NM

Pesticide Lecture 3: Worker Protection Standards (WPS) Training Notes

Overview

  • The EPA initially interpreted and enforced safeguards for workers under the Worker Protection Standard (WPS), which has since become law and is now used to protect workers and handlers of pesticides.
  • The regulation arose from public health concerns in agricultural settings, notably migrant workers in California who were getting poisoned while working in fruit and vegetable fields; this spurred the creation of stronger protections.
  • The speaker acknowledges political tensions around regulation and immigration, but emphasizes the practical and health-protective value of WPS.
  • WPS applies to workers and handlers across farms, forests, nurseries, greenhouses, and related agricultural settings, including public institutions like universities where pesticide work is done.
  • The goal is to reduce pesticide exposure and associated health risks through training, proper procedure, recordkeeping, and emergency response.

Covered Establishments and Roles

  • Agricultural establishments include places where plants are produced: farms, forests, nurseries, greenhouses, and similar locations (and by extension public institutions with pesticide activity).
  • Types of workers:
    • Agricultural workers: employees who do not directly handle pesticides but perform tasks such as watering, weeding, pruning, harvesting, planting, etc.
    • Pesticide handlers: workers who mix, load, transfer, apply pesticides, clean pesticide containers, repair/maintain application equipment, or dispose of pesticides; crop advisers may also be handlers in some situations.
  • Example scenarios from the transcript:
    • A small greenhouse operation growing tomato transplants in Pike County, selling to co-ops; these are farms and would be subject to WPS training for handlers if pesticides are involved.
    • Cameron, a cotton farmer, hiring a worker who is knowledgeable about pests to act as the spray technician; such a worker would be a pesticide handler and require training and a training record under WPS.
  • If you hire someone to work around pesticides (e.g., you plant, manage, or spray), you as the farmer must ensure training and protection for that worker as a handler.

Licenses and Permits

  • Types of pesticide-related licenses/permits:
    • Private applicator permit: allows the holder to buy and use restricted-use pesticides (RUPs) on their own farms; you cannot hire someone to spray you if you only hold a private applicator permit—you would be in violation if you attempted to use someone else’s services for regulated work.
    • Commercial license: allows holding and delivering pesticide application services; this is typically more advanced and may require different testing and demonstrations.
    • Demonstration and research license: a specialized commercial category enabling extension and research work; the speaker mentions this as a category they hold.
  • Example details:
    • To purchase bifenthrin (a restricted-use pesticide) as a private applicator, you must hold a private applicator permit.
    • A person with a commercial license, unless in a category that allows selling services, may not necessarily be in a position to directly sell pesticide applications to the general public.
  • Training and testing:
    • Training and licensing are often completed online via extension services; example: a private applicator permit can be obtained online after taking a test and paying a fee (the speaker mentions around 45 as a typical permit fee).
    • The “automatic pest control” license referenced is a potential December offering that would allow holding a bid and starting lawn spraying services.
  • Practical takeaway:
    • Distinguish between private applicator permits (buy/use RUP on your own land) and commercial licenses (provide pesticide applications as a service). The restrictions determine who can spray and under what conditions.

Worker Protection Standard (WPS) Training Requirements

  • Training scope:
    • All workers entering areas where pesticides have been applied or where an REI is in effect must be informed and trained in pesticide safety at least once per year (annual training).
    • Agricultural employers must maintain a copy of each worker’s training on file for 2 years.
  • After today’s session: participants are expected to complete WPS handler training for pesticide handling.
  • Training records and access:
    • Employers must inform workers where to find posted information and decontamination supplies; records or postings should be accessible during work hours.
    • Workers (or their designated representatives) may request copies of records in writing.
  • How training integrates with roles:
    • Those who are trained are authorized to be PPE-compatible handlers; untrained individuals should not mix, load, transfer, or apply pesticides.
  • Practical note:
    • An online training and verification process often accompanies the WPS training, and the regulatory framework requires annual refreshers to ensure up-to-date safety practices.

