From MORTENSEN.GINAH@EPAMAIL.EPA.GOV Fri Mar 1 07:32:31 1996 Received: from ARTHUR.RTPTOK.EPA.GOV (arthur.rtptok.epa.gov [134.67.212.29]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id HAA23280 for ; Fri, 1 Mar 1996 07:32:28 -0800 (PST) Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with Novell_GroupWise; Fri, 01 Mar 1996 10:22:43 -0500 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Fri, 01 Mar 1996 10:04:04 -0500 From: GINAH MORTENSEN To: wps-forum@are.Berkeley.EDU Subject: Re: -Reply would like to order the ams lite. thanks ginah mortensen (913) 551-7864 From smcdonld@freenet.columbus.oh.us Fri Mar 1 08:36:28 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id IAA24612 for ; Fri, 1 Mar 1996 08:36:26 -0800 (PST) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.6.10/4.940426) id LAA15222; Fri, 1 Mar 1996 11:36:20 -0500 Received: by acme.freenet.columbus.oh.us (8.6.10) id LAA14089; Fri, 1 Mar 1996 11:36:16 -0500 Date: Fri, 1 Mar 1996 11:22:58 -0500 (EST) From: Sally McDonald Subject: Re: WPS and Sec 18 Exemptions To: wps-forum@are.Berkeley.EDU cc: "'WPS-Forum'" In-Reply-To: <960229153246_73507.555_HHB74-2@CompuServe.COM> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII In response to the questions Bob Roach posed about the Ag Use Requirements box appearing on Sec 18 Exemptions, I would offer my two cents. Due to the nature of a Sec 18 Exemption, it is possible that information in the Ag Use Requirements box, such as restricted-entry intervals, early-entry personal protective equipment, or "double" notification requirements, may be different for the Sec 18 exemption as compared to existing labeling. Some existing labels, for example, do not list the restricted-entry interval in the Ag Use box. The REIs are found instead in the use directions associated with each crop or WPS use. In such a case, the Sec 18 Exemption would have to state the REI(s) for the crops or uses that fall under the Sec 18. For another example, many existing labels do not require "double" notification. If the Sec 18 use(s) will require "double" notification, that requirement would have to appear on the Sec 18. There are many instances where the Sec 18 Ag Use Requirements would differ from those on the existing labeling. The simplest solution seems to be to place the relatively brief Ag Use Requirements box into the Sec 18 Exemption so there will be no question that the WPS requirements apply and what specific REI, early-entry PPE, and notification requirements are applicable. Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From Zax0114@aol.com Wed Mar 6 13:26:30 1996 Received: from emout08.mail.aol.com (emout08.mx.aol.com [198.81.11.23]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id NAA04657 for ; Wed, 6 Mar 1996 13:26:22 -0800 (PST) From: Zax0114@aol.com Received: by emout08.mail.aol.com (8.6.12/8.6.12) id QAA11884 for wps-forum@are.berkeley.edu; Wed, 6 Mar 1996 16:26:39 -0500 Date: Wed, 6 Mar 1996 16:26:39 -0500 Message-ID: <960306162637_239205772@emout08.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: Non-employee notification Employees and employees of contractors need to be notified when they are on or within 1/4 mile of property to be treated , during application and REI. What about unannounced visitors such as employees of the local utility company or representatives of the winery you sell your grapes to (or packing house, shipper, etc.) who is inspecting your crop? Can you post a generic notice at the entrance stating that visitors should check at a central location for pesticide application notification? What are the requirements and what are the options for growers? Zach Berkowitz Domaine Chandon zachb@napanet.net From RDSHS@aol.com Wed Mar 6 19:12:33 1996 Received: from mail06.mail.aol.com (mail06.mail.aol.com [152.163.172.108]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id TAA16007 for ; Wed, 6 Mar 1996 19:12:31 -0800 (PST) From: RDSHS@aol.com Received: by mail06.mail.aol.com (8.6.12/8.6.12) id WAA17607 for wps-forum@are.berkeley.edu; Wed, 6 Mar 1996 22:11:59 -0500 Date: Wed, 6 Mar 1996 22:11:59 -0500 Message-ID: <960306221157_343430406@mail06.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: EPA Rose Exception response? On February 16, 1996, I formally asked Mr. Donald Baumgartner of USEPA six questions regarding the Rose Exception. There has been no response since he forwarded the questions to Washington. There have been some vocal participants on the WPS-Forum of which their comments indicate they have VERY close connections/relationships with EPA D.C. insiders. It is important to find out what those contacts know about the Rose Exception and why there has been no response from USEPA regarding this important policy issue. Can anyone help? From 73507.555@compuserve.com Thu Mar 7 07:29:13 1996 Received: from arl-img-3.compuserve.com (arl-img-3.compuserve.com [198.4.7.3]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id HAA24108 for ; Thu, 7 Mar 1996 07:29:12 -0800 (PST) Received: by arl-img-3.compuserve.com (8.6.10/5.950515) id KAA02685; Thu, 7 Mar 1996 10:28:39 -0500 Date: 07 Mar 96 10:26:53 EST From: Bob Roach <73507.555@compuserve.com> To: "'WPS-Forum'" Subject: Non-employee notice Message-ID: <960307152653_73507.555_HHB73-1@CompuServe.COM> Zach, These people are not covered by the WPS. Only agricultural workers fall under the WPS scope. You do not have to give notice to the meter reader. The "generic notice" does not seem necessary to me. I did once