From charlie@hpirs.stjohn.hawaii.edu Thu May 2 11:24:47 1996 Received: from relay1.Hawaii.Edu (root@relay1.Hawaii.Edu [128.171.3.53]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id LAA27152 for ; Thu, 2 May 1996 11:24:44 -0700 (PDT) Received: from uhunix4.its.Hawaii.Edu ([128.171.44.54]) by relay1.Hawaii.Edu with SMTP id <11562(7)>; Thu, 2 May 1996 08:24:30 -1000 Received: from hpirs.stjohn.hawaii.edu ([128.171.243.7]) by uhunix4.its.Hawaii.Edu with SMTP id <105789>; Thu, 2 May 1996 08:24:06 -1000 Received: from HPIRS/MAILQUEUE by hpirs.stjohn.hawaii.edu (Mercury 1.21); 2 May 96 08:20:37 -1000 Received: from MAILQUEUE by HPIRS (Mercury 1.21); 2 May 96 08:20:30 -1000 Received: from [128.171.243.35] by hpirs.stjohn.hawaii.edu (Mercury 1.21); 2 May 96 08:20:22 -1000 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: WPS-Forum@are.berkeley.edu From: charlie@hpirs.stjohn.hawaii.edu Cc: ccrocker@hawaii.edu Date: Thu, 2 May 1996 08:24:05 -1000 Have there been any changes to the list of active ingredients in EPA's communication to pesticide registrants, PR Notice 93-7? It's date stamped 4-20-93. I'm referring to the back section of the Notice titled "SUPPLEMENT THREE-A". Charles Nagamine Environmental Biochemistry Dept. College of Tropical Agriculture & Human Resources Univeristy of Hawaii @ Manoa From 73507.555@CompuServe.COM Thu May 2 19:17:12 1996 Received: from dub-img-4.compuserve.com (dub-img-4.compuserve.com [198.4.9.4]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id TAA13928 for ; Thu, 2 May 1996 19:17:10 -0700 (PDT) Received: by dub-img-4.compuserve.com (8.6.10/5.950515) id WAA18452; Thu, 2 May 1996 22:15:48 -0400 Date: 02 May 96 22:12:46 EDT From: Bob Roach <73507.555@CompuServe.COM> To: "'WPS-Forum'" Cc: "'Monterag'" Subject: Hole in the WPS? Message-ID: <960503021246_73507.555_HHB2-3@CompuServe.COM> Regarding mushroom production: I was speaking to a California mushroom grower yesterday and he told me about an interesting idea of some of his counterparts in the East. They say they will avoid all of these WPS complications by using a chlorine product that is not registered and so has no WPS labeling to follow. He told them, "You can't do that, it's illegal!" They asked, "Why can't we?" He asked me to locate the federal law that said it is illegal to use unregistered pesticides. I thought that would be easy. I am not sure if the state in question has any law or regulation that would prevent this practice. It is illegal in California. I was surprised to find nothing in FIFRA that prevents this practice. I asked about and some reliable sources told me that FIFRA gives the U.S. EPA the authority to enact regulations to make the use of unregistered products illegal but they have not proposed any such regulation. It is illegal to sell unregistered pesticides but not to use them. To use a registered pesticide for a purpose not intended would be illegal but if it is not registered there is no federal law to stop anyone from doing so. Can any one confirm this or produce a federal regulation that prohibits the use of unregistered pesticides? Another question he had was: what is the treated area when mushroom beds are drenched? I am of the opinion that the treated area is the bed and not the room. Does any one disagree? I believe this would also hold true in a greenhouse and a mushroom house is now legally defined as a greenhouse, albeit one that is without green or light. Bob Roach 73507.555@Compuserve.com From smcdonld@freenet.columbus.oh.us Fri May 3 04:29:28 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id EAA19990 for ; Fri, 3 May 1996 04:29:26 -0700 (PDT) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.7.5/5.960408) id LAA03907; Fri, 3 May 1996 11:29:23 GMT Received: by acme.freenet.columbus.oh.us (8.6.10) id HAA24769; Fri, 3 May 1996 07:29:22 -0400 Date: Fri, 3 May 1996 07:14:50 -0400 (EDT) From: Sally McDonald Subject: Re: Hole in the WPS? To: wps-forum@are.Berkeley.EDU In-Reply-To: <960503021246_73507.555_HHB2-3@CompuServe.COM> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On 2 May 1996, Bob Roach wrote: > Regarding mushroom production: > > What is the treated area when mushroom beds are > drenched? I am of the opinion that the treated area is the bed. . . Sally replies: The treated area is the "bed" or the area that receives the drench provided: 1) The pesticide labeling does not require the applicator to wear a respirator, and 2) The pesticide drench is applied from a height of 12 inches or less from the planting medium as a coarse spray using a spray pressure of 40 psi or less per square inch. (This presumes the pesticide is neither a fumigant nor is applied as a mist, fog, or aerosol.) All workers and other persons who are not involved with the application would be allowed to remain in the mushroom house during the application, provided they are not in the treated area. The REI applies to the treated (drenched) area. If the application is applied from a height of greater than 12 inches from the planting medium or as a fine spray or using a spray pressure greater than 40 psi, the treated area is still the drenched area. However, while the application is taking place, all workers and other persons who are not involved with the application must be kept out of the treated area plus 25 feet in all directions within the entire enclosed area. The REI, however, would applied solely to the treated (drenched) area. If the pesticide requires the applicator to wear a respirator, workers and other persons who are not involved with the application are prohibited in the entire enclosed area (presumably the mushroom house, although sub-enclosures are allowed) during the entire application and until one of the WPS ventilation criteria have been met. Once one of the ventilation criteria have been met, workers may enter and work in untreated areas of the mushroom house. The REI applies solely to the treated (drenched) area. Hope this helps. Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From howardr@are.Berkeley.EDU Fri May 3 08:42:17 1996 Received: from [204.32.168.134] (ala-ca12-14.ix.netcom.com [199.35.209.206]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id IAA22636 for ; Fri, 3 May 1996 08:42:11 -0700 (PDT) Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Fri, 3 May 1996 08:43:42 -0700 To: wps-forum@are.berkeley.edu From: howardr@are.Berkeley.EDU (Howard Rosenberg) Subject: single notification okay for methyl parathion Forwarding from today's Federal Register . . . [Federal Register: May 3, 1996 (Volume 61, Number 87)] [Proposed Rules] [Page 19889] 40 CFR Part 170 [OPP-250101B; FRL-5366-2] Exceptions to Worker Protection Standard Early Entry Restrictions; Limited Contact Activities; Correction AGENCY: Environmental Protection Agency (EPA). ACTION: Correction. SUMMARY: EPA issued a document in the Federal Register that proposed a rule change allowing early entry into pesticide-treated areas. In that proposal, EPA indicated that methyl parathion requires both oral and written notification (``double notification'') of agricultural workers when it is applied. Methyl parathion was mentioned incorrectly, as the Agency had previously determined that its acute dermal toxicity is Toxicity Category II, which does not require double notification. Moreover, a study of methyl parathion's potential for acute dermal irritation demonstrated that it is Toxicity Category IV and that it is not a skin sensitizer. FOR FURTHER INFORMATION CONTACT: Joshua First, Office of Pesticide Programs (7506C), Environmental Protection Agency, 401 M St., SW., Washington, DC 20460. Office location, telephone number, and e-mail address: 1921 Jefferson Davis Highway, Crystal Mall #2, Rm. 1121, Arlington, VA, 703-305-7437, e-mail: first.joshua.@epamail.epa.gov. SUPPLEMENTARY INFORMATION: In the Federal Register of January 11, 1995 (60 FR 2842) (FRL-4930-4), EPA issued a proposed rule to change allowing early entry into pesticide-treated areas under certain conditions (the proposal was subsequently finalized on May 3, 1995 (60 FR 21955) (FRL-4950-4). In the January 11th proposal, EPA described some pesticides whose labeling requires ``double notification'' when those pesticides are applied. The ``double notification'' requirement is set by the Worker Protection Standard (40 CFR part 170). EPA is hereby stating that its previous indication that methyl parathion requires ``double notification'' was incorrect. Methyl parathion does not require ``double notification.'' Lists of Subjects Environmental protection, Administrative practice and procedure, Labeling, Occupational safety and health, Pesticides and pests. Dated: April 26, 1996. Daniel M. Barolo, Director, Office of Pesticide Programs. [FR Doc. 96-11074 Filed 5-2-96; 8:45 am] BILLING CODE 6560-50-F From gallen@ICON.IMOK.UFL.EDU Tue May 7 08:14:20 1996 Received: from icon.imok.ufl.edu (icon.imok.ufl.edu [204.199.164.11]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id IAA05296 for ; Tue, 7 May 1996 08:14:17 -0700 (PDT) Received: from 204.199.164.12 by ICON.IMOK.UFL.EDU (PMDF V4.3-10 #7627) id <01I4F7NCCI68000B3L@ICON.IMOK.UFL.EDU>; Tue, 07 May 1996 11:13:30 -0500 (EST) Date: Tue, 07 May 1996 11:13:30 -0500 (EST) Date-warning: Date header was inserted by ICON.IMOK.UFL.EDU From: gallen@ICON.IMOK.UFL.EDU (Ginger Allen) Subject: Costs/Benefits X-Sender: gallen@icon.imok.ufl.edu To: wps-forum@are.berkeley.edu Message-id: <01I4F7NCK08I000B3L@ICON.IMOK.UFL.EDU> MIME-version: 1.0 X-Mailer: Content-type: text/plain; charset="us-ascii" Content-transfer-encoding: 7BIT Hello, I am new to this BBs, my county extension agent suggested I join. I am a research assistant in the Economics Department, University of Florida, IFAS Research and Education Center, Immokalee FL. My first project was researching the WPS. I found alot of information in the Berkeley archives. Since the WPS has now been instated for a year we will begin to determine the costs and benefits for farmers, nurserymen, growers etc. Mainly I will be looking at establisments in SW Florida but if anyone has a case study of their own on how much it cost to implement and maintain their WPS rules, signs, decontamination sites, training, etc please reply.(94 training, administration, labor budget vs 95) Also have you seen any benefits? Reduced sicknesses, accidents, etc. I will be looking into other regulations as well and how they interconnect, overlap, and affect growers. From BAUMGARTNER.DONALD@EPAMAIL.EPA.GOV Tue May 7 14:45:27 1996 Received: from merlin.rtpnc.epa.gov (merlin.rtpnc.epa.gov [134.67.208.148]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id OAA21506 for ; Tue, 7 May 1996 14:45:23 -0700 (PDT) Received: from ARTHUR.RTPTOK.EPA.GOV by merlin.rtpnc.epa.gov (8.6.9/1.34) id RAA09485; Tue, 7 May 1996 17:44:30 -0400 Received: from RTPMAINHUB-Message_Server by ARTHUR.RTPTOK.EPA.GOV with Novell_GroupWise; Tue, 07 May 1996 17:44:09 -0400 Message-Id: X-Mailer: Novell GroupWise 4.1 Date: Tue, 07 May 1996 17:49:34 -0400 From: DONALD BAUMGARTNER To: wps-forum@are.berkeley.edu Subject: WPS Rose Exception Follow-up Last February, I initiated discussion on this Forum regarding the expiration of the WPS Rose Exception. As you are aware, the current Exception expires June 10, 1996. Last March, Mr. Reed Smith posed several questions pertinent to the expiration of this particular Exception, and at that time these questions were forwarded to U.S. EPA Headquarters (HQ) for a reply. I have been now asked by the Certification, Training and Occupational Safety Branch (U.S. EPA) to provide you with further information regarding the status of any new extensions of this Exception. As Mr. Smith had aptly pointed out in his February 16 message on the Forum, last August 24, 1994 Mr. James Krone of Roses Inc. met with U.S. EPA Headquarters staff to discuss the needs for additional technical and non-tecninical information in order for the Agency to consider any additional extensions of the current Rose Exception. The eight page document dated Aug. 10, 1994 requested responses to numerous questions regarding needed Benefits and Risk data, and projected an average time of at least 6 months (including a minimum of 30 day public comment period) in order for the Agency to review the data received and reach a decision on the associated risks/exposures surrounding an extension request, after in fact it was received. In a March 18 letter from Mr. Krone to the U.S. EPA, he stated his intention to provide to EPA a draft request for an extension within 30 days. To date, the U.S. EPA has not received this request. Before that, the California Floral Council has also expressed an interest in a Rose Exception extension in a March 7, 1996 meeting with EPA HQ, but has not provided a data supported petition. At this time, the U.S. EPA does not forsee a Rose Exception in place after June 10. The below letter was recently mailed to Mr. James Krone addressing a Rose extension. Donald Baumgartner U.S. EPA Region 5 ****************************************************** May 3, 1996 Mr. James C. Krone Roses, Inc. 1152 Haslett Road P.O. Box 99 Haslett, MI 48840 Dear Mr. Krone: Thank you for agreeing to meet with us in Crystal City, Virginia on Wednesday, May 8, 1996 at 9:00 am. We received your letter, dated March 18, 1996, stating your intention to provide the EPA, within 30 days, a draft request for an extension of the Administrative Exception to Worker Protection Standard Early Entry Prohibition for Harvesting Cut Roses. Your letter further indicated that you would submit a final request for an extension after receiving EPA comment on your draft request. The expiration date of this exception is June 10. To date, neither you, nor other representatives from the floral industry, have submitted a final exception request, a draft request or any of the data that EPA needs in order to consider granting another exception. In light of these circumstances, we think it is essential for a discussion to occur. As you are aware, the exception established in 1994 allows, for a 2-year period, under specified conditions, early entry to harvest greenhouse-grown cut roses. The exception was granted to provide cut-rose producers time to develop and implement safe alternatives to early entry. In an August 1994 letter to Roses, Inc., EPA outlined the additional data it would need and timeline we would follow, if asked to consider another exception. In addition to data requirements, the August 1994 letter indicated that the Agency would need at least six months to review and reach a decision on the submission. EPA also offered to work with the rose industry to review and advise on protocols; however, I don't believe we've been taken up on this offer. A copy of this letter was given to Ms. Stone of the California Floral Council on March 7, 1996 when she met with us to discuss the need for an extension to this exception. I am also enclosing a copy for your convenience. EPA recognizes that developing