AGRICULTURAL PERSONNEL MANAGEMENT

NEWSLETTER

This checklist blends current California regulations with proposed revisions conforming to the federal EPA Worker Protection Standards.

1. Restricted use materials, acquired under permit, are used by or under supervision of a certified private or commercial applicator aware of application site conditions and available to direct noncertified applicators. The ag commissioner gets a "notice of intent" at least 24 hours before application of a restricted use material. Pesticide use is reported to the commissioner monthly. Pest control operators (PCOs) give notice (by site ID) to the operator of the property treated, within 24 hours after an application. Notice and use records are kept 2 years.

2. Labels are at use sites. Pesticide containers are properly labeled, rinsed, and drained at time of use. PCOs mark equipment (readable from 25 feet) with a business name or license number.

3. Skull-and-crossbones and irrigation warning signs are posted around treated fields when required by label or regulation, unless access to the field is controlled to assure no employees (except applicators) enter or walk within 1/4 mile during the application and the restricted entry interval (REI). Generally, posting is required for: pesticides with high dermal toxicity or skin irritation potential; application of a category 1 or minimal exposure pesticide (bromoxynil, folpet, oxydemeton, propargite); and applications with REIs over 7 days. Signs are erected before application, but not unless it is scheduled within 24 hours; they are removed within 3 days after the REI.

4. California REIs for certain crop/pesticide combinations, longer than label-specified REIs, are followed (azinphos-methyl, chlorpyriphos, diazinon, endosulfan, methidathion, methomyl, parathion-methyl, phorate, phosmet, propargite, and sulfur).

5. Pesticide storage areas with containers which hold or have held pesticides labeled with the signal words "DANGER" or "WARNING" are posted with signs visible from all directions of likely approach. Signs (readable from 25 feet) say in English and Spanish: "Danger, Poison Storage Area, All Unauthorized Persons Keep Out, Keep Door Locked When Not In Use."

6. Unless the field is posted, prior notice of application (treated area's location/description, the time entry is restricted, and instructions not to enter the treated field during the REI) is given employees, FLCs, and commercial applicators who may come within 1/4 mile of the treated field during the application or REI.

7. Fieldworkers assigned to work in a treated field have received within the last 5 years, prescribed general pesticide safety training, conducted by a qualified trainer, before they begin work in the treated field. When employees are working as fieldworkers in a treated field a completed PSIS leaflet A-9 is displayed at the worksite, or any central location employees gather at before transport to the worksite. A treated field is a field that has been treated with a pesticide or had a REI in effect in the last 30 days. The A-9 is read to any requesting employee in a language (s)he understands.

8. Use records and MSDSs for pesticides that have been applied to the treated field within the past 2 years are kept in a central location accessible to fieldworkers who enter the field, including FLC employees, and employees' representatives and physicians. Employees and FLCs are advised of the location of this information before they're allowed to enter the field. Fieldworkers are advised they have a right of access to the information (within 48 hours), and that they are protected against discharge or other discrimination when exercising these rights.

9. Application-specific information for fieldworkers and pesticide handlers (treated area identification; application time/date; REI; product name, EPA registration number, and active ingredients) is displayed within 24 hours of an application's completion, and includes all applications on the establishment made to treated fields within 1/4 mile of where employees will work. The information stays displayed until the area no longer meets the treated field definition, or employees are no longer on the establishment, whichever occurs earlier. A binder or filing cabinet may be used to display application-specific information. Document originals or copies may be used.

10. Fieldworker "decontamination facilities" requirements are met by compliance with the handwashing and toilet facilities required by Cal/OSHA's field sanitation standard.

11. No employee is allowed or directed to enter or stay in a treated field before the REI specified by the product label or California regulation ends, except as provided by early entry, limited contact or no contact activity. Operating tractors or other equipment from inside an enclosed cab or when shields or other control methods, such as operator placement, physically prevent the employee's contact with anything that has been treated is considered "no contact" activity.

12. Employees entering a treated field during a REI at least 4 hours after application, to do "limited contact irrigation and other activities" are provided label-specified early entry PPE (or coveralls, socks, chemical-resistant footwear, chemical-resistant gloves, and any label-specified protective eyewear), are informed (orally or by posting notice) that this early entry exception is being used, and such employee's time in the treated area does not exceed specified limits. The early entry, limited contact exception is not allowed for "double notification" pesticides requiring both oral notification of and the posting of treated fields.

13. Early entry fieldworkers are advised of: the importance of washing after the exposure period; the label's human hazards/precautions; poisoning symptoms; first aid; use and care of required early entry PPE; and prevention, recognition, and first aid for heat related illness. Measures are taken to prevent heat illness, when necessary.

14. Early entry fieldworkers are given required PPE and are provided for its cleaning (according to the label or, absent instructions, washed in detergent and hot water), repair and replacement when it cannot be adequately cleaned or repaired. PPE is inspected before each day of use, and is used properly. Early entry PPE is kept separate from clothing, in a pesticide free place, when not used.

15. A clean, pesticide free place for storing personal clothes and putting on PPE before work and taking off PPE after work is provided for early entry fieldworkers. Cleaned, early entry PPE is dried or stored in a well-ventilated place. Contaminated PPE is kept and washed separately from other clothing/laundry. PPE remains the employer's property. Early entry workers are not allowed or directed to take pesticide contaminated PPE home. Persons who clean/launder PPE are informed that the equipment may be contaminated, and told about hazards and how to properly handle and clean it.

