From 73507.555@compuserve.com Mon Oct 2 20:06:16 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 UAA28455 for ; Mon, 2 Oct 1995 20:06:13 -0700 Received: by dub-img-1.compuserve.com (8.6.10/5.950515) id XAA17120; Mon, 2 Oct 1995 23:05:42 -0400 Date: 02 Oct 95 23:03:56 EDT From: Bob Roach <73507.555@compuserve.com> To: "'WPS-Forum'" Subject: Zero Day REI Message-ID: <951003030356_73507.555_HHB28-1@CompuServe.COM> I have not yet seen a product label with a 0 day REI. Before WPS you had to wait at least until the spray had dried or the dust settled. Now the minimum time to wait before entry is 4 hours. Do you still have to wait 4 hours with a 0- day REI? Bob Roach From 73414.252@compuserve.com Tue Oct 3 13:22:17 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 NAA17762 for ; Tue, 3 Oct 1995 13:22:12 -0700 Received: by arl-img-4.compuserve.com (8.6.10/5.950515) id QAA09701; Tue, 3 Oct 1995 16:21:41 -0400 Date: 03 Oct 95 15:37:26 EDT From: Judith Hauswirth <73414.252@compuserve.com> To: wps-forum Subject: 0-day REI example Message-ID: <951003193726_73414.252_DHS90-1@CompuServe.COM> Regarding the restricted entry intervals for pheromones, Bob Roach stated that he had not yet seen a label with a 0-day REI. NoMate TPW MEC by Ecogen is an example (EPA REG No. 55638-23). The product is a microencapsulated pheromone that is under the scope of the WPS. Within the Agricultural Use Requirement box is the following statement: This product does not have a restricted-entry interval. There are no other references to an REI within the box or elsewhere on the label. Standard Tox category IV PPE requirements for handlers is on the label as is the prohibition against applying the product in a way that will contact workers or others either directly or through drift. The label permits reentry immediately after the completion of application. Curt Lunchick (703) 312-8555 From LTrue@aol.com Wed Oct 4 11:05:29 1995 Received: from emout05.mail.aol.com (emout05.mail.aol.com [198.81.10.37]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id LAA11973 for ; Wed, 4 Oct 1995 11:05:27 -0700 From: LTrue@aol.com Received: by emout05.mail.aol.com (8.6.12/8.6.12) id OAA08651 for wps-forum@are.berkeley.edu; Wed, 4 Oct 1995 14:04:55 -0400 Date: Wed, 4 Oct 1995 14:04:55 -0400 Message-ID: <951004140455_116087294@emout05.mail.aol.com> To: wps-forum@are.Berkeley.EDU Subject: Re: 0-day REI example I'd like to add to Curt Lunchick's response to questions Bob Roach had about zero-day REI's. Bob suggested a possible conflict with a WPS prohibition on entry for the first 4 hours after application. It should be noted that such restrictions only apply DURING an REI, even if the label does not, as it did in Curt's example, specify that entry may occur immediately. If the label specifies no REI, or one of zero duration, it should be pretty clear that the WPS restrictions in 170.112 do not apply. Lou True From aftgoul@gatekeeper.ddp.state.me.us Wed Oct 4 12:15:39 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 MAA14563 for ; Wed, 4 Oct 1995 12:15:37 -0700 Received: from @gatekeeper.ddp.state.me.us by gatekeeper.ddp.state.me.us (8.6.5/1.37) id PAA14455; Wed, 4 Oct 1995 15:09:42 -0400 Date: Wed, 4 Oct 1995 15:09:42 -0400 Message-Id: <199510041909.PAA14455@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: Proposed Changes to the Decontamination Requirements I'd like to throw out for comment an idea which struck me while I was reading the recently published Federal Register Notice about changes in WPS decontamintion requirements. For those of you who haven't read it yet, EPA is proposing to lower the period during which decontamination supplies must be provided to workers from 30 days to between 1 and 15 days for the designated "low risk", 4-hour REI pesticides. In the original August 1992 FR notice and the Response to Comments Document, EPA described the studies and process used to arrive at the 30 day interval. The 30-day interval is also not tied solely to the provision of decontamination supplies. Information at a central location and pesticide safety training must also be provided to workers who enter areas which have been treated or under REI in the last 30 days. If EPA has re-evaluated their original risk/benefit determination in light of these "low risk" pesticides and has found that the number of days can be reduced for provision of decontamination supplies, is possible that the central information and training intervals can also be reduced? What I'm suggesting is that EPA has opened the door for two classes of WPS products -- one "high risk" class where workers must be provided decontamination supplies, information at a central display, and pesticide safety training for 30 days following the REI and one "low risk" class where these same protections are provided for fewer days. If you're going to comment on the rule, think about this. I'd be interested in what others may have to say on this idea. Tammy Gould Maine Board of Pesticides Control From howardr@are.Berkeley.EDU Wed Oct 4 15:47:05 1995 Received: from DialupEudora (eudora@are.Berkeley.EDU [128.32.175.17]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id PAA21343; Wed, 4 Oct 1995 15:47:00 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Wed, 4 Oct 1995 15:49:38 -0700 To: wps-forum@are.Berkeley.EDU From: howardr@are.Berkeley.EDU (Howard Rosenberg) Subject: Re: Proposed Changes As Tammy says in her message today, EPA has published in the Federal Register (September 29, 1995; Volume 60, Number 189) a proposal to shorten the time that decontamination sites for workers are required when certain low-toxicity pesticides are used. On that same day it also published a second proposed amendment to the WPS. This second one 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 proposed rules is November 13, 1995. The full text of these proposals, plus the complete notice that announces denial of the Delaware request for an REI exception (which I posted a summary of last Thursday), will be placed in the forum archive within