Definitions and Core Concepts

  • Agricultural establishment: a place where plants are produced, including farms, forests, nurseries, greenhouses, or other sites where pesticides are applied.
  • Agricultural workers: employees of an agricultural establishment who do not work directly with pesticides or pesticide equipment (they perform tasks like watering, weeding, pruning, planting, harvesting, etc.).
  • Pesticide handlers: employees who work directly with pesticides (mixing, loading, transferring, applying, cleaning containers, maintaining equipment, disposing of pesticides; crop advisers may also be handlers in some cases).
  • Pesticide: a substance used to protect plants and control pests (insects, weeds, fungi, diseases).
  • Pesticide formulations: various forms such as liquids, sprays, powders, granules, gases; examples include wettable powders, water-dispersible granules, suspension concentrates, soluble concentrates, emulsifiable concentrates, fumigants.
  • EPA registration number: the unique EPA registration number identifying a pesticide product; contains critical medical and emergency information.
  • Signal words (acute toxicity):
    • Danger with skull-and-crossbones: highly toxic or extremely poisonous; small exposures can cause serious harm or death.
    • Danger: very poisonous if ingested, absorbed through the skin, or inhaled; highly hazardous.
    • Warning: moderately toxic; may cause moderate irritation.
    • Caution: slightly toxic; still potentially harmful.
  • Agricultural Use Requirements box: part of the label that communicates WPS requirements (e.g., PPE, REI, and whether an employer must notify workers by posting or speaking to them).
  • REI (Restricted Entry Interval): the time after application during which entry is restricted; length varies by pesticide.
  • AEZ (Application Exclusion Zone): area around application equipment during outdoor application where entry is restricted to trained handlers only.
  • Early entry workers: workers entering treated areas before the REI ends; must be at least 18 years old and have PPE and label-provided information, with training.
  • PPE: personal protective equipment required by the label (gloves, boots, coveralls, respirators, eye protection, etc.); PPE must be provided by the employer and kept in good condition.
  • SDS (Safety Data Sheet): provides hazard information, health risks, toxicity, first aid, and emergency spill procedures; not the same as the pesticide label.

Training, Testing, and Certification Details

  • Handler training: required for those who mix, load, apply, or handle pesticides; must be completed annually and is essential for complying with WPS.
  • Records: training records must be kept for 2 years and be accessible to workers who request them.
  • User access: central posting and accessible information regarding pesticides are required to be posted in a central location for workers to review.
  • Testing and licensure specifics:
    • Private applicator permits and commercial licenses require testing, with online testing through extension services.
    • Fees (example): around 45 for a private applicator permit.
  • Example flow:
    • A farm hires workers; some are private applicators, others are general workers; the farm must ensure those handling pesticides have the appropriate training and licenses, and that workers know where to find posted information and decontamination supplies.

Pesticide Handling, Application, and PPE (Personal Protective Equipment)

  • Label directions are law: applying a pesticide in a manner not in the label is illegal.
  • Formulations: different formulations require different PPE and handling practices; some formulations (e.g., wettable powders) are dusty and require extra precautions.
  • PPE and equipment: employer must provide PPE specified by the pesticide label; types include gloves, aprons, eye protection, coveralls, boots, respirators; PPE may be reusable or disposable.
  • Respirators:
    • If a pesticide requires a respirator, the employer must provide a medical evaluation (medical) questionnaire, a respirator fit test, and respirator training before use; ensure proper seal checks prior to each use.
    • Use only the cartridges/filters listed on the product label.
  • PPE maintenance and removal:
    • Do not remove PPE during mixing/loading or while working on application equipment.
    • Remove PPE in a specific order to avoid transferring residues; dirty gloves touch the outside of dirty PPE; clean gloves or hands touch clean parts of PPE.
    • Clean and store PPE properly; keep clean clothes free of pesticide residues; store PPE in a pesticide-free area.
  • Heat and PPE:
    • PPE can contribute to heat stress; employers should provide shade, breaks, water, or assign tasks to reduce heat exposure when PPE is heavy or extensive.
  • Work clothing and decontamination:
    • Wear long-sleeved shirts, long pants, socks, shoes, and a hat; gloves recommended; wash work clothes separately from family clothes in hot soapy water; dry outside when possible to minimize cross-contamination; rinse washing machine between loads if needed.
    • Decontamination supplies (soap, towels, water) should be within a quarter of a mile of the treated site for a specified time after REI ends.
  • PPE and exposure prevention:
    • PPE reduces exposure; never bypass PPE; PPE effectiveness relies on proper selection, fit, maintenance, and use.

