PESTICIDE WORKER SAFETY REGULATORY DEVELOPMENT 

Issue: EPA is considering changes to the agricultural worker protection regulation and to the pesticide 

 applicator certification regulation. These regulations, for 11 and 32 years respectively, have been

 unchanged. 

Background: 

• The agricultural worker protection regulation is intended to safeguard workers in farms, forests, nurseries, and 

greenhouses that enter pesticide treated areas to perform crop-related tasks, such as harvesting or pruning, and for 

those who mix, load, or handle agricultural pesticides. The regulation has provisions for training, posting in treated 

areas, entry restrictions, and personal protective equipment. 

• The certification of pesticide applicators regulation requires that those who intend to apply restricted use pesticides 

demonstrate competency and become certified to use these pesticides. This requirement is designed to assure that 

certified applicators are adequately prepared to protect human health and the environment from misapplication and 

exposure to pesticides. 

• The changes to the regulations being considered are based, in part, on the culmination of separate assessments of the 

certification of pesticide applicator and the agricultural worker protection programs. The process for, and the 

findings from, these assessments are summarized in the Report on the National Assessment of EPA’s Pesticide 

Worker Safety Program. In both assessments, issues were identified that only can be addressed through regulation 

change. 

• For more information about these proposed regulatory changes, please refer to the Report on the National 

Assessment of EPA’s Pesticide Worker Safety Program at http://www.epa.gov/oppfead1/safety/workshops.htm

Status: 

• Based on internal program review and stakeholder input from the assessments, EPA has developed issue papers 

which describe the concern, the background, and the proposed regulatory options for addressing the concern. These 

issue papers provide the beginning point for developing regulatory text, which in turn will be formed into a proposal 

for regulatory change. 

• A workgroup of the Pesticide Program Dialogue Committee (PPDC) has been formed to provide a mechanism for 

stakeholder input on the regulation change process. The PPDC Worker Safety Regulation Change Workgroup met 

in February and in June 2006, and a process has been developed for their informed participation in the regulation 

change discussions. 

• At the June 2006 PPDC meeting, OPP committed to sharing the preliminary draft issue papers with the PPDC 

workgroup, and to follow up with conference calls for discussion. 

PPDC Workgroup Process: 

• The issue papers, in draft, are sent to the workgroup for conference call discussion. Input from the PPDC 

workgroup and from other processes will be used to refine existing options and identify new ones. The process is 

expected to be iterative as stakeholders provide their input. 
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Title Protect the Health of Agricultural Workers by Providing Them Pesticide 

Specific Hazard Information 

Issue Statement

• The current agricultural worker protection regulation (40 CFR 170) lacks provisions 

requiring employers to provide agricultural workers with pesticide-specific hazard 

information for the pesticide hazards they are exposed to in the workplace. This lack of 

knowledge inhibits their ability to protect themselves or respond appropriately in an 

emergency situation, placing these workers at significant risk of experiencing adverse 

effects from workplace exposures to pesticides. 

Public Health / Risk Concern

• Agricultural pesticide workers need appropriate information about the pesticide hazards 

they are exposed to on the job. It is widely recognized that providing employees with 

appropriate information and training about workplace hazards increases their ability to 

take measures to protect themselves and reduces their risk for occupational injuries or 

illness. This premise is the basis for the Occupational Safety and Health Administration 

(OSHA's) Hazard Communication Standard (HCS) regulation (29 CFR 1910.1200). 

• In promulgating the HCS regulations, OSHA has established that employees have a 

"right-to-know" the hazards and identities of the chemicals they are exposed to in the 

workplace, as well as the measures they can take to protect themselves. Further, OSHA 

determined that employees also have a need to know about these hazards in order to 

better protect themselves and reduce their chance for illness/injury as they are at 

significant risk of experiencing adverse health effects in the absence of such knowledge 

(48 FR 53280, 52 FR31852, 59 FR 6126). 

• The revised HCS regulation of 1987 applies to the agricultural industry, but in practice 

OSHA's HCS is only applicable to a limited number of agricultural establishments, and 

only to those hazardous chemicals that are not pesticides (59 FR 6126). OSHA is 

prohibited from enforcing the HCS on farms with 10 or fewer employees unless the farm 

has a temporary labor camp. Additionally, even on HCS covered agricultural 

establishments OSHA generally does not enforce the HCS requirements with respect to 

pesticide hazards since these establishments are covered under EPA's worker protection 

regulation. OSHA generally defers to EPA in this area since the worker protection 

regulation has requirements designed to protect agricultural pesticide workers exposed to 

pesticides and EPA is recognized as the Agency with the authority to regulate pesticides 

under FIFRA. 

 

• By lacking a pesticide-specific hazard communication (hazcomm) provision similar to 

OSHA's HCS, the worker protection regulation does not provide OSHA-equivalent 

protections to agricultural pesticide workers. Therefore, these employees do not receive 

HCS protections (or OSHA-equivalent protections under EPA regulation) that are 

intended to be provided to employees in all industries. This regulatory gap puts 
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agricultural pesticide workers at higher risk for occupational illnesses and injuries 

because they are being exposed to pesticide hazards in the workplace they are not 

adequately informed about or trained on. This significantly inhibits their ability to 

protect themselves or respond appropriately in an emergency situation, creating 

unacceptable occupational risks for these workers. 

Background

• The 1992 agricultural worker protection regulation amendments added several hazcomm 

and right-to-know protections for agricultural pesticide workers including requirements for: 

providing general pesticide safety training; providing notice of pesticide applications and 

posting of warning signs at entry-restricted areas; posting of general pesticide safety 

information; providing certain information about pesticide applications on the 

establishment; and providing pesticide labeling information to handlers. 