a couple of days. As soon as they are, I will post a note with filenames and a reminder of how to download them. --Howard From 73414.252@compuserve.com Thu Oct 5 05:35:20 1995 Received: from dub-img-5.compuserve.com (dub-img-5.compuserve.com [198.4.9.5]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id FAA04187 for ; Thu, 5 Oct 1995 05:35:18 -0700 Received: by dub-img-5.compuserve.com (8.6.10/5.950515) id IAA02597; Thu, 5 Oct 1995 08:34:47 -0400 Date: 05 Oct 95 08:31:09 EDT From: Judith Hauswirth <73414.252@compuserve.com> To: wps-forum Subject: proposed decontamination changes Message-ID: <951005123109_73414.252_DHS58-1@CompuServe.COM> I would like to throw out the following thoughts for people to think about before they comment on the reduced decontamination period for "less toxic" pesticides. The original reason for requiring decontamination facilities and central notification, etc beyond the expiration of the REI was that the pesticide's dislodgeable foliar residues were still present and field worker exposure will still occur. The REIs set by WPS were only interim and only based on acute toxicity. Therefore, providing workers with decontamination facilities to wash off pesticide residues after the REI expired made sense and still makes sense. Remember that the "low risk" pesticides may not have been competely evaluated for nonacute tox endpoints like developmental toxicity, reproductive toxicity, or carcinogenicity. This evaluation is supposed to occur during the Reregistration process. This process is far from complete. Therefore generic blanket reductions in requirements based on acute toxicity classification removes what may be very important safety requirements for products that are not acutely toxic but may be determined to be potent developmental toxins upon completion of the RED process. I don't think this proposal is well thought out. Curt Lunchick From kaiser@ssnet.com Thu Oct 5 06:08:11 1995 Received: from marlin.ssnet.com (marlin.ssnet.com [205.216.96.3]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id GAA04428 for ; Thu, 5 Oct 1995 06:08:10 -0700 Received: (from kaiser@localhost) by marlin.ssnet.com (8.6.12/8.6.12) id JAA01472; Thu, 5 Oct 1995 09:07:52 -0400 Date: Thu, 5 Oct 1995 09:07:51 -0400 (EDT) From: Roger Kaiser To: wps-forum@are.Berkeley.EDU Subject: Decontamination sites Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII The proposed changes in decontamination site requirements sound like a good idea to me. The sites are located in the field so that workers can wash after exposures that result in acute toxic symptoms. They are not designed as substitutes for a bath after the work day. There is nothing in the law that says that workers cannot wash their clothing and bodies when they return home. Let us not fall into the trap of legislation for zero risk from pesticide exposure. If we do, then soon the risks and dangers that arise from our rules become much worse than the risk from the pesticides. Roger Kaiser From LTrue@aol.com Thu Oct 5 14:18:50 1995 Received: from emout06.mail.aol.com (emout06.mail.aol.com [198.81.10.43]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id OAA19353 for ; Thu, 5 Oct 1995 14:18:47 -0700 From: LTrue@aol.com Received: by emout06.mail.aol.com (8.6.12/8.6.12) id RAA14210 for wps-forum@are.berkeley.edu; Thu, 5 Oct 1995 17:18:15 -0400 Date: Thu, 5 Oct 1995 17:18:15 -0400 Message-ID: <951005171811_117061544@emout06.mail.aol.com> To: wps-forum@are.Berkeley.EDU Subject: Re: proposed decontamination changes Some further thoughts and facts for the Forum's consideration -- When EPA selected the criterion of 30 days post-REI or application for decontamination and certain other provisions, it did so in the belief that it was permitting these basic, inexpensive and prudent protections to be omitted only in unusual situations. EPA's intention was to have these protections in place for workers essentially always on a typical agricultural establishment using pesticides and workers in the production of agricultural plants. This objective is clear in the 1988 proposed rule, which required decontamination facilities for any worker "during any task which causes the worker to come into contact with any surface that has been treated with a pesticide DURING THE AGRICULTURAL PRODUCTION CYCLE IN WHICH THE TASK OCCURS." The all-caps passage was the proposed rule's counterpart to the 30 days in the final rule. It was basically intended to require that decontamination supplies be available for all those working in areas previously treated during the growing season. It was worded as it was because EPA felt it was unnecessary, for example, to require such protections on a grain operation in the spring when the last application was in the summer, or on a farm that may not have used a pesticide for years. On the other hand, EPA clearly had concluded that on a typical, non-organic establishment using workers -- say a fruit, vegetable or nut operation -- decontamination was appropriate always. This was due not only to the approriate concerns that Curt Lunchick mentioned -- WPS REI's set on limited information and the expected duration of the reregistration program -- but also because other things can and do happen on the agricultural worksite that can cause workers to be exposed to pesticides. Winds do shift and accidents do occur that cause workers to be exposed during applications, "hot spots" in and away from fields occur from spillage, drift causes residues outside areas intended for treatment, etc. In short, things happen. Having soap, water and towels available was viewed as a rudimentary and essential element of any reasonable worker safety practices on agricultural worksites in which pesticides are used. Nothing between the proposed and final rules altered this aspect of EPA's basic purpose or conclusions. On the other hand, good comments were received on the proposed rule that pointed out practical problems with interpreting the quoted timing criterion. For example, it was noted that the "production