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Conditions and Certification Statement: WPS Exception for Harvesting Greenhouse-Grown Cut Roses

Certification Statement. No early entry is permitted under this exception at any particular establishment until the greenhouse establishment owner completes and signs this statement and returns it to: Certification Worker Safety Branch, US EPA, Office of Pesticide Programs (7506C), 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460. The post mark date on the envelope of the completed statement will be the effective date for the establishment.

Scope. This exception covers all hand cut-rose production in greenhouses and all pesticide products registered for use on roses.

Requirements. All provisions of the Worker Protection Standard (40 CFR part 170) apply. Under this exception, a worker may enter a treated area during a restricted-entry interval (REI) to harvest cut roses, unless early entry is expressly not allowed on product labeling, if the agricultural employer ensures that the following early entry and risk-reduction requirements are met:

Early Entry Requirements for Any Exception.

  1. Workers must receive the pesticide safety training required in Section 170.130(a)(2) before they engage in harvesting tasks under this exception.
  2. Requirements of Section 170.112(c)(3-9) continue to remain in effect. These are: a prohibition against entry during the first 4 hours, and until applicable ventilation criteria have been met, and until any label specified inhalation exposure level has been reached; informing workers of safety information on the product labeling; provision, proper management, and care of personal protective equipment (PPE); heat-related illness prevention; requirements for decontamination facilities; prohibition on taking PPE home.

    Of particular note, PPE for early entry must be provided to the worker by the agricultural employer for early-entry, cut-rose harvesting. Such PPE shall conform with the label requirements for early-entry PPE. Leather gloves may be worn over chemical-resistant liners. However, per Section 170.112(c)(4)(vii), once leather gloves have been worn for this use, thereafter they shall be worn only with chemical-resistant liners and they shall not be worn for any other use. In addition, unattached, absorbent glove liners may be worn underneath the chemical resistant liners, provided the unattached, absorbent glove liners are disposed of at the end of the day in which early-entry harvesting occurred.

Additional Risk-Reduction Requirements for the Rose Exception.

  1. The time in treated areas during an REI for any worker harvesting roses under this exception does not exceed a maximum of 3 hours in any 24-hour period.
  2. The agricultural employer shall notify workers before entering a treated area, either orally or in writing, in a language the workers understands, that the establishment is using this exception to allow workers to enter treated areas before the REI expires, to hand harvest roses; all conditions of this exception must be described.
  3. The agricultural employer shall notify EPA (address provided above) within 5 consecutive days of any incident believed to be the result of exposure to pesticides and pesticide residues that occurred during early-entry harvesting performed under the conditions of this exception.

Definitions. The terms used in this exception have the same meanings as they have in the Worker Protection Standard, 40 CFR part 170.

Expiration. This exception is effective on December 18, 1996 and will expire two years from the date of publication in the Federal Register.

Expectations. EPA expects all greenhouse cut-rose agricultural employers using this exception to:

  1. Participate in the EPA-funded NIOSH rose-harvester risk research and allow unrestricted access to their premises and workers and support the generation of additional data to evaluate the effectiveness of mitigation measures such as use of PPE.
  2. Support the generation of additional data and research on alternative practices, to early cut-rose harvesting and pilot test the feasibility of incorporating such practices into their operations.
  3. Participate in education programs provided by EPA Headquarters or Regional Offices and/or State Lead Agencies on WPS. Cut-rose growers using the exception are encouraged to provide interactive pesticide safety training to their work force rather than relying solely on a training video.

Certification Statement. I hereby acknowledge that I have read this Conditions and Certification Statement, as well as the accompanying cover letter, and agree to abide by the conditions of this exception.

Establishment Owner: _______________________________

Establishment Name: _______________________________

Establishment Telephone # : __________________________

Establishment Address: _____________________________



Owner Signature: _________________________________

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