• The regulation now provides occupational protections for agricultural pesticide workers that 

are essentially equivalent to that required for workers in other industrial sectors under 

OSHA's HCS - with one major exception. OSHA's HCS requires that chemical-specific 

hazard information be made available to workers. The EPA regulation does not have such a 

provision. 

• The Agency intended to add pesticide-specific hazcomm requirements to the regulation 

when it was revised in 1992. However, there were still several unresolved issues associated 

with adding these provisions that would have held up the 1992 issuance of the final 

regulation. The Agency decided to proceed without adding pesticide-specific hazcomm 

provisions, believing it was unreasonable to delay issuance of all the other protective 

measures unrelated to the hazcomm requirements. The Agency believed agricultural 

pesticide workers would be better protected by receiving the bulk of the new protections as 

soon as possible. 

• Instead, the Agency published a companion proposed hazcomm rule at the same time the 

final worker protection regulation was issued (57 FR 38167). The Agency proposed to 

amend the regulation to add pesticide-specific hazcomm requirements. However, the 1992 

proposal to add hazcomm requirements was never finalized. 

 

• Internal and external program assessments since the time of the 1992 hazcomm proposal 

have resulted in recommendations to the Agency to add appropriate pesticide-specific 

hazcomm provisions. The Government Accountability Office and Children’s Health 

Protection Advisory Committee issued reports that recommend adding pesticide-specific 

hazcomm requirements. During public meetings held in the course of the National 

Assessment of the Pesticide Worker Safety Program (National Assessment), health 

agencies, the medical community and those who often respond to reports of pesticide 

illnesses among migrant workers (e.g., Migrant Clinicians Network, community health 

programs, advocacy groups, etc.) told the Agency that workers should have access to 

pesticide-specific hazard information for pesticides they may be exposed to in the 

workplace so they receive appropriate medical care in the event of a pesticide exposure 
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incident or illness. [Note: The full report from the National Assessment can be found 

online at: http://www.epa.gov/oppfead1/safety/2005/workersafety-assessrpt.pdf ] 

• In the original 1992 hazcomm proposal, the Agency noted that it met with OSHA to 

resolve issues related pesticide hazcomm requirements and EPA/OSHA jurisdiction. It 

was OSHA's position that once the proposed pesticide-specific hazcomm requirements 

were added to the EPA regulation and enforced, the regulations would provide 

protections effectively equivalent to OSHA's HCS. In view of this similarity, OSHA 

agreed they would defer to EPA and not enforce their HCS with regard to employees 

exposed to pesticides who are covered by the EPA regulation (57 FR 38167). By not 

adding the pesticide-specific hazcomm provisions the issue of OSHA deferral to EPA in 

this area has been left in doubt, resulting in agricultural employers being potentially 

subjected to compliance with two sets of similar, but still substantially different 

regulations. 

Options Under Consideration

1. Protect the health of agricultural workers by adding requirements for pesticide-specific 

hazard communication to the agricultural worker protection regulation. 

The current requirements are inadequate and provide a lower standard of occupational 

protection for agricultural workers compared to workers in other industrial sectors. The 

Agency believes provisions should be added to the regulation to require employers to 

make certain pesticide-specific hazard information available to agricultural pesticide 

workers for those pesticides which they are exposed to in the workplace. The Agency 

believes these changes are needed to assure that agricultural pesticide workers: 

o have access to adequate information about the pesticide hazards they are exposed to 

in their workplace so they can take steps to protect themselves and respond 

appropriately in an emergency situation; 

o know what pesticides they are being exposed to so they receive appropriate medical 

care in the event of a pesticide exposure incident or illness; and 

o receive occupational protection under the EPA regulation that is equivalent and 

comparable to that which workers would be entitled to under OSHA's HCS when they 

are exposed to chemical hazards in the workplace so that existing OSHA equivalency, 

jurisdiction, and preemption issues are resolved. 

There are numerous options and approaches being considered regarding how to implement 

pesticide-specific hazcomm requirements. The Agency has undertaken several hazcomm 

pilot projects and studies, based on the suggestions of the hazard communication pilot 

project workgroup formed as part of the National Assessment, to evaluate some of these 

options / approaches. The final results from these various efforts will provide the Agency 

with better information regarding the best options and approaches for communicating 

pesticide-specific hazards to agricultural pesticide workers. 

Even with the information obtained from the hazcomm pilot work, the Agency is seeking 

input on the issues and options that must be considered and resolved before developing 
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its final proposal for adding pesticide-specific hazcomm requirements to the agricultural 

worker protection regulation. Some of the issues the Agency must consider and resolve 

include: 

o how should the pesticide-specific hazard information be made available and conveyed 

(posted or handed out; orally or written; if written - MSDSs, fact sheets, crop sheets, 

or label; text-based or text and pictograms; what language(s); etc.); 

o what pesticide-specific hazard information should be conveyed to workers and 

handlers (acute toxicity, chronic toxicity, flammability, other chemical/physical 

hazards, etc.); 

o who should have the responsibility for developing the required pesticide-specific 

hazard information materials (registrants, employers, EPA, states/tribes, etc.); and 

o what other issues must be considered regarding implementation of pesticide-specific 

hazcomm requirements. 

The Agency is seeking input and comment on the full range of options/approaches that 

are associated with adding pesticide-specific hazcomm requirements to the EPA 

regulation. For additional information on the full range of issues and options being 

considered regarding adding pesticide-specific hazcomm requirements, refer to the original 

1992 hazcomm proposal (57 FR 38167) which is provided as an attachment. 

2. Make no changes and do not amend the WPS to add pesticide-specific hazard 

communication requirements. 

