Worker Protection Standard - Greenhouse
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, trades staff). 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.
- Instructors and students who use greenhouses or handle plants brought from greenhouses 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 greenhouse and a reminder to wash hands after handling plants or plant materials. A “prompt” (poster with instructions on back) is available from the Director, CALS Occupational and Environmental Health to assist instructors in providing this information.
- Students and instructors may enter greenhouses which have been sprayed only after the posted Restricted Entry Interval (REI) has expired. No plant materials may be removed from a greenhouse 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 greenhouse management should follow these suggestions:
- Carry out chemical pest control procedures late on Fridays. Regardless of Toxicity Class of the pesticide used, the REI will be expired by Monday morning.
- Limit use of Toxicity Class I and II pesticides.
- Consider alternative pest control strategies (cultural, biological, mechanical, etc.).
- Do not treat plants housed in corridors. Treatment in corridors would require shutting down the entire facility until the REI has expired.
- Faculty should notify greenhouse managers of their greenhouse class schedule no later than one week prior to the start of the semester. Faculty should also discuss their pest control requirements with greenhouse management so that appropriate pest management strategies may be selected.
RESEARCH USE [faculty, staff, and students (including work
- All research faculty, staff, and students who work in greenhouses, 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 greenhouse during pesticide application.
- For early entry to greenhouses (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, including a respirator if ventilation criteria have not been met, must be worn according to label requirements.
- For early entry to greenhouses (during the REI) with no contact: Early entry is allowed without PPE if contact with pesticide-treated surfaces will not occur and ventilation criteria have been met. But the following must be provided:
- WPS pesticide safety training (or certified pesticide applicator)
- Information at a central location
- Restrictions during application and during the REI (such as meeting the ventilation criteria)
- 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 greenhouse manager for central posting prior to the application.
- Only certified pesticide applicators or persons with valid WPS handler training may access pesticide storage areas.
- 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. If no REI has been identified for the product, then a 72-hour REI will be enforced [For more information, please refer to Chapter 19. “Pesticide Use and Selection” of the CALS Greenhouse Use Policy].
RESEARCH USE - SUGGESTIONS
In order to minimize interference from regulatory requirements, faculty and greenhouse management should follow these suggestions:
- Apply pesticides in the late afternoon (Fridays, if possible) and ventilate in the early morning.
- 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 greenhouse personnel orally.
- Avoid the need for early entry in the research design. Consider crop watering needs in advance.
Visitors may not be granted access to greenhouse 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.
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Published by CALS 5/5/1998
Most recent verification: 04/04/2011
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