and conducting studies and collecting and analyzing data can be a lengthy process. We look forward to hearing about the progress made in the last 2 years to gather the data necessary for the Agency to make a determination regarding the need and scope for early entry to harvest cut roses beyond June 10, 1996. Beyond the technical information requested, there is considerable non-technical information that was outlined in the August 1994 letter. We are interested in discussing and receiving this information, addressing issues such as cultural practices, amount of production and typical annual spray schedules. It is good news that many of the key products used on cut roses have reduced entry intervals (REIs) which are manageable for the involved cultural practices. Of the major products used on cut roses, we are interested in learning from you which products have restricted entry intervals (REIs) that prove problematic for the cut rose industry and what products, if any, are no longer used as a result of REIs. As of this time, I do not foresee the possibility of coming to a decision prior to June 10, 1996. Once we receive the request and supporting data, regulations require EPA to provide a 30-day public comment period before determining exception decisions. The Agency will then review public comments and make a determination based on all the information/data on the record. Nonetheless, we are interested in exploring what options may be available to address your concerns. We look forward to meeting with you this Wednesday and discussing this matter. I can be reached at 703-305-7410 and Don Eckerman and Sara Ager of the Certification and Occupational Safety Branch can be reached at 703-305-7666. Sincerely, William L. Jordan, Deputy Director Field Operations Division Office of Pesticide Programs Enclosures cc: Dan Barolo, EPA Penny Fenner-Crisp, EPA Stephanie Irene, EPA Al Jennings, EPA Cathy Kronopolus, EPA Betty Stone, California Floral Society From wgl@televar.com Tue May 7 15:03:29 1996 Received: from bing.ncw.net (root@bing.ncw.net [199.79.131.5]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id PAA22054 for ; Tue, 7 May 1996 15:03:27 -0700 (PDT) Received: from PHIL by bing.ncw.net (8.6.12/8.940801) id PAA21608; Tue, 7 May 1996 15:05:07 -0700 Date: Tue, 7 May 1996 15:05:07 -0700 Message-Id: <199605072205.PAA21608@bing.ncw.net> X-Sender: wgl@televar.com (Unverified) X-Mailer: Windows Eudora Light Version 1.5.2 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.berkeley.edu From: Phil Subject: Are poultry barns geenhouses? After the birds are removed, poultry growers fumigate their barns (chicken houses)to rid them of insect pests. I have two questions. One, is this activity covered under WPS, and two, do these barns fall under the same requirements as greenhouses for posted warnings, ventilation criteria, etc? A chicken house fits the definition of a greenhouse on Page 10 of the How to Comply Manual, except it does not produce plants. But, page 15 talks about a "greenhouse or other enclosed area," which leads me to think that it does not just have to grow plants. However, page 17 states that the WPS does not cover pesticides applied "on livestock or other animals, or in or around animal premises." The fumigants do have EPA registration numbers but I am unclear if they have the Agricultual Use Requirements section on the label. Could someone answer these questions please? From wgl@televar.com Tue May 7 15:48:48 1996 Received: from bing.ncw.net (root@bing.ncw.net [199.79.131.5]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id PAA23833 for ; Tue, 7 May 1996 15:48:45 -0700 (PDT) Received: from MIKE by bing.ncw.net (8.6.12/8.940801) id PAA26313; Tue, 7 May 1996 15:50:19 -0700 Date: Tue, 7 May 1996 15:50:19 -0700 Message-Id: <199605072250.PAA26313@bing.ncw.net> X-Sender: wgl@televar.com X-Mailer: Windows Eudora Light Version 1.5.2 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: mike gempler Subject: Re: Costs/Benefits Ginger: We don't have anything now but we would be willing to trade information. We are especially interested in studies documenting cost of regulation. Good luck with your research. Sincerely, Michael Gempler Executive Director Washington Growers League At 11:13 AM 5/7/96 -0500, you wrote: >Hello, I am new to this BBs, my county extension agent suggested I join. I >am a research assistant in the Economics Department, University of Florida, >IFAS Research and Education Center, Immokalee FL. > >My first project was researching the WPS. I found alot of information in >the Berkeley archives. Since the WPS has now been instated for a year we >will begin to determine the costs and benefits for farmers, nurserymen, >growers etc. > >Mainly I will be looking at establisments in SW Florida but if anyone has a >case study of their own on how much it cost to implement and maintain their >WPS rules, signs, decontamination sites, training, etc please reply.(94 >training, administration, labor budget vs 95) > >Also have you seen any benefits? Reduced sicknesses, accidents, etc. > >I will be looking into other regulations as well and how they interconnect, >overlap, and affect growers. > > > From 73414.252@CompuServe.COM Wed May 8 04:22:38 1996 Received: from dub-img-5.compuserve.com (dub-img-5.compuserve.com [198.4.9.5]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id EAA03391 for ; Wed, 8 May 1996 04:22:35 -0700 (PDT) Received: by dub-img-5.compuserve.com (8.6.10/5.950515) id HAA20826; Wed, 8 May 1996 07:22:04 -0400 Date: 08 May 96 07:18:30 EDT From: Judith Hauswirth <73414.252@CompuServe.COM> To: wps-forum Subject: Fumigation of Poultry Barns Message-ID: <960508111829_73414.252_DHS41-1@CompuServe.COM> Phil sent the forum a question concerning the fumigation of poultry barns and whether the activity is covered by the WPS. The WPS covers activities involved in the production of agricultural plants including in nurseries, greenhouses and other enclosed structures. Poultry production is not covered nor is the fumigation of poultry barns which is an integral part of poultry production. The term "greenhouse or other enclosed area" was intended to encompass any structures or spaces that are enclosed with any nonporous material and in which the production of agricultural plants occur. If a poultry barn were used to grow ornamentals for commercial production, the fumigation of the barn would then be under the WPS. As long as the barn is used for poultry production it is not covered, even if the fumigation activities were identical. It is important to remember that a grower using a fumigant for the poultry production does not have to follow the Ag Use Requirements box or WPS; however, the grower must follow any label requirements for the given fumigant concerning ventilation, reentry, and the instructions in the nonAg Uses box. Curt Lunchick From onn@gnv.ifas.ufl.edu Wed May 8 05:14:22 1996 Received: from gnv.ifas.ufl.edu (gnv.ifas.ufl.edu [128.227.242.11]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id FAA03680 for ; Wed, 8 May 1996 05:14:19 -0700 (PDT) Received: from ppp-01-nerdc-ts5.nerdc.ufl.edu by gnv.ifas.ufl.edu (PMDF V4.3-10 #7627) id <01I4GFOERX0W8XHDST@gnv.ifas.ufl.edu>; Wed, 08 May 1996 08:14:15 -0500 (EST) Date: Wed, 08 May 1996 08:14:15 -0500 (EST) Date-warning: Date header was inserted by gnv.ifas.ufl.edu From: onn@gnv.ifas.ufl.edu (on nesheim) Subject: Re: Are poultry barns geenhouses? X-Sender: onn@gnv.ifas.ufl.edu To: wps-forum@are.Berkeley.EDU Message-id: <01I4GFOFJS428XHDST@gnv.ifas.ufl.edu> MIME-version: 1.0 X-Mailer: Content-type: text/plain; charset="us-ascii" Content-transfer-encoding: 7BIT The Worker Protection Standard covers pesticides that are used in the production of agricultural plants on farms, forests, nurseries, and greenhouses. It does not cover livestock (including chickens) and the facilities that house them. I suspect the labels of the fumigants used for the chicken houses have information pertaining to ventilation or when it is safe to enter them after their use. >After the birds are removed, poultry growers fumigate their barns (chicken >houses)to rid them of insect pests. I have two questions. One, is this >activity covered under WPS, and two, do these barns fall under the same >requirements as greenhouses for posted warnings, ventilation criteria, etc? > >A chicken house fits the definition of a greenhouse on Page 10 of the How to >Comply Manual, except it does not produce plants. But, page 15 talks about a >"greenhouse or other enclosed area," which leads me to think that it does >not just have to grow plants. > >However, page 17 states that the WPS does not cover pesticides applied "on >livestock or other animals, or in or around animal premises." > >The fumigants do have EPA registration numbers but I am unclear if they have >the Agricultual Use Requirements section on the label. > >Could someone answer these questions please? > > From mcstiles@ucdavis.edu Wed May 8 09:08:45 1996 Received: from ucdavis.ucdavis.edu (ucdavis.ucdavis.edu [128.120.2.153]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id JAA06962 for ; Wed, 8 May 1996 09:08:43 -0700 (PDT) Received: from [128.120.162.58] by ucdavis.ucdavis.edu (8.7.5/UCD3.5.1) id JAA09470; Wed, 8 May 1996 09:07:52 -0700 (PDT) Date: Wed, 8 May 1996 09:07:52 -0700 (PDT) Message-Id: <199605081607.JAA09470@ucdavis.ucdavis.edu> X-Sender: szstiles@bullwinkle.ucdavis.edu Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: mcstiles@ucdavis.edu (Martha C. Stiles) Subject: Re: Costs/Benefits There are a group of researchers here at UC Davis who are conducting a study on the cost of regulation....primarily pesticide regulation in CA....sponsored by DPR...names and .e-mail addresses are: Christina Cecchettini clcecchettini@ucdavis.edu Carol Shennan shennan@vegmail.ucdavis.edu Barbara Goldman bggoldman@ucdavis.edu (Barbara Goldman) ---------------------------------------------------------------------------- ---------------------------------------------- >At 11:13 AM 5/7/96 -0500, you wrote: >>Hello, I am new to this BBs, my county extension agent suggested I join. I >>am a research assistant in the Economics Department, University of Florida, >>IFAS Research and Education Center, Immokalee FL. >> >>My first project was researching the WPS. I found alot of information in >>the Berkeley archives. Since the WPS has now been instated for a year we >>will begin to determine the costs and benefits for farmers, nurserymen, >>growers etc. >> >>Mainly I will be looking at establisments in SW Florida but if anyone has a >>case study of their own on how much it cost to implement and maintain their >>WPS rules, signs, decontamination sites, training, etc please reply.(94 >>training, administration, labor budget vs 95) >> >>Also have you seen any benefits? Reduced sicknesses, accidents, etc. >> >>I will be looking into other regulations as well and how they interconnect, >>overlap, and affect growers. >>------------------------------------------------------------------------------ >>-------------------------------------------- Martha C. Stiles Research Associate UC Davis Dept. of Human & Community Development Davis, CA 95616 (916) 752-2606 FAX (916) 752-5660 From 73414.252@CompuServe.COM Thu May 9 04:30:34 1996 Received: from arl-img-5.compuserve.com (arl-img-5.compuserve.com [198.4.7.5]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id EAA08349 for ; Thu, 9 May 1996 04:30:33 -0700 (PDT) Received: by arl-img-5.compuserve.com (8.6.10/5.950515) id HAA21932; Thu, 9 May 1996 07:30:02 -0400 Date: 09 May 96 07:29:15 EDT From: Judith Hauswirth <73414.252@CompuServe.COM> To: wps-forum Subject: At Plant Corn reentry activities Message-ID: <960509112914_73414.252_DHS47-3@CompuServe.COM> I have recently been asked about the possible types of activities that may occur within 7 days after the application of an at plant soil incorporated granular formulation insecticide applied to field corn. The interest is in determining potential postapplication exposure potentials to workers and setting the REI. An example of a postapplication is "nose-picking" in Idaho in which the workers will go in to pick rocks out of the fields. Three workers can cover 80 acres a day doing this. Does anyone know of other activities. I'd also be interested in any firsthand experiences with how much of the incorporated material is still left on the soil for potential contact with workers. Thanks, Curt Lunchick From LTrue@aol.com Thu May 9 21:08:02 1996 Received: from emout15.mail.aol.com (emout15.mx.aol.com [198.81.11.41]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id VAA03062 for ; Thu, 9 May 1996 21:08:00 -0700 (PDT) From: LTrue@aol.com Received: by emout15.mail.aol.com (8.6.12/8.6.12) id AAA25698 for wps-forum@are.berkeley.edu; Fri, 10 May 1996 00:07:29 -0400 Date: Fri, 10 May 1996 00:07:29 -0400 Message-ID: <960510000728_291012173@emout15.