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Early-Entry Work Situations under the Current WPS

The WPS allows entry into a pesticide-treated area that remains under a restricted-entry interval (REI) only in a few narrow work situations. When early entry is permitted under the WPS, special protections must be given to the early-entry workers.

What are the work situations where early entry is allowed?

Early entry involving contact with pesticide-treated surfaces is permitted in only the following work situations:

Hand labor is any agricultural activity performed by hand, or with hand tools, that might cause a worker to have substantial contact with surfaces (such as plants, plant parts, or soil) that may contain pesticide residues. Examples of hand labor tasks include: harvesting, detasseling, thinning, weeding, topping, planting, girdling, caning, sucker removal, pruning, disbudding, roguing, and packing produce into containers in the field.

Note: The definition of hand labor does not include operating, moving, or repairing irrigation or watering equipment. These tasks can be performed during the REI, but only under approved situations and with proper early-entry personal protective equipment (PPE).

A state, tribal, or federal agency must declare that circumstances exist, have occurred, or are forecast that might cause an agricultural emergency where your establishment is located. Examples of such circumstances include flooding, hail, high winds, hurricane, tornado, freeze, or frost.

EPA has approved two specific tasks for early entry through EPA’s formal regulatory exemption process:

Limited-contact tasks are tasks where early-entry workers’ only contact with treated surfaces – including soil, water, surfaces of plants, crops, and any equipment – is minimal and is limited to their feet, lower legs, hands, and forearms. Hand labor tasks are not limited-contact tasks. Examples of limited-contact tasks are:

Irrigation tasks are tasks related to operating, moving, or repairing irrigation or watering equipments and where early-entry workers’ only contact with treated surfaces – including soil, water, surfaces of plants, crops, and irrigation equipment – is minimal and is limited to their feet, lower legs, hands, and forearms.

There are specific requirements and conditions that must be met for employees to make use of the EPA-approved exceptions for limited contact activities and irrigation activities. Read more about these exceptions at:

Under what conditions is early entry allowed for these work situations?

There are specific conditions that must be met for early-entry for short-term tasks, limited-contact tasks, irrigation tasks, and agricultural emergency tasks. Some examples of these conditions are provided in the following table. However, these lists are not complete so see Unit 4 of the How to Comply Manual (PDF) (14 pp, 1.1MB, About PDF) and the two Federal Register notices from May 3, 1995 listed above for all of the details.

Condition Short Term Limited Contact Irrigation Agricultural Emergency
Wait at least 4 hours after the pesticide application is completed?
Yes
Yes
Yes
Yes
Wait until inhalation exposure level on the pesticide label has been reached or any WPS ventilation criteria have been met?
Yes
Yes
Yes
Yes
Maximum amount of time allowed per 24-hour period?
1 hour
8 hours
8 hours
No limit
Allowed for pesticides whose labeling requires double notification (verbal notification and posting signs)?
Yes, allowed for all WPS pesticides
No
No
Yes, allowed for all WPS pesticides
Are hand labor tasks permitted?
No
No
No
Yes, but must be related to the ag emergency
Employer provides special protections for early-entry workers regarding training, instructions, decontamination supplies and personal protective equipment (PPE)?
Yes
Yes
Yes
Yes
Need for entry could/could not have been anticipated
Doesn’t matter
Only if need could not have been foreseen
Only if need could not have been foreseen
Only if circumstances could not have been anticipated when pesticide was applied
Entry is/is not an economic necessity
Doesn’t matter
Only if delay would cause significant economic loss
Only if delay would cause significant economic loss
Early entry is only practice to prevent or reduce a substantial economic loss

What are the special protections for early-entry workers?

Worker employers must provide the following additional protections to early-entry workers who contact anything that has been treated with a pesticide:

Training and Instructions

Worker employers must make sure each early-entry worker is trained as a WPS worker before entering a pesticide-treated area during an REI. The 5-day grace period for training that applies to other workers does not apply to early-entry workers.

Worker employers must instruct early-entry workers, in a manner they can understand:

Worker employers must inform early-entry workers, in a manner they can understand, about the safety information and instructions on the labeling of the pesticide(s) to which the REI applies, including:

Decontamination Supplies

Worker employers must provide early-entry workers with:

Worker employers must make sure that the decontamination supplies:

A worker employer must provide each early-entry worker with at least 1 pint of emergency eyeflush water when the pesticide labeling requires protective eyewear. The emergency eyeflush water must be immediately accessible.

At the site where early-entry workers take off their PPE, the worker employer must provide soap, clean towels, and enough water to allow early-entry workers to wash thoroughly after removing their PPE.

PPE for Early-Entry Workers

Worker employers must provide their early-entry workers with the early-entry PPE required by the pesticide labeling, make sure they wear the PPE, and make sure they use the PPE correctly. The specific duties regarding PPE are the same as for handler employers providing PPE for handlers.

Where can I get more information?

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