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Worker Protection Standard

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Worker Protection Standard
EPA’s requirements for workers and
handlers of pesticides
Worker Protection Standard
Regulations issued by the EPA
пЃ® Took effect January 1995
пЃ® Included specific language to require
protection of workers and handlers of
pesticides
пЃ® Added duties to the w&h jobs
пЃ® Required new signing & w&h notification
пЃ®
Worker Protection Standard
Not all forestry applications
are affected by this Standard,
but compliance with the
standard is mandatory where
the Standard applies
Worker Protection Standard
The WPS applies only to
those personnel applying
pesticides as part of the
processes of commodity
production
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
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
пЃ®
Worker Protection Standard
Applies to:
Herbicide release of seedlings for fiber
production
пЃ® Agricultural applications performed
under special use permit
пЃ® Greenhouse or nursery operations
пЃ®
Worker Protection Standard
Does NOT Apply to:
пЃ®
Improvement of wildlife habitat
 Treatments for “general forest protection”
(such as a Bacillus thuringiensis application
to combat gypsy moth)
пЃ® Pasture or range improvement or right-of-way
maintenance
пЃ® Research activities
Worker Protection Standard
There are two basic parts to the Standard:
пЃ® Information required to be included on
labels issued by the manufacturer
пЃ® Required personnel protective
equipment (PPE) for workers and
handlers who must enter the treated
area prior to the expiration of the REI
Worker Protection Standard
Label requirements
пЃ®
The regulations require that all pesticides
have at least a 12 4 hour REI (restricted
entry interval) required by the label
пЃ® The REI is an interval of worker and handler
exclusion unless specific protective
equipment is worn
пЃ® Labels must specify special PPE for entry
into treated areas in less than the REI
Worker Protection Standard
Label 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
Worker Protection Standard
Employer responsibilities
WPS requires several things of the
employers of handlers and workers
Worker Protection Standard
Employer Responsibilities
пЃ®
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
пЃ®
Information must be current and legible, and
both handlers and workers must be told
where to find it
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
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
Worker Protection Standard
Employer Responsibilities
A decontamination site must be provided within
Вј mile of where the handlers are working
At the site, the employer must provide soap,
wash water, and towels for personnel cleanup; clean coveralls to replace work clothes in
the event of accidental contamination
And drinking water (separate container from the
wash water)
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)
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 Вј
mile of the work site
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
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
Worker Protection Standard
Employer Responsibilities
Before beginning a pesticide application,
handlers must be given specific, clear,
and understandable instructions on
пЃ® how the pesticide is to be applied
пЃ® operation of application equipment
пЃ® applicator safety requirements
пЃ® the REI applicable to the project area
Worker Protection Standard
Employer Responsibilities
пЃ®
Application areas must either be posted with
specified warning signs, or workers and
handlers must be orally warned of entry
restrictions
пЃ® In most forestry applications oral warnings
will be adequate
пЃ® In areas where worker entry is likely, EPA
warning signs may need to be posted
пЃ® Some labels will require BOTH signs and oral
warnings
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
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
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)
пЃ® Steps must be taken to avoid heat injury
resulting from PPE use
пЃ®
Worker Protection Standard
Employer Responsibilities
пЃ®
A pesticide-free area for storage of PPE and
personal clothing must be provided
пЃ® Handlers may not take or wear PPE home.
пЃ® PPE must be stored and washed separately
from other clothing
пЃ® Persons who clean PPE must be informed of
proper cleaning procedures and of the
potential for contamination with, and possible
harmful effects of pesticides
Worker Protection Standard
F. S. Responsibilities
Insure that contractors do not become
lax in fulfilling WPS requirements
regarding training and PPE
пЃ® Do not assume liability for handler
safety (properly placed with the
employer (contractor))
пЃ®
Worker Protection Standard
F. S. Responsibilities
Most forestry herbicides fall into EPA
toxicity categories III and IV (slightly
toxic and relatively nontoxic)
пЃ® Minimum PPE is long-sleeved shirt,
long pants, shoes, socks, and gloves
пЃ® Under WPS handlers are not allowed to
take or wear PPE home
пЃ®
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
Worker Protection Standard
пЃ®
There may be state, local, or Tribal
requirements which are more restrictive than
those in the WPS
пЃ® Enforcement authority for WPS lies with the
State Lead Agency specified by EPA in each
state
пЃ® State Lead Agencies are listed on the internet
at http://www. vttp.ext.vt.edu/htmldocs/
srpchome.html
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
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
пЃ® Ensure that crews have 1 pint of
eyewash water for each handler in the
field
пЃ®
Worker Protection Standard
What to do:
пЃ®
Be sure that a copy of the label and the
MSDS go to the field with each crew
пЃ® Post EPA/WPS posters in each District or
Supervisor's Office and one in each work
center where pesticides are being used
пЃ® Maintain a current listing of all pesticide
treated sites on the district which are within
30 days of the completion of the REI
Worker Protection Standard
What to do
Choose coverall use versus
washer/drier facilities for cleaning
applicator's clothing
пЃ® 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
пЃ®
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