Unit 4 PART C
Early Entry
The WPS allows entry into a treated area that remains under a restricted-entry interval only in a few narrow work situations. When early entry is permitted under the WPS, special protections must be given to the early-entry workers.
This subsection describes those work situations and
protections.
Early-Entry Work Situations
General Protections for Early-Entry Workers
Training and Instructions for Early-Entry Workers
Decontamination Sites for Early-Entry Workers
Personal Protective Equipment for
Early-Entry Workers
Early-Entry Work Situations
Basic Responsibilities
Worker employers must not allow their workers to enter
treated areas where they will contact treated surfaces, except in a
few very limited work situations.
Worker employers must provide special protections to
any of their workers who do early-entry tasks involving contact
with anything that has been treated with a pesticide, including
soil, water, air, and surfaces of plants.
Employers should make every effort to schedule pesticide
applications and worker tasks in a way that will avoid the necessity
of early entry of workers into treated areas.
Specific Duties
Early entry involving contact with treated surfaces is permitted in
only three work situations:
- short-term tasks
that last less than 1 hour and do not involve
hand labor,
- emergency tasks
that take place because of an agricultural
emergency, and
- specific tasks
approved by EPA through a formal
exception process.
Short-Term Tasks With No Hand Labor
Workers may enter treated areas before the restricted-entry
interval is over to do short-term jobsthat do not involve hand
labor, if provided with the protections and PPE required for early
entry. Each worker must:
- wait at least 4 hours after the pesticide application is
completed before entering the treated area, AND
- wait at least until any inhalation exposure level listed on the
product labeling has been reached or any WPS ventilation
criteria have been met, AND
- spend no more than I hour in a 24-hour period on short-
term early-entry tasks.
For additional protections that must be provided to
workers who do short-term early-entry tasks,
click here.
Hand labor:
Any agricultural activity performed by hand, or with hand
tools, that might cause a worker to have substantial contact
with surfaces (such as plants, plant parts, or soil) that may
contain pesticide residues. Examples of hand labor tasks
include: harvesting, detasseling, thinning, weeding, topping,
planting, sucker removal, pruning, disbudding, roguing,
and packing produce into containers in the field.
Examples of short-term tasks NOT considered hand labor
include: operating, moving, or repairing irrigation or
watering equipment not used to apply pesticides.
Only appropriately trained and equipped pesticide handlers
may operate, move, or repair the parts of chemigation
equipment that may contain pesticide residues.
(Chemigation equipment is equipment used to apply
pesticides with irrigation water.)
Tasks During an Agricultural Emergency:
Early-entry workers may enter treated areas before the restricted-
entry interval is over to do tasks that are necessary because of an
agricultural emergency, if provided with the protections and PPE
required for early entry. Each worker must:
- do only those tasks relating to mitigating the emergency,
AND
- wait at least 4 hours after the pesticide application is
completed before entering the treated area,
AND
- wait at least until any inhalation exposure level listed on the
product labeling has been reached or any WPS ventilation
criteria have been met.
For additional
protections that
must be provided to
early-entry workers,
click here.
- Declaring a Potential Agricultural Emergency
A State, Tribal, or Federal agency having jurisdiction must
declare that circumstances exist, have occurred, or are
forecast that might cause an agricultural emergency where
your establishment is located. Such circumstances may
include, for example, flooding, hail, high winds, hurricane,
tornado, freeze, or frost.
- Agricultural Emergency on Your Establishment
Once such an agency has declared that circumstances might
cause (or might already have caused) an agricultural
emergency in your area, you must decide if an agricultural
emergency actually exists for any treated areas on your
establishment that remain under a restricted-entry interval.
All of the following conditions must be met before you may
let workers go into a treated area where a restricted-entry
interval is in effect:
- You could not have anticipated the circumstances that led
to the emergency when you made the pesticide
application. For example, you do not qualify if weather
forecasts before the application warned you that the
emergency was imminent.
- You had no control over the circumstances that led to the
emergency. For example, you do not qualify if you forgot
to heat your greenhouse or over-watered with an
irrigation system.
- Early entry is the only practice that will prevent or reduce a
substantial economic loss involving the crop in that treated
area. For example, you do not qualify if you have access to
mechanical harvesting equipment that could harvest your
crop in lieu of hand-harvesting.
- If early entry does not occur, the loss of profit will be
greater than the loss that would be expected on the basis
of experience and the variation in crop yields in
previous years. The contribution of mismanagement
cannot be considered in determining the loss.
EPA-Approved Exceptions
EPA has established a formal regulatory process for considering
additional exceptions to the restrictions on entering treated areas
during an REI, If any such exceptions are approved, EPA will
publish them in the Federal Register and intends to inform State
and Tribal pesticide agencies, the Cooperative Extension Service,
affected commodity, industry, and worker associations, and other
interested parties. Check with them or the EPA office in your
region for an updated list of approved exceptions and for
information about the requirements and limitations of those
exceptions.
General Protections for Early-Entry Workers
Basic Responsibilities
Worker employers must provide several types of
protections, described below, to their early-entry workers
who contact anything that has been treated with a pesticide,
including soil, water, air, and surfaces of plants.
Specific Duties
Protections Required by the Pesticide Labeling
Provide any protections required by the pesticide labeling for
early-entry tasks.
Required Protections That Are the Same as for Other Workers
Provide protections that are required for all agricultural workers:
Special Protections for Early-Entry Workers
A few WPS requirements for early-entry workers differ from those
for other agricultural workers. Provide special protections to early
entry workers in the following areas:
- Training and instructions,
- Decontamination sites, and
- Personal protective equipment.
These requirements are described in detail in the next
several pages.