Decontamination, First Aid, and Medical Considerations

  • Decontamination steps:
    • Wash hands/skin with soap and water as soon as possible after contact or potential exposure; if decontamination supplies are far away, rinse with nearby clean water (stream, pond) and then wash with soap and water and shampoo hair.
    • Remove contaminated clothing and change into clean clothes; wash contaminated clothes separately; avoid bringing contaminated items into the home; cycle washing machine to remove residues.
  • Eye exposure:
    • If pesticides contact the eye, flush with clean water or an eye wash kit for at least 15 minutes with the eye downward and head tilted to keep contaminated water from entering the other eye.
    • Seek medical attention immediately.
  • Ingestion/exposure through the mouth:
    • Do not induce vomiting unless advised by medical personnel or the product label.
    • If ingestion occurs, contact the employer and seek medical attention; follow label-provided first aid directions.
  • Inhalation exposure:
    • Pesticide vapors, dust, or spray particles can be dangerous; seek fresh air and medical attention as needed; some pesticides (e.g., fumigants) form gases that require immediate medical care.
  • General exposure signs:
    • Acute pesticide illness signs often appear within 24 hours and include headaches, sweating, weakness, rapid pulse, nausea, or loss of consciousness.
    • Chronic pesticide illness may result from long-term exposure and can include cancer, chronic respiratory problems, or nervous system damage; repeated exposures can lead to sensitization (allergic-like reactions) with symptoms like rashes or respiratory issues.
  • If exposure occurs:
    • Notify the employer or supervisor immediately; ensure medical care is obtained; inform medical personnel about the pesticide involved and exposure circumstances; provide the Safety Data Sheet (SDS) when available.

Exposure Routes, Residue, and Environmental Considerations

  • Residue sources:
    • Pesticide residue can be found on leaves, stems, fruits, vegetables, equipment, dirty PPE, irrigation components, soil, and in stored containers.
  • Drift:
    • Drift occurs when droplets/dust travel away from the target site during application; drift violations should be reported to the state or tribal pesticide regulatory agency.
  • Environmental hazards:
    • The label’s environmental hazard statements provide guidance on environmental risks; PPE and application methods are designed to minimize environmental impact.
  • Central posting content:
    • A central posting must include: pesticide safety information, name/address/phone of an emergency medical facility, contact information for the state/tribal pesticide regulatory agency, hazard information from SDS, and pesticide application information (pesticide name, active ingredients, EPA registration numbers, dates/time, REI duration).
  • Documentation and access:
    • The central posting must be updated within 24 hours of completing a pesticide application and before workers re-enter the treated area; records stay on file for 2 years; workers can request copies.
  • Decontamination and water accessibility:
    • Decontamination supplies must be available within a quarter-mile of the treated site; include at least 3 gallons of water per handler, soap, towels, and a change of clothes; emergency eye flushing supplies if mixing/loading with protective eyewear or using a closed system.
  • Handling equipment and transport:
    • Transport pesticides securely in a way that keeps them away from drivers/passengers; check containers for leaks; do not leave pesticides unattended; keep them in a locked area when possible.
  • Spills:
    • In a spill, follow the four Cs: Control, Contain, Clean up, and Contact (state/tribal environmental agency or fire department); do not hose spills as this spreads contamination; report per state/tribal requirements.