Not amending the EPA regulation to add hazard communication requirements will result 

in the inadequate protection of human health since agricultural pesticide workers will not 

have access to the information necessary to protect themselves or take appropriate action 

in the event of an emergency. It would also not address the OSHA jurisdictional and 

preemption problems that currently exist. 
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Title Improve Timing and Frequency of Safety Training to Help Agricultural 

Workers Protect Themselves from Pesticide Exposure 

Issue Statement

 

• Agricultural workers can be made ill from pesticide residues in treated fields. A key 

element in worker protection is the worker's ability to help in their own protection. 

Agricultural workers must receive pesticide safety training prior to entry into pesticidetreated fields. 

Public Health / Risk Concerns

• Agricultural worker risk is managed through limiting entry into treated fields (Restricted 

Entry Intervals or REIs) and by pesticide safety training to inform workers of the risks 

and how they may protect themselves. When pesticide use benefits outweigh risks, the 

Agency allows shorter REIs to accommodate crop production, increasing reliance on 

pesticide safety training as a protection for agricultural workers. Without rigorous and 

frequent safety training, there is a serious gap in their protection. 

• The current regulation requires that workers be trained once every five years. Employers 

may delay full training until the 6th day that a worker enters an area in which a pesticide 

has been applied or an REI has been in effect within the last 30 days. This weakness in 

protection does not adequately manage risks to agricultural field workers and their 

families. 

• The pesticide safety retraining interval of five years is clearly inadequate. A study with 

second-year medical students which provided a focused training intervention related to 

infection control demonstrated that although immediate post-test gains were made, the 

long-term (two year) retention of this information was negligible.1

 Obviously, this raises 

concerns for the five-year interval for field worker training, particularly when combined 

with the transitional nature and low-literacy characteristics of the population and the 

abstract concepts of pesticide risk. 

• Between 1998 and 1999, 313 farmworkers in California doing routine field work were 

made ill from pesticides2

. Agricultural farm workers are extremely vulnerable to 

exposures to pesticides as they enter treated fields because they do not recognize the 

potential for harm, and therefore do not protect themselves. 

• Allowing farmworkers to enter treated areas before they receive full safety training 

weakens their ability to protect themselves. The reduced information provided prior to 

 

1

Calabro K, Bright K, Kouzekanani K. Long-Term Effectiveness of Infection Control Training among Fourth Year 

Medical Students. Med Educ Online. 2000. URL: http://www.med-ed-online.org 

2

 Das R, Steege A, Baron S, Beckman J, Harrison R. Pesticide-related Illness among Migrant Farm Workers in the 

United States. Int J Occup Environ Health Vol 7/No 4,Oct/Dec 2001. 
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field entry fails to describe hazards associated with pesticides, provide information on 

how to recognize poisoning symptoms, or how to access emergency medical care if made 

ill. Workers entering fields with this limited information are vulnerable to exposures 

without recognizing their potential impacts and how to fully protect themselves. 

Additionally, it is possible for a worker to miss full training by moving from employer to 

employer, as is not uncommon during some harvesting periods. 

Options Under Consideration

1. Eliminate the grace period and the option for the brief training; require annual 

retraining to ensure that workers have an adequate understanding of risks and 

protective measures. 

The current training grace period allows field workers to enter treated fields for five days 

prior to receiving comprehensive safety training. Without complete training, workers are 

at a higher risk of exposure because they do not have the tools or knowledge available to 

protect themselves and their families. Field workers must have the full array of safety 

information on how to protect themselves, and they must know how to react if they are 

over-exposed. To ensure these protections are made available, the grace period for full 

training must be abolished, so that field workers would be trained in the full set of safety 

information prior to entering pesticide-treated fields. If the training grace period is 

eliminated, there would be no need for a brief training requirement, as all agricultural 

field workers would receive full training before their work begins. 

The regulations permit a retraining interval of up to five years. A shorter training interval 

would reinforce the information and elevate its importance. Many employers already 

conduct annual training on pesticide safety and other topics. Studies have shown that the 

retention of even highly relevant information to a well-educated audience deteriorates 

rapidly. Based on this, it is reasonable to require annual training for agricultural field 

workers. 

These changes to the regulations would significantly enhance protections to agricultural 

field workers by providing them with high quality, timely, and meaningful pesticide 

safety training. 

2. Eliminate the grace period and the option for the brief training; require bi-annual 

retraining to ensure that workers have an adequate understanding of risks and 

protective measures. 

The current training grace period allows field workers to enter treated fields for five days 

prior to receiving comprehensive safety training. Without complete training, workers are 

at a higher risk of exposure because they do not have the tools or knowledge available to 

protect themselves and their families. Field workers must have the full array of safety 

information on how to protect themselves, and they must know how to react if they are 

over-exposed. To ensure these protections are made available, the grace period for full 

training would have to be abolished, so that field workers would be trained in the full set 
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of safety information prior to entering pesticide-treated fields. If the training grace period 

is eliminated, there would be no need for a brief training requirement, as all agricultural 

field workers would receive full training before their work begins. 

The regulations currently permit a retraining interval of up to five years. A shorter 

training interval would reinforce the information and elevate its importance. Many 

employers already conduct annual training on pesticide safety and other topics. Studies 

have shown that the retention of even highly relevant information to a well-educated 

audience deteriorates rapidly. Based on this, it is reasonable to require more frequent 

training for agricultural field workers. 

These changes to the regulations would significantly enhance protections to agricultural 

field workers by providing them with high quality, timely, and meaningful pesticide 

safety training. 

 

3. Eliminate the grace period and the option for the brief training to ensure that workers 

do not enter the field without full safety training. No change to the five year re-training 

interval. 

The current training grace period allows field workers to enter treated fields for five days 

prior to comprehensive safety training. Without complete training, workers are at a 

higher risk of exposure and do not have the tools available to protect themselves and their 

families. Field workers must have the full array of safety information available to protect 

themselves, and they must know how to react if they are affected by exposure. To ensure 

these protections are made available, the grace period for full training would have to be 

reduced or abolished, and field workers trained in the full set of safety information prior 

to entering pesticide-treated fields. 