meet with our local P.G &E. meter readers and inform them about some basic precautions. I think that people who actually enter treated fields should have some awareness of basic precautions, such as those a farm worker is to be trained in. >Employees and employees of contractors need to be notified when they are >on or within 1/4 mile of property to be treated , during application and REI. > What about unannounced visitors such as employees of the local utility >company or representatives of the winery you sell your grapes to (or packing >house, shipper, etc.) who is inspecting your crop? Can you post a generic >notice at the entrance stating that visitors should check at a central >location for pesticide application notification? What are the requirements >and what are the options for growers? And just in case you are interested, for Compuserve members only, you may enter: Matthew Lesko's $1,000 Favorite Bureaucrat Contest The contest will run from March 1 through March 15. Entrants must submit a nomination for a United States Federal Government official or employee who has somehow provided assistance to the entrant. GO LESKO for more information ********************************************************************************* *** An informed and involved local community always does a better job of environmental protection than some distant bureaucracy. Robert Roach - Carol Browner 73507.555@compuserve.com ********************************************************************************* *** From aftgoul@gatekeeper.ddp.state.me.us Thu Mar 7 07:51:46 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id HAA24529 for ; Thu, 7 Mar 1996 07:51:44 -0800 (PST) Received: from @gatekeeper.ddp.state.me.us by gatekeeper.ddp.state.me.us (8.6.5/1.37) id KAA20503; Thu, 7 Mar 1996 10:45:18 -0500 Date: Thu, 7 Mar 1996 10:45:18 -0500 Message-Id: <199603071545.KAA20503@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: Non-employee notification Zach - Unannounced visitors, utility workers, and salesmen are not your employees and therefore do not need to be notified according to the WPS. For people who are not your employees and who are entering the field (such as the winery reps.), it is probably a good idea to let them know if the area is recently treated. We have a similar situation in our state with potatoes. State agriculture inspectors rogue potatoes looking for disease. They are not the employees of the farmer. We have advised the inspectors to check the central information display at the farmstead before reporting the field. Although not required by the WPS, it may simply be a metter of common courtesy to let visitors know about recently treated areas. That's one state's opinion. Tammy L. Gould Maine Board of Pesticides Control >Employees and employees of contractors need to be notified when they are on >or within 1/4 mile of property to be treated , during application and REI. > What about unannounced visitors such as employees of the local utility >company or representatives of the winery you sell your grapes to (or packing >house, shipper, etc.) who is inspecting your crop? Can you post a generic >notice at the entrance stating that visitors should check at a central >location for pesticide application notification? What are the requirements >and what are the options for growers? > >Zach Berkowitz >Domaine Chandon >zachb@napanet.net > From BAUMGARTNER.DONALD@EPAMAIL.EPA.GOV Thu Mar 7 10:00:10 1996 Received: from ARTHUR.RTPTOK.EPA.GOV (arthur.rtptok.epa.gov [134.67.212.29]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id KAA28440 for ; Thu, 7 Mar 1996 10:00:08 -0800 (PST) Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with Novell_GroupWise; Thu, 07 Mar 1996 12:04:52 -0500 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Thu, 07 Mar 1996 11:12:43 -0500 From: DONALD BAUMGARTNER To: wps-forum@are.Berkeley.EDU Cc: KRONOPOLUS.CATHLEEN@EPAMAIL.EPA.GOV, WARD.JOHN@EPAMAIL.EPA.GOV Subject: EPA Rose Exception response? -Reply Dear Mr. Reed Smith, In reply to your post below and to reiterate that which I replied directly to you earlier (February 20), the purpose of my February post on the Rose Exception was merely to notify those with an interest in this particular Exception. I purposefully avoided a further detailed response to your inquiries because I am not in a position to address this issue any further. Any need by the Rose growers for an extension of the present Exception must originate from them and be forwarded to EPA Headquarters by way of a petition with supportive data. To my knowledge, such a petition has not been received by EPA. No further action by the Agency is required unless the rose growers re-open the issue. Perhaps, many rose growers have found that they really did not need the Exception afterall, or perhaps now after a year of implementation they are comfortably working within the confines of the Regulation. Your earlier February 16 inquiries about the Rose Exception were forwarded to EPA HQ, as will this response. Donald Baumgartner U.S. EPA Region 5 ***************************************** >>> 3/6/96, 09:11pm >>> On February 16, 1996, I formally asked Mr. Donald Baumgartner of USEPA six questions regarding the Rose Exception. There has been no response since he forwarded the questions to Washington. There have been some vocal participants on the WPS-Forum of which their comments indicate they have VERY close connections/relationships with EPA D.C. insiders. It is important to find