Agricultural workers want and need to know what pesticides are being used where they work. Employers need to make this hazard communication information available to their workers. Hazard communication is a core part of protections provided by EPA and Occupational Safety and Health Administration.
Read the details of the proposed changes and the rationale before you comment.
All your comments are welcome but we have specific questions for you on changes to Hazard Communication:
A. Pesticide-Specific Hazard Communication Materials – General
- What would be the burden on employers to maintain the SDS and pesticide label for 2 vs. 5 years?
- Do agricultural employers already collect SDSs? If so, how do they obtain them and what burden is associated with retrieving the SDS for one or more products?
- What are the benefits and drawbacks of requiring employers to maintain and provide access to employees and others the proposed pesticide-specific hazard information?
- Are there other approaches to providing pesticide-specific information to workers and handlers that the Agency should consider? If so, please describe and provide rationales for implementing them.
- Are there other data on the benefit to workers and handlers from receiving pesticide-specific information before every entry into a pesticide treated area?
- Does opening access to pesticide-specific information to authorized representatives raise any problems? If so, please describe the potential issues with particularity and provide supporting information where available.
B. Pesticide Application Information – Content and Timing
- Would the additional pesticide application information proposed by EPA impose undue burden on the applicator or the employer?
- Are there benefits or drawbacks to requiring this additional information that EPA has not considered? If so, please describe.
C. Pesticide Application Information – Location and Accessibility (No additional questions)
D. Pesticide Application Information and Pesticide-Specific Hazard Communication Materials — Retention of Records
- Should EPA consider a different timeframe for recordkeeping for this requirement? If so, what period and why?
- What burdens would be imposed on agricultural employers as a consequence of the proposed two-year record retention requirement?
- How would the burden of the proposal to maintain application records compare with the current requirement to maintain a central display?