### 1 

# ECONOMIC ANALYSIS OF

FINAL REVISIONS TO THE WOR KER PROTECTION STAND ARD

APPENDIX B

Cost Estimation, Final Regulations



# Table of Contents

B.1. Pesticide Safety Training

................................ ................................ ................................ ..... 2

a. Baseline

................................ ................................ ................................ ................................ 2

b. Final Rule

................................ ................................ ................................ ........................... 11

B.2. Hazard Communication

................................ ................................ ................................ .... 15

a. Baseline

................................ ................................ ................................ .............................. 15

b. Final Rule

................................ ................................ ................................ ........................... 19

B.3. Notification

................................ ................................ ................................ .......................... 20

a. Baseline

................................ ................................ ................................ .............................. 20

b. Final Rule

................................ ................................ ................................ ........................... 28

B.4. Age

................................ ................................ ................................ ................................ ..... 35

a. Baseline

................................ ................................ ................................ .............................. 35

b. Final Rule

................................ ................................ ................................ ........................... 36

B.5. Entry

................................ ................................ ................................ ................................ .. 37

B.6. Personal Protective Equipment (PPE)

................................ ................................ ........... 37

a. Baseline

................................ ................................ ................................ .............................. 37

b. Final Rule

................................ ................................ ................................ ........................... 44

B.7. Decontamination Supplies

................................ ................................ ............................... 47

a. Baseline

................................ ................................ ................................ .............................. 47

b. Final Rule

................................ ................................ ................................ ........................... 48

### 2 

## B

. 1. Pesticide Safety Training

a. Baseline

Worker

Table B .1.a

- 1. Baseline Cost, per worker, Worker Safety Training

Action/Material wage/price unit

time/quantity annual

probability cost

Full training session 14.64 0.5 0.490 3.59

Abbreviated training session 14.64 0.05 0.052 0.04

Trainer, abbreviated session 33.44 0.05 0.052 0.09

Expected per

- worker Cost ( cost r,i, workr B ) 3.71



### • Worker wages, including for benefits, are $14.64/hr ( BLS, 2014b )

.

• Worker safety training takes approximately 30 minutes, based on length of training videos and

EPA experience

.

• Workers trained each year account for 49.0% of the total workforce (16% + 33.6%)*(1

– 1.2%)

.

o Includes 16% of total workforce who are new hires (DoL, 2005)

o Includes 33.6% of total workforce representing returning workers who are r etrained;

based on 40% retraining rate (20% whose training has expired after 5 years and 20%

whose training cannot be verified) out of remaining 84% of total workforce

o Excludes workers employed less than five days, which EPA calculates to be 1. 2 % of total

workforce, assuming 5% of part

- time employees are employed less than five days; part

time employees are estimated to be 2 4 % of total workforce (NASS, 2014b )

• EPA assumes an abbreviated training takes 3 minutes.

• Workers taking an abbreviated training account for 5. 2 % of total workforce (1.2% + 4.0%)

.

o Includes 1.2% of workers employed less than five days ( as above)

o Includes 4.0% of total workforce who are new hires receiving abbreviated training prior

to full training ; assuming 25% of new hires employed (1 6% o f total workforce, as above)

• Abbreviated training is given individually to each worker by the owner/operator whose time is

valued at $ 33.44 /hr, including benefits (BLS, 2014b )

.



### Table B .1.a

- 2. Baseline Costs, per worker, Training Verification Program

Action/Material wage/price unit

time/quantity annual

probability cost

WPS worker

Verification card 0.06 1 0.490 0.03

Distribute card (handler trainer) 47.18 0.033 0.069 0.11

Distribute card (tr ai n

- the

- tr ai n e r) 47.18 0.033 0.049 0.08

Distribute card (cert ified app licator ) 33.44 0.033 0.368 0.41

Distribute Certificates (handler) 20.04 0.033 0.005 0.00

Expected per

- worker Cost ( cost r,i, a B ) 0.6 3



### • EPA produces and distributes training cards to states at cost; in 2010, EPA spent $23,900 for

400,000 cards or about $0.06 per card.

• EPA calculates that 49.0% of workers receive training each year and could be provided a

verification card (as above)

.

### 3 • Trainers must fill out and distribute the cards. Four categories of trainers eligible to conduct

worker safety training with differing wage (BLS, 2014b):

o trainers of handlers and certified applicators ($47.18/hr);

o individuals who have completed a train the trainer program ($47.18/hr);

o certified applica tors, typically the employer, ($33.44/hr); and

o handlers ($20.04/hr).

• Tests by EPA staff indicate it takes about 2 minutes per card to enter the name, date of training,

and other pertinent information.