out what those contacts know about the Rose Exception and why there has been no response from USEPA regarding this important policy issue. Can anyone help? From newman@lamar.ColoState.EDU Thu Mar 7 10:38:00 1996 Received: from lamar.ColoState.EDU (lamar.ColoState.EDU [129.82.103.75]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id KAA29680 for ; Thu, 7 Mar 1996 10:37:57 -0800 (PST) Received: from [129.82.119.155] by lamar.ColoState.EDU (AIX 4.1/UCB 5.64/4.03) id AA207784; Thu, 7 Mar 1996 11:37:13 -0700 X-Nupop-Charset: English Date: Thu, 7 Mar 1996 11:41:05 -0600 (CST) From: "Steven E. Newman" Sender: newman@lamar.ColoState.EDU Reply-To: newman@lamar.ColoState.EDU Message-Id: <42066.newman@lamar.colostate.edu> To: wps-forum@are.Berkeley.EDU, wps-forum@are.Berkeley.EDU Subject: RE: EPA Rose Exception response? In regards to progress on the Rose Exception. Roses Inc. has contacted NIOSH to conduct some studies. They are currently considering a few rose growers in the state of Colorado, and Colorado State University will most likely participate as well. My understanding is that this study will be conducted in a manner to verify the need or feasibility of continuing the exception. More as this study progresses. Steve Newman In message Wed, 6 Mar 1996 22:11:59 -0500, RDSHS@aol.com writes: > On February 16, 1996, I formally asked Mr. Donald Baumgartner of USEPA six > questions regarding the Rose Exception. There has been no response since > he forwarded the questions to Washington. > There have been some vocal participants on the WPS-Forum of which their > comments indicate they have VERY close connections/relationships with EPA > D.C. insiders. It is important to find out what those contacts know about > the Rose Exception and why there has been no response from USEPA regarding > this important policy issue. Can anyone help? > Steven E. Newman, Ph.D. Commercial Greenhouse Crops Specialist Department of Horticulture Tel: 970-491-7118 Colorado State University Fax: 970-491-7745 Fort Collins CO 80523-1173 E-mail: newman@lamar.colostate.edu From howardr@are.Berkeley.EDU Thu Mar 7 12:14:50 1996 Received: from [128.32.251.102] (gia5mac22.Berkeley.EDU [128.32.251.102]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id MAA03497 for ; Thu, 7 Mar 1996 12:14:47 -0800 (PST) Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Thu, 7 Mar 1996 12:15:10 -0800 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: J. Horton response on Non-employee notification [forwarding an attempted post that got stuck in error-checker] >>From HORTON.JANE@EPAMAIL.EPA.GOV Thu Mar 7 05:17:37 1996 >Subject: Re: Non-employee notification > You are required only to provide notification to your employees. If you >have a contract with a labor provider, then you must also provide notification >to these individuals - as long as they are engaging in agricultural >activities. >You do not meed to provide notification for other people such as: neighbors, >utility workers, delivery men, representatives of the packing/shipping >company) >etc, unless they are performing 'worker', 'handler' or 'crop advisor' >activities >as defined at the beginning of the WPS ( 40 CFR Part 170.3 DEFINITIONS). > > >Jane Horton >Region 4 EPA >404/ 347-3555 ext. 6975 From p009289b@pbfreenet.seflin.lib.fl.us Tue Mar 12 12:04:20 1996 Received: from pbfreenet.seflin.lib.fl.us (p009289b@pbfreenet.seflin.lib.fl.us [199.227.192.35]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id MAA29720 for ; Tue, 12 Mar 1996 12:04:15 -0800 (PST) Received: (from p009289b@localhost) by pbfreenet.seflin.lib.fl.us (8.6.12/8.6.12) id PAA03711; Tue, 12 Mar 1996 15:03:05 -0500 Date: Tue, 12 Mar 1996 15:03:01 -0500 (EST) From: Scott Morrison Subject: Cholinesterase monitoring To: wps-forum@are.berkeley.edu Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII I do not have a copy, but a friend of mine asked me about a proposed requirement in the Aug. 21, 1992 Federal Register to require (?) cholinesterase monitoring in those working with organophosphorus pesticides. What happened to this proposal? TIA *These opinions are my own* Standard Disclaimers: Use at Scott Morrison your own risk, consult local USSC Environmental Specialist authorities, batteries are P.O. Box 113, Bryant, FL 33439 not included, hire a few p009289b@pbfreenet.seflin.lib.fl.us expensive lawyers From ALFRENCH@mailbox.econ.ag.gov Wed Mar 13 04:51:32 1996 Received: from mailbox.econ.ag.gov (MAILBOX.econ.ag.gov [151.121.64.123]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id EAA23593 for ; Wed, 13 Mar 1996 04:51:27 -0800 (PST) Received: from ECONSMTP-Message_Server by mailbox.econ.ag.gov with Novell_GroupWise; Wed, 13 Mar 1996 07:49:59 -0500 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Wed, 13 Mar 1996 08:05:35 -0500 From: Al French To: wps-forum@are.Berkeley.EDU Subject: Cholinesterase monitoring Scott Morrison asked: > a proposed requirement in the Aug. 21, 1992 Federal Register to< >require (?) cholinesterase monitoring in those working with< >organophosphorus pesticides. What happened to this proposal? TIA< EPA discussed cholinesterase monitoring in the WPS, but did not require it. See below. Al French alfrench@usda.gov ---------------- The Agency is concerned about many of the problems of cholinesterase monitoring, including the difficulty in finding knowledgeable physicians to set up monitoring programs and qualified laboratories to perform the analyses. The comments noted that a quality control program