Training for Workers and Handlers
Training is at the core of EPA’s efforts to help agricultural workers and pesticide handlers better protect themselves and their families.
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 Training for Workers and Handlers.
A. Shorten Retraining Interval for Workers and Handlers
- Should EPA consider different pesticide safety training timing? If so, what timeframe and why?
- Do you have information concerning the relationship between the frequency of training of workers and handlers and the frequency of incidents of pesticide exposure or illness? If so, please provide.
- Are there other ways EPA could ensure that workers and handlers retain the information presented in pesticide safety training so the retraining interval can be longer than one year?
- Are there other burdens or benefits associated with a 2-year retraining interval that EPA has not considered?
- What would be the impact of a 1- or 2-year retraining interval on states and tribes?
- Should EPA consider retaining the current 5 year retraining interval for workers and handlers and adding a requirement for annual refresher training? Please provide information on the relative benefits to and burdens on employers, workers, and handlers. EPA currently envisions that, if adopted, the annual refresher training for workers would include the topics proposed at 170.309(e), the grace period training (see Unit XVIII for a full discussion of the proposed points for training workers under the grace period). The annual refresher training for handlers would include a review of information necessary for handlers to protect themselves, their families, workers, and the environment from pesticide exposure. EPA anticipates that the refresher training would be slightly shorter in duration than the proposed full pesticide safety training, but seeks comment on the duration of such refresher training. Retaining the current 5 year retraining interval and adding a requirement for annual refresher training would necessitate additional recordkeeping by the employer. The employer would maintain training records for workers and handlers as discussed in Unit VII.B. below, as well as records containing the same information for the refresher training.
B. Establish Recordkeeping Requirements to Verify Training for Workers and Handlers
- Would a requirement for employers to report worker and handler training information to the state or federal government for compilation in a central repository have benefits? If so, please detail the potential benefits and cost.
- Should the Agency reconsider any of the alternate options presented in developing a final rule? If so, why? Please provide data to support your position.
- Are there changes that would make the training verification card program more effective and less prone to falsified cards? If so, please provide detailed suggestions for improving the system.
- Should EPA consider a performance standard to evaluate worker and handler training (asking questions based on the training content) rather than recordkeeping? Are there benefits or drawbacks to this approach that the Agency has not considered?
- Would employers rely on training records provided by the worker or handler as verification that the worker or handler had received pesticide safety training?
C. Require Employers to Provide Establishment-Specific Information for Workers and Handlers
- To what extent do employers already provide this information to all workers and handlers when they first arrive at the establishment, for example, during the hiring process?
- The current rule requires employers to ensure that the workers and handlers receive information in a manner they understand. Are there any issues with the current requirement for employers? If so, please describe and provide data to support this position.
D. Establish Trainer Qualifications
- Are there other programs that would prepare trainers to convey pesticide safety information to workers and handlers? Please describe the program and the feasibility of its implementation for affected establishments.
- Should EPA consider requiring trainers of workers and handlers to refresh their qualifications periodically, such as requiring attending a train-the-trainer program every 5 years? Please provide data in support or opposition.
- The current rule requires employers to ensure that the workers and handlers receive information in a manner they understand. Are there any issues with the current requirement for trainers? If so, please describe and provide data to support this position.
E. Expand the Content of Worker and Handler Pesticide Safety Training
vi. Respirator Fit-Testing and Medical Evaluation for Handlers.
- Are there any training points listed above that EPA should consider not including in the final proposal? If so, which points and why?
- Are there points that EPA should consider adding to the training content? If so, what points should be added? Please provide a rationale for why the additional content would benefit workers and/or handlers.
F. Retain Audiovisual Presentations as Permissible Methods for Pesticide Safety Training
- Please provide any additional information on the efficacy of different methods used to conduct worker and handler training.
G. Eliminate Exception to Handler Training Requirements
- Should the proposed training under 40 CFR part 171 include a requirement for expanded training on the WPS?
- How would the benefits to employers from giving a single training that would apply to both WPS handlers and applicators using RUPs under the direct supervision of a certified applicator compare to the costs of requiring agricultural applicator training for all applicators using RUPs under the direct supervision of a certified applicator?