cycle" of timber could be said to be decades long. EPA had not intended that such protections were necessary long after application, as in the case of the only use being herbicide applications when planted seedlings are young. Comments also questioned the need for entire growing cycles to be covered for other crops, and encouraged EPA to adopt a specific interval. EPA responded by seeking a reasonable period, resulting in the 30-day criterion. Since many field workers are on establishments in which growers are using pesticides on their crops at least this often, this requirement translates into a continuous one on these establishments. This was EPA's intention. That is, the 30-day criterion for decontamination and certain other provisions was intended by EPA to deal with extraordinary situations, not create an on-again/off-again pattern of requirements on typical establishments. This still seems to me to be prudent and practical public policy. Separately, I think it should be asked whether the additional complexity EPA proposes is productive in a broader sense. I suspect most growers would find that it would not be worth their time to keep track of when they must versus need not supply decontamination supplies under WPS. After all, many supplied these things in the absence of WPS. I also worry that this, like some of the other elaborations of WPS EPA has moved toward, will increase employer frustrations, confuse worker expectations, and thereby decrease compliance with WPS in general. Lou True From howardr@are.Berkeley.EDU Thu Oct 5 15:32:14 1995 Received: from [128.32.251.96] (gia5mac16.Berkeley.EDU [128.32.251.96]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id PAA22214 for ; Thu, 5 Oct 1995 15:32:07 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Thu, 5 Oct 1995 15:32:52 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: decision and proposed rules in archive The three WPS documents recently published in the Federal Register are now available in the forum archive, thanks to Dana. One of them announces denial of the Delaware petition for an administrative exception that would allow worker entry into chlorothalonil-treated cantaloupe and squash fields for hand harvest work before the end of a 48-hour REI, from July 1 through September 15, 1995. Name of the file in archive is "deldeny1.frn", and its size is 24667 bytes. The second is a proposed rule that would shorten the time that decontamination sites for workers are required when certain low-toxicity pesticides are used. This document also includes (a) clarification of the decontamination requirements, (b) a review of stakeholder concerns, (c) discussion of options considered, and (d) a request for comments and information on the proposal and options presented. The deadline for delivery of written comments, data, or evidence regarding the proposal is November 13, 1995. Name of this file in the archive is "decon95.pro", and size is 35452 bytes. The third is a proposed rule that would allow substitution of another language for Spanish on the warning sign, and that would allow the use of smaller warning signs in greenhouses and nurseries where the use of the standard size sign may interfere with operations or the clear identification of treated areas. This document also solicits comments on both the bilingual and size aspects of the proposal, requesting responses to several specific questions. The comment deadline is November 13, 1995. Name of the archive file containing this document is "sign95.pro", and size is 24727 bytes. To obtain a copy of any file in the forum archive, send to ListProc@are.berkeley.edu the message: GET WPS-FORUM Multiple GET commands may be stacked in a single message. --Howard From MEEDS_C@wpb1.dep.state.fl.us Fri Oct 6 09:05:07 1995 Received: from epic66.dep.state.fl.us (epic66.dep.state.fl.us [199.73.128.6]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id JAA06761 for ; Fri, 6 Oct 1995 09:05:06 -0700 Received: from mr.dep.state.fl.us by EPIC66.DEP.STATE.FL.US (PMDF V5.0-4 #7204) id <01HW42ZDGMWW0004UU@EPIC66.DEP.STATE.FL.US>; Fri, 06 Oct 1995 08:12:50 -0500 (EST) Received: with PMDF-MR; Fri, 06 Oct 1995 08:12:40 -0500 (EST) MR-Received: by mta WPB1; Relayed; Fri, 06 Oct 1995 08:12:40 -0500 MR-Received: by mta EPIC66; Relayed; Fri, 06 Oct 1995 08:12:42 -0500 Alternate-recipient: prohibited Date: Fri, 06 Oct 1995 08:08:15 -0500 (EST) From: Carol Meeds WPB 407-433-2650 x 113 Subject: Compost BMP Table of Contents To: wps-forum%are.berkeley.edu%in@mr.dep.state.fl.us Cc: pmillner%asrr.arusda.gov%in@mr.dep.state.fl.us, mlehman%cafe.berkeley.edu%in@mr.dep.state.fl.us, mflynn%ix.netcom%in@mr.dep.state.fl.us Message-id: MIME-version: 1.0 Content-type: MULTIPART/MIXED; BOUNDARY="Boundary (ID Q9e4fgd2HIHDHhYN98Quuw)" Posting-date: Fri, 06 Oct 1995 08:12:00 -0500 (EST) Importance: normal Priority: normal UA-content-id: E19ZVYZBQ9PX X400-MTS-identifier: [;04218060015991/61293@WPB1] A1-type: MAIL Hop-count: 2 --Boundary (ID Q9e4fgd2HIHDHhYN98Quuw) Content-type: TEXT/PLAIN; CHARSET=US-ASCII Hello: Please excuse if this is a repost, but I got a message from Howard saying that my message didn't go to the list. Please asist me by passing on this document to anyone who may be interested in helping review it. It is supposed to be camera ready mid-month. By the way, this is a draft and I am supposed to proclaim, "Draft. do not cite or quote." --Boundary (ID Q9e4fgd2HIHDHhYN98Quuw) MIME-version: 1.0 Content-type: MESSAGE/RFC822 Date: Sat, 30 Sep 1995 02:09:48 EST Subject: Compost BMP Table of Contents MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Importance: normal A1-type: DOCUMENT BEST MANAGEMENT PRACTICES MANUAL FOR YARD TRASH MANAGEMENT First Draft by Florida Organics Recycling Association In conjunction with the Florida Center for Solid and Hazardous Waste Management For the Florida Department of Envirinmental Protection September 15, 1995 BEST MANAGEMENT PRACTICES MANUAL FOR YARD TRASH MANAGEMENT TABLE OF CONTENTS _______________________________________________________________________ Introduction 1 Background 2 Chapter 1 - Florida Yard Trash Composition and Characteristics 4 Florida MSW Composition 4 Florida Yard Trash Composition by Region 5 Weight and Volume Characteristics 5 Chapter 2 - Yard Waste Recycling Alternatives 8 Composting 8 Mulching 9 Fuel Production 9 Direct Land Application 9 Landfill Cover Amendment 10 Firewood 11 Chapter 3 - Fundamentals of Compost Production 12 Contamination 12 Feedstock Preparation 12 Oxygen and Aeration 13 Particle Size and Surface Area 13 Moisture Content 14 Carbon/Nitrogen Ratio 14 pH 15 Pathogens 15 Chapter 4 - Fundamentals of Mulch Production 16 Types of Mulch 16 Characteristics 16 Fresh Mulch 17 Sanitized Mulch 17 Log Mulch 18 Plant Safety 18 Chapter 5 - Fundamentals of Fuel Production 19 Material Description 19 Particle Size 19 Product Storage 20 Non-wood Contamination 20 Moisture Content 20 Ash Content 20 BTU Value 20 Chapter 6 - Facility Siting and Design 21 Location 21 Permitting Requirements 21 Local Zoning and Building Requirements 22 Local Environmental Agencies 22 Waste Management Districts 23 Florida Department of Environmental Protection 22 Setbacks 22 Buffers 23 Entrance and Exit Requirements 23 Stormwater Control 24 Percolation 24 Slope 24 Retention or Detention Areas 24 Land Area Requirements 24 Staging Area 25 Processing Area 25 Storage and Curing Area 25 Projections for Site Capacity and Layout for Composting and Mulching Facilities 25 Staging Area Operations 26 Processing Area 26 Storage Area 27 Site Surface and Sub-Surface 27 Utilities 27 Security 27 Signage 27 Materials Measurement 28 Chapter 7 - Operational Considerations 30 Incoming Material 30 On-Site Personnel 30 Incoming Materials Considerations 31 Separation by Material Type 31 Plastic Bags 31 Grass 31 Contaminants 31 Storage Parameters 32 Size Reduction 32 Volume Reduction 32 Processing Times 33 Minimal Level 33 Low Level 33 Intermediate Level 34 Pile to Alley Relationship 34 Dust Control 34 Bioaerosols 34 Odors 35 Noise 35 Noise Reduction Measures 36 Pest and Insect Control 36 Fire Prevention 37 Employee Safety and Health 38 Material Screening 39 Chapter 8 - Product Considerations 41 Nutrients 42 Recordkeeping 43 Product Testing 43 Representations of Product 44 Marketing Guidelines 44 Appendix We are the Ones we have been waiting for. When the people lead, the leaders will follow. Why would you think that I speak for my employer? Carol Meeds: mother, chemist, woman, warrior --Boundary (ID Q9e4fgd2HIHDHhYN98Quuw)-- From 75222.2562@compuserve.com Fri Oct 6 11:44:18 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 LAA13167 for ; Fri, 6 Oct 1995 11:44:16 -0700 Received: by arl-img-4.compuserve.com (8.6.10/5.950515) id OAA19047; Fri, 6 Oct 1995 14:43:43 -0400 Date: 06 Oct 95 14:39:42 EDT From: Doug Edwards <75222.2562@compuserve.com> To: WPS-FORUM Subject: Decontamination Proposal Message-ID: <951006183941_75222.2562_GHI145-1@CompuServe.COM> I would like to agree with Lou True's comments about regulatory complexity. Though I agree with the logic of reducing the period of time decontamination facilities are required for some lower toxicity materials, I believe that sometimes in our zeal to be reasonable, we create regulatory schemes which are so complex that compliance and enforcement are impossible. Good law is simple, easily understood and based on good "common" sense. (KISS) REI +30 is something that even a person of my limited mental capacity can remember and comply with. Doug Edwards Deputy Ag. Commissioner Fresno County From howardr@are.Berkeley.EDU Sat Oct 7 08:24:44 1995 Received: from DialupEudora (eudora@are.Berkeley.EDU [128.32.175.17]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id IAA12826 for ; Sat, 7 Oct 1995 08:24:40 -0700 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Sat, 7 Oct 1995 08:27:28 -0700 To: wps-forum From: howardr@are.Berkeley.EDU (Howard Rosenberg) Subject: yikes, wromg filename Mea culpa. The name of the file containing the denial decision on Delaware's request for an REI exception is "deldeny1.dec". The name provided in Thursday's post had the wrong suffix ("deldeny1.frn"; names of the other two files described in that post are correct as is). Apologies to those who have already sent GET commands with the erroneous filename and gotten abuse from ListProc in return. --Howard From shenkm@ava.bcc.orst.edu Mon Oct 9 12:20:05 1995 Received: from BCC.ORST.EDU (root@ava.BCC.ORST.EDU [128.193.86.4]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id MAA16239 for ; Mon, 9 Oct 1995 12:20:02 -0700 Received: from smo-1000-E by BCC.ORST.EDU (4.1/SMI-4.1) id AA02624; Mon, 9 Oct 95 12:20:55 PDT Date: Mon, 9 Oct 95 12:20:55 PDT Message-Id: <9510091920.AA02624@BCC.ORST.EDU> X-Sender: shenkm@bcc.orst.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: shenkm@ava.bcc.orst.edu (Myron Shenk) Certain pesticide labels require both oral and written notification of pesticide applications. Although I have never seen a list of the criteria which EPA used when establishing posting requirements, I am sure the acute toxicity and persistence were among the key factors. I was recently reading some bilingual publications from another state, in which they state that any pesticide with a REI of 24 hours or more requires posting. Is this truly the case? It seems plausible, but I have not seen this or other criterion listed. Where might one find such a list of justifications? Thanks. Myron Shenk. Oregon State U. From 73414.252@compuserve.com Tue Oct 10 04:51:37 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 EAA06209 for ; Tue, 10 Oct 1995 04:51:35 -0700 Received: by dub-img-1.compuserve.com (8.6.10/5.950515) id HAA22829; Tue, 10 Oct 1995 07:51:04 -0400 Date: 10 Oct 95 07:47:01 EDT From: Judith Hauswirth <73414.252@compuserve.com> To: wps-forum Subject: Posting requirement notification Message-ID: <951010114701_73414.252_DHS32-1@CompuServe.COM> In response to Myron Shenk's request on the whereabouts of the criterion for double notification. The Worker Protection