for laboratories would be needed nationwide if a monitoring program were to be successful. EPA is not prepared to establish such a program nationwide at this time. The Agency believes that despite the practical difficulties associated with a nationwide program, the monitoring of employee exposure is a prudent occupational health practice and encourages employers wishing to operate such programs. To facilitate voluntary programs, the Agency has required that pesticides that contain cholinesterase-inhibiting compounds be identified as such in the labeling of the product. The Agency also is interested in cooperating in research or evaluations that might be done on new or existing exposure monitoring programs. The Agency is concerned, however, that even reliable blood-level cholinesterase monitoring often would not prevent pesticide poisoning incidents. Blood samples are taken at intervals--weekly, biweekly, or monthly--during the exposure season; the handler may accumulate enough exposure between samples to become ill. In addition, the delay between sampling and the evaluation of the test results is such that most handlers will receive more exposure before the test results are known. Before such a monitoring system can indicate that handlers should be removed from further exposure to cholinesterase-inhibiting pesticides because their blood cholinesterase levels are dangerously low, the handlers may have received enough additional exposure to precipitate acute poisoning. EPA is troubled by the reactive nature of available cholinesterase monitoring methods. The Agency would prefer to explore methods of monitoring exposures to cholinesterase-inhibiting pesticides, and perhaps to other pesticides, which are more likely to be preventive. One promising approach involves immunoassay-based detection. Immunoassay techniques could provide rapid, simple, and cost-effective monitoring methods for exposure monitoring systems under field conditions. It is expected that inexpensive kits can be developed that will yield quantitative results in less than 30 minutes, thus enabling more frequent monitoring and rapid response if unacceptable exposure is indicated. This technology could provide an effective means of signaling to the pesticide handler when exposure is unacceptably high. [Fed. Reg. Aug. 21, 1992, Page 38131] From 73507.555@compuserve.com Wed Mar 13 21:59:50 1996 Received: from arl-img-4.compuserve.com (arl-img-4.compuserve.com [198.4.7.4]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id VAA21366 for ; Wed, 13 Mar 1996 21:59:48 -0800 (PST) Received: by arl-img-4.compuserve.com (8.6.10/5.950515) id AAA06854; Thu, 14 Mar 1996 00:59:16 -0500 Date: 14 Mar 96 00:57:34 EST From: Bob Roach <73507.555@compuserve.com> To: "'WPS-Forum'" Subject: Cholinesterase Monitoring Message-ID: <960314055734_73507.555_HHB48-6@CompuServe.COM> Re: Cholinesterase Monitoring Obviously this requirement has never come to pass. It works quite well in California. Any handler regularly using cholinesterase inhibiting pesticides used in the production of an agricultural commodity must be under medical supervision. This allows employers to detect exposure and take corrective actions early. Medical supervision and closed system requirements are two California ideas that were not folded into the federal WPS. I also would be interested to know what became of any federal proposal to require medical supervision for pesticide handlers. >I do not have a copy, but a friend of mine asked me about a proposed >requirement in the Aug. 21, 1992 Federal Register to require (?) >cholinesterase monitoring in those working with organophosphorus >pesticides. > >What happened to this proposal? TIA P.S. - The U.S. EPA is planning to have the California WPS meetings in Fresno and Salinas on July 23 and 25. ******************************************************************************** An informed and involved local community always does a better job of environmental protection than some distant bureaucracy. Robert Roach - Carol Browner 73507.555@compuserve.com ******************************************************************************** From johnb@agr.state.vt.us Mon Mar 18 06:52:38 1996 Received: from vtagr02.agr.state.vt.us (vtagr02.agr.state.vt.us [159.105.50.2]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id GAA02217 for ; Mon, 18 Mar 1996 06:52:35 -0800 (PST) From: John Berino Received: from smtpgate id: 314D7907.B0E (WordPerfect SMTP Gateway V3.1a 04/27/92) Received: from vtagr02 (WP Connection) MMDF-Warning: Parse error in original version of preceding line at vtagr02.agr.state.vt.us To: wps-forum@are.berkeley.edu MMDF-Warning: Parse error in original version of preceding line at vtagr02.agr.state.vt.us Subject: Filtration and enclosed cabs Date: Mon Mar 18 09:53:59 1996 Message-ID: <9603180954.aa22874@vtagr02.agr.state.vt.us> I have an interesting question for the forum. I received a call from a grower that is using an Italian-made tractor with enclosed cab. The cab is equipped with an air filtration device designed to remove organic vapors (organic vapor-removing cartridges). The spec sheets that the grower received with the cartridges give removal efficiencies, time-use limitations for the filters, etc. However, since these cartridges were manufactured in Italy for this tractor, they apparently do not carry the MSHA/NIOSH "tc" approval rating required for respirator cartridges in the U.S. The grower is concerned about liability. I am wondering