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: Re: At Plant Corn reentry activities In a message dated 96-05-09 07:31:29 EDT, Curt Lunchick wrote: >I have recently been asked about the possible types of activities that may occur >within 7 days after the application of an at plant soil incorporated granular >formulation insecticide applied to field corn. The interest is in determining >potential postapplication exposure potentials to workers and setting the REI. >An example of a postapplication is "nose-picking" in Idaho in which the workers >will go in to pick rocks out of the fields. Three workers can cover 80 acres a >day doing this. >Does anyone know of other activities. There is an important sense in which this is an inappropriate question. Naturally, we would all like to understand as much as possible about the nature of activities that might bring people into contact with residues. On the other hand, we should acknowledge that there is no way we can understand ALL of these tasks or situations to the extent that we could reasonably rely upon that understanding in setting REI's, or deciding whether an REI is needed at all. In the development of WPS, EPA struggled with this question and concluded that neither EPA nor registrants could possibly know all of the reasons employees might enter a treated area soon after application. Nor could all of the circumstances of each such entry be known, in order to be confident that any associated exposure opportunities were completely understood. The example of rock picking soon after application is a new one on me, and is therefore a perfect illustration of why EPA elected to take the original approach in WPS. It set at least a minimal REI for all applications, but permitted early entry with no-contact and under certain other exceptions. While it may be useful to know that early entry is far less frequent for some applications than others (in order to estimate the incidence of possible effects of exposure at the population level), such knowledge does nothing whatever to protect those individuals who DO enter, including those who enter erroneously or to perform tasks we will inevitably failed to predict, such as digging into soil into which the pesticide has been incorporated. That is an important part of what REI's were designed to do. In short, in setting REI's, it would be realistic and prudent for registrants and EPA to be guided by what risks might be if entry with contact DID occur, and not worry so much about how likely it is TO occur. The REI provisions of WPS were designed specifically to make the REI inexpensive for the employer if no early entry were required. If there is any chance at all that entry (that might lead to contact with residues) could occur soon after application, an REI is appropriate, unless the pesticide is so fully-understood and nontoxic that even high exposure wouldn't matter. Specifically, the presumed fact that at-plant uses on some crops are rarely, if ever, associated with entry soon after application should provide no basis for eliminating the REI from the label. Using such presumptions to eliminate or reduce the REI is inviting unacceptable worker exposure, IMHO. Lou True From smcdonld@freenet.columbus.oh.us Fri May 10 05:58:13 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id FAA06584 for ; Fri, 10 May 1996 05:58:11 -0700 (PDT) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.7.5/5.960408) id MAA15946; Fri, 10 May 1996 12:58:06 GMT Received: by acme.freenet.columbus.oh.us (8.6.10) id IAA17859; Fri, 10 May 1996 08:58:06 -0400 Date: Fri, 10 May 1996 08:49:33 -0400 (EDT) From: Sally McDonald Subject: Re: At Plant Corn reentry activities To: wps-forum@are.Berkeley.EDU In-Reply-To: <960509112914_73414.252_DHS47-3@CompuServe.COM> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On 9 May 1996, Curt Lunchick wrote: > I have recently been asked about the possible types of activities that may occur > within 7 days after the application of an at plant soil incorporated granular Sally replies: In Ohio, Spring is often characterized by an abundance of rain. Planting corn (and soybeans and wheat) becomes a real challenge. If there is an excess of rainfall soon after planting, it sometimes is necessary to enter the fields to perform tasks to aid drainage. Such tasks include repairing or maintaining drainage tiles and digging shallow channels to facilitate drain-off. Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From howardr@are.Berkeley.EDU Fri May 10 09:49:34 1996 Received: from [128.32.251.95] (gia5mac15.Berkeley.EDU [128.32.251.95]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id JAA10281 for ; Fri, 10 May 1996 09:49:28 -0700 (PDT) Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" X-mailer: Eudora Pro 2.1.3 Date: Fri, 10 May 1996 09:49:42 -0700 To: wps-forum From: howardr@are.Berkeley.EDU (Howard R. Rosenberg) Subject: announcement of heat stress poster FOR RELEASE: FRIDAY, MAY 9, 1996 ENGLISH/SPANISH POSTER AVAILABLE ON MEASURES TO CONTROL HEAT STRESS IN AGRICULTURE EPA and the Occupational Safety and Health Administration (OSHA) have published a multi-colored poster summarizing key elements for employers and workers to follow for controlling heat stress. EPA's Worker Protection Standard for agricultural pesticides requires employers to protect workers from heat-related illness when protective gear must be worn to reduce pesticide exposure. The poster, 20"X 24", is in English on one side and Spanish on the other. In addition to providing basic instructions for preventing heat-related illnesses, the poster also outlines in detail the signs, symptoms, and causes of various heat-related illnesses, as well as first-aid treatment. The poster is a summary of "A Guide to Heat Stress In Agriculture," issued jointly by EPA and OSHA. Copies of the poster (document number 055-000-00544-3) are $1.25 each; the Guide (document number 055-000=00474-9) is $3.50. Both are available from the U.S. Government Printing Office, Superintendent of Documents, Washington, D.C. 20402 (telephone, 202-512-1800). Orders of l00 or more copies receive a 25 percent discount. From RDSHS@aol.com Fri May 10 14:26:31 1996 Received: from emout08.mail.aol.com (emout08.mx.aol.com [198.81.11.23]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id OAA20546 for ; Fri, 10 May 1996 14:26:29 -0700 (PDT) From: RDSHS@aol.com Received: by emout08.mail.aol.com (8.6.12/8.6.12) id RAA26612 for wps-forum@are.berkeley.edu; Fri, 10 May 1996 17:25:59 -0400 Date: Fri, 10 May 1996 17:25:59 -0400 Message-ID: <960510172558_110984223@emout08.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: Re: Costs/Benefits It is my understanding that EPA "drylabbed" the justification for the WPS in the first place. How do you measure a WPS benefit if there were -0- illnesses in any particular commodity in the first place? If you want to measure benefits, do a body count - Illnesses before and after. From 73507.555@CompuServe.COM Fri May 10 19:38:07 1996 Received: from dub-img-1.compuserve.com (dub-img-1.compuserve.com [198.4.9.1]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id TAA28063 for ; Fri, 10 May 1996 19:38:06 -0700 (PDT) Received: by dub-img-1.compuserve.com (8.6.10/5.950515) id WAA10044; Fri, 10 May 1996 22:37:35 -0400 Date: 10 May 96 22:34:57 EDT From: Bob Roach <73507.555@CompuServe.COM> To: "'WPS-Forum'" Subject: Nose-Picking Message-ID: <960511023456_73507.555_HHB79-2@CompuServe.COM> Kurt, It sounds like you are filling out survey forms for that study the registrants are doing to help the U.S. EPA decide how much exposure occurs for all the tasks associated with various crops. Is that where this is coming from? As far as the WPS, one must only decide of it is a limited-contact or no-contact activity. How is the material incorporated? How deep is it and how deep are the rocks? Where are the rocks in relation to the pesticide? is the pesticide banded? It seems to me that it would be difficult to categorize this as "no-contact" unless it were a banded application. Does that means those 3 workers will now be able to do 10 acres a day in the one hour they are allowed to perform early reentry? Don't forget the eyewash, that should be immediately available in case some of those granules get into the eye. >I have recently been asked about the possible types of activities that may >occur within 7 days after the application of an at plant soil incorporated >granular formulation insecticide applied to field corn. The interest is in setting the REI. An example of a post application is "nose-picking" in Idaho in >which the workers will go in to pick rocks out of the fields. Three workers can >cover 80 acres a day doing this. Bob Roach From LTrue@aol.com Fri May 10 20:28:58 1996 Received: from emout16.mail.aol.com (emout16.mx.aol.com [198.81.11.42]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id UAA28487 for ; Fri, 10 May 1996 20:28:56 -0700 (PDT) From: LTrue@aol.com Received: by emout16.mail.aol.com (8.6.12/8.6.12) id XAA29690 for wps-forum@are.berkeley.edu; Fri, 10 May 1996 23:28:25 -0400 Date: Fri, 10 May 1996 23:28:25 -0400 Message-ID: <960510232824_291700163@emout16.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: Re: Costs/Benefits In a message dated 96-05-10 17:28:47 EDT, "RDSHS" wrote: >It is my understanding that EPA "drylabbed" the justification for the WPS in >the first place. How do you measure a WPS benefit if there were -0- >illnesses in any particular commodity in the first place? >If you want to measure benefits, do a body count - Illnesses before and >after. The odd comment above is apparently in response to Ginger Allen's request for information. Ginger, if you want to know what EPA actually did in assessing the likely costs and benefits of WPS, I suggest you obtain a copy of the Regulatory Impact Assessment that accompanied the August, 1992 final WPS regulation. Joe Hogue of EPA's Office of Pesticide Programs supervised the work, which was the subject of close scrutiny and protracted debate among several agencies of the federal government before it was issued. As to the comment above, a quick review of chapter V of the RIA should quickly persuade you that an attempt was made to use all available information on poisonings, and that it is not a simple matter. It should also be noted that many of the effects of pesticide exposure that are anticipated in sufficiently-exposed humans (based on tests on laboratory animals) are extremely difficult to associate with occupational exposures to pesticides when they occur in the real world. Examples include delayed effects such as cancer, developmental defects, and persistent neurotoxicity. Existing poisoning reporting systems are essentially incapable of establishing a causal link between such effects and exposure to pesticides, or, for that matter, to any other potential agents. In short, the uncertainties in this area are regrettably large. As a result, unfortunately, we do not have reliably complete "body counts" of zero or any other value. I would be happy to provide additional information or references. Feel free to contact me directly. Lou True From 73507.555@CompuServe.COM Sat May 11 15:05:21 1996 Received: from hil-img-3.compuserve.com (hil-img-3.compuserve.com [149.174.215.203]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id PAA06008 for ; Sat, 11 May 1996 15:05:17 -0700 (PDT) Received: by hil-img-3.compuserve.com (8.6.10/5.950515) id SAA03705; Sat, 11 May 1996 18:05:16 -0400 Date: 11 May 96 18:03:53 EDT From: Bob Roach <73507.555@CompuServe.COM> To: "'WPS-Forum'" Subject: Damming Regulatory Flow Message-ID: <960511220353_73507.555_HHB31-1@CompuServe.COM> Chicago Tribune Legal Affairs Column Source: Chicago Tribune WASHINGTON--May 9--DAMMING REGULATORY FLOW: WISE RESTRAINT OR ALL WET?: Like his father and grandfather, Bob Brace is a farmer, working the land his family bought at the turn of the century in northwestern Pennsylvania. That, however, was before seven federal, state and local agencies descended on his farm, accused him of destroying wetlands and threatened him with fines as high as $50,000 a day. His crime? Brace was cleaning out beaver dams that clogged the streams on the land and made it too water-logged for crops. Officials said he was destroying wetlands, in violation of federal environmental law. Brace's story is a regulatory nightmare that shows how people with the best intentions can be all but destroyed by complicated government regulations and overzealous bureaucrats. And it's providing ammunition for House Republicans, who are pushing legislation that would give citizens and businesses more defenses when facing accusations that they violated federal regulations. In Brace's case, various state and federal agencies gave him permission to clear out the dams and overhaul his farm's drainage system before he even started the work. But, once under way, other agencies came in and disagreed. "And now," Brace told a congressional subcommittee last week, "I am faced with the loss of my farm." The House bill would have prevented that because it would let people or businesses avoid punishment if they can show they didn't know about the regulation or believed they were complying with it. It's similar to a law enacted in March to help small businesses navigate the often rocky shoals of regulatory compliance. That law encourages the government to help small businesses follow federal rules by requiring agencies to answer questions and waive penalties in some cases. The bill now under consideration would cover all private citizens and businesses subject to federal regulations, from environmental laws to workplace safety requirements. Business managers say it's a long time in coming. But the Justice Department and other federal officials and environmental groups say the bill goes too far. Not only will it make it harder for the government to enforce the law uniformly, they say, it also will hinder prosecution of violations of any federal regulation -- from environmental protection and workplace safety to health-care fraud. On its face, they say, the bill appears fair. But, they say, it would have harmful and dangerous consequences. Among other things, it would make criminal enforcement depend on what the defendant believed about the law. "To use a baseball analogy, this is like ordering umpires to stop calling balls and strikes, and instead let the batter make the call," James F. Simon, U.S. deputy assistant attorney general, told the Subcommittee on Commercial and Administrative Law last week. Instead, Simon said, Congress should support efforts to simplify regulations and improve coordination with state regulators. But House Republicans say their bill is moderate, crafted in response to concerns federal officials had with a similar bill the Senate approved 80-0 last year. Like the Senate bill, the House legislation requires that people have fair warning of a regulation before they are penalized and some notice that they're violating the law. The two bills also would allow people to avoid punishment if they can show they believed in good faith that they were complying with the rule or were exempt from it. The Clinton administration takes exception to that provision. The House bill differs from the Senate version in several ways. For one thing, it prevents a federal agency from imposing a sanction only if the defendant determined he was following the law before he committed the violation. And the bill isn't retroactive; the Senate bill is. From tolson@ocsnet.net Sat May 11 15:28:51 1996 Received: from ntserv1.ocsnet.net ([206.14.63.1]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id PAA06444 for ; Sat, 11 May 1996 15:28:49 -0700 (PDT) Date: Sat, 11 May 1996 15:28:49 -0700 (PDT) Message-Id: <199605112228.PAA06444@are.Berkeley.EDU> Received: from tolson.ocsnet.net (206.14.63.10) by ntserv1.ocsnet.net (EMWAC SMTPRS 0.50) with SMTP id ; Sat, 11 May 1996 15:32:58 -0700 X-Sender: tolson@ocsnet.net X-Mailer: Windows Eudora Light Version 1.5.2 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: Ted Olson Subject: Re: Damming Regulatory Flow >The two bills also would allow people to avoid punishment if they can show >they believed in good faith that they were complying with the rule or were >exempt from it. >The Clinton administration takes exception to that >provision. So what else is new? At the risk of turning this benign forum political, I cannot resist adding my two cents' worth: if 1992's results were met with nervous resignation, in 1996 it is absolutely astonishing and very upsetting to contemplate that the same administration actually stands a real chance of doing it again -- which would obviously lead to claims of approval and endorsement of these kinds of attitudes and policies. Too depressing to think about for long, hopefully a majority of voters will wake up in time. Ted Olson From 73507.555@CompuServe.COM Sun May 12 21:50:18 1996 Received: from hil-img-3.compuserve.com (hil-img-3.compuserve.com [149.174.215.203]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id VAA19710 for ; Sun, 12 May 1996 21:50:16 -0700 (PDT) Received: by hil-img-3.compuserve.com (8.6.10/5.950515) id AAA08228; Mon, 13 May 1996 00:50:15 -0400 Date: 13 May 96 00:48:08 EDT From: Bob Roach <73507.555@CompuServe.COM> To: "'WPS-Forum'" Subject: Costs/Benefits Message-ID: <960513044807_73507.555_HHB59-2@CompuServe.COM> Lou True said: >It should also be noted that many of the effects of pesticide exposure that are >anticipated in sufficiently-exposed humans (based on tests on laboratory >animals) are extremely difficult to associate with occupational exposures to >pesticides when they occur in the real world. Examples include delayed >effects such as cancer, developmental defects, and persistent neurotoxicity. >Existing poisoning reporting systems are essentially incapable of >establishing a causal link between such effects and exposure to pesticides, >or, for that matter, to any other potential agents. In short, the uncertainties in >this area are regrettably large ----------------------------------------------- I think the uncertainties in the U.S. EPA's risk/benefit analysis were regrettably large also. Now that the WPS has been in effect for a while perhaps we may see what it is costing. I know that it will cost a lot in California to comply with the "display" of information required over and above the existing hazard communication system that was in place. The benefit derived from this activity is nil, IMHO. Workers will hardly ever use the displayed information. When the union or their representative wants a copy of the use records they usually go to the county agricultural commissioner anyway. The notice of application/REI requirements likewise require a great deal more effort than the existing California system with little or no additional benefit derived. I think in time we will actually see an erosion of protection as workers become desensitized to the warnings because they are so common. On the other hand, training workers gives a lot of bang for the buck. Most pesticide related illnesses occur when somebody did not follow directions. The statement above troubles me. The pesticide registration process is a very conservative process designed to provide large safety factors. Who is being "sufficiently exposed?" Lou points out that existing reporting systems are not adequate to establish a causal link. I would add that epidemiological studies also fail to find such links. Yet cancer, developmental effects and delayed neurotoxicity are anticipated? Is it fair to make such an assertion and then admit it can never be proven? I think in any risk/benefit analysis we should factor in the result of our current agricultural production system: a cheap, safe and abundant supply of food and fiber. An adequate diet containing lots of fresh fruits and vegetables promotes good health. The availability of agricultural chemicals has done more to improve the Nation's health in the last 50 years than anything else, with the possible exception of advances in refrigeration technology. Bob Roach From LTrue@aol.com Mon May 13 14:57:13 1996 Received: from emout13.mail.aol.com (emout13.mx.aol.com [198.81.11.39]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id OAA07448 for ; Mon, 13 May 1996 14:57:11 -0700 (PDT) From: LTrue@aol.com Received: by emout13.mail.aol.com (8.6.12/8.6.12) id RAA05670 for wps-forum@are.berkeley.edu; Mon, 13 May 1996 17:56:39 -0400 Date: Mon, 13 May 1996 17:56:39 -0400 Message-ID: <960513175530_490269028@emout13.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: Re: Costs/Benefits In a message dated 96-05-13 00:51:15 EDT, Bob Roach wrote: >The pesticide registration process is a very >conservative process designed to provide large safety factors. Who is being >"sufficiently exposed?" Lou points out that existing reporting systems are not >adequate to establish a causal link. I would add that epidemiological studies >also fail to find such links. Yet cancer, developmental effects and delayed >neurotoxicity are anticipated? Is it fair to make such an assertion and then >admit it can never be proven? 1. No system is perfect. It should be sufficient to note that there has never been a pesticide that needed to be cancelled or have restrictions placed on its use by EPA, or by California, that did not first pass successfully through the registration process. This alone should give us pause. It might also be of interest to note as general background that about one third of all pesticides tested and evaluated under the registration or reregistration programs are found by EPA to be oncogenic in animals. Similarly, about one third are found to cause developmental defects in the offspring of tested animals. Other delayed effects are detected in animals as well And, as we all know, many ag pesticides remain to be fully tested and evaluated to current standards. This includes the need to learn a great deal more about occupational exposures. Finally, the history of toxic substances (including pesticide) regulation shows the emergence of concerns for which pesticides already on the market have not been evaluated. Some of those concerns, like delayed neurotoxicity, are eventually incorporated into the registration system. A current example of an emerging but still controversial concern is provided by possible endocrine system disrupters, including many pesticides. The message here is that, even when we have all the data we've asked for on a pesticide, we are likely to eventually decide that more information is essential for the evaluation of the substance. 2. It is in the very nature of incident reporting systems such as California's to be weak in determining that health effects that occur long after exposure to causative agents are associated with occupational exposures. That the system doesn't find much in the way of delayed effects should provide no comfort. 3. The epidemiological literature, while not as clear and complete as is desirable, does contain studies that raise concerns that delayed effects of pesticide exposure may indeed be occurring in the agricultural workforce. EPA cited a number of such studies in its 1992 Regulatory Impact Assessment for WPS. It is my undertanding that epidemiological work relevant to agricultural chemicals continues, albeit with limited resources. In the end, however, it should be noted that epidemiology is not a suitable instrument to demonstrate safety, both because of an intrinsically weak capacity to detect many relationships and because of the point in no. 4 below. Again, not seeing the effects in epidemiology results may put an upper bound on the frequency of the effect, but is not likely to allow us to conclude that the effect is not occurring at a rate below the study's power to detect it. 4. As for the matter of proof, however, I suggest that every instance of proof of unacceptable risk based on incidents or long-term epidemiology is best viewed as an important failure of the national system which, as a premarket approval process, is designed to prevent such effects. 5. In my view, all of this argues for simple prudence, which is what exposure reduction through workplace safety practices (like those in WPS) is all about. Lou True From aftgoul@gatekeeper.ddp.state.me.us Tue May 14 05:08:01 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id FAA17719 for ; Tue, 14 May 1996 05:07:58 -0700 (PDT) Received: from [141.114.137.97] ([141.114.137.97]) by gatekeeper.ddp.state.me.us (8.7.4/8.6.12) with SMTP id DAA21570 for ; Tue, 14 May 1996 03:05:52 -0400 (EDT) Date: Tue, 14 May 1996 03:05:52 -0400 (EDT) Message-Id: <199605140705.DAA21570@gatekeeper.ddp.state.me.us> X-Authentication-Warning: gatekeeper.ddp.state.me.us: Host [141.114.137.97] didn't use HELO protocol 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: Worker Handbook Translations While I would like to throw my hat into the cost/benefit fracas, I have a much more practical question to ask. In October 1994, EPA released a booklet describing materials developed by EPA, States and others. As of that date, the worker handbook had been translated into Korean, Philippian, Chinese, Vietamese and Laotian. (1) What is the current list of languages in which the worker handbook is available? (2) Who do I contact at EPA (or outside EPA) to obtain copies of these non-English/non-Spanish worker handbooks? Now, everyone can get back to the cost/benefit discussion. Thanks. Tammy Gould Maine Board of Pesticides Control From smcdonld@freenet.columbus.oh.us Tue May 14 07:42:41 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id HAA18827 for ; Tue, 14 May 1996 07:42:39 -0700 (PDT) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.7.5/5.960408) id OAA21086; Tue, 14 May 1996 14:42:35 GMT Received: by acme.freenet.columbus.oh.us (8.6.10) id KAA23968; Tue, 14 May 1996 10:42:34 -0400 Date: Tue, 14 May 1996 10:34:37 -0400 (EDT) From: Sally McDonald Subject: Re: Worker Handbook Translations To: wps-forum@are.Berkeley.EDU cc: wps-forum@are.Berkeley.EDU In-Reply-To: <199605140705.DAA21570@gatekeeper.ddp.state.me.us> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On Tue, 14 May 1996, Tammy Gould wrote: > The worker handbook had been translated into Korean, Philippian, > Chinese, Vietamese and Laotian. > Sally replies: I don't have a list, but I do know that the worker handbook has been translated into: Creole (Florida) Ilocano (Hawaii) Chamorro (Guam) Carolinian (Northern Mariana Islands) Samoan (American Samoa) Palauan (Republic of Palau) Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From kick-raack.1@osu.edu Tue May 14 10:12:28 1996 Received: from agvax2.ag.ohio-state.edu (agvax2.ag.ohio-state.edu [128.146.143.101]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id KAA22764 for ; Tue, 14 May 1996 10:12:25 -0700 (PDT) Date: Tue, 14 May 1996 10:12:25 -0700 (PDT) Message-Id: <199605141712.KAA22764@are.Berkeley.EDU> Received: from jkr.ag.ohio-state.edu ([140.254.84.25]) by agvax2.ag.ohio-state.edu (MX V4.1 VAX) with SMTP; Tue, 14 May 1996 13:12:20 +500 X-Sender: kickraack@agvax2.ag.ohio-state.edu X-Mailer: Windows Eudora Pro Version 2.1.2 MIME-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: Joanne Kick-Raack Subject: Re: Worker Handbook Translations There is also a Polish version of the worker handbook translated by Cornell extension. Joanne At 10:34 AM 5/14/96 -0400, you wrote: >On Tue, 14 May 1996, Tammy Gould wrote: > >> The worker handbook had been translated into Korean, Philippian, >> Chinese, Vietamese and Laotian. >> >Sally replies: > >I don't have a list, but I do know that the worker handbook has been >translated into: > >Creole (Florida) >Ilocano (Hawaii) >Chamorro (Guam) >Carolinian (Northern Mariana Islands) >Samoan (American Samoa) >Palauan (Republic of Palau) > >Sally > >-- >Sally A. McDonald, Information Impact >5837 Tartan Circle, Dublin, OH 43017 > > > Joanne Kick-Raack Ohio State University 249 Howlett Hall 2001 Fyffe Ct. Columbus, OH 43210 Ph. 614-292-9085 FAX 614-292-3505 kick-raack.1@osu.edu From afgfish@state.me.us Tue May 14 10:49:10 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id KAA24270 for ; Tue, 14 May 1996 10:49:08 -0700 (PDT) Received: from smtp.state.me.us ([141.114.136.138]) by gatekeeper.ddp.state.me.us (8.7.4/8.6.12) with SMTP id IAA15545 for ; Tue, 14 May 1996 08:46:59 -0400 (EDT) Date: Tue, 14 May 1996 08:46:59 -0400 (EDT) Message-Id: <199605141246.IAA15545@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: Costs/Benefits Lou: Your message is right on. Despite that fact, the WPS is still hard to justify to the farmer, forester and nursery or greenhouse operator when all they are using are very low toxicity materials (i.e., Bt., glyphosate, soaps, oils etc.). They just don't see the potential for significant health effects with these products. It is especially hard to explain for crop systems that require worker re-entry but the amount of contact with treated surfaces is minimal, but not non-existent. > > 1. No system is perfect. It should be sufficient to note that there >has never been a pesticide that needed to be cancelled or have restrictions >placed on its use by EPA, or by California, that did not first pass >successfully through the registration process. This alone should give us >pause. It might also be of interest to note as general background that about >one third of all pesticides tested and evaluated under the registration or >reregistration programs are found by EPA to be oncogenic in animals. > Similarly, about one third are found to cause developmental defects in the >offspring of tested animals. Other delayed effects are detected in animals >as well And, as we all know, many ag pesticides remain to be fully tested >and evaluated to current standards. This includes the need to learn a great >deal more about occupational exposures. Finally, the history of toxic >substances (including pesticide) regulation shows the emergence of concerns >for which pesticides already on the market have not been evaluated. Some of >those concerns, like delayed neurotoxicity, are eventually incorporated into >the registration system. A current example of an emerging but still >controversial concern is provided by possible endocrine system disrupters, >including many pesticides. The message here is that, even when we have all >the data we've asked for on a pesticide, we are likely to eventually decide >that more information is essential for the evaluation of the substance. > 2. It is in the very nature of incident reporting systems such as >California's to be weak in determining that health effects that occur long >after exposure to causative agents are associated with occupational >exposures. That the system doesn't find much in the way of delayed effects >should provide no comfort. > 3. The epidemiological literature, while not as clear and complete as >is desirable, does contain studies that raise concerns that delayed effects >of pesticide exposure may indeed be occurring in the agricultural workforce. > EPA cited a number of such studies in its 1992 Regulatory Impact Assessment >for WPS. It is my undertanding that epidemiological work relevant to >agricultural chemicals continues, albeit with limited resources. In the end, >however, it should be noted that epidemiology is not a suitable instrument to >demonstrate safety, both because of an intrinsically weak capacity to detect >many relationships and because of the point in no. 4 below. Again, not >seeing the effects in epidemiology results may put an upper bound on the >frequency of the effect, but is not likely to allow us to conclude that the >effect is not occurring at a rate below the study's power to detect it. > 4. As for the matter of proof, however, I suggest that every instance >of proof of unacceptable risk based on incidents or long-term epidemiology is >best viewed as an important failure of the national system which, as a >premarket approval process, is designed to prevent such