 

4. No change 

No change to the training interval or grace period would impose no additional burden on 

states. Agricultural field workers would continue to receive training after grace periods 

have expired and or at lengthy intervals. 

 

Stakeholders have held that quality training is necessary for agricultural farmworkers to 

appreciate the risks they face and learn tools to protect themselves. Without this critical 

safety information, they may continue to face pesticide risks without options to protect 

themselves. 
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IVC Trainer Competency 1 of 3 8/9/2006 

Title Ensure that Safety Trainers are Competent to Provide Needed Safety 

 Information to Workers 

Issue Statement

 

• Agricultural workers are exposed to potential health risks from pesticide residues when 

entering treated fields. Because residues can be difficult to identify on plant surfaces, 

workers may not realize they are contacting potential toxins while performing their work. 

A key element in worker protection is the worker's ability to help in their own protection. 

Agricultural workers must receive high quality training from competent trainers in order 

to adopt protective behaviors. 

Public Health / Risk Concerns

• Trainers influence behavior and are a primary source of information for agricultural field 

workers, but are not currently required to demonstrate competency as trainers. This lack 

of training skills increases risks to workers and others. 

• The current requirement for training may be satisfied by using an approved video. 

Concerns have been raised about the passive nature of this training. Studies have shown 

that comprehension of pictorials for safety-related information is significantly enhanced 

when accompanied by even brief training1

. If workers are not actively engaged during 

video training, they may miss critical protective information. A skilled, competent 

trainer ensures that workers are attentive and better understand the information. 

• Because field workers are less likely than pesticide handlers or applicators to recognize 

risks from pesticides, pesticide safety information must be presented by trainers who are 

knowledgeable and competent in educating this difficult to reach population. A recent 

pilot study using train-the-trainer materials shows that participants who learned training 

techniques applicable to this population were more successful in educating their target 

audience. Data from the farm worker training program implemented by the American 

Farmworker Opportunities Program, which provides significant training skills to its 

trainers, reinforces these findings. 

• Between 1998 and 1999, 313 farm workers in California doing routine field work were 

made ill from pesticides2

. Agricultural farm workers are extremely vulnerable to 

exposures to pesticides as they enter treated fields because they may not recognize the 

potential for harm. 

• Worker education goals must focus on relevant information, the development of problemsolving skills, and the confidence needed to use these tools. Training programs should 

help assure that workers become, and remain, active participants in protecting their health 

 

1

 Brelsford J, Sojourner J, Wolgalter S. Comprehension and retention of safety pictorials. Ergonomics Vol 40/No 

5/May 1, 1997. 

2

 Das R, Steege A, Baron S, Beckman J, Harrison R. Pesticide-related Illness among Migrant Farm Workers in the 

United States. Int J Occup Environ Health Vol 7/No 4,Oct/Dec 2001. 
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from occupational risks. In a program for training challenging populations such as these, 

issues such as literacy and the use of appropriate adult education techniques must be 

addressed. 

Background

• Part of the rationale for the trainer eligibility requirements in the agricultural worker 

protection regulation was to make adequate numbers of trainers available. Agricultural 

workers and handlers may be trained by a certified applicator, a trainer of certified 

pesticide applicators, one who has completed a pesticide safety train-the-trainer program 

recognized by the state agency, or one who has completed a pesticide safety training 

course. After training, handlers are eligible to train workers. While persons may have 

significant knowledge about pesticides and their application, their ability to impart key 

self-protective information in a competent manner is not currently verified.

Options Under Consideration

The Agency had considered requiring a demonstration of competency for trainers of 

agricultural handlers. However, proposed amendments include requiring that handlers – as 

occupational users of pesticides – demonstrate a level of competency appropriate to their 

level of use. Under the revised regulation at 40 CFR 171, agricultural handlers would be 

required to demonstrate their competency, similar to that currently required for applicators 

of restricted use products. Imposing this requirement will reduce the need for competency 

gauges for agricultural handler trainers, because handler competency will be verified by a 

competency gauge. 

1. Establish verification of competency for trainers of field worker by requiring 

certification under the pesticide applicator certification regulation at 40 CFR § 171. 

 Trainers influence behavior and are one of the primary sources of pesticide safety 

information for agricultural workers. To ensure this occupationally-exposed group is 

adequately protected, safety trainers must not only be knowledgeable about pesticides, 

they must also possess training competencies. Requiring trainers to demonstrate the 

appropriate knowledge and training skills would enhance the likelihood that agricultural 

workers receive and use information on how to protect themselves from potential 

exposures. 

 

Providing adequate training for field workers who work in areas that have been treated 

with pesticides is challenging – the pesticide-exposed workers have low literacy, may not 

speak or read English, and are more concerned with satisfying their basic needs than with 

the abstract concepts of pesticide risks. For these reasons, it is important that their 

training be highly relevant, practical, and motivating. Requiring trainers to demonstrate 

competency is particularly important, because agricultural workers are not tested on their 

knowledge of pesticide risks. 
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This population’s safety from pesticide risks relies on adequate training, which is 

relevant, understandable, and useful to them. Requiring that trainers possess appropriate 

competencies would encourage field workers to adopt practices to protect themselves 

from pesticide exposures, help them identify if exposures make them ill, and understand 

how to mitigate exposures. Requiring that a trainer accompany video training would help 

ensure that workers would be attentive, and would be more likely to absorb the 

information presented. 