if it is a violation of OSHA/FIFRA law by using cartridges of this sort that do not carry the MSHA/NIOSH approval rating? If these cartridges do need the U.S. approval rating, am I to tell growers with foreign-made tractors that their filtration systems cannot be used with foreign-made cartridges? Would inspectors then need to examine all filtration devices? I welcome any comments or answers to these questions. Many thanks. John Berino WPS Coordinator/Toxicologist Vermont Department of Agriculture 116 State St. Montpelier, VT 05620-2901 (802) 828-2431 johnb@agr.state.vt.us From pandre@mail.state.mo.us Mon Mar 18 09:44:05 1996 Received: from services (services.state.mo.us [168.166.0.67]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id JAA06675 for ; Mon, 18 Mar 1996 09:43:49 -0800 (PST) Received: from services by services (SMI-8.6/SMI-SVR4) id LAA03829; Mon, 18 Mar 1996 11:46:05 -0600 Date: Mon, 18 Mar 1996 11:46:02 -0600 (CST) From: Paul Andre X-Sender: pandre@services To: wps-forum@are.Berkeley.EDU cc: wps-forum@are.Berkeley.EDU Subject: Re: Filtration and enclosed cabs In-Reply-To: <9603180954.aa22874@vtagr02.agr.state.vt.us> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII In response to John Berino's question. You raise some good issues. I believe the label statements for respirators specifically require the MSHA/NIOSH specifications and do not allow use of "equivalent" filters. This would seem to rule out using other filters. Are there MSHA/NIOSH filters available to fit these enclosed cabs? Has the manufacturer been made aware of the situation and be willing to apply for MSHA/NIOSH approval? Good Luck, Paul From ROYR@cdprsmtp.cdpr.ca.gov Mon Mar 18 11:57:26 1996 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id LAA12779 for ; Mon, 18 Mar 1996 11:57:22 -0800 (PST) From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Mon, 18 Mar 1996 11:59:01 -0800 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Mon, 18 Mar 1996 11:57:33 -0800 To: johnb@agr.state.vt.us, wps-forum@are.Berkeley.EDU Subject: Filtration and enclosed cabs -Reply For what it is worth: Part 170.240 (d) (5) (ii) & (iii) speciically addresses the circumstance described. Has the manufacturer or a governmental agency (or is it willing?) certified that it provides equivalent protection to the MSHA/NIOSH approved respiratory protection? It does not appear that a grower can do this on their own. For the record, When CA first entered the area of filtered air enclosed cabs we contacted MSMA and NIOSH and they told us that they did not certify filters for this purpose. Only for personal protective devices. A cab was not considered to be a "big respirator". The area inside the cab was considered to be the work environment. The ASAE is working on a national standard for enclosed cabs suitable for respiratory protection. I believe they may already have a standard for "plain" enclosed cabs. ROYR From bth0jds@bth20.med.navy.mil Mon Mar 18 12:15:11 1996 Received: from bth20.med.navy.mil ([131.158.80.20]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id MAA13446 for ; Mon, 18 Mar 1996 12:15:08 -0800 (PST) Received: by bth20.med.navy.mil id AA08593 (5.65c/IDA-1.4.4 for wps-forum@are.berkeley.edu); Mon, 18 Mar 1996 15:04:13 -0500 Date: Mon, 18 Mar 1996 15:04:13 -0500 From: "Jolane D. Souris" Message-Id: <199603182004.AA08593@bth20.med.navy.mil> To: wps-forum@are.berkeley.edu Subject: unsubscribe I will be on maternity for several months. How do I unenroll from this forum, since my mail will be unacessable to me??? JoLane Souris HazMat Coord. National Naval Med. Center 301-295-6436 From LTrue@aol.com Mon Mar 18 12:57:00 1996 Received: from mail06.mail.aol.com (mail06.mail.aol.com [152.163.172.108]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id MAA14779 for ; Mon, 18 Mar 1996 12:56:57 -0800 (PST) From: LTrue@aol.com Received: by mail06.mail.aol.com (8.6.12/8.6.12) id PAA24443 for wps-forum@are.berkeley.edu; Mon, 18 Mar 1996 15:56:26 -0500 Date: Mon, 18 Mar 1996 15:56:26 -0500 Message-ID: <960318155626_249067230@mail06> To: wps-forum@are.berkeley.edu Subject: Re: Filtration and enclosed cabs See pages 86 and 87 of EPA's WPS "How to Comply" manual for the full terms of the WPS PPE exception for enclosed cabs. In crafting the exception, EPA was attempting to encourage wider use of enclosed cabs. NIOSH/MSHA ratings are not required for the cabs, but a written statement is required from either the manufacturer or a government agency declaring that the respiratory protection afforded by the cab is equivalent to the respiratory protection specified on the pesticide labeling. In short, there is no bar in WPS to use of foreign cabs under the exception. Note, however, that some states may require more than WPS. There are also several Interpretive Guidance Q/A's on this subject. Lou True From MEEDS_C@wpb1.dep.state.fl.us Tue Mar 19 09:55:08 1996 Received: from epic66.dep.state.fl.us (epic66.dep.state.fl.us [199.73.128.6]) by are.Berkeley.EDU (8.7.4/8.7.3) with ESMTP id JAA09893; Tue, 19 Mar 1996 09:54:58 -0800 (PST) Received: from mr.dep.state.fl.us by EPIC66.DEP.STATE.FL.US (PMDF V5.0-4 #7204) id <01I2IUX27HHC001DEL@EPIC66.DEP.STATE.FL.US>; Tue, 19 Mar 1996 12:54:53 -0500 (EST) Received: with PMDF-MR; Tue, 19 Mar 1996 12:54:44 -0500 (EST) MR-Received: by mta WPB1; Relayed; Tue, 19 Mar 1996 12:54:44 -0500 MR-Received: by mta EPIC66; Relayed; Tue, 19 Mar 1996 12:54:44 -0500 Alternate-recipient: prohibited Date: Tue, 19 Mar 1996 