Training and Instructions for Early-Entry Workers
Basic Responsibilities
Worker employers must make sure that each of their early-
entry workers is currently trained as a WPS worker and,
in addition, receives specific information and instructions,
described below.
Specific Duties
Training
Make sure that each early-entry worker is currently trained as a
WPS worker (see requirements here
and here)
before
entering a treated area on the agricultural establishment during a
restricted-entry interval.
The 5-day (or 15-day) grace period for training that applies to
other agricultural workers does NOT apply to early-entry workers.
Instructions Related to Personal Protective Equipment (PPE)
Instruct early-entry workers, in a manner they can understand:
- how to put on, use, and take off early-entry PPE correctly,
- *about the importance of washing thoroughly after removing
PPE, and
- how to prevent, recognize, and give correct first aid for heat
illness (too much heat stress).
For definitions of
PPE, click here.
Labeling Information and Instructions
Inform early-entry workers, in a manner they can understand,
about the safety information and instructions on the labeling of
the pesticide(s) to which the REI applies, including:
- human hazard statements and precautions,
- first aid,
- signs and symptoms of poisoning,
- PPE required for early entry, and
- any other precautions or instructions related to safe use or
early entry.
Option: You may allow workers who will do early-entry
tasks to read the labeling themselves, if they are able to
read and understand it.
Decontamination Sites for Early-Entry Workers
Basic Responsibilities
Worker employers must provide their early-entry workers with
decontamination sites for washing off pesticides and pesticide residues.
Specific Duties
Supplies
Provide each decontamination site with:
1. Water-enough for:
- routine washing, and
- emergency eyeflushing.
If the water is stored in a tank, the water must not be used for
mixing pesticides, unless the tank is equipped with correctly
functioning antibacksiphoning or check valves or other
mechanisms (such as air gaps) that prevent pesticides from
moving into the tank.
How Much Water Should Be Provided?
Obviously, running water meets the requirement. However,
if it is not available, use the following guidelines:
- Early-Entry Workers:
At least I gallon of water is
recommended for each early-entry worker using the site.
If you find that I gallon per early-entry worker is -
inadequate to last for the entire work period, provide
more water or replenish the water at some point during
the work period.
Decontamination and emergency eyeflush water must,
at all times when it is available to early-entry workers, be of
a quality and temperature that will not cause illness or
injury when it contacts the skin or eyes or if it is swallowed.
2.Soap and single-use towels-enough for the needs of early-
entry workers.
Location
Make sure:
- The decontamination site is not in an area being treated
with pesticides.
- The decontamination site is not in an area under a restricted-
entry interval, UNLESS that location is necessary for the site
to be reasonably accessible to early-entry workers.
- The decontamination site is reasonably accessible to and not
more than 1/4 mile from early-entry workers.
Exception:
For tasks performed more than 1/4 mile from the nearest point
reachable by vehicle (car, truck, or tractor), the decontamination
site may be at the access point. In this circumstance, clean
water from springs, streams, lakes, or other sources may be used
for decontamination if such water is more readily available than
the water at the decontamination site.
Emergency Eyeflushing
Provide each early-entry worker with at least I pint of emergency
eyeflush water when the pesticide labeling requires protective
eyewear for early entry. The emergency eyeflush water must be
immediately accessible. For example, it could be carried by the
handler or be on a vehicle the early-entry worker is using. The
emergency eyeflush water may be the water at the
decontamination site if the decontamination site is
immediately accessible.
Decontamination at the End of Exposure Period
At the site where early-entry workers take off their PPE, provide:
- soap,
- clean towels, and
- enough water to allow early-entry workers to wash thoroughly
after removing their PPE.
Personal Protective Equipment for
Early-Entry Workers
Basic Responsibilities
Worker employers must provide their early-entry workers with the
early-entry PPE required by the pesticide labeling, make sure they
wear the PPE, and make sure the use the PPE correctly.
PPE for early-entry activities is listed on the pesticide label
in the Directions for Use section under the heading
Agricultural Use Requirements.
Specific Duties
Duties Related to Personal Protective Equipment
- Provide the appropriate PPE in clean and operating
condition to each early-entry worker.
- Make sure early-entry workers wear PPE correctly for its
intended purpose and use it according to the manufacturer's
instructions.
- Inspect all PPE before each day of use for leaks, holes, tears,
or worn places. Repair or discard any damaged equipment.
- Provide early-entry workers clean places away from pesticide
storage and pesticide use areas to:
- store personal clothing not in use,
- put on PPE at the start of any exposure period, and
- take off PPE at the end of any exposure period.
- Take necessary steps to prevent heat illness (too much heat
stress) while PPE is being worn.
- Do not allow early-entry workers to wear home or take home
PPE contaminated with pesticides.
See PPE definitions
Cleaning and Maintaining PPE
- Keep pesticide-contaminated PPE separate from other
clothing or laundry, and wash it separately.
- If PPE will be reused, clean it before each day of reuse
according to the instructions from the PPE manufacturer,
unless the pesticide labeling specifies different requirements.
If there are no such instructions or requirements, wash the
PPE thoroughly in detergent and hot water.
- Thoroughly
dry the clean PPE before it is stored, or put it in
a well-ventilated place to dry.
- Store clean PPE separately from personal clothing and away
from pesticide-contaminated areas.
Disposal of PPE
Comply with any applicable Federal, State, Tribal, and local
regulations when you dispose of PPE that cannot be cleaned correctly.
Instructions for Persons Who Clean PPE
Inform anyone who cleans or launders PPE:
- that PPE may be contaminated with pesticides,
- of the potentially harmful effects of pesticides,.
- how to protect themselves when handling contaminated
PPE, and
- how to clean PPE correctly.
For an example of what to tell people
who clean PPE,click here.
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