effects. > 5. In my view, all of this argues for simple prudence, which is what >exposure reduction through workplace safety practices (like those in WPS) is >all about. > >Lou True > > Gary Fish Maine Board of Pesticides Control Station 28 Augusta, ME 04333 207-287-2731 gary.fish@state.me.us From afgfish@state.me.us Tue May 14 12:22:17 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id MAA28538 for ; Tue, 14 May 1996 12:22:14 -0700 (PDT) Received: from smtp.state.me.us ([141.114.136.138]) by gatekeeper.ddp.state.me.us (8.7.4/8.6.12) with SMTP id KAA01439 for ; Tue, 14 May 1996 10:20:07 -0400 (EDT) Date: Tue, 14 May 1996 10:20:07 -0400 (EDT) Message-Id: <199605141420.KAA01439@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: announcement of heat stress poster Does anyone know if it is possible to get a free sample of this poster so we can decide if we want to make a bulk purchase. I hate to do all the PO rigamaroll to get just one to see what they are all about. >FOR RELEASE: FRIDAY, MAY 9, 1996 > >ENGLISH/SPANISH POSTER AVAILABLE ON MEASURES >TO CONTROL HEAT STRESS IN AGRICULTURE > >EPA and the Occupational Safety and Health Administration (OSHA) have >published a multi-colored poster summarizing key elements for employers and >workers to follow for controlling heat stress. EPA's Worker Protection >Standard for agricultural pesticides requires employers to protect workers >from heat-related illness when protective gear must be worn to reduce >pesticide exposure. > >The poster, 20"X 24", is in English on one side and Spanish on the other. >In addition to providing basic instructions for preventing heat-related >illnesses, >the poster also outlines in detail the signs, symptoms, and causes of >various heat-related illnesses, as well as first-aid treatment. The poster >is a summary of "A Guide to Heat Stress In Agriculture," issued jointly by >EPA and OSHA. > >Copies of the poster (document number 055-000-00544-3) are $1.25 each; the >Guide (document number 055-000=00474-9) is $3.50. Both are available from >the U.S. Government Printing Office, Superintendent of Documents, >Washington, D.C. 20402 (telephone, 202-512-1800). Orders of l00 or more >copies receive a 25 percent discount. > > > > Gary Fish Maine Board of Pesticides Control Station 28 Augusta, ME 04333 207-287-2731 gary.fish@state.me.us From smcdonld@freenet.columbus.oh.us Wed May 15 04:34:12 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id EAA14625; Wed, 15 May 1996 04:34:10 -0700 (PDT) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.7.5/5.960408) id LAA20107; Wed, 15 May 1996 11:34:07 GMT Received: by acme.freenet.columbus.oh.us (8.6.10) id HAA19148; Wed, 15 May 1996 07:34:07 -0400 Date: Wed, 15 May 1996 07:27:26 -0400 (EDT) From: Sally McDonald Sender: Sally McDonald Reply-To: Sally McDonald Subject: Re: your mail To: wps-forum@are.Berkeley.EDU cc: WPS-Forum@are.Berkeley.EDU, ccrocker@hawaii.edu In-Reply-To: Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; CHARSET=US-ASCII On Thu, 2 May 1996 charlie@hpirs.stjohn.hawaii.edu wrote: > Have there been any changes to the list of active ingredients in EPA's > communication to pesticide registrants, PR Notice 93-7? It's date stamped > 4-20-93. I'm referring to the back section of the Notice titled > "SUPPLEMENT THREE-A". > >Sally replies: I hesitated to answer this question, but when no one else responded, I had to try. I don't know for sure whether there have been any changes to the active ingredient list that appeared in Supplement Three-A of PR Notice 93-7. I hope there have not been any updates, since that listing has no meaning at all outside the context of the PR Notice. That list does NOT definitively list the restricted-entry intervals or notification requirements or respirator requirements for those active ingredients. It lists what the restricted-entry interval or notification requirement would be if only the WPS requirements were applicable. Many of the active ingredients on the list had restricted-entry intervals established by EPA before the revision of the WPS. Those longer REIs were retained, but are NOT reflected on the active ingredient list. Similarly, a few pesticides had mandatory field posting requirements established prior to the WPS and these are not reflected on the list. Furthermore, since the publication of the PR Notice and the active ingredient list in April, 1993, many active ingredients have undergone reregistration. The reregistration process looks at the possible acute and other adverse effects of an active ingredient and establishes a restricted-entry interval and/or notification requirement based on all possible known adverse effects. Therefore, with respect to restricted-entry intervals and notification, the active ingredient list is not intended to reflect the actual REI(s) or notification requirements for an active ingredient. The situation for the respirator columns is even more complicated. Rather than trace in this message what those columns actually indicate, suffice it to say that neither column has any stand-alone meaning. Both had meaning only in the context of PR Notice 93-7 and only at that point in time. (If anyone wants a more detailed explanation, please contact me.) Sally > > -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From smcdonld@freenet.columbus.oh.us Wed May 15 04:51:12 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id EAA14741 for ; Wed, 15 May 1996 04:51:11 -0700 (PDT) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.7.5/5.960408) id LAA20929; Wed, 15 May 1996 11:51:07 GMT Received: by acme.freenet.columbus.oh.us (8.6.10) id HAA22962; Wed, 15 May 1996 07:51:07 -0400 Date: Wed, 15 May 1996 07:40:08 -0400 (EDT) From: Sally McDonald Subject: Re: Costs/Benefits To: wps-forum@are.Berkeley.EDU cc: wps-forum@are.Berkeley.EDU In-Reply-To: <199605141246.IAA15545@gatekeeper.ddp.state.me.us> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On Tue, 14 May 1996, Gary Fish wrote: > Lou: > > Your message is right on. Despite that fact, the WPS is still hard to > justify to the farmer, forester and nursery or greenhouse operator when all > they are using are very low toxicity materials (i.e., Bt., glyphosate, > soaps, oils etc.). They just don't see the potential for significant health > effects with these products. It is especially hard to explain for crop > systems that require worker re-entry but the amount of contact with treated > surfaces is minimal, but not non-existent. > > > Sally replies: I cannot help but comment on the the list of active ingredients that growers consider to be "low toxicity." While most Bt strains are toxicity III and IV and meet the criteria as candidates for a 4-hour REI, one stain is classified as Tox category I for eye irritation effects. I believe that it has appeared in the California poisoning incident data base as an eye concern. Glyphosate is classified as tox III or IV for acute or irritation effects, but has appeared repeatedly in the California poisoning incident data base as an eye irritant. Presumably, it does not, therefore, meet the criteria as a candidate for a 4-hour REI. Often growers concentrate on systemic toxicity concerns and dismiss concerns about eye and skin irritation potential. However, evidence indicates that eye and skin irritation incidents for reentering workers is a substantial percentage of the California poisoning incident data. Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From afgfish@state.me.us Wed May 15 05:16:56 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id FAA14919 for ; Wed, 15 May 1996 05:16:53 -0700 (PDT) Received: from smtp.state.me.us ([141.114.136.138]) by gatekeeper.ddp.state.me.us (8.7.4/8.6.12) with SMTP id DAA26935 for ; Wed, 15 May 1996 03:14:46 -0400 (EDT) Date: Wed, 15 May 1996 03:14:46 -0400 (EDT) Message-Id: <199605150714.DAA26935@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: Costs/Benefits Sally: I realize that many low toxicity materials can cause skin and eye irritations as do the growers. These instances primarily involve handlers. They don't involve workers. Especially when you look at workers entering areas 10 - 30 days after the application. If the material isn't dry then people should stay away. Our problem comes when we explain to growers that they must provide training to workers that are harvesting a vegetable crop that was last treated with a low toxicity material weeks ago. I fully support the concept of training, it's what I do for a living, but the one size fits all regulation is tough to sell in many situations. I think selling this regulation to growers has done more to hurt our credibility than any other law or regulation we've had to enforce in the past 8 years I've been in this job. Gary Fish Maine Board of Pesticides Control Station 28 Augusta, ME 04333 207-287-2731 gary.fish@state.me.us From GRAVES.JAMES@epamail.epa.gov Wed May 15 08:52:24 1996 Received: from pyxis.rtpnc.epa.gov (pyxis.rtpnc.epa.gov [134.67.208.82]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id IAA17086 for ; Wed, 15 May 1996 08:52:22 -0700 (PDT) Received: from mr.rtpnc.epa.gov by mail.rtpnc.epa.gov (PMDF V4.3-10 #8611) id <01I4QF9II8K08YDEPT@mail.rtpnc.epa.gov>; Wed, 15 May 1996 11:50:13 -0400 (EDT) Received: with PMDF-MR; Wed, 15 May 1996 11:48:11 EDT MR-Received: by mta CARINA; Relayed; Wed, 15 May 1996 11:48:11 -0400 Alternate-recipient: prohibited Disclose-recipients: prohibited Date: Wed, 15 May 1996 11:44:00 -0400 (EDT) From: JAMES GRAVES 202-260-3417 Subject: Deletion of subscription To: wps-forum@are.berkeley.edu Message-id: <01I4QF9N2QMW8YDEPT@mr.rtpnc.epa.gov> X-Envelope-to: wps-forum@are.berkeley.edu MIME-version: 1.0 Content-type: TEXT/PLAIN; CHARSET=US-ASCII Content-transfer-encoding: 7BIT Posting-date: Wed, 15 May 1996 11:46:00 -0400 (EDT) Importance: normal Priority: normal X400-MTS-identifier: [;11841151506991/4519458@MAIL] A1-type: MAIL Hop-count: 1 Please cancel subscription for graves.james. From afgfish@state.me.us Wed May 15 09:56:28 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id JAA18644 for ; Wed, 15 May 1996 09:56:24 -0700 (PDT) Received: from smtp.state.me.us ([141.114.136.138]) by gatekeeper.ddp.state.me.us (8.7.4/8.6.12) with SMTP id HAA07530 for ; Wed, 15 May 1996 07:54:16 -0400 (EDT) Date: Wed, 15 May 1996 07:54:16 -0400 (EDT) Message-Id: <199605151154.HAA07530@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: Heat stress poster Does anyone know if it is possible to get a free sample of this poster so we can decide if we want to make a bulk purchase. I hate to do all the PO rigamaroll to get just one to see what they are all about. > >>FOR RELEASE: FRIDAY, MAY 9, 1996 >> >>ENGLISH/SPANISH POSTER AVAILABLE ON MEASURES >>TO CONTROL HEAT STRESS IN AGRICULTURE >> >>EPA and the Occupational Safety and Health Administration (OSHA) have >>published a multi-colored poster summarizing key elements for employers and >>workers to follow for controlling heat stress. EPA's Worker Protection >>Standard for agricultural pesticides requires employers to protect workers >>from heat-related illness when protective gear must be worn to reduce >>pesticide exposure. >> >>The poster, 20"X 24", is in English on one side and Spanish on the other. >>In addition to providing basic instructions for preventing heat-related >>illnesses, >>the poster also outlines in detail the signs, symptoms, and causes of >>various heat-related illnesses, as well as first-aid treatment. The poster >>is a summary of "A Guide to Heat Stress In Agriculture," issued jointly by >>EPA and OSHA. >> >>Copies of the poster (document number 055-000-00544-3) are $1.25 each; the >>Guide (document number 055-000=00474-9) is $3.50. Both are available from >>the U.S. Government Printing Office, Superintendent of Documents, >>Washington, D.C. 20402 (telephone, 202-512-1800). Orders of l00 or more >>copies receive a 25 percent discount. >> >> >> >> >Gary Fish >Maine Board of Pesticides Control >Station 28 >Augusta, ME 04333 >207-287-2731 > >gary.fish@state.me.us > >============== End part 2 ============================ > > Gary Fish Maine Board of Pesticides Control Station 28 Augusta, ME 04333 207-287-2731 gary.fish@state.me.us From DHenCox@aol.com Wed May 15 21:38:06 1996 Received: from emout17.mail.aol.com (emout17.mx.aol.com [198.81.11.43]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id VAA08356 for ; Wed, 15 May 1996 21:38:04 -0700 (PDT) From: DHenCox@aol.com Received: by emout17.mail.aol.com (8.6.12/8.6.12) id AAA24333 for wps-forum@are.berkeley.edu; Thu, 16 May 1996 00:37:33 -0400 Date: Thu, 16 May 1996 00:37:33 -0400 Message-ID: <960516003733_536246216@emout17.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: change of address Please change my address from this one to dhcox@lightspeed.net Thank you David Cox From cfcbetty@coastside.net Thu May 16 21:14:34 1996 Received: from poseidon (poseidon.coastnet.net [205.162.38.5]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id VAA09309 for ; Thu, 16 May 1996 21:14:32 -0700 (PDT) Received: from LOCALNAME ([205.162.38.75]) by poseidon (8.6.11/8.6.12) with SMTP id VAA16706 for ; Thu, 16 May 1996 21:13:01 -0700 Date: Thu, 16 May 1996 21:13:01 -0700 Message-Id: <199605170413.VAA16706@poseidon> X-Sender: cfcbetty@coastside.net X-Mailer: Windows Eudora Light Version 1.5.2 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: Betty Stone Subject: Re: Costs/Benefits Would someone be able to get the schedule of the WPS hearings in California to me? Many Thanks!!! Betty From 73507.555@CompuServe.COM Fri May 17 06:40:52 1996 Received: from dub-img-4.compuserve.com (dub-img-4.compuserve.com [198.4.9.4]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id GAA13348 for ; Fri, 17 May 1996 06:40:34 -0700 (PDT) Received: by dub-img-4.compuserve.com (8.6.10/5.950515) id JAA02668; Fri, 17 May 1996 09:40:02 -0400 Date: 17 May 96 09:38:24 EDT From: Bob Roach <73507.555@CompuServe.COM> To: "'WPS-Forum'" Subject: Credibility Message-ID: <960517133823_73507.555_HHB64-2@CompuServe.COM> Gary, I think you are right on in your assessment. With an irony often found in attempts to regulate reduced risk, the erosion of the credibility of established state programs may ultimately result in an effect opposite to that intended. In my experience California has had a program that is fairly well accepted by industry because it is tailored to the state's particular needs. The regulated can see how the requirements help eliminate risk and ultimately benefit them. We will soon be faced with a situation where some of the requirements don't make much sense and don't provide any tangible reduction in risk. This may erode respect for the pesticide use enforcement program and cause attitudes of cooperation to become adverse. What I am referring to for the most part are some of the changes in hazard communication and giving of notice. Now growers will have to "display" application specific information rather than provide it when asked. Nobody