• The probability a trainer from a given category provide s a trainee the verification card is the

probability that a worker receives training (0.490) times the probability that the training is led by

a trainer in that category.

o trainers of handlers and certified applicators (14% of sessions), or 6.9% of workers;

o individuals who have completed a train the trainer program (10% of sessions), or 4.9% of

workers;

o certified applicators (75% of sessions), or 36.8% of workers; and

o handlers (1% of sessions), or 0.5% of workers



### Handler

Table B .1.a

- 3. Baseline Cost, pe r WPS handler, Handler Safety Training

Action/Material wage/price unit

time/quantity annual

probability cost

( cost r,i, a B )

WPS farm handler 20.04 0.75 0.328 4.93

CPHE handler 23.26 0.75 0.328 5.72



### • WPS and CHPE handler wages, including benefits, are $20.04/hr and $23.26/hr, respectively

(BLS, 2014b)

.

• EPA assumes training typically last 45 minutes.

• EPA calculates that 32.8% of handlers will be trained each year, based on the following.

o Includes 16% of handlers, those who are new hires

– based on a 16% new hire rate for all

farm employees(DOL, 2005)

o Includes 16.8% of handlers, who are returning handlers whose training has expired after

5 years (20% of remaining 84% of handlers).



### Table B .1.a

- 4. Baselin e Costs, per handler, Training Verification Program

Action/Material wage/price unit

time/quantity annual

probability cost

WPS farm handler

Verification card 0.06 1 0.328 0.03

Distribute card (handler trainer) 47.18 0.033 0.046 0.07

Distribute card (train

- the

- trainer) 47.18 0.033 0.033 0.05

Distribute card (certified applicator) 33.44 0.033 0.249 0.28

Expected per

- handl er Cost ( cost r,i, a B ) 0.42

### 4 Action/Material wage/price unit

time/quantity annual

probability cost

CPHE handler

Verification card 0.06 1 0.328 0.03

Distribute card (handler trainer) 47.18 0.033 0.046 0.07

Distribute card (train

- the

- trainer) 47.18 0.033 0.033 0.05

Distribute card (certified applicator) 32.65 0.033 0.249 0.27

Expected per

- handler Cost ( cost r,i, a B ) 0.41



### • Verification cards cost about $0.06 per card. See above.

• EPA calculates that 32.8% of handlers receive training each year and could be provided a

verification card (as above).

• Trainers must fill out and distribute the cards. Three categories of trainers eligible to conduct

worker safety training with differing wage (BLS, 2014b):

o trainers of handlers and certified applicators ($47.18/hr);

o individuals who have completed a train the trainer program ($47.18/hr); and

o certified applicators, typically the employer, ($32.65/hr).

• Tests by EPA staff indicate it takes about 2 minutes per card to enter the name, date of training,

and other pertinent information.

• The probability a trainer from a given category provides a trainee the verification card is the

probability that a handler receives training (0.328) times the probabil ity that the training is led by

a trainer in that category.

o trainers of handlers and certified applicators (14% of sessions), or 4.6% of handlers;

o individuals who have completed a train the trainer program (10% of sessions), or 3.3% of

handlers;

o certified applicators (76% of sessions), or 24.9% of handlers.



### Establishment

Table B .1.a

- 5. Baseline Cost, per WPS farm, by size, Worker Training

Action/Material wage/price unit

time/quantity annual

frequency cost

Large WPS farm

Training by Handler Trainer 47.18 0.5 0.272 6.42

Training by Train

- the

- Trainer 47.18 0.5 0.195 4.59

Training by Certified Applicator 33.44 0.5 1.459 24.39

Training by WPS Handler 20.04 0.5 0.019 0.19

Expected per

- farm Cost ( cost r,i, a B ) 35.60

Small WPS farm

Training by Handler Trainer 47.18 0.5 0.113 2.66

Training by Train

- the

- Trainer 47.18 0.5 0.081 1.90

Training by Certified Applicator 33.44 0.5 0.604 10.10

Training by WPS Handler 20.04 0.5 0.008 0.08

Expected per

- f a rm Cost ( cost r,i, a B ) 14.75



### • Four categories of trainers eligible to conduct worker safety training with differing wage (BLS,

2014b):

### 5 o trainers of handlers and certified applicators ($47.18/hr);

o individuals who have completed a train the trainer program ($47.18/hr);

o certified applica tors, typically the employer, ($33.44/hr); and

o handlers ($20.04/hr).

• Worker safety training takes approximately 30 minutes, based on length of training videos and

EPA experience.