Standard criterion are provided in CFR Part 156.210 Notification to Workers Statements. This section tells registrations when to put double notification (oral and posted notification) statements on the label. Part 170 requires the grower to post when using a pesticide with double notification on the label. The requirements laid out in 156.210 are that the ACTIVE INGREDIENT be classified in Toxicity Category I for either acute dermal toxicity or skin irritation potential. By definition these pesticides have 48-hr REIs. The Agency can determine that posting is required for other pesticides during the reregistration process and it can also determine through reregistration or a registrant petition that pesticides required by 156.210 to have posting no longer require posting. Curt Lunchick From 73507.555@compuserve.com Tue Oct 10 21:44:50 1995 Received: from arl-img-5.compuserve.com (arl-img-5.compuserve.com [198.4.7.5]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id VAA29600 for ; Tue, 10 Oct 1995 21:44:48 -0700 Received: by arl-img-5.compuserve.com (8.6.10/5.950515) id AAA15446; Wed, 11 Oct 1995 00:44:17 -0400 Date: 11 Oct 95 00:39:23 EDT From: Bob Roach <73507.555@compuserve.com> To: "'INTERNET:wps-forum@are.Berkeley.EDU'" Subject: RE: WPS-FORUM digest 337 Message-ID: <951011043923_73507.555_HHB32-1@CompuServe.COM> Myron, As I understand it, pesticides requiring oral notice only do not require field posting but field posting can substitute for oral warning. All greenhouse applications require posting. From which state were the bilingual materials? Perhaps this was a translation problem. I understand that acute dermal toxicity is the trigger for the dual notifications. Unfortunately, the use pattern is not considered. A "dual notice" pesticide injected into the soil still requires oral and written notice, although no contact could occur! Bob Roach ---------- From: INTERNET:wps-forum@are.Berkeley.EDU Sent: Tuesday, October 10, 1995 12:15 AM To: "Worker Protection Standard Information Forum" Subject: WPS-FORUM digest 337 Certain pesticide labels require both oral and written notification of pesticide applications. Although I have never seen a list of the criteria which EPA used when establishing posting requirements, I am sure the acute toxicity and persistence were among the key factors. I was recently reading some bilingual publications from another state, in which they state that any pesticide with a REI of 24 hours or more requires posting. Is this truly the case? It seems plausible, but I have not seen this or other criterion listed. Where might one find such a list of justifications? Thanks. Myron Shenk. Oregon State U. ------------------------------ From smcdonld@freenet.columbus.oh.us Thu Oct 12 05:40:31 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 FAA03481 for ; Thu, 12 Oct 1995 05:40:29 -0700 Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.6.10/4.940426) id IAA05366; Thu, 12 Oct 1995 08:39:22 -0400 Received: by acme.freenet.columbus.oh.us (8.6.10) id IAA25474; Thu, 12 Oct 1995 08:41:36 -0400 Date: Thu, 12 Oct 1995 08:17:22 -0400 (EDT) From: Sally McDonald Subject: RE: WPS-FORUM digest 337 To: wps-forum@are.Berkeley.EDU cc: "'INTERNET:wps-forum@are.Berkeley.EDU'" In-Reply-To: <951011043923_73507.555_HHB32-1@CompuServe.COM> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On 11 Oct 1995, Bob Roach wrote > > As I understand it, pesticides requiring oral notice only do not require field > posting but field posting can substitute for oral warning. All greenhouse > applications require posting. Sally replies: For farms, forests, and nurseries (outdoor sites), agricultural employers have the choice between orally warning workers and posting signs at entrances to treated areas UNLESS the pesticide labeling requires that both forms of notification be given. For greenhouses, agricultural employers must post signs at entrances to treated areas for all WPS applications. If the pesticide labeling requires "double" notification, the employers must also warn workers orally. > > Bob wrote: I understand that acute dermal toxicity is the trigger for the dual notifications. Sally replies: The WPS requires double notification to be listed on the labeling of any pesticide product containing an active ingredient that is classified as category I (highly toxic) for acute dermal toxicity OR is category I (corrosive) for skin irritation potential. All fumigants used in greenhouses also have double notification requirements on their labeling. The WPS also states that EPA will establish "double notification" requirements on other active ingredients on a case-by-case basis when a short exposure could have the potential for a delayed effect, such as developmental toxicity. EPA most often establishes these additional "double notification" requirements through Reregistration or Special Review decisions. >> Bob wrote: Unfortunately, the use pattern is not considered. A "dual notice" pesticide injected into the soil still requires oral and written notice, although no contact could occur! > Sally replies: In the process of developing the WPS, use-patterns were considered. However, since many crop production practices involve worker contact with the soil -- transplanting, weeding, hoeing, thinning, etc. -- EPA determined that exempting the double notification requirement for soil-incorporated or soil-inject pesticides could not be justified on a generic basis. Registrants of soil-injected or -incorporated pesticides with registrations solely on crops where such production tasks are not practiced may petition EPA for a waiver of the double notification requirement. However, often in practice double notification is not required in those situations -- for example a soil-incorp for corn or soybeans -- because notification is not required if no workers will be in treated area or on foot within 1/4 mile of the treated area during the REI. Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From pat.marer@wserver.ipm.ucdavis.edu Thu Oct 12 16:41:56 1995 Received: from axp.ipm.ucdavis.edu (axp.ipm.ucdavis.edu [128.120.83.41]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id QAA21583 for ; Thu, 12 Oct 1995 16:41:53 -0700 Received: by axp.ipm.ucdavis.edu; id AA07450; Thu, 12 Oct 1995 16:51:22 -0700 Message-Id: Date: 12 Oct 1995 16:43:13 -0800 From: "Pat Marer" Subject: F.Y.I. Becoming a Trainer o To: "Forum WPS " X-Mailer: Mail*Link SMTP-QM 3.0.2 10/12/95 4:06 PM F.Y.I. Becoming a Trainer of Trainers Over the past year the UC IPM Project has trained over 2,000 people to be trainers of fieldworkers and pesticide handlers to comply with the WPS and California requirements. However, none of these people, nor other qualified trainers such as PCAs, certified private and commercial applicators, farm advisors, etc., are qualified to train trainers. California's Department of Pesticide Regulation now has a process by which other individuals can submit their own train-the-trainer programs to them for approval. Guidelines are available at county Agricultural Commissioner offices. UC IPM, in cooperation with the California Agricultural Production Consultants Association (CAPCA), is offering two 2-day courses to assist people in developing their train-the-trainer programs. Participants will be provided with models for the training programs and will receive guidance in their application to send to DPR. The course also includes actual teaching experience for each participant under the supervision of UC IPM staff members. Enrollment for this course is limited at each location to 18 participants. For registration information call (916)752-5273. Dates and locations for the courses are: November 15 and 16, 1995 - UC South Coast Field Station, Irvine February 1 and 2, 1996 - Yolo County Farm Bureau, Woodland Patrick J. Marer Pesticide Training Coordinator IPM Education and Publications UC Statewide IPM Project University of California Davis, CA 95616 From pat.marer@wserver.ipm.ucdavis.edu Thu Oct 12 17:11:50 1995 Received: from axp.ipm.ucdavis.edu (axp.ipm.ucdavis.edu [128.120.83.41]) by are.Berkeley.EDU (8.6.10/8.6.5) with SMTP id RAA22319 for ; Thu, 12 Oct 1995 17:11:48 -0700 Received: by axp.ipm.ucdavis.edu; id AA07696; Thu, 12 Oct 1995 17:21:17 -0700 Message-Id: Date: 12 Oct 1995 16:49:39 -0800 From: "Pat Marer" Subject: F.Y.I. Train the Trainer Wo To: "Forum WPS " X-Mailer: Mail*Link SMTP-QM 3.0.2 10/12/95 4:37 PM F.Y.I. Train the Trainer Workshops Here is an updated schedule of the current train-the-trainer programs being held in California by the UC IPM Project. Note that there are now pesticide handler trainer workshops offered in Spanish. Rohnert Park Oct. 16 Workshop for trainers of handlers and fieldworkers (English) Oct. 17 Workshop for trainers of fieldworkers only (English and Spanish) CANCELLED Holtville Oct. 31 Workshop for trainers of fieldworkers only (English and Spanish) Nov. 1 Workshop for trainers of handlers and fieldworkers (English) Nov. 2 Workshop for trainers of handlers and fieldworkers (Spanish) Irvine Nov. 13 Workshop for trainers of fieldworkers only (English and Spanish) Nov. 14 Workshop for trainers of handlers and fieldworkers (Spanish) Nov. 15 Becoming a trainer of trainers (English) Nov. 16 Workshop for trainers of handlers and fieldworkers (English) Marysville Jan. 8 Workshop for trainers of handlers and fieldworkers (English) Jan. 9 Workshop for trainers of handlers and fieldworkers (Spanish) Woodland Feb. 1 Becoming a trainer of trainers (English) Feb. 2 Workshop for trainers of handlers and fieldworkers (English) San Diego Feb. 27 Workshop for trainers of handlers and fieldworkers (English) Feb. 28 Workshop for trainers of handlers and fieldworkers (Spanish) Feb. 29 Workshop for trainers of fieldworkers only (English and Spanish) Call the IPM Project for more information at (916) 752-5273 Patrick J. Marer Pesticide Training Coordinator IPM Education and Publications UC Statewide IPM Project University of California Davis, CA 95616 From 73507.555@compuserve.com Sun Oct 15 13:48:14 1995 Received: from dub-img-5.compuserve.com (dub-img-5.compuserve.com [198.4.9.5]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id NAA12586 for ; Sun, 15 Oct 1995 13:48:07 -0700 Received: by dub-img-5.compuserve.com (8.6.10/5.950515) id QAA19358; Sun, 15 Oct 1995 16:47:36 -0400 Date: 15 Oct 95 16:46:00 EDT From: Bob Roach <73507.555@compuserve.com> To: "'WPS-Forum'" Subject: Dual Notification Message-ID: <951015204600_73507.555_HHB23-1@CompuServe.COM> Sally McDonald said: >Registrants of soil-injected or -incorporated >pesticides with registrations solely on crops where such production tasks >are not practiced may petition EPA for a waiver of the double notification >requirement. However, often in practice double notification is not >required in those situations -- for example a soil-incorp for corn or >soybeans -- because notification is not required if no workers will be in >treated area or on foot within 1/4 mile of the treated area during the REI. Sally, Our problem is that we do not grow corn or soybeans or any crop planted to quarter sections with very little hand labor. We grow vegetables. The average lot size is 12 acres. Numerous crews of labor contractors, harvest companies, PCOs, besides the grower's employees, have free access to ranches and are found daily within one quarter mile of REI areas. It is a logistical nightmare to develop a process whereby the oral notice can be delivered. When it is delivered it will be meaningless and useless. The crews do not go wandering about the ranch. If the field is posted, they do not enter. If the Disyston is 12 inches beneath the ground, they would need a shovel to dig it up. I have not seen one label change. Registrants do not want to do this. It usually costs them a lot of money and they have to deal with the USEPA. Is anyone aware of one soil-injected dual-notification pesticide that is in the process of changing their label to remove the dual warning requirement? Since enforcement outside of California will probably be minimal, there is