Pesticide Labels, Safety Data Sheets (SDS), and Application Information

  • Label basics:
    • The label contains the form of the pesticide, application site restrictions, rates, equipment type, and any special restrictions.
    • The site also has an Agricultural Use Requirements box detailing WPS requirements, REI duration, and whether posting and/or spoken notice is required.
  • Safety Data Sheets (SDS):
    • SDS provides health hazards, chemical/physical hazards, toxicity, first aid, and emergency spill procedures; it is not a substitute for the pesticide label.
  • PPE and protection:
    • The label’s PPE requirements must be followed for mixing, loading, applying, cleaning, repairing, and maintaining equipment.
    • The required PPE varies by product and task; the label will specify the exact PPE needed.
  • Emergency and environmental actions:
    • The label includes environmental hazard statements and first aid steps; responders should have the SDS and product details at the treated site.
  • Application details:
    • The label lists where applications are allowed, the rate, the equipment type, and any special restrictions.
  • Storage and disposal:
    • The label provides guidance on rinsing containers, storage, disposal, and whether containers can be re-used.
  • Avoiding misuse:
    • It is illegal to store pesticides with food or feed products; always follow label directions for safe waste handling and disposal.
  • Controlled sites and posting:
    • The employer is responsible for ensuring posting and safety measures align with the label, including signage and notifications as required by the label.

Posting, Records, Access, and Decontamination Logistics

  • Central location postings:
    • Must display pesticide information and safety content for easy access during work hours.
  • REI and access control:
    • Workers must stay out of areas where an REI is in effect; warning signs may be posted; access is managed to prevent entry during REI.
  • Application Exclusion Zone (AEZ):
    • An AEZ is the area around application equipment during outdoor spraying; entry is restricted to properly trained/ equipped handlers.
    • If people are inside the AEZ but within the agricultural establishment, spraying must stop until they leave or it is safe to continue.
  • Early entry requirements:
    • Early entry workers must be at least 18 years old, have PPE, and understand why entry is needed; they must be trained and follow label instructions.
  • Decontamination and PPE logistics:
    • Decontamination supplies must be available within a quarter-mile of the treated site; include water, soap, towels, change of clothes; eyewash supplies if required.
  • Notification and access to information:
    • Employers must notify workers of REI and where to find information; workers have the right to request copies of records and SDS information.
  • Transportation and handling:
    • Pesticides must be transported securely away from people in the vehicle; containers must be checked for leaks; never leave pesticides unattended.

Health, Safety, and Real-World Scenarios

  • Acute vs chronic health effects:
    • Acute pesticide illness: symptoms typically appear within 24 hours; headaches, sweating, weakness, rapid pulse, nausea, dizziness, or loss of consciousness.
    • Chronic pesticide illness: results from prolonged or repeated exposures; may include cancer, chronic respiratory problems, or nervous system injury; sensitization may occur with repeated exposure, causing dermatitis or respiratory issues.
  • Exposure pathways:
    • Skin: pesticide residues on plants, soil, dirty clothing, contaminated equipment, or PPE can absorb through the skin.
    • Eyes: pesticides can enter eyes from dust, splashes, or contact with contaminated hands or PPE; urgent flushing is required.
    • Mouth: avoid eating or drinking without washing hands or produce before consumption; never eat or drink from pesticide containers.
    • Inhalation: vapors, dust, or spray particles can be inhaled; certain fumigants are particularly hazardous.
  • Heat-related illness in the field:
    • Heat exhaustion signs include heavy sweating, clammy skin, weakness, dizziness, nausea, cramps, and rapid breathing.
    • Heat stroke is life-threatening and requires immediate emergency response (911) and rapid cooling.
    • Preventive strategies include hydration, shade, breaks, and adjusting PPE requirements when possible.
  • Practical takeaway from scenarios:
    • A cotton farmer hiring a spray technician must ensure the worker is trained as a handler and has appropriate PPE and access to the required information and emergency procedures.
    • A greenhouse operation must treat all workers as potentially exposed to pesticides if pesticides are used in the operation; WPS training and central postings apply.
  • Inspector interactions:
    • Pesticide safety inspections can occur at any time; inspectors are generally there to help ensure compliance, not to “get” the farmer; retaliation against workers for reporting WPS violations is illegal.
  • Retaliation and rights:
    • The WPS protects workers who cooperate with inspectors or report violations; employers cannot threaten or fire workers for compliance or reporting.
  • Quick recall of “central location” content and access:
    • The central location must include: safety information, emergency facility contact, regulatory agency contact, SDS hazard info, and pesticide application details; records must be kept for 2 years and can be requested in writing.

