Pesticide Safety in our Vineyards
By Jamie Reamer
You might remember seeing an email from me in February about the Department of Pesticide Regulation inspecting farms in the Clarksburg area. Due to an anonymous complaint from one of our neighbors, the State and the Yolo County Ag Department have ramped up inspections in our area. Many of us are safe applicators, who work carefully to ensure the safety of our employees, our neighbors, and our families. Nonetheless, these regulations can be rather specific, and it is easy to be cited for seemingly small oversights. With that in mind, I put this brief overview together. This is not necessarily an all-inclusive compilation of the regulations that might apply to your particular operation, and I encourage you to reach out to the Yolo County Ag Department with any questions (530-666-8140). The Ag Department is always helpful and is a great resource as we all try to get our “ducks in a row”.
There are a few basics that are important to review. First, there are specific rules that apply to pesticide HANDLERS that are distinct from those regulations that apply to FIELD WORKERS, who do not directly handle pesticides but work in fields where they are applied (more on this later but it is important to know that different standards apply to each group, and you must be in compliance with both sets of standards). Make sure that you always keep your Restricted Permit current, submit your pesticide use reports by the 10th of the month following application, and observe the 24 Hour NOI requirements for California restricted materials. As a reminder, NOIs can be submitted online at www.CalAgPermits.org , by fax, or by phone. If you are applying pesticides within a ¼ mile of a school, there can be no ground application while school is in session and no application at all if by air. Always be sure to make every effort possible to protect people, animals and property (being communicative with your neighbors can be very helpful); be aware of surface temperature inversions; and, of course, never spray in windy conditions. Finally, remember that adjuvants are considered pesticides.
With the 2016 harvest nearly wrapped up, here are 10 areas of pesticide safety that I hope will help you tidy up the details of your operation’s pesticide safety program before the 2017 season begins:
1. WRITTEN TRAINING PROGRAM – Your written training program must include the labels for all pesticides your operation uses, Safety Data Sheets (SDS, formerly MSDS) for all pesticides your operation uses, and the Pesticide Safety Information Series (PSIS) leaflets www.cdpr.ca.gov/docs/whs/psisenglish.htm with the blanks filled in. There are many templates available online including these from the California Department of Pesticide Regulation website:
2. TRAINING – Your pesticide trainer must have a QAC, QAL, PAC, PCA license or must have completed a “Train the Trainer” program (more information on this program can be found here: www.cdpr.ca.gov/docs/license/trainers.htm
a. Prior to using pesticides (including adjuvants), make sure your HANDLERS are trained annually in general pesticide storage and handling safety; the effects of pesticides on people; the location of the labels, SDS, and PSIS leaflets; how to access your decontamination facilities; and how to obtain emergency services. Annual HANDLER training must also include how to read the label for each product they will handle (signal words, caution statements, first aid, rate, dilution volume, etc.); how to read the Safety Data Sheets for each product they will handle (accidental release measures, toxicity, etc.); and a review of the entire PSIS. Keep these training records for two years.
b. FIELD WORKER (employees working in treated fields) training must include the content of leaflet A9 (in the PSIS), how to access your decontamination facilities, an explanation of restricted entry intervals (what “posting” means), basic first aid, and how to obtain emergency medical services. As of January 2017, FIELD WORKERS must also be trained annually and these training records must be kept on file for two years.
3. POSTINGS -
a. A8 of the PSIS is a required hazard communication posting for Pesticide HANDLERS; A9 is a mandatory hazard communication posting for FIELD WORKERS. These leaflets, which include general topics about worker safety, must be posted in your shop in all languages spoken by your employees. Remember to fill in the blanks. As of January 2017, these leaflets will also need to be displayed at each of your decontamination sites if you have 11 or more employees.
b. After applying pesticides, you must post the details of the application on an “Application Completion Notice/Application Specific Information” chart in a place that all workers entering your fields can access.
c. A “Warning”/“Danger” sign must be posted outside of pesticide storage areas. It must be readable at 25 feet and available in all appropriate languages for your operation/location.
d. Service Container Labeling (secondary containers like backpacks, tanks) must include the name of your operation, address of the person responsible for the container, and the names and signal words of all pesticides (including adjuvants) in the container.
e. If you offer dust masks to your employees for voluntary use, you must post this notice with your PSIS leaflets:
4. RESPIRATORY PROTECTION – If your operation uses pesticides where respirators are required by the label, restricted material permit condition, or regulation, you must have a written Respiratory Protection Program and your employees must use approved respiratory equipment when handling such pesticides. As the employer, you must provide the respirators, training, fit testing, and medical evaluations at no cost to your employees. You can find more information on establishing a complete Respiratory Protection Program here: www.cdpr.ca.gov/docs/whs/pdf/hs1513.pdf. Keep all associated records for three years.