12:36:11 -0500 (EST) From: Carol Meeds WPB 407-681-6666 Subject: arsenic in So. Fla. golfcourses? In-reply-to: To: owner-wps-forum Cc: wps-forum Message-id: MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Tue, 19 Mar 1996 12:54:00 -0500 (EST) Importance: normal Priority: normal UA-content-id: E52ZWFIIFVXC X400-MTS-identifier: [;44452191306991/82379@WPB1] A1-type: MAIL Hop-count: 2 Please help again :-) by forwarding this to any appropriate lists or persons. The Florida environmental regulatory agency where I work has developed soil clean up criteria. This criteria was used initally to answer end use questions about soil or soil like debris recovered during the recycling of hurricane Andrew debris, but now is receiving a broader application. The soil clean up criteria sets the allowable level for Arsenic at 0.8 mg/Kg for residential end uses and 3.7 mg/Kg for Industrial end uses. Soils on most of the golf courses in South Florida have elevated Arsenic levels. (Palm Beach County in South Florida has more golf courses than any other County in the Nation.) It appears that the golf courses in South Florida reach that level by using pesticides only in an approved manner. Internally, in this District Office, we are just starting to look at what actions might be taken to address this situation... clean-up? prevention? education? rule revision? Your comments and discussion are appreciated. Carol Meeds (407) 681-6666 From 73507.555@compuserve.com Tue Mar 19 23:11:58 1996 Received: from dub-img-4.compuserve.com (dub-img-4.compuserve.com [198.4.9.4]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id XAA02964 for ; Tue, 19 Mar 1996 23:11:54 -0800 (PST) Received: by dub-img-4.compuserve.com (8.6.10/5.950515) id CAA24861; Wed, 20 Mar 1996 02:11:22 -0500 Date: 20 Mar 96 02:09:24 EST From: Bob Roach <73507.555@compuserve.com> To: "'WPS-Forum'" Subject: Enclosed Cabs/Respiratory Protection Message-ID: <960320070924_73507.555_HHB69-2@CompuServe.COM> Is any one aware of any manufacturer or government agency that has put such a thing in writing? Would they have to address pesticides as a group or specific classes or individual materials? It sounds like a big risk to me. The lawyers would probably advise against it in the absence of any standards to follow. I understand that the TC-21 rating is going to be abandoned in favor of a new rating, TC-84. Does anybody know anything about this? How will this affect pesticide labeling? This is to happen over the next 2 years, I believe. Bob Roach ----------------------------------------------------------- Lou True wrote: NIOSH/MSHA ratings are not required for the cabs, but a written statement is required from either the manufacturer or a government agency declaring that the respiratory protection afforded by the cab is equivalent to the respiratory protection specified on the pesticide labeling. From stew@gnv.ifas.ufl.edu Fri Mar 22 11:13:10 1996 Received: from gnv.ifas.ufl.edu (gnv.ifas.ufl.edu [128.227.242.11]) by are.Berkeley.EDU (8.7.4/8.7.3) with ESMTP id LAA21316 for ; Fri, 22 Mar 1996 11:13:05 -0800 (PST) Received: from ppp-04-nerdc-ts5.nerdc.ufl.edu by gnv.ifas.ufl.edu (PMDF V4.3-10 #7627) id <01I2N4HD4APC8WYO3V@gnv.ifas.ufl.edu>; Fri, 22 Mar 1996 14:11:43 -0500 (EST) Date: Fri, 22 Mar 1996 14:11:43 -0500 (EST) Date-warning: Date header was inserted by gnv.ifas.ufl.edu From: stew@gnv.ifas.ufl.edu (Stewart Swanson (Vegetable Crops)) Subject: Re: arsenic in So. Fla. golfcourses? X-Sender: stew@gnv.ifas.ufl.edu To: wps-forum@are.Berkeley.EDU Message-id: <01I2N4HDVW4Y8WYO3V@gnv.ifas.ufl.edu> MIME-version: 1.0 X-Mailer: Windows Eudora Version 1.4.4 Content-type: text/plain; charset="us-ascii" Content-transfer-encoding: 7BIT Dear Carol, I was interested in finding out where the information came from on high arsenic levels in South Florida Golf Courses. Could you let me know the source, or study? Thanks, Stewart Swanson University of Florida Collier County From MEEDS_C@wpb1.dep.state.fl.us Fri Mar 22 11:30:57 1996 Received: from epic66.dep.state.fl.us (epic66.dep.state.fl.us [199.73.128.6]) by are.Berkeley.EDU (8.7.4/8.7.3) with ESMTP id LAA22038; Fri, 22 Mar 1996 11:30:54 -0800 (PST) Received: from mr.dep.state.fl.us by EPIC66.DEP.STATE.FL.US (PMDF V5.0-4 #7204) id <01I2N54T3BA8001TZW@EPIC66.DEP.STATE.FL.US>; Fri, 22 Mar 1996 14:30:36 -0500 (EST) Received: with PMDF-MR; Fri, 22 Mar 1996 14:30:27 -0500 (EST) MR-Received: by mta WPB1; Relayed; Fri, 22 Mar 1996 14:30:27 -0500 MR-Received: by mta EPIC66; Relayed; Fri, 22 Mar 1996 14:30:29 -0500 Alternate-recipient: prohibited Date: Fri, 22 Mar 1996 14:30:25 -0500 (EST) From: Carol Meeds WPB 407-681-6666 Subject: Re: arsenic in So. Fla. golfcourses? To: owner-wps-forum , wps-forum Message-id: MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Fri, 22 Mar 1996 14:30:27 -0500 (EST) Importance: normal Priority: normal Sensitivity: Company-Confidential UA-content-id: E79IFK33Y8S X400-MTS-identifier: [;72034122306991/82996@WPB1] A1-type: MAIL Hop-count: 2 Dear Carol, I was interested in finding out where the information came from on high arsenic levels in South Florida Golf Courses. Could you let me know the source, or study? Thanks, Stewart Swanson University of Florida Collier County Answer: So far it is preliminary information from several site investigations that the Waste Clean-up section has investigated. This is from the Waste Clean-up section's monthly reprot for February. " Many issues regarding the application of the "Soil Cleanup Goals for Florida" memorandum remain very controversial. As you know, several golf courses that exhibit groundwater contamination above MCL's and arsenic levels that exceed cleanup goals will need resolution (Frenchman's Creek, Ocean Estates, Arvida Pompano, Sandalfoot Cove, City of West Palm Beach, among others)". From afgfish@state.me.us Mon Mar 25 05:26:19 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id FAA10329 for ; Mon, 25 Mar 1996 05:26:17 -0800 (PST) Received: from smtp.state.me.us by gatekeeper.ddp.state.me.us (8.6.5/1.37) id OAA18578; Mon, 25 Mar 1996 14:27:13 -0500 Date: Mon, 25 Mar 1996 14:27:13 -0500 Message-Id: <199603251927.OAA18578@gatekeeper.ddp.state.me.us> X-Sender: afgfish@smtp.