Worker Protection Standard

1
Worker Protection Standard

• EPAs requirements for workers and handlers of
  pesticides

2
Worker Protection Standard

• Regulations issued by the EPA
• Took effect January 1995
• Included specific language to require protection
  of workers and handlers of pesticides
• Added duties to the wh jobs
• Required new signing wh notification

3
Worker Protection Standard
Not all forestry applications are affected by
this Standard, but compliance with the standard
is mandatory where the Standard applies
4
Worker Protection Standard
The WPS applies only to those personnel applying
pesticides as part of the processes of commodity
production
5
Worker Protection Standard
It applies only to workers and handlers of
pesticides Does not apply to visitors or other
persons not involved in commodity production
6
Worker Protection Standard

• Handlers are personnel whose jobs require that
  they mix, load, or apply pesticides
• Workers are defined as persons whose job
  requires that they work in a treated area prior
  to the expiration of the REI or during the 30 day
  period subsequent to a treatment

7
Worker Protection Standard Applies to

• Herbicide release of seedlings for fiber
  production
• Agricultural applications performed under special
  use permit
• Greenhouse or nursery operations

8
Worker Protection Standard Does NOT Apply to

• Improvement of wildlife habitat
• Treatments for general forest protection (such
  as a Bacillus thuringiensis application to combat
  gypsy moth)
• Pasture or range improvement or right-of-way
  maintenance
• Research activities

9
Worker Protection Standard

• There are two basic parts to the Standard
• Information required to be included on labels
  issued by the manufacturer
• Required personnel protective equipment (PPE) for
  workers and handlers who must enter the treated
  area prior to the expiration of the REI

10
Worker Protection StandardLabel requirements

• The regulations require that all pesticides have
  at least a 12 4 hour REI (restricted entry
  interval) required by the label
• The REI is an interval of worker and handler
  exclusion unless specific protective equipment is
  worn
• Labels must specify special PPE for entry into
  treated areas in less than the REI

11
Worker Protection StandardLabel Requirements

• By requiring that this information be included on
  the label
• Failure to comply with the WPS requirements has
  been made a violation of FIFRA
• Which in turn enables the assessing of severe
  penalties for that failure

12
Worker Protection Standard Employer
responsibilities

• WPS requires several things of the employers of
  handlers and workers

13
Worker Protection Standard Employer
Responsibilities

• Pesticide information must be provided at a
  central location including
• an appropriate EPA WPS safety warning poster
• the name, address, and telephone number of the
  nearest medical facility
• specific information about the location,
  pesticide(s) applied, and timing of each
  application completed more recently than the REI
  plus 30 days
• Information must be current and legible, and both
  handlers and workers must be told where to find
  it

14
Worker Protection Standard Employer
Responsibilities

• For the purpose of F.S. applications the central
  location should be a bulletin board in the
  district office or the work center or both

15
Worker Protection Standard Employer
Responsibilities

• Pesticide safety training must be provided to all
  handlers
• Training must follow certain specifications
• Training must be renewed at least every five
  years

16
Worker Protection Standard Employer
Responsibilities

• A decontamination site must be provided within ¼
  mile of where the handlers are working
• At the site, the employer must provide soap, wash
  water, and towels for personnel clean-up clean
  coveralls to replace work clothes in the event of
  accidental contamination
• And drinking water (separate container from the
  wash water)

17
Worker Protection Standard Employer
Responsibilities

• At least one pint of eyeflush water must be
  available for the handler at the actual work site
• (The decontamination site may be the crew
  vehicle, but the eyewash water must be with the
  crew)

18
Worker Protection Standard Employer
Responsibilities

• The easiest way to fulfill the eyewash
  requirement for Force Account crews is to provide
  each handler with a belt mounted eyewash bottle
  holster and an eyewash bottle containing at least
  one pint of water and have additional water on
  the crew vehicle or at a site within ¼ mile of
  the work site

19
Worker Protection Standard Employer
Responsibilities

• In the event that a handler is injured or
  poisoned by a pesticide
• Transportation to an appropriate medical facility
  must be made available immediately
• Label and MSDS, and the nature of the injury or
  exposure, must be provided to the attending
  physician