2. Require under 40 CFR 170, that trainers successfully complete an approved train-thetrainer workshop to advance their skills in teaching to this difficult to reach population 

 

 Trainers influence behavior and are one of the primary sources of pesticide safety 

information for agricultural workers. To ensure this occupationally-exposed group is 

adequately protected, safety trainers must not only be knowledgeable about pesticides, 

they must also possess training competencies. Requiring trainers to demonstrate the 

appropriate knowledge and training skills would enhance the likelihood that agricultural 

workers receive and use information on how to protect themselves from potential 

exposures. 

 

Providing adequate training for field workers who work in areas that have been treated 

with pesticides is challenging – the pesticide-exposed workers have low literacy, may not 

speak or read English, and are more concerned with satisfying their basic needs than with 

the abstract concepts of pesticide risks. For these reasons, it is important that their 

training be highly relevant, practical, and motivating. Requiring trainers to attend 

relevant Train the Trainer workshops is important in assuring their skills are adequate to 

provide quality training, because agricultural workers are not tested on their knowledge of 

pesticide risks. 

A recent pilot study using train-the-trainer materials shows that participants who learned 

training techniques applicable to this population were more successful in educating their 

target audience. Data from the farm worker training program implemented by the 

American Farmworker Opportunities Program, which provides significant training skills 

to its trainers, reinforces these findings. 

 

This population’s safety from pesticide risks relies on adequate training, which is 

relevant, understandable, and useful to them. Requiring that trainers possess appropriate 

competencies would encourage field workers to adopt practices to protect themselves 

from pesticide exposures, help them identify if exposures make them ill, and understand 

how to mitigate exposures. Requiring that a trainer accompany video training would help 

ensure that workers would be attentive, and would be more likely to absorb the 

information presented. 

3. No Change 

Trainers would continue without additional verification of their adequacy, which puts 

agricultural workers at risk for their health and safety. 
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IVD WPS Recordkeeping Page 1 of 2 8/9/2006 

Title Protect Agricultural Workers’ Health by Ensuring Pesticide the Verification 

of Safety Training 

Issue Statement

• Agricultural workers who have not received pesticide safety training are at increased risk 

for pesticide poisoning from entering treated fields. The lack of a required national 

standard to verify pesticide safety training creates a burden for employers, workers, and 

regulators. 

Public Health/ Risk Concerns

• Untrained agricultural workers are not equipped with self-protective information when 

they enter a pesticide-treated area. A worker protection program that requires training 

records improves the ability of enforcement to verify that the required safety training has 

been provided. 

• Agricultural worker risk is managed through limiting entry into treated fields (Restricted 

Entry Intervals or REIs) and through providing required pesticide safety training to 

inform workers of the risks and how they may protect themselves. When pesticide use 

benefits outweigh risks, the Agency allows shorter REIs, increasing reliance on pesticide 

safety training. Without this safety training, there is a serious gap in their protection. 

• In 2005, States reported 614 enforcement actions taken involving pesticide safety 

training1

. Pesticide safety training violations were the second most frequently reported 

violation in 2005. 

• Florida reported 106 of these pesticide safety training violations; the state regulatory 

agency identified these violations as untrained workers or the use of incorrect training 

materials. Florida expressed misgivings about the current voluntary training verification 

card system and recommends recordkeeping. 

• EPA’s Office of Enforcement and Compliance Assistance reports similar concerns from 

state inspectors about the current voluntary training verification card system. The 

majority of state inspectors prefer required recordkeeping. 

• A recent study of farm worker parents in NC found that, based on interviews, up to 40% 

had not received pesticide safety training.2

 

Background 

• In 1994, EPA implemented a voluntary program intended to alleviate employers' training 

burden by establishing a system of training verification cards indicating that safety 

 

1

 WPS Inspection and Enforcement Accomplishment Report 2005 2

 North Carolina Employment Security Commission interviews with farm workers, 2004 
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training had been give to employees. The program requires that employers keep a roster 

of those trained. Many states use the program, but some states and growers chose not to 

adopt the program. There is an issue of inconsistent state and national recordkeeping. 

The establishment of a consistent employer recordkeeping system could replace the 

voluntary program. 

• Agricultural workers are currently required to receive pesticide safety training within 5 

days of entering pesticide-treated fields. This safety training provides agricultural 

workers with information on how they can best protect themselves and their families 

from pesticide exposure. Employers must ensure that their employees have been trained 

in the basic concepts of pesticide safety. 

• Several states have incorporated recordkeeping of trained workers into state law. 

Consistent recordkeeping of workers who receive pesticide safety training would assist 

inspectors in determining if a training violation occurred. 

Options Under Consideration

 

1. Require employers to keep records of workers who receive WPS training for at least 

two years. 

Recordkeeping of trained agricultural workers will facilitate inspections and provide 

evidence of employer compliance. Currently, inspectors may not have access to such 

records, making it necessary to interview workers. Agricultural workers may misunderstand 

the question or not connect it to the training they had, and report they have not been trained, 

when in fact they were trained. Inspectors frequently affirm that the lack of a recordkeeping 

provision prevents states from pursuing enforcement action in cases where workers’ training 

is in question. Having a record of who was trained will provide evidence that the employer is 

in compliance and has acted to help protect his workers. 

2. Require employers to keep and submit records to the state lead agency. 

Recordkeeping by employers could provide reliable numbers of workers trained each year. 

The state regulatory agency could use this information to help shape their programs and 

target outreach. Recordkeeping will facilitate inspections and provide evidence of employer 

compliance. Recordkeeping by the employer will enhance enforcement efforts and 

demonstrate and effort to help protect workers. 

3. No change 

Agricultural workers will continue to be at risk if pesticide safety training is not delivered. 

Enforcement of this as a violation will continue to be difficult. 
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IVE Children in Fields Page 1 of 4 8/9/2006 

Title Protect Agricultural Workers’ Children Who Enter Pesticide-Treated Areas 

Issue Statement

• Children are more susceptible to effects from pesticides than adults because their 

neurological, immunological, digestive and other bodily systems are rapidly developing. 