probably not enough pressure to force label changes. I think the USEPA has made a bad rule and then put the burden on the registrants to fix it. California, by executive decree of the Governor, is undergoing a regulatory improvement initiative. The stated purpose is to eliminate regulations that are duplicative, obsolete, hard to understand, difficult to enforce or unduly burdensome. Have I ever called the WPS any of these? If anyone wants more information, go to the CDPR WWW page at and get the "Strawman Document." If you have trouble with that, contact me directly. Time for comments is short - October 20! Bob Roach 73507.555@compuserve.com From cefresno@ucdavis.edu Mon Oct 16 06:50:53 1995 Received: from guilder.ucdavis.edu (root@guilder.ucdavis.edu [128.120.8.181]) by are.Berkeley.EDU (8.6.10/8.6.5) with ESMTP id GAA21665 for ; Mon, 16 Oct 1995 06:50:52 -0700 From: cefresno@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by guilder.ucdavis.edu (8.6.12/UCD3.4) id GAA09682; Mon, 16 Oct 1995 06:50:47 -0700 Date: Mon, 16 Oct 1995 06:50:47 -0700 Message-Id: <199510161350.GAA09682@guilder.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: thought from fresno Cc: cefresno@ucdavis.edu This is Steve Sutter, UC Area Farm Advisor ... The WPS allows fieldworker pesticide safety training done by those who've completed the handler training requirements of Section 170.230(c). ... However a comparable provision's absent in the 5/15/95 "final draft proposed" California rules. ... Experienced "hose benders," including "noncertified" applicators, should be suitable fieldworker pesticide safety trainers. ... Our Governor's Executive Order W-127-95 requires agencies to search regulations for "anything that might be obsolete, duplicative, too complex and difficult to understand, or unduly burdensome." .. unduly burdensome .. unduly burdensome .. "Fresno Clear." From alfrench@mailbox.econ.ag.gov Wed Oct 25 13:06:42 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 NAA01646 for ; Wed, 25 Oct 1995 13:06:40 -0700 (PDT) Received: from ECONSMTP-Message_Server by mailbox.econ.ag.gov with Novell_GroupWise; Wed, 25 Oct 1995 16:05:27 -0400 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Wed, 27 Sep 1995 13:04:59 -0400 From: Al French To: wps-forum@are.Berkeley.EDU Subject: Re: Pheremone Reentry Re: Pheremone Reentry Bob, are these pheremone "puffers" used in conjunction with another pesticide? Although pheremones by themselves are explicitly exempt from WPS if used as an attractant for traps or as a repellent (170.102(8)), it seems to me there could be a problem if used to attract to another material that does have a REI. I recall discussions between USDA and EPA about the use of attractants in conjunction with other pesticides and whether containers could be designed to avoid worker exposure; however, I don't recall that this question was ever resolved. My guess is that it would have to be resolved on a case by case basis. Al French USDA Coordinator of Agricultural Labor Affairs 202/720-4737 alfrench@usda.gov < < From IPMPBG@UCKAC.EDU Wed Oct 25 13:32:44 1995 Received: from www.uckac.edu (root@[199.99.218.68]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id NAA02507 for ; Wed, 25 Oct 1995 13:32:42 -0700 (PDT) Received: from uckac.edu. (uckac.uckac.edu [199.99.218.65]) by www.uckac.edu (8.6.11/8.6.9) with ESMTP id NAA16885 for ; Wed, 25 Oct 1995 13:28:19 -0700 Received: from UCKAC/SpoolDir by uckac.edu. (Mercury 1.21); 25 Oct 95 13:32:40 PDT Received: from SpoolDir by UCKAC (Mercury 1.21); 25 Oct 95 13:32:24 PDT From: "Peter B. Goodell" To: wps-forum@are.Berkeley.EDU Date: Wed, 25 Oct 1995 13:32:19 PDT Subject: Re: Pheremone Reentry Priority: normal X-mailer: Pegasus Mail for Windows (v2.01) Message-ID: Al French wrote: > Bob, are these pheremone "puffers" used in conjunction with another pesticide? The puffers that are being refenced is the work of Dr. Harry Shorey here at Kearney Ag Center, University of California. He is using the same release cans used in public restrooms. He has the system working experimentally for beet armyworm and has been successful in disrupting the mating of this pest. His intentions were to develiver only the necessary pheromone component to accomplish this. PETER B. GOODELL, Ph.D 209 891-2500V 8912593F IPM Advisor/Extension IPM Coordinator Kearney Ag Center ^^^^^ //// From Mac82nd@aol.com Thu Oct 26 07:10:00 1995 Received: from emout06.mail.aol.com (emout06.mail.aol.com [198.81.10.43]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id HAA24321 for ; Thu, 26 Oct 1995 07:09:58 -0700 (PDT) From: Mac82nd@aol.com Received: by emout06.mail.aol.com (8.6.12/8.6.12) id KAA29303 for wps-forum@are.berkeley.edu; Thu, 26 Oct 1995 10:09:22 -0400 Date: Thu, 26 Oct 1995 10:09:22 -0400 Message-ID: <951026100912_54838640@emout06.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: Re: Pheremone Reentry Does anyone have the names and phone numbers of the researchers in California looking at pheremone "puffers."? If so could you pass them on to me. Thank you. From 73507.555@compuserve.com Thu Oct 26 23:07:29 1995 Received: from dub-img-3.compuserve.com (dub-img-3.compuserve.com [198.4.9.3]) by are.Berkeley.EDU (8.7.1/8.7.1) with SMTP id XAA21065 for ; Thu, 26 Oct 1995 23:07:28 -0700 (PDT) Received: by dub-img-3.compuserve.com (8.6.10/5.950515) id CAA07298; Fri, 27 Oct 1995 02:06:56 -0400 Date: 27 Oct 95 02:05:47 EDT From: Bob Roach <73507.555@compuserve.com> To: "'WPS-Forum'" Subject: Reentry Questions Message-ID: <951027060546_73507.555_HHB30-1@CompuServe.COM> To All: Disyston is injected into the soil in a bed application. Reentry is a no-contact activity for the irrigators who are to enter and set pipe. Disyston is a "dual-notice" material so they have to be informed about the REI, what the restrictions are, what PPE would be required, and then you tell them to go in there, they don't need any of that. Don't worry about the field posting signs either, it's OK. Fine. The label does not require incorporation by irrigation. The irrigation