20
Worker Protection Standard Employer
Responsibilities

• Employer must insure that pesticide is applied
  only in such a way that it does not contact,
  either directly or via drift, any worker or
  handler not equipped with appropriate PPE

21
Worker Protection Standard Employer
Responsibilities

• Before beginning a pesticide application,
  handlers must be given specific, clear, and
  understandable instructions on
• how the pesticide is to be applied
• operation of application equipment
• applicator safety requirements
• the REI applicable to the project area

22
Worker Protection Standard Employer
Responsibilities

• Application areas must either be posted with
  specified warning signs, or workers and handlers
  must be orally warned of entry restrictions
• In most forestry applications oral warnings will
  be adequate
• In areas where worker entry is likely, EPA
  warning signs may need to be posted
• Some labels will require BOTH signs and oral
  warnings

23
Worker Protection Standard Employer
Responsibilities

• In Region 8, ALL areas treated with pesticide
  will be posted
• Signing must be adequate to remain in place for
  at least 30 days from the expiration of the REI

24
Worker Protection Standard Employer
Responsibilities

• Application equipment must be inspected and
  repaired as needed before each use
• If equipment contains pesticides or residues,
  only trained handlers may clean, adjust, or
  repair it

25
Worker Protection Standard Employer
Responsibilities

• PPE specified on the label must be provided to
  handlers (by the contractor for all members of a
  contract crew or by the F.S. for Force Account
  work crews)
• Steps must be taken to avoid heat injury
  resulting from PPE use

26
Worker Protection Standard Employer
Responsibilities

• A pesticide-free area for storage of PPE and
  personal clothing must be provided
• Handlers may not take or wear PPE home.
• PPE must be stored and washed separately from
  other clothing
• Persons who clean PPE must be informed of proper
  cleaning procedures and of the potential for
  contamination with, and possible harmful effects
  of pesticides

27
Worker Protection Standard F. S. Responsibilities

• Insure that contractors do not become lax in
  fulfilling WPS requirements regarding training
  and PPE
• Do not assume liability for handler safety
  (properly placed with the employer (contractor))

28
Worker Protection Standard F. S.
Responsibilities

• Most forestry herbicides fall into EPA toxicity
  categories III and IV (slightly toxic and
  relatively nontoxic)
• Minimum PPE is long-sleeved shirt, long pants,
  shoes, socks, and gloves
• Under WPS handlers are not allowed to take or
  wear PPE home

29
Worker Protection Standard F. S.
Responsibilities

• Simplest solution
• Wear coverall over clothes in the field which
  will be taken off at the end of the day prior to
  going home
• Coveralls must either be reusable and cleaned
  before re-use, or disposable and discarded after
  a single use

30
Worker Protection Standard

• There may be state, local, or Tribal requirements
  which are more restrictive than those in the WPS
• Enforcement authority for WPS lies with the State
  Lead Agency specified by EPA in each state
• State Lead Agencies are listed on the internet at
  http//www. vttp.ext.vt.edu/htmldocs/
  srpchome.html

31
Worker Protection Standard

• Forest Service has been operating under the basic
  principles of WPS for many years
• Current pesticide projects in compliance with all
  of the mitigations required in the Vegetation
  Management EIS Records of Decision are already
  very close to being in full compliance with the
  WPS

32
Worker Protection Standard What to do

• Double check your projects and ensure that they
  continue to comply with the applicable R-8
  Vegetation Management FEIS
• Ensure that crews have 1 pint of eyewash water
  for each handler in the field

33
Worker Protection Standard What to do

• Be sure that a copy of the label and the MSDS go
  to the field with each crew
• Post EPA/WPS posters in each District or
  Supervisor's Office and one in each work center
  where pesticides are being used
• Maintain a current listing of all pesticide
  treated sites on the district which are within 30
  days of the completion of the REI

34
Worker Protection Standard What to do

• Choose coverall use versus washer/drier
  facilities for cleaning applicator's clothing
• Incorporate into contract language (a requirement
  that the contractor shall insure that all
  provisions of the WPS will be met by his/her
  handlers and workers