally support the proposed smaller sign requirements for greenhouses and nurseries. The smaller signs will provide the necessary warnings to workers while providing management flexibility to the industry. However, the EPA proposal is too narrow and restrictive. EPA would allow the smaller signs only when use of a larger sign may interfere with operations or the clear identification of treated areas. We would suggest that all nursery and greenhouse growers should have the choice of using 14" X 16" signs or smaller signs, without having to meet additional EPA requirements. This would provide a consistent regulation which treats all growers the same, would not provide an economic disadvantage to certain growers, and would provide for consistent enforcement among regulators. EPA did not propose a minimum size sign. The undersigned organizations believe that there should, however, be a minimum size, and suggests that the 3" X 4" minimum size as approved and shown effective in the Oregon plan is the best approach. We also agree with EPA that the rule should not include a maximum distance between signs. Rather, the "performance standard" should be that the treated area is adequately identified, and signs are visible and legible. We appreciate the opportunity to support the Agency on these important rule changes to the WPS. Sincerely, American Association of Nurserymen American Corn Growers Association American Soybean Association Hawaiian Sugar Planters Association National Agricultural Aviation Association National Association of State Departments of Agriculture National Association of State Foresters National Association of Wheat Growers National Corn Growers Association National Cotton Council National Council of Agricultural Employers National Grange Society of American Florists Western Growers Association From BAUMGARTNER.DONALD@EPAMAIL.EPA.GOV Mon Nov 13 16:03:08 1995 Received: from ARTHUR.RTPTOK.EPA.GOV (arthur.rtptok.epa.gov [134.67.212.29]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id QAA22130 for ; Mon, 13 Nov 1995 16:03:06 -0800 (PST) Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with Novell_GroupWise; Mon, 13 Nov 1995 17:22:14 -0500 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Mon, 13 Nov 1995 17:19:21 -0500 From: DONALD BAUMGARTNER To: wps-forum@are.berkeley.edu Subject: WPS Immediate Pesticide Safety Information The U.S. EPA has just released new pocket booklets intended to satisfy the pre-traiing pesticide safety requirement under the May 1995 Training Rule Amendment. Beginning January 1, 1996, the agricultural employer shall assure that untrained workers receive basic pesticide safety information before their entry into previously treated areas on the establishment. This information may be conveyed by written materials, handouts, posters, oral communicaion, or otherwise. Up to this point one existing EPA document (brochure) entitled "Protect Yourself From Pesticides" (EPA #735-F-94-001, dated Jan. 1994) met the required content of pre-training pesticide safety information which employers must convey to workers. Added to this employers must inform workers also that "further training will be provided in 5 days" (of entry into treated areas where pesticides have been applied in the last 30 days). Now available at all EPA Regional offices and soon to be available at all State Department of Agriculture offices, and at some State Cooperative Extension offices, is a new pocket booklet entitled "Steps to Protect Yourself From Pesticides" (EPA #735-F-95-002, dated October 1995). It is available in English/Spanish and English/Cambodian (EPA #735-F-95-005). The booklet is a miniaturized and abbreviated version of the WPS worker handbook and which addresses the 7 points of safety required to be conveyed. There is an anticipated large demand for these booklets begining with the new year. Donald Baumgartner EPA Region 5 From smcdonld@freenet.columbus.oh.us Tue Nov 14 12:04:24 1995 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id MAA15267 for ; Tue, 14 Nov 1995 12:04:21 -0800 (PST) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.6.10/4.940426) id PAA00257; Tue, 14 Nov 1995 15:01:12 -0500 Received: by acme.freenet.columbus.oh.us (8.6.10) id PAA29255; Tue, 14 Nov 1995 15:01:09 -0500 Date: Tue, 14 Nov 1995 14:56:57 -0500 (EST) From: Sally McDonald Subject: Re: WPS Immediate Pesticide Safety Information To: wps-forum@are.Berkeley.EDU cc: wps-forum@are.Berkeley.EDU In-Reply-To: Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On Mon, 13 Nov 1995, DONALD BAUMGARTNER wrote: > The U.S. EPA has just released new pocket booklets intended to > satisfy the pre-traiing pesticide safety requirement under the May > 1995 Training Rule Amendment. Beginning January 1, 1996, the > agricultural employer shall assure that untrained workers receive > basic pesticide safety information before their entry into previously > treated areas on the establishment. This information may be conveyed > by written materials, handouts, posters, oral communicaion, or > otherwise. Sally replies: Just a reminder! The information must be conveyed in a manner the worker can understand. Therefore, unless the employer is able to "assure" that the worker can read and understand the written materials, handouts, or posters, the information will probably have to be conveyed orally. -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From smcdonld@freenet.columbus.oh.us Wed Nov 15 12:40:56 1995 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id MAA17881 for ; Wed, 15 Nov 1995 12:40:54 -0800 (PST) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.6.10/4.940426) id OAA13005; Wed, 15 Nov 1995 14:29:19 -0500 Received: by acme.freenet.columbus.oh.us (8.6.10) id OAA23757; Wed, 15 Nov 1995 14:29:19 -0500 Date: Wed, 15 Nov 1995 14:16:06 -0500 (EST) From: Sally McDonald Sender: Sally McDonald Reply-To: Sally McDonald Subject: Re: comment on proposed change to warning sign rule To: wps-forum@are.Berkeley.EDU cc: wps-forum@are.Berkeley.EDU In-Reply-To: Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; CHARSET=US-ASCII I just can't let the NASDA comments stand without my two-cents. The ONLY requirement in the WPS for both English and Spanish is on the standardized one-sign-fits-all WPS treated area posting sign. There are NO requirements in the WPS that require training or other information be conveyed in Spanish -- when the workers don't speak Spanish. The WPS requires that worker and handler training be conveyed in a manner the worker or handler can understand. If the worker or handler can understand English, the training can be delivered in English. If they don't understand English, the training must be conveyed in a language (or other manner) that the worker or handler can understand. The information that must be posted at a central place may be in English, regardless of what language workers or handlers speak or understand. I can understand some grower resistance to the Spanish words on the treated-area posting sign if there are no Spanish-speaking workers employed. However, it is permissible under the present rule to add a third language to the sign and I believe the more prudent option is to ADD the "Danger," "Pesticides," and "Keep Out" in the third language. Otherwise, under the proposed rule change, growers would have the burden of determining (1) which workers read and understand English, (2) then of the remaining workers determining which could read in any language, and (3) then of those workers who cannot read English, but can read another language, determining which language a majority can read. Since that could alter daily depending on the makeup of the crew, I can foresee a large burden on growers, with little obvious benefit. The acceptable language on the sign would, presumably, have to be altered as often as the crew's ability to read a non-English language changes -- perhaps more than once during the posting period. I certainly admire any grower who is willing to go to the trouble and expense, but how realistic is this option when one standard sign in English and Spanish is ALWAYS acceptable? Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017