The presence of children in the fields presents the potential for exposure. There is 

currently no requirement to keep children of agricultural workers out of pesticide-treated 

areas. 

Public Health/ Risk Concerns

• Children eat, drink, and breathe more than adults in proportion to their body weight and 

can be proportionally exposed to more pesticide as a result.1 

• Pesticides can harm a child by blocking the absorption of important food nutrients 

necessary for normal healthy growth.2

 Toddlers are at a critical growth period for 

absorption, detoxification, and organ development; these are particularly vulnerable to 

environmental toxins.3 When a child's excretory system is still developing, the body does 

not have the capacity to completely eliminate pesticides.4 Teens in agricultural fields that 

are exposed to endocrine disrupters are more susceptible to damaging their reproductive 

systems during puberty.5 

• Exposure to a chemical may have no effect on an adult while having negative health 

consequences for a child at the same level of exposure. Therefore, “studies of adult 

pesticide exposure and associated adverse health effects cannot be extrapolated to 

children.”6

• In 1996 and 1997, the Department of Labor’s National Agricultural Worker Survey 

(NAWS) reported that 7% of agricultural workers with children 5 or younger took their 

children with them, at least sometimes, to the fields. 

• In 1989, The National Agricultural Workers Survey estimated 587,000 children, age 21 

or younger, of seasonal migrant workers in the United States. 

 

1

 Pesticides and Food: Why Children may be Particularly Sensitive to Pesticides found online at 

http://www.epa.gov/pesticides/food/pest.htm

2

 ibid 

3

 Pediatric Environmental Health, Agency for Toxic Substances and Disease Registry (ATSDR) Case Studies in 

Environmental Medicine, July 2002 

http://www.atsdr.cdc.gov/HEC/CSEM/pediatric/susceptible.html

4

 ibid 

5

 Pediatric Environmental Health, ATSDR Case Studies in Environmental Medicine, July 2002 

http://www.atsdr.cdc.gov/HEC/CSEM/pediatric/susceptible.html

6

 Cooper, et al, 2001 Ascertainment of Pesticide Exposures of Migrant and Seasonal Farmworker Children, 

Findings from Focus Groups. American Journal of Industrial Medicine, 40:531-537. 
Pesticide Worker Safety Program Enhancement 

Material for Pesticide Program Dialogue Committee Workgroup Discussion 

IVE Children in Fields Page 2 of 4 8/9/2006 

• A Bureau of Labor Statistics summary of 1993-1998 NAWS data showed that 

 “7 percent of all farmworkers were between the ages of 14 to 17, equivalent to 

 126,000 children who did farm work in that period.”

7

 

• A comparative study in Mexico observed two groups of children with similar 

characteristics, the one distinction being exposure to pesticides. One group lived in an 

agrarian environment with heavy pesticide usage; the other lived in ranch settings and 

avoided pesticide use. The study found that those children exposed to pesticides 

demonstrated comparatively diminished motor skills and had reduced short-term memory 

skills, among other issues.8

Background 

• The Fair Labor Standards Act of 1938 (FLSA) as amended, sets standards for child labor 

in agriculture. These standards differ from those for non-farm jobs. The Department of 

Labor establishes the age standard for youths in agriculture. In general, youths 12 and 

older may work on farms. Youths of any age may work at any time in any job on a farm 

owned or operated by their parents. 

• Children living in agricultural communities or whose family members work with or 

around pesticides may be at risk of being exposed to pesticides. The concerns raised 

through the National Assessment of the Pesticide Worker Safety Program highlighted the 

fact that children of migrant workers who accompany parents to their workplace do so in 

order to generate additional income or due to lack of viable daycare options. 

• The National Agricultural Worker’s Survey (NAWS) data suggests that some children of 

migrant and seasonal agricultural laborers accompany their parents into pesticide-treated 

fields. Restricted Entry Intervals (REIs) are designed to protect adults and children at 

least 12 years old, but may not provide adequate protection for children younger than 12.9

• Children, especially very young children, cannot be expected to understand pesticide 

risks or how to avoid exposure. Children accompanying their parents to treated fields can 

contact pesticide-treated surfaces. Young children’s hand-to-mouth activity may increase 

their risk of oral exposure to pesticide residues.10 Children may also play in dirt 

containing pesticide residues, and contaminate their clothing as well. 

• EPA has taken steps to protect children’s health from environmental contaminants in 

homes, schools, and playgrounds. Additionally, EPA has developed outreach materials 

designed to protect children of farmworkers from parental take-home exposure. 

 

7

 Samardick et al. (2000). Youth employment in agriculture. In U.S. Bureau of Labor Statistics, Report on the youth 

labor force: Revised (pp. 52-57). Washington, DC: U.S. Department of Labor. 

8

 Guillette et al. (1998) An Anthropological Approach to the Evaluation of Preschool Children Exposed to Pesticides 

in Mexico. Environmental Health Perspectives Volume 106, Number 6, June 1998 9

 GAO (2000). Pesticides – Improvements Needed to Ensure the Safety of Farmworkers and their Children. 10 Pesticides and Food: Why Children may be Particularly Sensitive to Pesticides found online at 

http://www.epa.gov/pesticides/food/pest.htm
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• The GAO11 and EPA’s Office of Children’s Health Protection Federal Advisory 

Committee12 highlighted pesticide risks to the children of agricultural workers, and have 

advocated further protections for this vulnerable subpopulation. 

Options under Consideration

1. Amend the regulations at 40 CFR 170 to require employers to restrict field access, 

prohibiting farmworker children under age 12 from being in the field.

Employers would be responsible to ensure that persons in their fields were employed. It 

is likely that employers would pass the burden of restricting farmworker children from 

the fields to the farmworker parent. 