Practical Implications and Ethical Considerations

  • Ethical obligation to protect workers’ health and safety, especially for vulnerable populations such as migrant workers.
  • Public health relevance ties to safe agricultural practices, prevention of pesticide poisoning, and responsible environmental stewardship.
  • The WPS encourages ongoing training and documentation to ensure accountability and continual improvement in farm safety.
  • Practical burden on small farms: training, recordkeeping, and postings require resources and organization, but the health risks justify these investments.
  • The interplay between regulation and industry familiarity: while some workers may view these rules as burdensome, they provide a clear framework for safe work, emergency response, and compliance.

Quick Reference Points and Key Numbers (LaTeX format)

  • Minimum age for pesticide handlers/early entry: 18
  • Required annual handler training: yearly
  • Central posting duration after REI or completion: at least 30 days
  • Decontamination water per handler: at least 3 gallons
  • Decontamination distance from treated site: within 0.25 miles (quarter mile)
  • Permit fee example for private applicator: 45 (USD)
  • Retention of training records: 2 years
  • Typical high-speed sprayer example in transcript: up to 20 miles per hour; 48 rows wide
  • Acute illness onset window: within 24 hours
  • Eye flush duration: at least 15 minutes
  • Emergency contact: call 911 in an emergency
  • Warning posting and AEZ management: prioritize safety and ensure only trained personnel enter AEZ
  • December reference for automatic pest control license: December (calendar month)
  • Training date example in transcript: 08/26/2025

Appendix: Key Terms and Concepts

  • WPS: Worker Protection Standard; regulations to protect agricultural workers and pesticide handlers.
  • REI: Restricted Entry Interval; time post-application during which entry is restricted.
  • AEZ: Application Exclusion Zone; a restricted zone around application equipment.
  • RUP: Restricted Use Pesticide; pesticides restricted to trained and licensed applicators.
  • Private applicator permit: permit allowing purchase and use of RUP on one’s own land.
  • Commercial license: license allowing professional pesticide application services.
  • SDS: Safety Data Sheet; safety and first aid information; not the pesticide label.
  • LABEL: Pesticide product label; includes use directions, PPE, REI, and environmental/hazards information; obey all label directions.
  • PPE: Personal Protective Equipment required by the label; may include gloves, boots, respirators, eye protection, coveralls, etc.
  • Early entry worker: worker entering the treated area before REI ends; must be 18+ and trained.
  • Four Cs of spills: Control, Contain, Clean up, and Contact.
  • Central location: a location at the establishment where pesticide safety information, SDS, emergency contacts, and application data are posted for workers.

Real-World Takeaways

  • WPS is designed to keep workers safe from pesticide exposure by requiring training, PPE, postings, and emergency procedures.
  • Clear distinctions exist between private applicators (landowners) and commercial applicators (service providers): different permits, responsibilities, and capabilities.
  • Documentation, recordkeeping, and compliant posting are not optional; they form the backbone of accountability and safety.
  • Understanding label directions and safety data sheets is essential for safe handling, resistance management, and environmental protection.
  • Health and safety are dynamic: weather, heat, PPE, and work conditions all interplay and require adaptive, safety-first decision-making.