• The probability a trainer from a given category conducting a training session

o Trainer probabilities, based on conversations with state officials:

 trainers of handlers and certified applicators (14% of sessions);

 individuals who have completed a train the trainer program (10% of sessions);

 certified applicators (75% of sessions); and

 handlers (1% of sessions)

o Vector of probabilities [ 0.14 0.10 0.75 0.01 ]

• EPA assumes that the average number of training sessions conducted for each WPS farm is a

function of farms size, especially the number of workers per farm. Given estimates of the number

of farm workers and farms hiring labor (Appendix A):

o Large WPS farms (more than $750,000 in revenue/year) average 1.95 training sessions

per year. This is a weighted average of two groups of farms.

 Large farms with more than 10 employees hol d an average of 4.5 training

sessions per year. These farms include fruit, nut, and vegetable farms, nurseries,

and greenhouses and average about 50.7 workers/farm. Many workers will be

temporary, hired for peak activities like thinning and harvesting an d sessions will

be conducted throughout the year. EPA estimates that there are 16,454 such

farms out of 56,678 large WPS farms hiring workers.

 Large WPS farms with fewer than 10 employees hold an average of 0.9 training

sessions per year. These farms pri marily cultivate field crops such as grains,

oilseed, and cotton with more permanent workers and average of 4.5

workers/farm. EPA estimates that there are 40,224 such farms.

o Small WPS farms (less than $750,000 in revenue/year) average 0.81 training sessio ns per

year. This is a weighted average of four groups of farms.

 Large

- small farms (revenue/year between $100,000 and $750,000) with more

than 10 employees are assumed to hold an average of 2.2 training sessions per

year. T hese farms include f ruit, nut, and vegetable farms, nurseries, and

greenhouses with an average of 1 2.6 workers/farm, many of whom are temporary

workers; sessions will be conducted throughout the year. EPA estimates that

there are 17,598 such farms out of 255,892 small farms hiring work ers.

 Large

- s mall farms with fewer than 10 employees are assumed to hold an average

of 0.7 3 training sessions per year

. These farms primarily cultivate field crops

such as grains, oilseed, and cotton and employ 2.7 workers/farm, on average.

EPA estimates that there are 84,687 such farms.

 Medium

- small farms ( revenue/year between $10,000 and $100,000 ) regardless of

primary production are assumed to hold an average of 0.73 training sessions per

year. These farms average 3.3 workers per farm.

 Small

- small farm s (revenue/year less than $10,000) are assumed to hold an

average of 0.65 training sessions per year. These farms average 2.5

workers/farm.

o Vector of number of sessions = [ 1.95 0.81 ]

• Matrix of annual frequency of sessions lead by various trainers

┌ ┐ ┌ ┐ │0.14│ ┌ ┐ │0.272 0.113│

### 6 │0.1 0 │∙ │1.95 0.81│ = │0.195 0.081│ │ 0.75 │ └ ┘ │1.459 0.604│ │ 0.01 │ │0.019 0.008│

└ ┘ └ ┘



### Table B .1.a

- 6. Baseline Cost, per WPS farm or CPHE, Handler Training

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Training by Handler Trainer 47.18 0.75 0.073 2.60

Training by Train

- the

- Trainer 47.18 0.75 0.052 1.86

Training by Certified Applicator 33.44 0.75 0.399 10.00

Expected per

- farm Cost ( cost r,i, a B ) 14.46

Large

- Small WPS farm

Training by Handler Trainer 47.18 0.75 0.034 1.22

Training by Train

- the

- Trainer 47.18 0.75 0.025 0.87

Training by Certified Applicator 33.44 0.75 0.187 4.69

Expected per

- farm Cost ( cost r,i, a B ) 6.78

CPHE

Training by Handler Trainer 47.18 0.75 0.140 4.95

Training by Train

- the

- Trainer 47.18 0.75 0.100 3.54

Training by Certified Applicator 32.65 0.75 0.760 18.61

Expected per

- f i rm Cost ( cost r,i, a B ) 27.11



### • Three groups are eligible to conduct worker safety training at differing wage rates, including 30%

additional cost for benefits (BLS, 2014b):

o trainers of handlers and certified applicators ($47.18/hr);

o individuals who have completed a train the trainer program ($47.18/hr); and

o certified applicators, typically the employer, ($33.44/hr for WPS farms, $32.65 for

CPHE).

• EPA assumes training typically last 45 minutes, based on length of training videos and EPA

experience.

• The pro bability a trainer from a given category conducting a training session

o Trainer probabilities, based on conversations with state officials:

 trainers of handlers and certified applicators (14% of sessions);

 individuals who have completed a train the trainer program (10% of sessions);

and

 certified applicators (7 6 % of sessions)

o Vector of probabilities [ 0.14 0.10 0.75 ]

• EPA assumes establishments conduct varying number of handler trainings per year, on average.

o Large WPS farms

, employing two handlers on ave rage, average 0.525 handler

trainings/year (0.656 ∙ 0.8)

 65.6% chance of employing a handler who needs trained, given that 32.8% of

handlers will be trained each year (see above )

 EPA assumes that there are 4 trainings for every 5 farms that need a handler

trained, as some farms are able to share resources.

o L arge

- small WPS farms , employing one handler on average, average 0. 246 handler

trainings/year (0.328 ∙ 0.75)

### 7  32.8% chance of employing a handler who needs trained (see above)

 EPA assumes that there are 3 trainings for every 4 farms that need a handler

trained, as some farms are able to share resources and large

- small WPS farms are

more common than large WPS farms.

o CHPEs, employing 7.4 handlers on average, likely have 2 to 3 handlers to train each year.