This would restrict access to treated fields by farmworker children less than 12 years old. 

Although this places burden on both the farmer employer and the farmworker, it is the 

most enforceable option. 

2. Enhance training requirements to include the effects of pesticides on children and 

additional information protecting farm worker families. 

The National Assessment General Training Workgroup recommended bolstering the 

farmworker training with more information about the effects of pesticides on children and 

ways to better protect children and families. Placing more emphasis on the dangers of 

pesticide exposure to children would increase awareness among workers. 

3. No change 

No change would allow children to continue accompanying their parents into areas 

covered by the WPS where the potential for exposure to pesticide residues exists. 

 

11 GAO (2000). Pesticides – Improvements Needed to Ensure the Safety of Farmworkers and their Children. 12 Children’s Health Protection Advisory Committee (11/15/2005). Recommendations Regarding Protecting 

Farmworker Children from Exposure to Pesticides. Letter to Stephen Johnson, Administrator, EPA. 
Pesticide Worker Safety Program Enhancement 

Material for Pesticide Program Dialogue Committee Workgroup Discussion 

IVE Children in Fields Page 4 of 4 8/9/2006 

References

1. Lessons Learned for the Assessment of Children’s Pesticide Exposure: Critical Sampling and 

Analytical Issues for Future Studies, Environmental Health Perspectives, vol. 113, no. 10, 

October 2005 

2. Agricultural Health Study 

3. Pesticides and Food: Why Children may be Particularly Sensitive to Pesticides found online at 

http://www.epa.gov/pesticides/food/pest.htm

4. Pediatric Environmental Health, ATSDR Case Studies in Environmental Medicine, July 2002 

5. Children’s Environmental Health 2005 EPA Office of Children’s Health Protection, October 

2005 

6. GAO Report on Pesticides Improvements Needed to Ensure the Safety of Farmworkers and 

Their Children, March 2000 

7. National Commission on Migrant Education. Invisible children: a portrait of migrant 

education in the United States. A final report of the National Commission on Migrant Education. 

Washington (DC): US Government Printing Office 1992. 

8. Samardick et al. (2000). Youth employment in agriculture. In U.S. Bureau of Labor Statistics, 

Report on the youth labor force: Revised (pp. 52-57). Washington, DC: U.S. Department of 

Labor. 

9. Guillette et al. An Anthropological Approach to the Evaluation of Preschool Children Exposed 

to Pesticides in Mexico. Environmental Health Perspectives Volume 106, Number 6, June 1998
Pesticide Worker Safety Program Enhancement 

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IVF Expand WPS Training 1 of 4 8/9/2006 

Title Enhance Safety Training to Better Protect Agricultural Workers and Their 

Families 

Issue Statement

• Safety training and safety information helps farm workers and their families protect 

themselves from the adverse effects of pesticides. Gaps in current safety training must be 

filled to address take home exposure, hazard communication, incident reporting, family 

protection, and workers’ rights. 

Public Health / Risk Concern

• Agricultural workers are at a higher risk of exposure than the general population due to 

their occupational exposure to pesticides. Farm workers need to understand the inherent 

risks associated with exposure and the potential to transfer residues to their homes and 

families. For workers to be able to protect themselves and their families from risk of 

exposure, pesticide safety training must address these issues. 

• Children are more susceptible to the effects of pesticide exposure than adults, and 

agricultural workers should receive more information on preventing exposure to their 

families. Providing them with knowledge on how to protect themselves and their 

families from pesticide exposure are needed training enhancements. 

• Studies have shown that agricultural workers’ housing has higher concentrations of 

pesticide residues in dust than others in the same community.1

 Other studies have 

demonstrated that children of agricultural workers have higher levels of metabolites than 

other children in the same community, indicating exposure to organophosphates, the 

active ingredient in many commonly used insecticides.2 These data demonstrate that 

take-home exposure is a key route by which agricultural worker families may be exposed 

to pesticides. 

• Workers do not currently receive information on the hazards of working in pesticide 

treated areas comparable to the information required by the Occupational Safety and 

Heath Administration (OSHA) for other occupations. Pilot studies have been conducted 

on how to provide such critical self-protective information. The results presented to the 

Agency will offer suggestions on the best methods to communicate risks to workers. 

• A study of agricultural handlers and workers shows that, 79.4% of handlers wash their 

hands right after work compared to 48.8% of workers. Only 51.2% and 45.4% of 

handlers and workers respectively shower or bathe within 1 hour of returning home. The 

study shows that a common route of pesticide exposure to farm worker children is 

through residues brought into the home on the clothing and skin of farm workers. This 

study shows that farm workers are not aware about the dangers of carrying home 

 

1

 Simcox et al 

2

 Loewenherz et al 
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pesticide residues from their work in the fields. The training currently required for 

handlers includes significantly more information on the hazards of pesticides and 

preventing take-home exposure, which could account for the difference in hygienic 

practices.3

• Although the content of the training provides valuable information to workers on the 

potential hazards of pesticides, program assessments and stakeholder recommendations 

have highlighted gaps in the current requirements. The current training's 11 points 

present valuable information to workers, but in a very general fashion. Training content 

must be specific enough to ensure that workers can be active participants in their own 

protection. 

• Underreporting of pesticide illnesses is a major issue, especially for agricultural workers. 

Modifying the existing training requirements to include information on preventing 

exposures and on what to do in the case of an exposure would provide agricultural 

workers with tools that would enable them to participate in their own protection, without 

significantly increasing the burden on employers or state lead agencies. More wellinformed workers reporting suspected illnesses would allow the Agency to better tailor 

the program to address specific deficiencies in worker protection. 