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: afgfish@state.me.us (Gary Fish) Subject: Re: arsenic in So. Fla. golfcourses? Arsenic is a naturally occurring element in groundwater. In Maine there are many areas where no history of arsenical use exists, but the groundwater is contaminated with natural arsenic from the bedrock. This could also be the case in FLA. > >Dear Carol, > > I was interested in finding out where the information came >from on >high arsenic levels in South Florida >Golf Courses. Could you let me know the source, or study? > >Thanks, >Stewart Swanson >University of Florida >Collier County > >Answer: > >So far it is preliminary information from several site investigations >that the Waste Clean-up section has investigated. This is from the >Waste Clean-up section's monthly reprot for February. > >" Many issues regarding the application of the "Soil Cleanup Goals >for Florida" memorandum remain very controversial. As you know, >several golf courses that exhibit groundwater contamination above >MCL's and arsenic levels that exceed cleanup goals will need >resolution (Frenchman's Creek, Ocean Estates, Arvida Pompano, >Sandalfoot Cove, City of West Palm Beach, among others)". > > Gary Fish Maine Board of Pesticides Control Station 28 Augusta, ME 04333 207-287-2731 gary.fish@state.me.us From shenkm@ava.BCC.ORST.EDU Mon Mar 25 07:12:44 1996 Received: from BCC.ORST.EDU (root@ava.BCC.ORST.EDU [128.193.86.4]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id HAA11349 for ; Mon, 25 Mar 1996 07:12:42 -0800 (PST) Received: from smo-1000-E by BCC.ORST.EDU (4.1/SMI-4.1) id AA01820; Mon, 25 Mar 96 07:13:15 PST Date: Mon, 25 Mar 96 07:13:15 PST Message-Id: <9603251513.AA01820@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) Subject: Re: arsenic in So. Fla. golfcourses? Gary Fish mentioned the problem of naturally occuring arsenic in groundwater in Maine. A very similar problem exists in various areas in Western Oregon. As Gary stated, these are problems associated with natural phenomenon (weathering of parent rock) not with pesticide use. > > >> >>Dear Carol, >> >> I was interested in finding out where the information came >>from on >>high arsenic levels in South Florida >>Golf Courses. Could you let me know the source, or study? >> >>Thanks, >>Stewart Swanson >>University of Florida >>Collier County >> >>Answer: >> >>So far it is preliminary information from several site investigations >>that the Waste Clean-up section has investigated. This is from the >>Waste Clean-up section's monthly reprot for February. >> >>" Many issues regarding the application of the "Soil Cleanup Goals >>for Florida" memorandum remain very controversial. As you know, >>several golf courses that exhibit groundwater contamination above >>MCL's and arsenic levels that exceed cleanup goals will need >>resolution (Frenchman's Creek, Ocean Estates, Arvida Pompano, >>Sandalfoot Cove, City of West Palm Beach, among others)". >> >> >Gary Fish >Maine Board of Pesticides Control >Station 28 >Augusta, ME 04333 >207-287-2731 > >gary.fish@state.me.us > > > Myron Shenk Integrated Plant Protection Center Oregon State University Cordley Hall 2040 Corvallis OR 97331-2915 Tel: (541) 737-6274 FAX: (541) 737-3080 email: shenkm@bcc.orst.edu From 73507.555@compuserve.com Wed Mar 27 06:33:22 1996 Received: from arl-img-5.compuserve.com (arl-img-5.compuserve.com [198.4.7.5]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id GAA08114 for ; Wed, 27 Mar 1996 06:33:20 -0800 (PST) Received: by arl-img-5.compuserve.com (8.6.10/5.950515) id JAA09543; Wed, 27 Mar 1996 09:32:49 -0500 Date: 27 Mar 96 09:30:32 EST From: Bob Roach <73507.555@compuserve.com> To: "'WPS-Forum'" Subject: Training Cards Required? Message-ID: <960327143032_73507.555_HHB34-2@CompuServe.COM> To All: A labor contractor returning to Salinas from Arizona tells me that in Arizona the enforcement officials are requiring that workers have a WPS training verification card in their possession. Furthermore, this individual was trained as a trainer in California. He says that Arizona does not recognize training cards he issues under his agreement with CDPR. The inspector has a list of Arizona numbers and the worker's card numbers must match this list. Can any one verify if these statements are true? Bob Roach From cefresno@ucdavis.edu Wed Mar 27 13:33:53 1996 Received: from guilder.ucdavis.edu (root@guilder.ucdavis.edu [128.120.8.181]) by are.Berkeley.EDU (8.7.4/8.7.3) with ESMTP id NAA18781 for ; Wed, 27 Mar 1996 13:33:51 -0800 (PST) From: cefresno@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by guilder.ucdavis.edu (8.7.5/UCD3.5.1) id NAA22332; Wed, 27 Mar 1996 13:33:42 -0800 (PST) Date: Wed, 27 Mar 1996 13:33:42 -0800 (PST) Message-Id: <199603272133.NAA22332@guilder.