will look at it. They will have to notify all employees within 1/4 mile rather than those who are likely to enter the treated area. As a result, at least in our area, the fields will be bristling with posting signs because it is logistically impossible in most cases to provide oral warning. Respect for field posting signs will diminish because they will be so common. Most of the WPS is beneficial. The lack of flexibility in its implementation is its greatest weakness. Gary Fish Said: >I fully support the concept of training, it's what I do for a living, but >the one size fits all regulation is tough to sell in many situations. I >think selling this regulation to growers has done more to hurt our >credibility than any other law or regulation we've had to enforce in the >past 8 years I've been in this job. ******************************************************************************** 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 73507.555@CompuServe.COM Fri May 17 06:42:08 1996 Received: from dub-img-5.compuserve.com (dub-img-5.compuserve.com [198.4.9.5]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id GAA13374 for ; Fri, 17 May 1996 06:42:07 -0700 (PDT) Received: by dub-img-5.compuserve.com (8.6.10/5.950515) id JAA04757; Fri, 17 May 1996 09:41:35 -0400 Date: 17 May 96 09:38:37 EDT From: Bob Roach <73507.555@CompuServe.COM> To: "'WPS-Forum'" Subject: Glyphosate Message-ID: <960517133837_73507.555_HHB64-3@CompuServe.COM> Sally, Be careful how you interpret the California illness data. Glyphosate is a translocated herbicide. It is generally not applied to growing crops and reentry is usually not an issue. The reported illnesses are, in my experience, applicators who get it in their eye and experience conjunctivitis from which they fully recover. The formulated products are category II and it is my understanding that the surfactants are what causes the eye irritation and not the glyphosate. Since eye exposure was determined to be a hazard of some types of applications, California regulations have long required the use of eye protection in these cases. Now the labels of most glyphosate products also require eye protection. This is an example of responding to a real hazard with appropriate action. Another reason glyphosate has a lot if illnesses is that it is widely used. Many glyphosate injuries I see now are the result of employees not wearing the eye protection they have been trained to wear, told to wear and provided with. Regarding risk assessment, I am reading an interesting report out of U.C. Berkeley on pesticide use in California. They attempt to rank pesticides as to hazard using various approaches. Glyphosate is not even on the list of 150 pesticides ranked. I do not understand why. It is mentioned in another chart as being third ranked for farmworker illnesses. But then the fifth material is chlorine, which has no production agricultural uses I am aware of. Bt is nowhere mentioned. This report is very interesting and I may post an excerpt from it regarding risk reduction. One point made is that to reduce risk effectively you must concentrate efforts on activities that are hazardous. Sally McDonald said: >Glyphosate is classified as tox III or IV for acute or >irritation effects, but has appeared repeatedly in the California >poisoning incident data base as an eye irritant. Presumably, it does not, >therefore, meet the criteria as a candidate for a 4-hour REI. ******************************************************************************** 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 afgfish@state.me.us Fri May 17 08:25:51 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id IAA14399 for ; Fri, 17 May 1996 08:25:48 -0700 (PDT) Received: from smtp.state.me.us ([141.114.136.138]) by gatekeeper.ddp.state.me.us (8.7.4/8.6.12) with SMTP id GAA20389 for ; Fri, 17 May 1996 06:23:32 -0400 (EDT) Date: Fri, 17 May 1996 06:23:32 -0400 (EDT) Message-Id: <199605171023.GAA20389@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: Glyphosate Bob: You are right on. >Sally, > >Be careful how you interpret the California illness data. Glyphosate is a >translocated herbicide. It is generally not applied to growing crops and >reentry is usually not an issue. The reported illnesses are, in my experience, >applicators who get it in their eye and experience conjunctivitis from which >they fully recover. The formulated products are category II and it is my >understanding that the surfactants are what causes the eye irritation and not >the glyphosate. Since eye exposure was determined to be a hazard of some types >of applications, California regulations have long required the use of eye >protection in these cases. Now the labels of most glyphosate products also >require eye protection. This is an example of responding to a real hazard with >appropriate action. Another reason glyphosate has a lot if illnesses is that it >is widely used. Many glyphosate injuries I see now are the result of employees >not wearing the eye protection they have been trained to wear, told to wear and >provided with. > >Regarding risk assessment, I am reading an interesting report out of U.C. >Berkeley on pesticide use in California. They attempt to rank pesticides as to >hazard using various approaches. Glyphosate is not even on the list of 150 >pesticides ranked. I do not understand why. It is mentioned in another chart >as being third ranked for farmworker illnesses. But then the fifth material is >chlorine, which has no production agricultural uses I am aware of. Bt is >nowhere mentioned. > >This report is very interesting and I may post an excerpt from it regarding risk >reduction. One point made is that to reduce risk effectively you must >concentrate efforts on activities that are hazardous. > > >Sally McDonald said: > >>Glyphosate is classified as tox III or IV for acute or >>irritation effects, but has appeared repeatedly in the California >>poisoning incident data base as an eye irritant. Presumably, it does not, >>therefore, meet the criteria as a candidate for a 4-hour REI. > >*************************************************************************** ***** > 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 >*************************************************************************** ***** > > > > > > Gary Fish Maine Board of Pesticides Control Station 28 Augusta, ME 04333 207-287-2731 gary.fish@state.me.us From Rudolph.Kay@epamail.epa.gov Fri May 17 09:12:09 1996 Received: from merlin.rtpnc.epa.gov (merlin.rtpnc.epa.gov [134.67.208.148]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id JAA15590 for ; Fri, 17 May 1996 09:12:08 -0700 (PDT) Received: from epahub2.rtptok.epa.gov by merlin.rtpnc.epa.gov (8.6.9/1.34) id MAA07417; Fri, 17 May 1996 12:11:19 -0400 Received: by epahub2.rtptok.epa.gov (IBM OS/2 SENDMAIL VERSION 1.3.2)/1.0) id AA2522; Fri, 17 May 96 12:10:31 -0400 Message-Id: <9605171610.AA2522@epahub2.rtptok.epa.gov> Received: from EPA with "Lotus Notes Mail Gateway for SMTP" id 5300B6308681D6E08825632D00566146; Fri, 17 May 96 12:10:30 To: wps-forum From: Kay Rudolph Date: 17 May 96 9:09:17 Subject: Re: WPS public meetings X-Importance: High Mime-Version: 1.0 Content-Type: Text/Plain I wasn't sure if Betty Stone's question referred to the two public meetings on WPS that EPA's Assistant Administrator of the Office of Prevention, Pesticides, and Toxic Substances (Dr. Lynn Goldman) will be holding in California in July, or to some other hearings. But thank you, Betty, for reminding me that the WPS-Forum is a great way to get the word out. The U.S. EPA has scheduled a series of public meetings across the country. The meetings are designed to provide an opportunity for those directly affected by the WPS to relay their experiences with the regulation during the first full year of implementation. EPA is soliciting public comment and discussion on the following topics: * Understanding WPS requirements * Success in implementing the requirements * Difficulties in implementing the requirements * Suggestions to improve implementation * Available assistance from regulatory partners and others involved with the WPS * Usefulness of available assistance The results of the public meetings will be used to develop strategies for improving the administration of the WPS. The Agency is interested in receiving written comments as well. Please send comments (to be included in the public docket) to: Jeanne Heying Office of Pesticide Programs (7506C) U.S. Environmental Protection Agency 401 M Street, S.W. Washington, D.C. 20460 Phone (703) 305-7164 Fax (703) 308-2962 The schedule for Lynn Goldman's two meetings in California: July 23, 7:00 to 10:00 PM (people can register as early as 5:00PM) Portuguese Hall 172 West Jefferson Fresno, CA 93706 209-486-6060 July 25, 7:00 to 10:00 PM (again, people can register as early as 5:00PM) Salinas Community Center 940 N. Main Street Salinas, CA 93906 408-758-7351 From sg132@umailsrv0.umd.edu Fri May 17 11:22:51 1996 Received: from umailsrv0.UMD.EDU (umailsrv0.umd.edu [128.8.10.34]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id LAA21595 for ; Fri, 17 May 1996 11:22:46 -0700 (PDT) Received: by umailsrv0.UMD.EDU (5.57/Ultrix3.0-C) id AA08024; Fri, 17 May 96 14:19:25 -0400 Date: Fri, 17 May 96 14:19:25 -0400 Message-Id: <9605171819.AA08024@umailsrv0.UMD.EDU> X-Sender: sg132@umailsrv0.umd.edu Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.berkeley.edu From: sg132@umailsrv0.umd.edu (Susan M. Gardner) Subject: New WPS training material X-Mailer: I work for Pesticide Education Program through the Maryland Cooperative Extension and we are looking to update our audiovisual resources (videos, slide sets, etc.). I was interested if anyone knows of any relatively new videos or slide sets that deal with WPS or endangered species?? If anyone has any suggestions, please send me an email note. Thanks! ****************************************************** Susan Gardner 1300 Symons Hall Dept. of Entomology University of Maryland College Park, Maryland 20742 Phone: 301-405-3940 Fax: 301-314-9290 email address: sg132@umailsrv0.umd.edu From ROYR@cdprsmtp.cdpr.ca.gov Fri May 17 11:55:40 1996 Received: from cdprsmtp.cdpr.ca.gov (cdprsmtp.cdpr.ca.gov [134.186.193.1]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id LAA23358 for ; Fri, 17 May 1996 11:55:38 -0700 (PDT) From: ROYR@cdprsmtp.cdpr.ca.gov Received: from PestReg-Message_Server by cdprsmtp.cdpr.ca.gov with WordPerfect_Office; Fri, 17 May 1996 12:03:54 -0700 Message-Id: X-Mailer: WordPerfect Office 4.0 Date: Fri, 17 May 1996 11:58:06 -0700 To: wps-forum@are.berkeley.edu Subject: REENTRY RISKS As regulators, we have long been critized for what is referred to as a "body count" approach to regulation. There have been several posts on the topic of reentry risks to field workers recently. I would like to throw in a short quote from a recent letter from a highly placed official in CDPR. "You were also questioning the need or basis for restrictions on early entry following pesticide applications. Although we have a considerable volume of illness data, which you have correctly interpreted, it does little to allay concerns about potential long-term effects from lower exposures that are not sufficient to cause a clinical level illness. Acute illness is only one possible outcome from exposure and, if it occurs, usually indicates higher levels of exposure." The issue isn't illness the issue is exposure. ROYR From SHAPIRO.STEVE@EPAMAIL.EPA.GOV Fri May 17 12:14:11 1996 Received: from merlin.rtpnc.epa.gov (merlin.rtpnc.epa.gov [134.67.208.148]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id MAA24188 for ; Fri, 17 May 1996 12:13:55 -0700 (PDT) From: SHAPIRO.STEVE@EPAMAIL.EPA.GOV Received: from lancelot.rtptok.epa.gov by merlin.rtpnc.epa.gov (8.6.9/1.34) id PAA04302; Fri, 17 May 1996 15:13:05 -0400 Received: from cc:Mail by lancelot.rtptok.epa.gov id AA832370770; Fri, 17 May 96 14:53:56 EST Date: Fri, 17 May 96 14:53:56 EST Message-Id: <9604178323.AA832370770@lancelot.rtptok.epa.gov> To: wps-forum@are.Berkeley.EDU Subject: Announcement of Heat Stress Poster WPS FORUM: A VERY limited number of copies of the heat stress poster have been shipped to EPA's Regional Worker Protection Program Contacts. Unfortanately, there was not much funding available when we prepared to go to press at the end of the last fiscal year, but we wanted to get this poster "into the system" with the U.S. Government Printing Office before the fiscal year 1996 budget situation came into full force. Apologies for this. Funds permitting, we hope to reprint the heat stress guide, the poster, and the laminated pocket cards. At present, the guide and the poster are available through GPO; the guide is also available through private sources. Included below are the EPA Press Advisory with two attached fact sheets - "Heat Stress in Agriculture" and "Features of EPA/OSHA's Guide to Heat Stress in Agriculture" Direct feedback to me on any field experience with the heat stress guide or poster would be appreciated. Steve Shapiro Field Operations Division (7506C) Office of Pesticide Programs U.S. EPA Washington, D.C. 20460 703 308-8536 SHAPIRO.STEVE@EPAMAIL.EPA.GOV - - - - - - - - - - - - - - - - - - - - - - - - - - - - - United States Communications, Education, Environmental Protection Agency And Public Affairs (1703) ________________________________________________________________________ Press Advisory FOR RELEASE: FRIDAY, MAY 10, 1996 ENGLISH/SPANISH POSTER AVAILABLE ON MEASURES TO CONTROL HEAT STRESS IN AGRICULTURE EPA and the Occupational Safety and Health Administration (OSHA) have published a multi-colored poster summarizing key elements for employers and workers to follow for controlling heat stress. EPA's Worker Protection Standard for agricultural pesticides requires employers to protect workers from heat-related illness when protective gear must be worn to reduce pesticide exposure. The poster, 20"X 24", is in English on one side and Spanish on the other. In addition to providing basic instructions for preventing heat-related illnesses, the poster also outlines in detail the signs, symptoms, and causes of various heat-related illnesses, as well as first-aid treatment. The poster is a summary of "A Guide to Heat Stress In Agriculture," issued jointly by EPA and OSHA. Copies of the poster (document number 055-000-00544-3) are $1.25 each; the Guide (document number 055-000=00474-9) is $3.50. Both are available from the U.S. Government Printing Office, Superintendent of Documents, Washington, D.C. 20402 (telephone, 202-512-1800). Orders of l00 or more copies receive a 25 percent discount. - - - - - - - - - - - - - - - - - - - - - - - - - - United States Prevention, Pesticides April 1996 Environmental Protection And Toxic Substances Agency (7506C) ________________________________________________________________________ HEAT STRESS IN AGRICULTURE Background In some regions, there are times during the