ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C.  20460

           OFFICE OF PREVENTION, PESTICIDES, AND TOXIC SUBSTANCES

                           [stamped Sep 22 1994]


Mr. Rick Perry
Chairman, NASDA Worker Protection Task Force
Commissioner, Texas Department of Agriculture
1154 15th Street, N.W., Suite 1020
Washington, D.C.  20005

Dear Mr. Perry:

   On July 8, 1994, the National Association of State Departments of 
Agriculture (NASDA) submitted to the Administrator of the Environmental 
Protection Agency (EPA) a petition for rulemaking to revise portions of 
the Worker Protection Standard (WPS). This letter is to acknowledge 
receipt of NASDA's petition.  We are in the process of completing our 
formal response to the petition and expect to forward the response to 
NASDA within thirty days.  This letter is also to inform you of other 
actions EPA anticipates taking by January 1995 to address five concerns 
raised earlier this year through public meetings.  These actions are 
discussed more fully below.

   As you know, the EPA Worker Protection Standard was revised in 1992 
to provide significant additional health protection for close to four 
million farmworkers exposed to pesticides in the course of their work.  
The revised standard was the result of a seven-year long rulemaking 
process which included extensive public outreach and comment, with full 
involvement of the agricultural community as well as other affected 
stakeholders.  Over three hundred public comments were received, 
reviewed and considered in developing the final rule.

   The rule takes basic steps to reduce exposure to pesticides, 
mitigate any harmful exposures, and inform farm workers so that they can 
take the measures needed to protect themselves.  The time has come to 
ensure health protection for the farmworkers of this nation.  I believe 
that this is a goal we all share.  To achieve this goal, we are moving 
forward to full implementation of the WPS.

   As you know, our 1994 agenda has been based on the results of two 
public meetings held earlier this year with those charged with 
implementing the WPS program.  Out of those meetings, we identified five 
major actions which needed to be addressed by this coming January.  
These are (1) complete and distribute the educational materials needed 
in the field; (2) explore an exemption for early entry irrigation 
activities; (3) consider proposing shorter restricted entry intervals 
(REIs) for lower risk pesticides, such as many biological pesticides; 
(4) reassess the training provisions of the rule; and (5) reassess the 
crop advisor provisions of the rule.

   The Agency committed to addressing these actions by January, and 
has been working diligently on them since April.  As you mentioned in 
your September 8, 1994, letter to Senator Cochran, the "EPA has done a 
good job in providing the educational materials...".  We are proud of 
this accomplishment.  Development, production and distribution of the 
needed materials is due to the successful cooperation and sharing of 
resources around the country, and has brought together many 
organizations and individuals who traditionally have been at both ends 
of the spectrum.  These groups included State Departments of 
Agriculture, Cooperative Extension Service, trade and grower groups, 
chemical companies and retail associations, farmworker groups, safety 
and health training specialists and the Federal government, among 
others.

   We are advancing the other four actions and expect to publish for 
comment the following: 1) a proposed exception for early-entry 
irrigation activities; 2) a Pesticide Registration Notice proposing 
shorter Restricted Entry Intervals for lower risk pesticides (such as 
many biologicals); 3) a proposed revision to safety training 
requirements; and 4) proposed revisions to the Crop Advisor provisions.  
Based on public comment, and if the administrative record supports the 
proposed changes, we fully expect to complete the first two actions by 
January 1, 1995.  Revisions to the training and crop advisor provisions 
require formal rulemaking.  These actions should be proposed by January, 
and completed rapidly after the close of the public comment period.  
With these actions, EPA is meeting its commitment to address these 
issues in the January timeframe.

   We want to keep the channels of communication open to NASDA and to 
the many other stakeholders in WPS implementation.  EPA will continue to 
work with you and others to make the Worker Protection Program a 
success.  Let me reiterate our commitment to work with the States as our 
full partners.  Please feel free to call me directly with any questions 
or comments.

                                         Sincerely,

                                         [signed: Susan H. Wayland for]

                                         Lynn R. Goldman, M.D.
                                         Assistant Administrator