Thus, CHPEs are likely to conduct one handler training every year.

o Vector of number of sections [ 0.525 0.328 1.0 ]

• Matrix of annual frequency of sessions lead by various trainers

┌ ┐ ┌ ┐ │0.14│ ┌ ┐ │0.073 0.034 0.140│ │0.10│∙ │0.525 0.328 1.0│ = │0.052 0.025 0.100│ │0.76│ └ ┘ │0.399 0.187 0.760│

└ ┘ └ ┘



### California

Table B .1.a

- 7. California Baseline Cost, per worker, Worker Safety Training

Action/Material wage/price unit

time/quantity annual

probability cost

Full training session 14.64 0.75 0.490 5.38

Abbreviated training session 14.64 0.05 0.052 0.04

Trainer, abbreviated session 33.44 0.05 0.052 0.09

Expected per

- worker Cost ( cost r,i, workr B ) 5.51



### • Worker safety training takes approximately 45 minutes, given expanded content.

• Cost per worker for verification cards is the same as for the national baseline (Table B .1.a

- 2.



### Table B .1.a

- 8. California Baseline Costs, per handler, Handler Safety Training

Action/Material wage/price unit

time/quantity annual

probability cost

WPS farm handler

Full training 20.04 1 1.000 20.04

Acknowledge training 20.04 0.008 1.000 0.17

Collect acknowledgement (handler

trainer) 47.18 0.013 0.140 0.08

Collect acknowledgement (train

the

- trainer) 47.18 0.013 0.100 0.06

Collect acknowledgement (certified

applicator) 33.44 0.013 0.760 0.32

Expected per

- handler Cost ( cost r,i, a B ) 20.67

### 8 Action/Material wage/price unit

time/quantity annual

probability cost

CPHE handler

Full training 23.26 1 1.000 23.26

Acknowledge training 23.26 0.008 1.000 0.19

Collect acknowledgement (handler

trainer) 47.18 0.013 0.140 0.08

Collect acknowledgement (train

the

- trainer) 47.18 0.013 0.100 0.06

Collect acknowledgement (certified

applicator) 32.65 0.013 0.760 0.31

Expected per

- handler Cost ( cost r,i, a B ) 23.91



### • Handler safety training typically last 60 minutes, given expanded content.

• Handler safety training must be taken annually.

• California requires employer to keep a record of training

o Handlers must sign a training record, taking approximately 30 seconds

o Trainer must collect the acknowledgements to provide the employer, taking 2 minutes per

handler



### Table B .1.a

- 9. California Baseline Costs, per handler, Training Verification Program

Action/Material wage/price unit

time/quantity annual

probability cost

WPS farm handler

Verification card 0.06 1 1.000 0.06

Distribute card (handler trainer) 47.18 0.033 0.140 0.22

Distribute card (train

- the

- trainer) 47.18 0.033 0.100 0.16

Distribute card (certified applicator) 33.44 0.033 0.760 0.85

Expected per

- handler Cost ( cost r,i, a B ) 1.28

CPHE handler

Verification card 0.06 1 1.000 0.06

Distribute card (handler trainer) 47.18 0.033 0.140 0.22

Distribute card (train

- the

- trainer) 47.18 0.033 0.100 0.16

Distribute card (certified applicator) 32.65 0.033 0.760 0.83

Expected per

- handler Cost ( cost r,i, a B ) 1.26



### • Verification cards issued annually.



### Table B .1.a

- 10. California Baseline Cost, per WPS farm, by size, Worker Training

Action/Material wage/price unit

time/quantity annual

frequency cost

Large WPS farm

Training by Handler Trainer 47.18 0. 7 5 0.272 9.64

Training by Train

- the

- Trainer 47.18 0.75 0.195 6.88

Training by Certified Applicator 33.44 0.75 1.459 36.59

Training by WPS Handler 20.04 0.75 0.019 0.29

Expected per

- farm Cost ( cost r,i, a B ) 53.40

### 9 Action/Material wage/price unit

time/quantity annual

frequency cost

Small WPS farm

Training by Handler Trainer 47.18 0.75 0.113 3.99

Training by Train

- the

- Trainer 47.18 0.75 0.081 2.85

Training by Certified Applicator 33.44 0.75 0.604 15.16

Training by WPS Handler 20.04 0.75 0.008 0.12

Expected per

- f a rm Cost ( cost r,i, a B ) 22.12



### • Worker safety training takes approximately 45 minutes, given expanded content.



### Table B .1.a

- 11. California Baseline Cost, per WPS farm or CPHE, Handler Training

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Training by Handler Trainer 47.18 1.0 0.112 5.28