has nothing to do with the application. Therefore they are not applicators, just irrigators performing no-contact early reentry. Fine. My confusion is that the label says that only protected applicators can be in the area during the application. What area does the label refer to? A representative of the company expressed the opinion that it referred to the area immediately adjacent to the application equipment. I think it refers to the treated area, which is the whole field. What do you think? In another situation, I was approached by a PG&E meter reader supervisor who wanted to get some training for his employees because they have to enter posted fields occasionally to read electric meters on pumps. I realized that they are not under the scope of WPS so they can do as they will. Is this not correct? They will benefit from some training, I am sure. Bob Roach 73507.555@compuserve.com From smcdonld@freenet.columbus.oh.us Fri Oct 27 04:58:30 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 EAA24484 for ; Fri, 27 Oct 1995 04:58:28 -0700 (PDT) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.6.10/4.940426) id HAA10529; Fri, 27 Oct 1995 07:55:40 -0400 Received: by acme.freenet.columbus.oh.us (8.6.10) id HAA26326; Fri, 27 Oct 1995 07:55:43 -0400 Date: Fri, 27 Oct 1995 07:32:29 -0400 (EDT) From: Sally McDonald Subject: Re: Reentry Questions To: wps-forum@are.Berkeley.EDU cc: "'WPS-Forum'" In-Reply-To: <951027060546_73507.555_HHB30-1@CompuServe.COM> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On 27 Oct 1995, Bob Roach wrote: > To All: > > Disyston is injected into the soil in a bed application. Reentry is a > no-contact activity for the irrigators who are to enter and set pipe. > Disyston is a "dual-notice" material so they have to be informed about > the REI, what the restrictions are, what PPE would be required, and then > you tell them to go in there, they don't need any of that. Don't worry > about the field posting signs either, it's OK. Fine. > Sally replies: The irrigators must only be told (1) the location and description of the treated area (i.e., "the field you are about to enter"), (2) the time during which entry is limited (i.e., "there's an REI in effect until noon tomorrow) and (3) instructions not to enter the treated area and contact treated surfaces until the REI has expired. They need not be told what PPE would be required or any other information. I believe this information is especially important to workers who are entering an area under a "no contact" early entry situation. I have yet to see a soil-incorporation application that is so "clean" that all of the pesticide is below the soil surface. Often there are "little spills" at the turn arounds or in other areas where the injection didn't work perfectly. The oral warning alerts the "no contact" worker to be aware of such possibilities and to avoid contacting pesticide that may be on the soil surface. I disagree that "they don't need any of that." Bob says: > My confusion is that the label says that only protected applicators can be in > the area during the application. What area does the label refer to? A > representative of the company expressed the opinion that it referred to the area > immediately adjacent to the application equipment. I think it refers to the > treated area, which is the whole field. What do you think? Sally replies: The full labeling statement to which Bob refers is: "Do not apply this product in a way that will contact workers or other persons, directly or through drift. Only protected handlers may be in the area during application." The "area" is the treated area or the area to which the pesticide is being or was directed. Such an area can be the "whole field" -- however, depending on the size of the area to be treated and the length of time necessary to treat the "whole field" -- the ag employer has the option of designating smaller areas as distinct treated areas. For example, the area treated in the morning could be one treated area and the REI would begin at noon whereas the area treated in the afternoon could be a second treated area with the REI beginning at 6 pm. The key is how the ag employer describes the "treated area" at the central notice board, in oral warnings, and in how the treated area is posted. Bob says: > In another situation, I was approached by a PG&E meter reader supervisor who > wanted to get some training for his employees because they have to enter posted > fields occasionally to read electric meters on pumps. I realized that they are > not under the scope of WPS so they can do as they will. Is this not correct? > They will benefit from some training, I am sure. > Sally replies: The meter readers as described are outside the scope of the WPS. Not only will they benefit from some training, but they will get incidental benefit if signs are posted at entrances to treated areas, since those signs will warn them that a pesticide has recently been applied and an REI remains in effect. Sally > -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From howardr@are.Berkeley.EDU Fri Oct 27 13:58:28 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 NAA06099 for ; Fri, 27 Oct 1995 13:58:18 -0700 (PDT) Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Fri, 27 Oct 1995 13:59:11 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: Rooting Compounds and "no-contact" entry Forwarding a post from Joanne Kick-Raack that got hung up in system: >Date: Wed, 25 Oct 1995 05:45:48 -0700 (PDT) >To: wps-forum@are.Berkeley.edu >From: kick-raack.1@osu.edu (Joanne Kick-Raack) >Subject: Rooting Compounds and "no-contact" entry > >In a Horticultural Newsletter from Cornell Extension reference was made to a >clarifying letter from EPA regarding rooting compounds and "no contact" >entry into greenhouses. The letter was to Ray Pavitt of Astoria-Pacific, the >formulator of Dip 'N Gro. Does anyone have a copy of this clarification >letter. I have been asked to find out more about this for Ohio greenhouse >growers. > >Thanks for your help. > >Joanne