Restrictions for Worker Entry into Treated Areas
Workers face the greatest potential for exposure to pesticides when entering an area recently treated with a pesticide. EPA is proposing multiple changes to provide greater protection for workers entering a treated area within the time period when general entry is restricted, according to the pesticide label.
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 Restrictions for Worker Entry into Treated Areas:
A. Establish Minimum Age of 16 for Workers Entering a Treated Area under an REI
- Are there other ways EPA could protect children less than 16 years old from pesticide risks associated with entry into a treated area during an REI? If so, please describe.
- What would be the impact on state programs of establishing a minimum age for early entry workers?
- Would establishing a minimum age of 16 or 18 for early entry workers have an adverse impact on state requirements for certified applicators to be a minimum age, generally 16 or 18?
- Are there additional benefits or burdens with establishing a minimum age of 16? If so, please provide data to support this position.
- Are there additional benefits or burdens associated with establishing a minimum age of 18? If so, please provide data to support this position.
B. Requirements for Entry During an REI
- Is there other information related to entry into a treated area under an REI that EPA should require employers to document? If so, what information and why?
- Are there other ways EPA could verify that workers received notification and the proper equipment to work in a treated area under an REI without the proposed recordkeeping?
C. Clarify Requirement for Decontamination Supplies for Workers Entering a Treated Area under an REI
- Is 3 gallons for decontamination a reasonable amount of water for an early-entry worker who has been exposed to a pesticide? If not, why?
- What amount of water would be reasonable, or what other alternative is there?
D. Exception to the General Prohibition against Sending Workers into a Treated Area under an REI
ii. Limit “agricultural emergency” exception.
- Are there reasons EPA should consider eliminating the agricultural emergency exception?
- What benefits and drawbacks are associated with limiting the agencies that can declare an agricultural emergency?
- Please share any data on the use of the agricultural emergency exception, establishing a time limit, or other restrictions associated with exceptions.
- Should EPA develop guidance on the criteria for declaring an agricultural emergency and/or how a person or organization could request an eligible agency to declare an agricultural emergency?
iv. Eliminate provision for exceptions requiring Agency approval.
- Do you have factual information about the current frequency of use of any of the exceptions? If so, please provide it to the Agency.
- What are the benefits and challenges of the proposed amendments to each of the exceptions?
- Are there other reasonable alternatives that EPA did not consider? If so, please describe and provide a rationale for their consideration.
- Should EPA consider a different time limit for the agricultural emergency exception? For other exceptions?
- Are there any drawbacks to adding the irrigation and limited contact exceptions into the rule?
- For all comments, please provide factual information in support of your assertions.
E. Expansion of Entry-Restricted Areas
- Is it reasonable for EPA to assume that workers can be reassigned for the duration of the pesticide application?
- Are there any burdens to applying an entry-restricted area on farms and in forests? Are there any other benefits?