Worker Protection Standard - Farm and
Nursery Facilities
CALS Policy
The Worker Protection Standard (WPS) is an amendment to FIFRA (the
Federal Insecticide, Fungicide, and Rodenticide Act), a federal law
which regulates pesticide registration and use. WPS is designed to
protect agricultural workers (people involved in the production of
agricultural plants) from the risks of exposure to pesticides. The
Cornell community includes persons not covered by WPS (e.g., students
who are not employees of Cornell). It is the desire of the College to
protect all members of its community in the spirit of WPS. The
following guidelines will serve to provide more information and
protection to students, faculty, staff, and visitors.
CLASS USE
- Instructors and students who visit agricultural production
facilities, fields, forests, or nurseries as part of undergraduate
course work should be informed of the law at a level appropriate
to the degree of anticipated exposure. At a minimum, this should
consist of instructions not to enter a posted field or other
treated area and a reminder to wash hands after handling plants or
plant materials. A "prompt" (poster with instructions on back) is
available from Mary-Lynn Cummings to assist instructors in
providing this information.
- Students and instructors may enter treated areas which have
been sprayed only after the posted Restricted Entry Interval (REI)
has expired. No plant materials may be removed from a treated area
for classroom use during a REI.
- Instructors and students having contact with plant material
must wash their hands with soap and water immediately upon leaving
the treated area or upon completion of work with treated plant
materials.
CLASS USE - SUGGESTIONS
In order to minimize interference from regulatory requirements,
particularly the need to provide personal protective equipment (PPE)
to classes, instructors and farm management should follow these
suggestions:
- Carry out chemical pest control procedures at least three days
prior to the scheduled class activity. Regardless of Toxicity
Class of the pesticide used, the REI will be expired by the third
morning after application.
- Limit use of Toxicity Class I and II pesticides.
- Consider alternative pest control strategies (cultural,
biological, mechanical, etc.).
- Faculty should notify farm managers of their class schedule no
later than one week prior to the start of the semester. Faculty
should also discuss their pest control requirements with farm
management so that appropriate pest management strategies may be
selected.
RESEARCH USE [faculty, staff, and students (including work
study)]
- All research faculty, staff, and students who work in
agricultural production facilities or nurseries, who are not
certified pesticide applicators, must have valid WPS worker or
handler training cards.
- Only a certified pesticide applicator or WPS trained handler
may be in a treated area during pesticide application.
- For early entry to treated areas (during the REI) with
contact: Only certified pesticide applicators, trained handlers,
and trained early entry workers may enter a treated area during
the REI when contact with pesticide residues is expected. Everyone
must always wait a minimum of four (4) hours after the pesticide
application before entry. PPE must be worn according to label
requirements.
- For early entry to treated areas (during the REI) with no
contact: Early entry is allowed without PPE if contact with
pesticide-treated surfaces will not occur. But the following must
be provided:
- WPS pesticide safety training (or certified pesticide
applicator)
- Information at a central location
- Notification
- Restrictions during application and during the REI
- Emergency assistance
(This policy does not include visitors)
- Supply and maintenance of any PPE required for research work
is the responsibility of the Principal Investigator.
- There are no exceptions to the requirement to supply specific
pesticide application information to the farm manager for central
posting prior to the application.
- Only certified pesticide applicators may access pesticide
storage buildings.
- Applications of experimental pesticides must be posted. Unless
the manufacturer has supplied explicit requirements for PPE,
including an LD50 for the material, it must be treated as a
Toxicity Class I pesticide with a 48 hour REI.
- Persons carrying out scouting activities must meet the WPS
requirements for Crop Advisors.
RESEARCH USE - SUGGESTIONS
In order to minimize interference from regulatory requirements,
faculty and farm management should follow these suggestions:
- Apply pesticides in the early evening.
- Use Toxicity Class III and IV pesticides whenever possible.
PPE for early entry will then be minimal - long pants and
long-sleeved shirt with gloves or less if the label permits.
Toxicity Class I materials have an additional requirement to warn
all farm personnel orally.
- Avoid the need for early entry in the research design.
VISITOR USE
Visitors may not enter treated areas until any applicable REIs
have expired. Visitors must be given clear instructions not to handle
plants.
Visiting scientists may have anywhere from very little to a great
deal of contact with treated materials. The primary host of the
visiting scientist is responsible for judging the potential exposure
and providing the appropriate information relating to any pesticide
applications.