• Gaps and unclear requirements have been highlighted by both internal and external 

program reviews. The General Training Issues Workgroup, formed as part of the 

National Assessment of the Pesticide Worker Safety Program, presented a series of 

recommendations related to pesticide safety training to the Agency in March 2003. The 

Government Accountability Office and Children’s Health Protection Advisory 

Committee also have recommended bolstering the safety training content. 

Background

• The Worker Protection Standard (WPS; 40 CFR 170) requires that an agricultural 

employer assure that a worker has been trained on a minimum of the 11 safety points 

before the 6th day that the worker enters a pesticide-treated field (i.e., a field in which a 

pesticide has been applied or a restricted entry interval has been in effect within the last 

30 days). Before entering any treated field, employers must ensure that workers have 

received the basic pesticide safety information. 

• The 11 points currently required in WPS training for agricultural workers are: 1) where 

and in what form pesticides may be encountered during work activities, 2) hazards of 

pesticides resulting from toxicity and exposure, including acute and chronic effects, 

delayed effects and sensitization, 3) routes through which pesticides can enter the body, 

4) signs and symptoms of pesticide poisoning, 5) emergency first aid for pesticide 

poisonings, 6) how to obtain emergency medical care, 7) routine and emergency 

decontamination procedures, including emergency eye flushing techniques, 8) hazards 

from chemigation and drift, 9) hazards from pesticide residues on clothing, 10) warnings 

 

3

 Thompson et al 
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IVF Expand WPS Training 3 of 4 8/9/2006 

about taking pesticides or pesticide containers home, and 11) requirements of the WPS 

designed to reduce the risks of illness or injury resulting from workers’ occupational 

exposure to pesticides. 

• The National Assessment of the Pesticide Worker Safety Program brought together a 

wide variety of program stakeholders who participated in assessment workshop meetings 

and workgroups. Members were recognized as national experts in the area of pesticide 

safety education. 

• The Assessment's General Training Issues Workgroup was comprised of a diverse, 

balanced group of stakeholders with experience related to pesticide safety education. The 

group was charged with reviewing the training requirements in the WPS and existing 

EPA-approved training materials and providing recommendations for improvement. This 

workgroup reached consensus on a set of recommendations related to pesticide safety 

training content and delivery. The full report is posted on the Agency website at 

http://www.epa.gov/oppfead1/safety/newnote/wksp4-training.pdf. 

Options Under Consideration

1. Enhance the existing pesticide safety training for agricultural workers by including all 

of the recommendations made by the assessment workgroup, focusing on areas such as: 

General Training

• How to prevent pesticide exposure while working, including the following subpoints: 

1) Following directions and/or signs about keeping out of treated or restricted 

areas. 

2) Washing before eating, drinking, using chewing gum or tobacco, or using the 

toilet. 

3) Wearing work clothing that protects the body from pesticide residues. (Add 

reference to appropriate work clothing – wear clothes that cover the skin.) 

4) Washing/showering with soap and water, shampooing hair, and putting on 

clean clothes after work. 

5) Washing immediately in the nearest clean water if pesticides are spilled or 

sprayed on the body. As soon as possible, shower, shampoo and change into 

clean clothes. 

• Subdivide the 11th point into the following requirements: 

1) Entry restrictions (REI) and different types of applications. 

2) Posting of warning signs, oral warnings and the design of the warning sign. 

3) The availability of specific information about applications and where it is 

located within the workplace. 

4) Protection against retaliatory acts. 

5) How to initiate a complaint. 

• Prevention, recognition, and first aid treatment of heat-related illness, based on 

the content in the current training for agricultural handlers 
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Protecting Families

• Populations who may be more sensitive to pesticide exposure – children and 

pregnant women 

• Properly washing clothes that might contain pesticide residues 

• Preventing take-home exposure to pesticide residues 

• Keeping children out of the field to work or play 

Reporting Suspected Pesticide Illnesses

• Contact Information: 

1) State-specific toll-free telephone number for tips, complaints and questions 

about the WPS. 

2) The National Poison Control number, to allow workers to access more 

information related to the pesticide exposure, to report suspected illnesses and 

to get information on treatment. 

• Recognizing and seeking care for pesticide poisoning 

2. Enhance the existing pesticide safety training for agricultural workers by including 

points on hazard communication and on protecting families. 

At a minimum, points related to hazard communication and protecting families must be 

added to pesticide safety training. Improvements to these two areas would have the most 

impact on the health and safety of agricultural workers and their families. 

3. No change 

The current pesticide worker safety training is inadequate given the evolving knowledge 

of risks that agricultural workers face. Not amending the content of pesticide worker 

safety training would not provide workers with information necessary for their own 

protection. 

Citations

EPA 2006-2011 Strategic Plan: Charting Our Course (Draft Document for Public Comment). 

http://www.epa.gov/cfo/plan/06strat_plan.pdf Section 4, pp. 4-5. Accessed on 25 July 2006. 

Loewenherz C, Fenske RA, Simcox NJ, Bellamy G, Kalman D. “Biological Monitoring of 

Organophosphorus Pesticide Exposure Among Children of Agricultural Workers in Central 

Washington State.” Environmental Health Perspectives. 1997. 105:1344-53. 

Simcox NJ, Fenske RA, Wolz SA, Lee IC, Kalman DA. “Pesticides in Household Dust and Soil: 

Exposure Pathways for Children of Agricultural Families.” Environmental Health Perspectives. 

1995. 103:1126-34. 

Thompson, B., Coronado, G., Grossman, J., Puschel, K., Solomon, C. C., Islas, I., Curl, C. L., 

Shirai, J. H., Kissel, J. C., and Fenske, R. (2003). “Pesticides take-home pathway among children 

of agricultural workers: Study design, methods, and baseline findings.” Journal of Occupational 

and Environmental Medicine. 45, 42-53.