growing season when the temperature stays above 90oF, even at night. High air temperatures and humidities put agricultural workers at special risk of heat illness. Worker Compensation claims for heat illness among agricultural workers are among the highest of any occupation. Pesticide handlers and early entry workers are at even greater risk. The special clothing and equipment they wear for protection from exposure to pesticides can restrict the evaporation of sweat, blocking the body's natural way of cooling itself, which results in a buildup of body temperature. Exposure to certain pesticides can also produce sweating and there can be combined effects with exposure to heat. In addition, pesticides are absorbed through hot, sweaty skin more quickly than through cool skin. What is heat stress? Heat stress is the buildup in the body of heat generated by the muscles during work and of heat coming from warm and hot environments. Heat exhaustion and heat stroke result when the body is subjected to more heat than it can cope with. When the body becomes overheated, less blood goes to the active muscles, the brain, and other internal organs. Workers get weaker, become tired sooner, and may be less alert, less able to use good judgment, and less able to do their jobs well. As strain from heat becomes more severe, there can be a rapid rise in body temperature and heart rate. Workers may not realize that this is happening because there is no pain. Mental performance can be affected with an increase in body temperature of 2oF above normal. An increase of 5oF can result in serious illness or death. The most serious illness is heat stroke. Its effects can include confusion, irrational behavior, convulsions, coma, and even death. Heat stroke can make survivors very sensitive to heat for months and cause varying degrees of brain and kidney damage. More than 20 percent of people afflicted by heat stroke die, even young and healthy adults. An average of nearly 500 people are killed each year in the United States by the effects of heat. During hot weather, heat illness may be an underlying cause of other types of injuries, such as heart attacks on the job, falls, and equipment accidents arising from poor judgment. A program to prevent heat illness will: Protect health. Heat illness is preventable. When less severe forms occur, they can be treated before they become life-threatening. Improve safety. Workers with even mild effects of heat illness are more likely to have accidents and use poor judgment. Increase productivity. People work slower and less efficiently when they are under too much strain from heat. EPA/OSHA's Guide to Heat Stress in Agriculture EPA's Worker Protection Standard for agricultural pesticides requires employers to protect workers who must wear protective gear from heat)related illness. EPA/OSHA's A Guide to Heat Stress in Agriculture was written to provide assistance in meeting this requirement. * * * The Guide is available from the U.S. Government Printing Office (GPO) and other, private sources. A summary of the Guide in chart form -- English on one side, Spanish on the other, 24" X 20", in color and suitable for posting -- is also available. To order the Guide from GPO, call (202) 512-1800 or write GPO, Superintendent of Documents, Washington, DC 20402, and refer to document number 055-000-00474-9. Copies of the Guide from GPO are $3.50 each, with a 25% discount for orders of 100 or more. To order the English/Spanish summary chart, call or write GPO and refer to document number 055-000-00544-3. Copies of the summary chart are $1.25 each, with a 25% discount for orders of 100 or more. - - - - - - - - - - - - - - - - - - - - - - - - - - United States Prevention, Pesticides April 1996 Environmental Protection And Toxic Substances Agency (7506C) ________________________________________________________________________ FEATURES OF EPA/OSHA's GUIDE TO HEAT STRESS IN AGRICULTURE EPA/OSHA's A Guide to Heat Stress in Agriculture offers practical, step-by-step guidance for non-technical managers on how to set up and operate a heat stress control program. The Guide was developed in response to requests from agricultural employers and others. Its "how-to" approach avoids presentation of overly technical information, while remaining precise and true to the principles of good occupational hygiene. OSHA views the Guide as useful in other industries also under its jurisdiction, including hazardous waste sites. EPA sought out reviews from people with practical experience, expertise, a critical point of view, or interest in the subject who would give the most rigorous reviews possible in order to make the Guide technically strong and practical. Over 40 people responded, including heat stress experts in the U.S. Public Health Service and the armed forces; psychrometric experts; occupational physicians; leaders of state pesticide programs; fixed- and rotary-wing aerial pesticide applicators; farm workers; farm worker advocates; and officials of grower associations. ~ Non-technical, comprehensive occupational program for heat stress. ~ Recognized heat stress management principles tailored to the particular conditions of agriculture. Offers "best practice." ~ First Aid chart: Streamlined, yet comprehensive for non-technical managers and workers. ~ Distinguishes between the symptoms of organophosphate/carbamate poisoning and heat exhaustion. The symptoms of these illnesses are somewhat similar. The Guide addresses the potential for confusion and inappropriate first-aid treatment. ~ Acclimatization to heat stress de-mystified. (Acclimatization is a person's adaption to levels of work and heat.) ~ Approaches for setting work/rest cycles make the benefits of a key technical index - Wet Bulb Globe Temperature - available to non-technical persons, using commonly available weather information and without the need for expensive instruments. (Wet Bulb Globe Temperature is a technical index which combines the effects of humidity, air movement, air temperature, and radiation, such as sunshine.) ~ Sympathetic approach taken to the considerations of employers and workers. E.g., frank discussion of how protective gear can be inconvenient and uncomfortable - and how to minimize these problems; how economic and other pressures of crop production can cause employers and workers themselves to resist interrupting work, even when heat stress conditions become hazardous; how some workers deliberately limit the amount of water they drink; and how flexibility and the use of experience and good judgment are important when setting work/rest cycles. ~ Cooling vests examined as a relatively inexpensive way to address certain in tolerable heat stress conditions, especially heat stress conditions involving protective gear. (Cooling vests have an added implicit benefit of boosting worker productivity.) ~ Special hazards of agricultural pilots addressed comprehensively. The particular dangers of sub-clinical effects of heat stress and pesticide exposure, singly and in combination, and the need for unimpaired mental performance among pilots are stressed. U.S. Air Force indices for hot weather aircraft operation were adapted, with U.S. Air Force review and concurrence, for agricultural aviation. ~ Procedures for heat stroke, a life-threatening medical emergency, spelled out in the first aid program. Included are special heat stroke procedures for pesticide handlers and early entry workers. ~ Procedures given for employers following-up on incidents of heat illness, to prevent additional occurrences and to improve, as needed, an employer's heat stress program. ~ Resources for agricultural employers and pesticide applicators included in the appendices. * * * The Guide is available from the U.S. Government Printing Office (GPO) and other, private sources. A summary of the Guide in chart form -- English on one side, Spanish on the other, 24" X 20", in color and suitable for posting -- is also available. To order the Guide from GPO, call (202) 512-1800 or write GPO, Superintendent of Documents, Washington, DC 20402, and refer to document number 055-000-00474-9. Copies of the Guide from GPO are $3.50 each, with a 25% discount for orders of 100 or more. To order the English/Spanish summary chart, call or write GPO and refer to document number 055-000-00544-3. Copies of the summary chart are $1.25 each, with a 25% discount for orders of 100 or more. From Mac82nd@aol.com Fri May 17 13:59:25 1996 Received: from emout12.mail.aol.com (emout12.mx.aol.com [198.81.11.38]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id NAA27292 for ; Fri, 17 May 1996 13:59:24 -0700 (PDT) From: Mac82nd@aol.com Received: by emout12.mail.aol.com (8.6.12/8.6.12) id QAA13059 for wps-forum@are.berkeley.edu; Fri, 17 May 1996 16:58:53 -0400 Date: Fri, 17 May 1996 16:58:53 -0400 Message-ID: <960517165852_537429671@emout12.mail.aol.com> To: wps-forum@are.berkeley.edu Subject: Pesticides and sex Thought people in this forum would be interested in this article that ran in the Milwaukee Journal Sentinel. Pesticide use is like unsafe sex Sex and farming have this in common: cavalier attitudes toward risk while in engaging in either one can result in fatal diseases. So says a Medical College of Wisconsin researcher with a new grant to take what has been learned about modifying sexual behavior to prevent AIDS and applying it to preventing cancer among farmers who use pesticides. "There are a lot of similarities," the researcher said. The four-year $750,000 study is being paid for by the National Cancer Institute. From fels@open.org Sat May 18 08:53:34 1996 Received: from hp_open.open.org (hp_open.open.org [199.2.104.1]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id IAA09903 for ; Sat, 18 May 1996 08:53:31 -0700 (PDT) Received: (from root@localhost) by hp_open.open.org (8.7/8.7) id IAA03740 for ; Sat, 18 May 1996 08:50:09 -0700 (PDT) Date: Sat, 18 May 1996 08:50:09 -0700 (PDT) Message-Id: <199605181550.IAA03740@hp_open.open.org> Received: from opengovt56.open.org(199.2.104.56) by hp_open.open.org via smap (V1.3) id sma003731; Sat May 18 08:49:59 1996 X-Sender: fels@opengovt.open.org X-Mailer: Windows Eudora Light Version 1.5.2 Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: Roberta Gruber Subject: Re: New WPS training material Farm Employers Labor Service has a great bi-lingual WPS video that is EPA approved and needs no addendum. Contact them at (800) 753-9073. Cost is $49.00 At 02:19 PM 5/17/96 -0400, you wrote: >I work for Pesticide Education Program through the Maryland Cooperative >Extension and we are looking to update our audiovisual resources (videos, >slide sets, etc.). I was interested if anyone knows of any relatively new >videos or slide sets that deal with WPS or endangered species?? If anyone >has any suggestions, please send me an email note. >Thanks! > >****************************************************** > Susan Gardner > 1300 Symons Hall > Dept. of Entomology > University of Maryland > College Park, Maryland 20742 > Phone: 301-405-3940 Fax: 301-314-9290 > email address: sg132@umailsrv0.umd.edu > > > From cefresno@ucdavis.edu Sun May 19 08:29:42 1996 Received: from guilder.ucdavis.edu (root@guilder.ucdavis.edu [128.120.8.181]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id IAA18685 for ; Sun, 19 May 1996 08:29:40 -0700 (PDT) From: cefresno@ucdavis.edu Received: from dialupAcorn.ucdavis.edu by guilder.ucdavis.edu (8.7.5/UCD3.5.4) id IAA09992; Sun, 19 May 1996 08:29:35 -0700 (PDT) Date: Sun, 19 May 1996 08:29:35 -0700 (PDT) Message-Id: <199605191529.IAA09992@guilder.ucdavis.edu> To: wps-forum@are.Berkeley.EDU Subject: news from fresno Cc: cefresno@ucdavis.edu This is Steve Sutter ... As part of the Motor Vehicle Safety Festival in Lindsay, Sunday, June 2, 1996, free Worker Protection Standard fieldworker pesticide safety trainings will be conducted in Spanish by Americorps volunteers in cooperation with the UC Agricultural Personnel Management Program. ... Classes will take place at various times starting at 1 p.m. inside the Lindsay Memorial Hall, 775 N. Elmwood, just across the street from Lindsay City Park. ... EPA training verification blue cards will be issued. ... For information about the fieldworker pesticide safety trainings, call Mary Bautista at (209) 627-0100, or Steve Sutter at (209) 456-7560. ... "Fresno Clear." From smcdonld@freenet.columbus.oh.us Mon May 20 08:20:30 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id IAA27103 for ; Mon, 20 May 1996 08:20:28 -0700 (PDT) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.7.5/5.960408) id PAA07232; Mon, 20 May 1996 15:20:23 GMT Received: by acme.freenet.columbus.oh.us (8.6.10) id LAA09307; Mon, 20 May 1996 11:20:23 -0400 Date: Mon, 20 May 1996 10:45:36 -0400 (EDT) From: Sally McDonald Subject: Re: Credibility To: wps-forum@are.Berkeley.EDU cc: "'WPS-Forum'" In-Reply-To: <960517133823_73507.555_HHB64-2@CompuServe.COM> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On 17 May 1996, Bob Roach wrote: > We will soon be faced with a situation where some of the requirements don't make much sense and don't provide any tangible reduction in risk. This may erode respect for the pesticide use enforcement program and cause attitude of cooperation to become adverse. > > What I am referring to for the most part are some of the changes in hazard > communication and giving of notice. Now growers will have to "display" > application specific information rather than provide it when asked. Nobody will look at it. Sally replies: When the WPS was proposed, pesticide-specific information was to be provided to workers upon request. This proposal generated many comments. The majority of the commenters, including worker organizations, State agencies, and a land-grant university, recommended that the information be provided through posting. NACA recommended that the information be provided with each oral warning. Some commenters cited worker intimidation as the reason for opposing the proposal that information be provided upon request. EPA was persuaded by the comments to require posting of this information at a central place. On that basis, EPA was persuaded to drop the proposed daily oral warnings and require one-time oral warnings instead. It should also be noted that there has already been an enforcement case where a grower refused to give a worker information about the pesticide the worker had been exposed to even though the worker was exhibiting signs of pesticide poisoning. Interestingly, among the strongest worker-organization comments opposed to workers having to request the pesticide-specific information came from California. Bob wrote: They will have to notify all employees within 1/4 mile rather than those who are likely to enter the treated area. Sally replies: In the proposed WPS, workers on an ag establishment would have to be notified of pesticide applications and areas remaining under an REI, except if the worker would not be in the treated area or any neighboring areas, including growing areas and labor camps, that are contiguous or separated only by a roadway from the treated area. Many comments were received on the proposed requirement. Some comments supported the exception as written; some, including Congress, requested that the exceptions be dropped and that workers be notified of any pesticide-treated areas on the property, because crews may enter treated areas by mistake. A few comments requested a definition of the word "neighboring." EPA decided to require notification if workers may be within 1/4 mile of the treated area's perimeter. This distance was chosen for several reasons. First, data from studies show that residue drift from a treated area is usually negligible beyond 1/4 mile. Second, the Agency believes that 1/4 mile is the farthest distance that workers would be likely to digress from their path or work site for rest or meal breaks. It is difficult to imagine EPA adopting a standard whereby a grower could determine whether to provide notification based on the grower's judgement of the likelihood that the worker would enter the area. Such a provision would be extremely difficult to enforce, since the grower could always assert that he/she had used their judgement and determined that the worker was "unlikely" to enter a particular area. Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From aftgoul@gatekeeper.ddp.state.me.us Mon May 20 08:21:42 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id IAA27160 for ; Mon, 20 May 1996 08:21:40 -0700 (PDT) Received: from [141.114.137.97] ([141.114.137.97]) by gatekeeper.ddp.state.me.us (8.7.4/8.6.12) with SMTP id GAA06985 for ; Mon, 20 May 1996 06:19:16 -0400 (EDT) Date: Mon, 20 May 1996 06:19:16 -0400 (EDT) Message-Id: <199605201019.GAA06985@gatekeeper.ddp.state.me.us> X-Authentication-Warning: gatekeeper.ddp.state.me.us: Host [141.114.137.97] didn't use HELO protocol 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: Training Materials In response to Susan in Maryland - Last summer, Don Baumgartner, EPA Region V, posted a listing of WPS videos and supplier information. I don't know if you have this already, but I think it's worth posting again. Tammy Gould Maine Board of Pesticides Control ---------------------------------------------------------------------------- ----------- > >In response to several inquiries recently received, asking for more >information on the purchase of the various WPS training videos which >I itemized last July 24, I provide below the direct contacts and >purchase information pertinent to each of the videos previously >listed. Please remember to include sales tax for those ordering >videos within the same State. Remember also to specify English or >Spanish for each video, since some videos are provided in one or the >other language for the same price. I trust that this will satisfy the >present and any future inquiries. > >Donald Baumgartner >EPA Region 5 > > >************************************************* >July 1995 > WORKER PROTECTION STANDARD > > EPA-APPROVED TRAINING VIDEOS AVAILABLE > > > Title; Producer(s); EPA-Approved; Source > >1) You Can Do It - How to Teach Pesticide Health & Safety to >Farmworkers & Their Families; Workgroup on Pest. Health & Safety >(Wash.); NOT Appr. for training (EPA funded, good for >train-the-trainer programs) (1991); Available at $19.00 ea. from Work >Group on Pesticide Health and Safety, P.O. Box 801, Vashon Island, >Wash. 98070 (206/463-9000). > >2) Shedding Some Light on Pesticide Protection; EPA Off. Res. & >Develop.; NOT Appr. for training (EPA funded, good for >train-the-trainer programs) (1994); Available at $15-20 ea. from >Cornell Univ. Audiovisual Center, 7 Business & Technology Park, >Ithaca, NY 14850 (607/255-2090) > >3) Pesticide Safety - Worker Protection (worker/handler); Univ. of >Idaho; Yes (1993); Available at $19.95 ea. (add $3 for postage) from >Ag Communications Center, Univ. of Idaho, Moscow, Idaho 83844-2332 >(208/885-7945). > >4) The Playing Field; Natl. Migrant Res. Prog.; NOT approved for >training (good for train-the-trainer programs); Available at $35.00 >ea. from Natl. Migrant Resource Program, Inc., 1515 Capital of Texas >Hwy. South, Ste. 220, Austin, TX 78746 (512/328-7682). > >5) WPS for Greenhouses & Nurseries (worker/handler); Iowa State >Univ.; NOT appr. for training (1994) (employer education tool); >Available at $20 ea. from Iowa State Univ., Extension Entomololgy, >109 Insectary Building, attn. Julie Honeick, Ames, IA 50011-3140 >(515/294-1101). > >6) Pesticide Handlers and the WPS (handler); Michigan State Univ.; >Yes (1994); Available at $25.00 ea. (VT048) from Michigan State >University Bulletin Office, 10-B Agriculture Hall, MSU, East Lansing, >MI 48824-1039 (517/355-0240). > >7) Chasing the Sun (worker); Natl. Migrant Res. Prog.; Yes (1994); >Available at $35.00 ea. from Natl. Migrant Resource Program, Inc., >1515 Capital of Texas Hwy. South, Ste. 220, Austin, TX 78746 >(512/328-7682). > >8) Protect Yourself from Pesticides (worker); SOS Communications; Yes >(1994); Available at $19.95 ea. (add 10% postage) from SOS >Communications, 2999 Monterey Salinas Hwy., Suite 4, Monterey, CA >93940 (408/375-2035). > >9) Greenhouse Pesticide Safety Training (worker/handler); >Floriculture Greenhouse Ind. Alliance; Yes (1995); Available at >$49.95 ea. (non-member) (add $5 shipping ea.) from Professional Plant >Growers Assoc., P.O. Box 27517, Lansing, MI 48909-0517 >(517/694-7700). > >10) Pesticide Safety for You & Your Family's Health (worker); Kent >Co. CES/Mich. State Univ.; Yes (1995); Available at $25 ea. (order # >VT046) (add $5 postage) from Mich. State Univ. Bulletin Office, 10-B >Agriculture Hall, MSU, East Lansing, MI 48824-1039 (517/355-0240). > >11) Safe Use of Pesticides in Outdoor Nurseries (worker/handler); >Visual Media (Univ. CA); Yes (1995); Available at $40.00 ea. (English >& Spanish combined) from Visual Media, Univ. California, Davis 95616 >(916/757-8980). > >12) Pesticide Safety - Help Workers Protect Themselves; St. Joseph >Co. CES/MI State Univ. Ext.; Yes (1995); Available at $30.00 ea. from >St. Joseph County Mich. State Univ. Extension, P.O. Box 280, >Centreville, MI 49032-0280 (616/467-5511). > >13) Pest. Safety Training for Ag. & Early-Entry Workers; W. VA Univ. >CES; Yes (1995); Available at $14.00 ea. from West Virginia Univ., >Safety & Health Extension, 130 Tower Lane, P.O. Box 6615, Morgantown, >WV 26506-6615 (304/293-3096). > >14) Pesticide Training for Agricultural Employees (worker/handler); >Farm Employers Labor Service (Calif.); Yes (1995); Available at $49 >ea. from Farm Employers Labor Service, 1601 Exposition Blvd., FB7, >Sacramento, CA 95815-5103 (916/924-4124). > From smcdonld@freenet.columbus.oh.us Mon May 20 08:42:39 1996 Received: from ronco.freenet.columbus.oh.us (ronco.freenet.columbus.oh.us [164.107.107.13]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id IAA27506 for ; Mon, 20 May 1996 08:42:36 -0700 (PDT) Received: from acme.freenet.columbus.oh.us by ronco.freenet.columbus.oh.us (8.7.5/5.960408) id PAA09386; Mon, 20 May 1996 15:42:32 GMT Received: by acme.freenet.columbus.oh.us (8.6.10) id LAA14924; Mon, 20 May 1996 11:42:32 -0400 Date: Mon, 20 May 1996 11:20:41 -0400 (EDT) From: Sally McDonald Subject: Re: Glyphosate To: wps-forum@are.Berkeley.EDU cc: "'WPS-Forum'" In-Reply-To: <960517133837_73507.555_HHB64-3@CompuServe.COM> Message-ID: MIME-Version: 1.0 Content-Type: TEXT/PLAIN; charset=US-ASCII On 17 May 1996, Bob Roach wrote: > Sally, Be careful how you interpret the California illness data. Glyphosate is a translocated herbicide. It is generally not applied to growing crops and > reentry is usually not an issue. The reported illnesses are, in my experience, > applicators who get it in their eye and experience conjunctivitis from which > they fully recover. Sally replies: Bob, I am nearly always VERY careful about how I interpret California illness data. I stand by my statements. Not only has glyphosate been implicated in numerous handler incidents, it has also been implicated in reentry (residues in fields) incidents. In fact, EPA's Reregistration Eligibility Document (RED) on glyphosate cited concerns about epidemiological evidence in noting it was establishing a permanent 12-hour restricted-entry interval. Whether the irritant is glyphosate itself or a surfactant makes little difference. Whatever is causing the irritation effects must still be present for at least some time period after application. Finally, it has been my observation in the years I've worked with pesticides that many pesticides thought at one time to be "low toxicity" have turned out to present a toxicity concern as more information about potential adverse effects are explored. Many fungicides, for example, are tightly regulated or have been removed from the market due to concerns about non-acute adverse effects. In addition, little is known about the possible synergistic effects of exposures to combinations of chemicals. However, the newest evidence in the Gulf War Syndrome concerning the potentially toxic effects resulting from the combination of two otherwise "low-toxicity" chemicals is, perhaps, a clue. I do not believe that all pesticides are harmful. I do believe that as our knowledge base increases pesticides (and other chemicals) previously thought to be low toxicity will be found to present a health risk. I believe that prudent health and safety measures designed to reduce overall exposure to any pesticide encountered in the workplace are a good hedge against "unknown" adverse effects. I also believe that agricultural workers will be far more willing to cooperate in these measures if they have been provided training about possible adverse effects. Sally -- Sally A. McDonald, Information Impact 5837 Tartan Circle, Dublin, OH 43017 From aftgoul@gatekeeper.ddp.state.me.us Tue May 21 13:26:56 1996 Received: from gatekeeper.ddp.state.me.us (gatekeeper.ddp.state.me.us [141.114.130.70]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id NAA00443 for ; Tue, 21 May 1996 13:26:52 -0700 (PDT) Received: from [141.114.137.97] ([141.114.137.97]) by gatekeeper.ddp.state.me.us (8.7.4/8.6.12) with SMTP id KAA00269 for ; Tue, 21 May 1996 10:52:28 -0400 (EDT) Date: Tue, 21 May 1996 10:52:28 -0400 (EDT) Message-Id: <199605211452.KAA00269@gatekeeper.ddp.state.me.us> X-Authentication-Warning: gatekeeper.ddp.state.me.us: Host [141.114.137.97] didn't use HELO protocol 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: Free Brochures! I recently received 125 copies EACH of the small "Steps to Protect Yourself from Pesticides" in English/Vietnamese, English/Laotion, and English/Haitian Creole from my short-on-shelf-space Regional office. We do not have a big call for materials in those languages in Maine. While supplies last, I will gladly send copies to states, industry associations, worker advocacy groups or individual growers on the Forum. I hate to see educational materials go to waste. To get your copies, email me at aftgoul@state.me.us with your request and snail-mail address. Tammy Gould Maine Board of Pesticides Control From MCMORRAJ@uma5.oes.orst.edu Tue May 21 17:00:30 1996 Received: from OES.ORST.EDU (OES.ORST.EDU [128.193.124.2]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id RAA08371 for ; Tue, 21 May 1996 17:00:28 -0700 (PDT) Received: from uma5.UUCP by OES.ORST.EDU with UUCP id AA24892 (5.65b/IDA-1.4.3); Tue, 21 May 96 16:59:11 -0700 Received: by uma5.OES.ORST.EDU (UUPC/extended 1.11q); Tue, 21 May 1996 15:55:24 pdt From: MCMORRAJ@uma5.oes.orst.edu Message-Id: <31a249dd.uma5@uma5.OES.ORST.EDU> To: wps-forum@are.Berkeley.EDU Date: 21 May 96 15:55:24 Subject: Priority: normal X-Mailer: Pegasus Mail v2.3 (R4). Could someone please tell me how to get off this list. I have tried everything!!!! Jeff McMorran********************************************************************** Philip B. Hamm Extension Plant Pathologist Hermiston Agricultural Research & Extension Center Oregon State University P.O. Box 105 Hermiston OR 97838 Phone (503) 567-8321 Fax (503) 567-2240 E-mail hammp@Uma5.oes.orst.edu ********************************************************************** From charlie@hpirs.stjohn.hawaii.edu Tue May 21 17:52:35 1996 Received: from relay1.Hawaii.Edu (root@relay1.Hawaii.Edu [128.171.3.53]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id RAA09510 for ; Tue, 21 May 1996 17:52:31 -0700 (PDT) Received: from uhunix4.its.Hawaii.Edu ([128.171.44.54]) by relay1.Hawaii.Edu with SMTP id <11403(10)>; Tue, 21 May 1996 14:52:28 -1000 Received: from hpirs.stjohn.hawaii.edu ([128.171.243.7]) by uhunix4.its.Hawaii.Edu with SMTP id <105790>; Tue, 21 May 1996 14:52:20 -1000 Received: from HPIRS/MAILQUEUE by hpirs.stjohn.hawaii.edu (Mercury 1.21); 21 May 96 14:48:26 -1000 Received: from MAILQUEUE by HPIRS (Mercury 1.21); 21 May 96 14:48:21 -1000 Received: from [128.171.243.35] by hpirs.stjohn.hawaii.edu (Mercury 1.21); 21 May 96 14:48:15 -1000 Message-Id: Mime-Version: 1.0 Content-Type: text/plain; charset="us-ascii" To: wps-forum@are.Berkeley.EDU From: charlie@hpirs.stjohn.hawaii.edu Subject: Re: Free Brochures! Date: Tue, 21 May 1996 14:52:14 -1000 Please send me one copy of the English/Lao & English/Vietnamese leaflet, "Steps to Protect Yourself from Pesticides" to: Charles Nagamine Env. Biochemistry 1800 East-West Rd., #329 Honolulu, HI 96822 Thanks for the offer. Charles Nagamine Environmental Biochemistry Dept. College of Tropical Agriculture & Human Resources University of Hawaii @ Manoa From jenbil@mail.calypso.com Tue May 21 18:58:12 1996 Received: from kinsey.fia.net (root@kinsey.fia.net [199.172.120.7]) by are.Berkeley.EDU (8.7.5/8.7.3) with ESMTP id SAA10675 for ; Tue, 21 May 1996 18:58:10 -0700 (PDT) Received: from 199.172.120.181 (3tsp8.calypso.com [199.172.120.181]) by kinsey.fia.net (8.7.4/8.6.12) with SMTP id SAA22619 for ; Tue, 21 May 1996 18:57:49 -0700 (PDT) Message-ID: <31A201DA.331D@mail.calypso.com> Date: Tue, 21 May 1996 17:48:10 +0000 From: Jensen X-Mailer: Mozilla 2.0 (Macintosh; I; 68K) MIME-Version: 1.0 To: wps-forum@are.Berkeley.EDU Subject: Re: References: <31a249dd.uma5@uma5.OES.ORST.EDU> Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit I am not really familiar with this particular computer's commands,but I subscribe to other mail lists, and it always works to do this: Send the email to the COMPUTER not the list. ONLY put UNSUBSCRIBE in the message body. Laurie From shenkm@ava.BCC.ORST.EDU Wed May 22 07:32:17 1996 Received: from BCC.ORST.EDU (root@ava.BCC.ORST.EDU [128.193.86.4]) by are.Berkeley.EDU (8.7.5/8.7.3) with SMTP id HAA15701 for ; Wed, 22 May 1996 07:32:14 -0700 (PDT) Received: from smo-1000-E by BCC.ORST.EDU (4.1/SMI-4.1) id AA09913; Wed, 22 May 96 07:32:44 PDT Date: Wed, 22 May 96 07:32:44 PDT Message-Id: <9605221432.AA09913@BCC.ORST.EDU> X-Sender: shenkm@bcc.orst.edu X-Mailer: Windows Eudora Version 1.4.4 Mime-Version: 1.0 Con