Exception for Limited Contact Activities

In April 1995, EPA completed an exception to the Worker Protection Standard (WPS) that would allow, under specified conditions, workers to enter pesticide treated areas during a restricted entry interval (REI) to perform tasks that involve limited contact with pesticide treated surfaces. The REI is the time period after a pesticide application when workers may not enter a pesticide treated area without protective clothing.

Background

Under the WPS, each pesticide label specifies an REI, usually ranging from 12 to 72 hours. The 1992 WPS limited worker early entry activity in treated areas under an REI to 1 hour in a 24 hour period. In July 1994, EPA received a petition from a coalition of agricultural organizations. These organizations recommended an exception to the WPS for performing tasks involving limited contact with pesticide treated surfaces. EPA considered the petition, and in a January 1995 Federal Register Notice, proposed to grant such a nationwide exception. In the Notice, EPA also solicited public comment. The public comments received helped to persuade EPA that there could be significant economic impacts if certain limited contact tasks were prohibited during the REI. Therefore, the Agency is granting an exception to the early entry prohibition for limited contact activities.

Summary of Final Action

This exception allows workers the flexibility during an REI to perform limited contact tasks that could not have been foreseen and which, if delayed, would cause significant economic loss. At the same time, the exception includes significant provisions to limit pesticide exposure and risk to employees performing limited contact tasks. The conditions of the exception for limited contact, early entry activities are:

The workers' contact with treated surfaces is minimal and is limited to the feet, lower legs, hands and forearms;

The pesticide product does not have a statement in the labeling requiring double notification (workers must be notified both verbally and by posting of these high toxicity pesticides);

Personal protective equipment for early entry is provided to the worker and must either conform with the label requirements or include at least coveralls, chemical resistant gloves, socks, chemical resistant footwear, and eyewear (if eyewear is required by the product labeling);

No hand labor activity (such as, hoeing, picking, pruning, etc.) is performed;

The time in treated areas under a REI for any worker may not exceed 8 hours in a 24 hour period;

The workers do not enter the area during the first 4 hours, and until applicable ventilation criteria have been met, and until any label specified inhalation exposure level has been reached;

Before workers enter a treated area under an REI, the agricultural employer shall give them oral or written notification of the specifics of the exception to early entry. The notification must be in a language that the workers understand.

For more information contact:

Certification and Worker Protection Branch
Office of Pesticide Programs
U.S. EPA (7506C)
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460-0001
Phone: 703 305-7666
Fax: 703 308-2962

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Exception for Limited Contact Activities

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