Training by Train

- the

- Trainer 47.18 1.0 0.080 3.77

Training by Certified Applicator 33.44 1.0 0.608 20.33

Training acknowledgement 0.02 1 1.16 0.02

Collect/store acknowledgement 33.44 0.067 1.16 2.59

Folder 0.20 1 1 0.20

Expected per

- farm Cost ( cost r,i, a B ) 32.20

Large

- Small WPS farm

Training by Handler Trainer 47.18 1.0 0.070 3.30

Training by Train

- the

- Trainer 47.18 1.0 0.050 2.36

Training by Certified Applicator 33.44 1.0 0.380 12.71

Training acknowledgement 0.02 1 1.16 0.02

Collect/store acknowledgement 33.44 0.067 1.16 2.59

Folder 0.20 1 1 0.20

Expected per

- farm Cost ( cost r,i, a B ) 21.18

CPHE

Training by Handler Trainer 47.18 1.0 0.182 8.59

Training by Train

- the

- Trainer 47.18 1.0 0.130 6.13

Training by Certified Applicator 32.65 1.0 0.988 32.26

Training acknowledgement 0.02 1 1.3 0.03

Collect/store acknowledgement 33.44 0.067 1.3 2.83

Folder 0.20 1 1 0.20

Expected per

- f i rm Cost ( cost r,i, a B ) 50.04



### • Handler safety training typically last 60 minutes, given expanded content.

• Handler safety training must be taken annually.

o Large farms will average 0.8 training sessions/year (4 trainings for every 5 farms, as

some farms are able to share resources)

o Large

- small farms will average 0.5 training sessions/year (1 training for every 2 farms, as

some farms are able to share resources)

o CPH Es will average 1.3 training sessions/year to account for turnover and different

scheduling.

• California requires employer to keep a record of training

### 10 o Signed training roster takes about a page at $0.02/page (Staples, 2014); average number

1.16 per farm to account for new hires, 1.3 times for CPHEs with every session.

o Collection and storage is assumed to take approximately 4 minutes.

o Storage requires a folder for training records at $0.20 (Staples, 2014).



### Subtropics, Northeast, and Northwest regions

Table B .1.a

- 12. Subtropic, Northeast, and Northwest Baseline Costs, Training Verification

Program

Action/Material wage/price unit

time/quantity annual

probability cost

WPS worker

Verification card 0.06 1 0.245 0.01

Distribute card (handler trainer) 47.18 0.033 0.034 0.05

Distribute card (train

- the

- trainer) 47.18 0.033 0.025 0.04

Distribute card (certified applicator) 33.44 0.033 0.184 0.20

Distribute Certificates (handler) 20.04 0.033 0.002 0.00

Expected per

- handler Cost ( cost r,i, a B ) 0.31

WPS farm handler

Verification card 0.06 1 0.164 0.01

Distribute card (handler trainer) 47.18 0.033 0.023 0.04

Distribute card (train

- the

- trainer) 47.18 0.033 0.016 0.03

Distribute card (certified applicator) 33.44 0.033 0.125 0.14

Expected per

- handler Cost ( cost r,i, a B ) 0.21

CPHE handler

Verification card 0.06 1 0.164 0.01

Distribute card (handler trainer) 47.18 0.033 0.023 0.04

Distribute card (train

- the

- trainer) 47.18 0.033 0.016 0.03

Distribute card (certified applicator) 32.65 0.033 0.125 0.14

Expected per

- handler Cost ( cost r,i, a B ) 0.21



### • Only about half the states in these regions participate in the program; probability of

worker obtaining a card is reduced by half.

Midwest, Ohio Valley, and Texas/Mountain West regions

• Almost none of the states in these regions participate in the training verification program;

baseline costs per worker are essentially zero.