5. PERSONAL PROTECTIVE EQUIPMENT – You must provide all required Personal Protective Equipment (PPE), keep it in a clean and pesticide free area, and not allow employees to take any contaminated PPE home. If an employee does not return to headquarters after use, PPE can be stored in a sealed container outside of his or her home. HANDLERS must use all PPE required by the labels of the pesticides they are handling. As a reminder, clean, untorn coveralls are required by any pesticide with DANGER or WARNING on the label. If your employee is working in an enclosed cab, he or she does not have to don required gloves or eyewear while inside the cab. However, chemical resistant gloves and protective eyewear must be worn when mixing and loading pesticides, applying by hand or rig, and when exposed to hoppers, tanks, or lines that are contaminated or contain pesticides. Chemical resistant gloves should be at least 14 mils thick and unflocked (liners can be worn underneath but cannot extend beyond the chemical resistant gloves and must be thrown away at the end of day). When chemical resistant footwear is required, they must be chemical resistant as opposed to any old boots. Protective eyewear must offer brow and temple protection (“ANSI 787.1-2010” further outlines these standards). As of January 2017, HANDLERS in an enclosed cab with air filtration will need to wear the label-specified respiratory protection except when the only label-specified respiratory protection is a particulate face piece respirator.
6. MIXING AND LOADING – Most pesticide injuries happen during mixing and loading. Accordingly, there are often specific PPE required for mixing and loading including, possibly, a chemical resistant apron (which covers the front of the body from chest to knees) and a face shield. If you are using liquid pesticides with a label that reads, “Fatal if absorbed through skin,” “May be fatal if absorbed through skin,” or “Corrosive, causes skin damage” – a closed mixing system is required. If you are using a pesticide with a label that reads, “Fatal if absorbed through skin” – then a closed system is required for mixing AND for rinsing and draining. Closed mixing systems must have written operating instructions and maintenance requirements on the vehicle. As of January 2017, employers will need to provide a system capable of delivering 0.4 gallons of water per minute for 15 minutes (or 6 gallons of water able to flow gently for about 15 minutes) at each mixing/loading site if HANDLERS are using products that require eye protection or are using a pressurized system.
7. DECONTAMINATION FACILITIES – As stated earlier, as of January 2017, A8 and/or A9 of the PSIS will need to be displayed at your decontamination sites if you have 11 or more employees.
a. For HANDLERS, decontamination facilities must include sufficient water, soap, towels, and an extra pair of coveralls. These must be at the mixing/loading site and never more than ¼ mile from the HANDLER. Decontamination facilities are required when handling any pesticides that say “CAUTION” or “WARNING” or “DANGER”. One pint of eye rinsing solution (or water for that purpose) must be immediately available to the HANDLER any time he or she is handling pesticides. As of January 2017, “sufficient water” at a decontamination facility will be defined as 3 gallons of water for each HANDLER and each early entry worker on site at the beginning of a work period.
b. For FIELD WORKERS, decontamination facilities must include sufficient water, soap, and single use towels and can never be more than ¼ mile from FIELD WORKERS. As of January 2017, “sufficient water” will be defined as 1 gallon of water for each FIELD WORKER. At Reamer Farms, in addition to plumbed eye rinsing stations at each mixing/loading site, we have loaded “Decontamination Kits” into ice chests that HANDLERS can take with them to worksites that are more than ¼ mile from the mixing/loading site. These decontamination kits include jugs of water, soap, a roll of paper towels, extra PPE (coveralls, goggles, chemical resistant gloves and a dusk mask), a first aid kit, and eye rinsing solution. Each item is individually wrapped in large Ziploc bags.