16. At least 1 pint of eyeflush water is immediately accessible (carried by the fieldworker or on the vehicle the fieldworker is using) to each fieldworker performing, during a label-specified REI, early entry activities in a treated field for which the label requires protective eyewear.

17. Before employees handle pesticides, a copy of Pesticide Safety Information Series leaflet A-8 is displayed at a central location. Use records, applicable PSIS leaflets, and MSDSs are kept at an accessible central workplace location. A written handler training program is maintained covering specific pesticides, or chemically-similar pesticide groups, and given by a qualified trainer, before employees handle them. Training, continually updated to cover new pesticides handled, is repeated annually. The date and extent of initial/annual handler training and the job assigned is recorded, signed by the trainee, and kept 2 years at an accessible central location. Certified applicators are deemed fully trained for these purposes.

18. Emergency medical care for handlers and fieldworkers working in treated fields is planned for in advance. Handler employees and fieldworkers (or fieldworker supervisors) are informed of the name, location, and telephone number of an emergency medical facility that has been located. This information is posted for handlers at the worksite. If the facility is not reasonably accessible from the worksite, procedures to get medical care are posted for handlers. Fieldworkers and their supervisors are informed of procedures to follow to get emergency medical help.

19. Employees handling category 1 pesticides alone during the day contact a responsible adult every 2 hours; each hour from sunset to sunrise. When employees use toxicity category 1 or 2 organophosphate or carbamate pesticides, records are kept of the employee, pesticide, and use date. A cholinesterase testing program is maintained for handlers regularly using these pesticides.

20. All handlers are provided sufficient water, soap, and single use towels for routine washing of hands and face and for emergency eye flushing and washing of the entire body. One clean change of coveralls is available at each decontamination site.

21. Employees regularly handling category 1 or 2 pesticides have a change area to remove PPE, change clothes, wash hands and face, and for eye flushing and washing of the entire body. Towels, soap, and wash water are available (minimum 10 gallons for one handler; 20 for two or more handlers). Handlers are instructed to shower with warm water and soap as soon as possible after work. A clean place to store personal clothing not used while working is provided.

22. Employees handling category 1 or 2 pesticides are provided coveralls to wear, and remove them and wash after work. Potentially contaminated coveralls removed at the worksite or headquarters are not taken home by employees. Employees whose work day does not involve return to headquarters remove and store potentially contaminated coveralls in a sealed container outside their home for later return to the employer. Coverall requirements do not apply to fumigant use, unless the label requires coveralls.

23. Required PPE is provided, inspected, and cleaned daily, and is repaired or replaced when damaged, worn, or heavily contaminated. Absorbent materials drenched or heavily contaminated with a category 1 or 2 pesticide are discarded. Potentially contaminated PPE is kept and washed separately from other clothing or laundry, dried before storage, or is put in a well-ventilated place to dry. Cleaned PPE, when not in use, is kept separate from personal clothing in a designated, pesticide free place. PPE is the employer's property. Pesticide handlers are not allowed or directed to take potentially contaminated PPE into their homes. Persons/firms hired to clean or repair potentially contaminated PPE are informed of pesticide hazards they may encounter, and ways to prevent injury.

24. Employees wear protective eyewear when label-required and when: flagging (except when in an enclosed vehicle); mixing or loading; adjusting, cleaning, or repairing mixing, loading, or application equipment containing pesticides in hoppers, tanks, or lines; certain hand applications; and ground application with vehicle mounted or towed equipment except when: injecting or incorporating pesticides into soil; or spray nozzles are located below the employee and nozzles are pointed downward; or working in an "enclosed cab" (a chemical resistant barrier surrounding its occupants that prevents contact with pesticides or treated surfaces).

25. Employees wear protective, generally unlined gloves when label-specified and when: mixing or loading; adjusting, cleaning, or repairing contaminated mixing, loading, or application equipment; and performing certain hand applications.

26. Appropriate measures are taken to prevent heat related illness. If ambient temperature exceeds 80[[ring]] F during daylight hours or 85[[ring]] F from sunset to sunrise, pesticides requiring a chemical-resistant suit are not handled, or are handled according to permissible exceptions and substitutions.

27. Employees in an enclosed cab may substitute coveralls for label-required PPE. If respiratory protection is required, it is worn, except in an enclosed cab acceptable for respiratory protection. Employees working in an enclosed cab have label-required PPE immediately available in a chemical resistant container to wear if they must exit the cab and contact pesticide treated surfaces.

28. Employees use approved respiratory protective equipment as required by the label or regulations. Written operating procedures for selecting, fitting, cleaning, sanitizing, inspecting, and maintaining respiratory protective equipment have been adopted.

29. Employees are advised before starting work that certain conditions may interfere with respirator use while engaged in pesticide handling (high blood pressure, heart disease, lung disease, perforated ear drum). A prescribed signed statement is filed for employees who must use a respirator. These employees are trained initially and annually in the need, use, sanitary care, and limitations of respiratory equipment they must wear.

30. Pesticide mixing, loading, transfer, or application equipment is inspected before each day of use. Defective equipment is repaired or altered to remove the hazard before use. Closed systems, meeting regulatory criteria, are provided and used by employees mixing or loading liquid category 1 pesticides (over 1 gallon/day), or loading diluted liquid mixes derived from dry category 1 pesticides.

31. Pest control advisers or their employees doing crop advisor tasks after application during the REI are licensed, or have received handler training. PCAs determine suitable PPE and decontamination facilities, and inform employees of the product/active ingredient(s) applied, application method and time, the REI, precautions, and how to contact them.