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: news from fresno Cc: cefresno@ucdavis.edu >From Steve Sutter, UC Area Farm Advisor ... A WPS fieldworker train-the-trainer workshop in Spanish is available May 7, 1996, 8 a.m. to Noon, at the Cooperative Extension Office, 680 N. Campus Dr., Hanford, CA. ... To preregister call Jennifer Weber, UCIPM Instructor, on 916-752-5930. ... "Fresno Clear." From pat.marer@wserver.ipm.ucdavis.edu Wed Mar 27 15:21:06 1996 Received: from axp.ipm.ucdavis.edu (axp.ipm.ucdavis.edu [128.120.83.41]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id PAA23362 for ; Wed, 27 Mar 1996 15:21:04 -0800 (PST) Received: by axp.ipm.ucdavis.edu; id AA02163; Wed, 27 Mar 1996 15:26:30 -0800 Message-Id: Date: 27 Mar 1996 15:08:32 U From: "Pat Marer" Subject: RE: Arizona Verification Ca To: "Forum WPS " X-Mailer: Mail*Link SMTP-QM 3.0.2 3/27/96 2:47 PM RE: Arizona Verification Cards I have looked into Bob Roach's question about WPS Verification Cards that have been issued in California (or other states) being accepted in Arizona. I contacted the U of A Pesticide Coordinators Office and they contacted the Arizona Department of Agriculture. The information given to Bob Roach was true! Arizona Department of Agriculture will not accept the blue WPS Worker Verification Cards issued by trainers who have not been qualified to train in Arizona. My suggestion for people who have workers who work in California and Arizona is to get qualified as an Arizona trainer, request blue cards from the Arizona Department of Agriculture, and issue these to their workers. These cards are valid in California. For the past two years we have been telling instructors who have participated in our train-the-trainer programs that their training of fieldworkers in California, as California-qualified instructors, would be accepted in Arizona. Now I discover we are wrong. I will contact these 2800 trainers by mail and update them on this. Patrick J. Marer Pesticide Training Coordinator University of California Davis, CA 95616 (916)752-5273 From howardr@are.Berkeley.EDU Wed Mar 27 17:18:16 1996 Received: from [128.32.251.101] (gia5mac21.Berkeley.EDU [128.32.251.101]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id RAA26873 for ; Wed, 27 Mar 1996 17:18:12 -0800 (PST) Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Wed, 27 Mar 1996 17:18:40 -0800 To: wps-forum@are.berkeley.edu From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: RE: training verification in Arizona >Arizona Department of Agriculture will not accept the blue WPS Worker >Verification Cards issued by trainers who have not been qualified to train in >Arizona. Is this because state regs in Arizona specify higher training standards than the WPS? If not, it appears to contradict WPS section 170.130 (d), Verification of Training: "Except as provided in paragraph (d)(2) of this section, if the agricultural employer assures that a worker possesses an EPA-approved Worker Protection Standard worker training certificate, then the requirements of paragraph (a) of this section will have been met." So if a trainer gives out blue cards, even if under his (EPA-authorized) agreement with California DPR, they're to be honored throughout the nation. It would be a different story if California was issuing its own, non-EPA, cards, but that's not the case. Would someone from Arizona describe (or do you know, Pat?) the state training requirements that exceed those of the WPS? --Howard Rosenberg From smcdonld@freenet.columbus.oh.us Thu Mar 28 08:23:05 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.4/8.7.3) with SMTP id IAA10604 for ; Thu, 28 Mar 1996 08:23:03 -0800 (PST) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.6.10/4.940426) id LAA24451; Thu, 28 Mar 1996 11:22:08 -0500 Received: by acme.freenet.columbus.oh.us (8.6.10) id LAA07922; Thu, 28 Mar 1996 11:20:03 -0500 Date: Thu, 28 Mar 1996 11:14:47 -0500 (EST) From: Sally McDonald Sender: Sally McDonald Reply-To: Sally McDonald Subject: RE: training verification in Arizona 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 Howard's information is correct. Unless Arizona has more stringent state regulations and is requiring worker training under those regulations rather than under the federal WPS reg, the WPS training verification cards issued in California or elsewhere must be accepted in Arizona. (See How-To-Comply page 27.) In fact, the training verification section of the WPS was established at the urging of USDA to prevent just such situations of unnecessary and expensive duplicative training. Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From cefresno@ucdavis.edu Thu Mar 28 09:41:25 1996 Received: from guilder.ucdavis.edu (root@guilder.ucdavis.edu [128.120.8.181]) by are.Berkeley.EDU (8.7.4/8.7.3) with ESMTP id JAA12987 for ; Thu, 28 Mar 1996 09:41:24 -0800 (PST) From: cefresno@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by guilder.ucdavis.edu (8.7.5/UCD3.5.1) id JAA17873; Thu, 28 Mar 1996 09:41:17 -0800 (PST) Date: Thu, 28 Mar 1996 09:41:17 -0800 (PST) Message-Id: <199603281741.JAA17873@guilder.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: new from fresno Cc: cefresno@ucdavis.edu >From Steve Sutter, UC Area Farm Advisor ... A WPS fieldworker train-the-trainer workshop in English is available April 12, 1996, 8:30 a.m. to Noon, at the Cooperative Extension Office, 1720 S. Maple Ave., Fresno, CA. ... To preregister call (209) 456-7285. ... "Fresno Clear."