8. EMERGENCY MEDICAL CARE – Make a detailed plan in advance of how your operation will handle emergency situations and train your employees on what to do (and document this training). Be sure to remind them to notify their supervisor in the event of an emergency as soon as time permits. Post the name, address, and telephone number of your preferred emergency facility in a prominent place at each worksite. As an example, at Reamer Farms, we post emergency signage in several places on each ranch including at each mixing/loading site. Additionally, we affix stickers – printed in both English and Spanish – to every vehicle and tractor with emergency instructions, emergency phone numbers, and the physical address of each worksite.
9. RESTRICTED ENTRY INTERVAL (REI) – As of January 2017, posted warning signs will be required when the REI is more than 48 hours or if the label requires it. When required, post the signage (with the signal word, skull and crossbones, or “Danger”/“Pesticides”/“Keep Out”) within 24 hours before the application begins at all regular entry points for the treated area. Make sure the REI signage remains posted, legible, and observable until its removal within 3 days after the REI ends. If the REI is greater than 7 days, signage needs to include the date of unrestricted entry, the name of your operation, and the field ID number. Early re-entry is permitted in certain circumstances including when a FIELD WORKER is in an enclosed cab and has limited contact with the treated area (i.e., uses prescribed PPE and is in the treated area for less than 8 hours in 24-hour period).
10. CONTAINER DISPOSAL – Pesticide containers must be triple rinsed and drained at the time of use and should never be left where they can present hazards to persons, animals (including bees), food, feed, crops, or property. If they are left unattended, they should be in a locked enclosure. Pesticide containers (55 gallons or smaller) that are triple rinsed, empty with no residue, have no labels or caps, and are inspected by the Yolo County Ag Department can be recycled at the Yolo County Landfill at no charge (on Fridays only). Remember to keep your cleaned containers in a dry and secure place until they are inspected and transferred to the landfill. Alternatively, if the Yolo County Ag Department does not inspect your empty pesticide containers, the Yolo County Landfill will still accept your triple rinsed containers, but you will be charged by the pound for their disposal. For partially full pesticide containers, Yolo County Landfill has a Hazardous Waste Collection Program (you must have an EPA ID number and schedule an appointment by calling 800-207-8222). You cannot burn pesticide containers; it is not allowed by Yolo/Solano AQMD. To dispose of pesticide bags, you can burn them at the use site if you have an ag burn permit and it is a burn day. These bags must be emptied, flattened, the pesticide must not have been absorbed by the bag, and employees burning the bags must wear PPE for airborne particulates. Alternatively, empty, flattened bags that have not absorbed pesticide materials can be disposed of at Yolo County Landfill. Sulfur bag should be bundled separately due to ignition hazards.
In one final effort to simplify these requirements, here is a summary of what needs to be where:
In the office – Written Training program, training records (two years for HANDLERS and FIELD WORKERS), Written Respiratory Protection Program and associated training records (three years), and Pesticide Use Records.
Displayed at headquarters – A8 (of the PSIS) for HANDLERS and A9 for FIELD WORKERS, pesticide application records, and Safety Data Sheets.
At the mixing/loading site and always within ¼ mile from anyone applying pesticides or working in a treated field – Decontamination supplies including soap, water (at least 6 gallons at the mixing/loading site if the product label requires HANDLERS to use eye protection or if they are working with a pressurized system; otherwise, 3 gallons for each HANDLER and 1 gallon for each FIELD WORKER on site), single use towels, extra PPE including coveralls, and, if you have 11 or more employees, you must post A8 and/or A9 of the PSIS at your decontamination sites.
At the each worksite – The registered label for each chemical being applied and information on obtaining emergency medical care (a sticker with emergency instructions, phone numbers, and worksite addresses on each spray rig is an easy way to be compliant).
In the tractor or affixed to the rig – Water for emergency eye flushing, all required PPE for handling/application. (Please see above in the “Postings” section for more information on Service Container Labeling.)
And one final suggestion: at Reamer Farms, we require applicators to keep a registered label for each chemical being applied with them in the rig in the event that they move between worksites during the day.
Please remember: I am not a pesticide safety expert and this list does not include every pesticide safety requirement. I have made every effort to be sure that the information presented here is correct including running this report by the Yolo County Ag Department before sharing it with our growers. Nonetheless, errors are possible and I recommend that you use this as a review of some of the major pesticide safety regulations and a “heads up” on some important changes coming soon. Once again, please contact the Yolo County Ag Department with your questions and concerns regarding pesticide safety. Good luck, Clarksburg Wine Grape Growers!
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