### 11 Summary, Pesticide Safety Training

Table B .1.a

- 1 3. Pesticide Safety Training Cost, by Employee

Action Worker Fa rm Handler CPHE Handler

South, Southwest Regions

Pesticide Safety Training $ 3.71 $ 4.93 $ 5.72

Verification Card $ 0.63 $ 0.41 $ 0.41

Expected Cost ( **cost TRAIN,i,a**  **B** ) $ 4.34 $ 5.35 $ 6.14

California

Pesticide Safety Training $ 5.51 $20.02 $23.26

Record Keeping $ 0.00 $ 0.63 $ 0.65

Verification Card $ 0.63 $ 1.28 $ 1.23

Expected Cost ( **cost TRAIN,i,a**  **B** ) $ 6.13 $21.95 $25.17

Subtropics, Northeast, Northwest

Pesticide Safety Training $ 3.71 $ 4.93 $ 5.72

Verification Card $ 0.31 $ 0. 2 1 $ 0.2 1

Expected Cost ( **cost TRAIN,i,a**  **B** ) $ 4 .03 $ 5.14 $ 5.93

Midwest, Ohio Valley, Texas/Mountain West

Pesticide Safety Training $ 3.71 $ 4.93 $ 5.72

Verification Card $ 0.00 $ 0. 00 $ 0.00

Expected Cost ( **cost TRAIN,i,a**  **B** ) $ 3.71 $ 4.93 $ 5.72



### Table B .1.a

- 14 . Pesticide S afety Training Cost, by Employer

Action Large WPS

Farm Large

- Small

WPS Farm Other Small

WPS Farm CPHE

All Regions, except California

Worker Safety Training $35.60 $14.75 $14.75 $ 0.00

Handler Safety Training $14.46 $ 6.78 $ 0.00 $27.11

Expected Cost ( **cost TRAIN,i,a**  **B** ) $50.06 $21.53 $14.75 $27.11

California

Worker Safety Training $53.40 $22.12 $22.12 $ 0.00

Handler Safety Training $29.39 $18.37 $ 0.00 $46.98

Record Keeping $ 2.81 $ 2.81 $ 0.00 $ 3.06

Expected Cost ( **cost TRAIN,i,a**  **B** ) $ 85.61 $43.30 $ 22.12 $50.04



## b. Final Rule

Worker

Table B .1.b

- 1. Cost under Final Rule, per worker, Worker Safety Training

Action/Material wage/price unit

time/quantity annual

probability cost

Full training session 14.64 0.75 0. 905 9.94

Acknowledge training 14.64 0.008 0. 905 0.11

Copy of training record 0.02 1 0 .302 0.01

Distribute copy 33.44 0.033 0 .302 0 .34

Expected per

- worker Cost ( cost r,i, workr B ) 1 0.39



### • Worker wages, including for benefits, are $14.64/hr ( BLS, 2014b ).

### 12 • Worker safety training will take an additional 15 minutes, based on EPA draft materials and pilot

projects, i.e.

, approximately 45 minutes.

• Workers trained each year account for 90.5% of the total workforce, excluding returning handlers

who comprise the remaining 9.5%.

• Each worker must sign an acknowledgement of receipt of training, estimated to take about 30

seconds.

• A copy of the training record must be provided to a worker upon request.

o The copy will be about a page at $0.02/page (Staples, 2014)

o About one

- third of trained workers will request a copy to present to subsequent

employers, given that 28% of employees report more than one employer (DoL, 2005)

o The employer spends about 2 minutes to provide a copy of the record, on average



### Handler

Table B .1.b

- 2. Costs under Final Rule, per handler, Handler Safety Training

Action/Material wage/price unit

time/quantity annual

probability cost

WPS farm handler

Full training 20.04 1 1.000 20.04

Acknowledge training 20.04 0.008 1.000 0.17

Copy of training record 0.02 1 0.160 0.00

Distribute copy 33.44 0.033 0.160 0.18

Expected per

- handler Cost ( cost r,i, a B ) 20.39

CPHE handler

Full training 23.26 1 1.000 23.26

Acknowledge training 23.26 0.008 1.000 0.19

Copy of training record 0.02 1 0.160 0.00

Distribute copy 32.65 0.033 0.160 0.17

Expected per

- handler Cost ( cost r,i, a B ) 23.63



### • Handler wages, including for benefits, are $20.04/hr for on

- farm handlers and $23.26/hr for

CPHE handlers ( BLS, 2014b ).

• Handler safety training will take an additional 15 minutes, based on EPA draft materials and pilot

projects, i.e.

, approximately 60 minutes.

• All handlers will be trained annually.

• Each handler must sign an acknowledgement of receipt of training, estimated to take about 30

seconds.

• A copy o f the training record must be provided to a handler upon request.

o The copy will be about a page at $0.02/page (Staples, 2014)

o About 16% of handlers will request a copy to present to subsequent employers, based on

the new hire rate (DoL, 2005)

o The employer spends about 2 minutes to provide a copy of the record, on aver age



### Establishment

### 13 Table B .1.b

- 3. Cost under Final Rule, per WPS farm, by size, Worker Training

Action/Material wage/price unit

time/quantity annual

frequency cost

Large WPS farm

Training by Handler Trainer 47.18 0.75 0.404 14.30

Training by Train

- the

- Trainer 47.18 0.75 0.289 10.22

Training by Certified Applicator 33.44 0.75 2.194 55.04

Collect/store training record 33.44 0.117 2.89 11.26

Training record 0.02 1 2.89 0.06

Folder 0.20 1 1 0.20

Expected per

- farm Cost ( cost r,i, a B ) 91.08

Small WPS farm

Training by Handler Trainer 47.18 0.75 0.194 6.87

Training by Train

- the

- Trainer 47.18 0.75 0.139 4.91

Training by Certified Applicator 33.44 0.75 1.054 26.44

Collect/store training record 33.44 0.117 1.39 5.41

Training record 0.02 1 1.39 0.03

Folder 0.20 1 1 0.20

Expected per

- f a rm Cost ( cost r,i, a B ) 43.85



### • Three categories of trainers eligible to conduct worker safety training with differing wage,

excluding handlers (BLS, 2014b):

o trainers of handlers and certified applicators ($47.18/hr);

o individuals who have completed a train the trainer program ($47.18/h r);

o certified applicators, typically the employer, ($33.44/hr); and

o handlers ($20.04/hr).

• Worker safety training takes approximately 45 minutes, given additional content

.

• The probability a trainer from a given category conducting a training session

o Trainer probabilities, based on conversations with state officials:

 trainers of handlers and certified applicators (14% of sessions);

 individuals who have completed a train the trainer program (10% of sessions);

and

 certified applicators (7 6 % of sessions)

o Vector of probabilities [ 0.14 0.10 0.7 6 ]

• EPA assumes that the average number of training sessions conducted for each WPS farm will

increase, given annual training and the elimination of a grace period.

o Large WPS farms (more than $750,000 in revenue/ye ar) average 2.89 training sessions

per year. This is a weighted average of two groups of farms.

 Large farms with more than 10 employees hold an average of 6. 4 training

sessions per year , an increase of 42% over the baseline

.

 Large WPS farms with fewer tha n 10 employees hold an average of 1.45 training

sessions per year , an increase of 61% over the baseline

.

o Small WPS farms (less than $750,000 in revenue/year) average 1 .39 training sessions per

year. This is a weighted average of four groups of farms.

 Larg e

- small farms (revenue/year between $100,000 and $750,000) with more

than 10 employees are assumed to hold an average of 3.25 training sessions per

year , an increase of 48% over the baseline . These farms include fruit, nut, and

vegetable farms, nurseries, and greenhouses with an average of 12.6

workers/farm, many of whom are temporary workers; sessions will be conducted

### 14 throughout the year. EPA estimates that there are 17,598 such farms out of

255,892 small farms hiring workers.

 Large

- small farms with few er than 10 employees are assumed to hold an average

of 1.27 training sessions per year , an increase of 75% over the baseline

.

 Medium

- small farms (revenue/year between $10,000 and $100,000) regardless of

primary production are as sumed to hold an average of 1.27 training sessions per

year , an increase of 75% over the baseline

.

 Small

- small farms (revenue/year less than $10,000) are assumed to hold an

average of 1.2 training sessions per year , an increase of 85% over the baseline

.

o Vector of number of sessions = [ 2.8 9 1.39 ]

• Matrix of annual frequency of sessions lead by various trainers

┌ ┐ ┌ ┐ │0.14│ ┌ ┐ │0. 404 0.1 94 │ │0.10│∙ │ 2.8 9 1.39│ = │0.289 0.139 │ │0.7 6 │ └ ┘ │2.194 1.054 │

└ ┘ └ ┘



### Table B .1.b

- 4. Cost under Final Rule, per WPS farm or CPHE, Handler Training

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Training by Handler Trainer 47.18 1.0 0.112 5.28

Training by Train

- the

- Trainer 47.18 1.0 0.080 3.77

Training by Certified Applicator 33.44 1.0 0.608 20.33

Training acknowledgement 0.02 1 1.16 0.02

Collect/store acknowledgement 33.44 0.067 1.16 2.59

Folder 0.20 1 1 0.20

Expected per

- farm Cost ( cost r,i, a B ) 32.20

Large

- Small WPS farm

Training by Handler Trainer 47.18 1.0 0.070 3.30

Training by Train

- the

- Trainer 47.18 1.0 0.050 2.36

Training by Certified Applicator 33.44 1.0 0.380 12.71

Training acknowledgement 0.02 1 1.16 0.02

Collect/store acknowledgement 33.44 0.067 1.16 2.59

Folder 0.20 1 1 0.20

Expected per

- farm Cost ( cost r,i, a B ) 21.18

CPHE

Training by Handler Trainer 47.18 1.0 0.182 8.59

Training by Train

- the

- Trainer 47.18 1.0 0.130 6.13

Training by Certified Applicator 32.65 1.0 0.988 32.26

Training acknowledgement 0.02 1 1.3 0.03

Collect/store acknowledgement 33.44 0.067 1.3 2.83

Folder 0.20 1 1 0.20

Expected per

- f i rm Cost ( cost r,i, a B ) 50.04



### • Handler safety training will take 60 minutes, given expanded content.

• Handler safety training must be taken annually.

o Large farms will average 0.8 training sessions/year (4 trainings for every 5 farms, as

some farms are able to share resources)

### 15 o Large

- small farms will average 0.5 training sessions/year (1 training for every 2 farms, as

some farms are able to share resources)

o CPHEs will average 1.3 training sessions/year to account for turnover and different

scheduling.

• Employers must keep a record of training

o Signed training roster takes about a page at $0.02/page (Staples, 2 014); average number

1.16 per farm to account for new hires, 1.3 times for CPHEs with every session.

o Collection and storage is assumed to take approximately 4 minutes.

o Storage requires a folder for training records at $0.20 (Staples, 2014).



## B .2. Hazard Communication

a. Baseline

Table B .2.a

- 1. Baseline Cost, per WPS farm with field workers , Information on Pesticide

Applications

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Post Application Information 33.44 0.017 18.4 10.23

Expected per

- large farm Cost ( 

### cost r, i

, a B ) 61.76

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Post Application Information 33.44 0.017 15.7 8.73

Expected per

- small farm Cost ( 

### cost r, i

, a B ) 52.67



### • The employer’s time is valued at $33.44/hr, consisting of the wage and benefits (BLS, 2014b).

• EPA assumes the owner/operator of a WPS farm spends 5 minutes per application gathering and

recording information on the product used, the field treated, the date treated and the duration of

the REI.

• EPA assumes a single sheet of paper

, at $0.02/sheet (Staples, 2014), is sufficient to reco rd the

information about each application.

• Posting the information is assumed to take one minute.

• EPA calculates that large WPS farms employing workers and/or handlers make an average of

1 8.4 pesticide applications per year and small WPS farms employing wo rkers and/or handlers

make an average of 15.7 pesticides applications per year

.

o EPA assumes an average of 20 applications per year, conditional on applying pesticides

.

o EPA estimates that 9 1.8 % of large WPS farms and 78.3% of small WPS farms with

workers wi ll make pesticide applications in any given year ( Appendix A )

.

### 16 California

Table B.2.a

- 2. California Baseline Cost, per WPS farm, Information on Pesticide Applications

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Obtain SDS 33.44 0.067 9.2 20.46

SDS 0.02 3.3 9.2 0.62

Post Information and SDS 33.44 0.017 18.4 10.23

Store Records 33.44 0.017 18.4 10.23

Copy of Information Sheet 0.02 1 18.4 0.37

Copy of SDS 0.02 3.3 9.2 0.62

Folder 0.20 1 0.918 0.18

Retrieve/Copy Record 33.44 0.1 0.918 3.07

Record copy 0 .02 4.3 0.918 0.08

Expected per

- large farm Cost ( 

### cost r, CA

, a B ) 97.38

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Obtain SDS 33.44 0.067 7.8 17.45

SDS 0.02 3.3 7.8 0.52

Post Information and SDS 33.44 0.017 15.7 8.73

Store Records 33.44 0.017 15.7 8.73

Copy of Information Sheet 0.02 1 15.7 0.31

Copy of SDS 0.02 3.3 7.8 0.52

Folder 0.20 1 0.783 0.16

Retrieve/Copy Record 33.44 0.1 0 0.783 2.62

Record copy 0.02 4.3 0.783 0.07

Expected per

- small farm Cost ( 

### cost r, CA

, a B ) 83.05



### • See Table B.2 .a

- 1 for explanation of wage/price, time/quantity, and annual probability.

• State require s employers to post the product’s Safety Data Sheet (SDS).

o EPA assumes the agricultural employer spends about 4 minutes obtain the SDS, based on

internet search times. Most SDS are available with the pro duct from the pesticide dealer.

o EPA assumes one SDS is needed for every two applications, on average, because the

same product is often used on multiple fields on an establishment.

o EPA estimates that 3.3 pages will be needed for the average SDS based on a sample of

SDS, which ranged in length from 2 to 10 pages, single sided. The average length was

6.7 pages.

• State requires employers to maintain records of application information and SDS.

o EPA assumes it takes 1 minute to file the records.

o Records entail a copy of the application information sheet and SDS.

o Establishments maintaining records will need a file folder for storage , at $0.20 (Staples,

2014)

.

• State requires that records be made available on request; EPA interprets the requirement to apply

only to c urrent employees

. EPA assumes that a copy of the record is the most convenient way to

make the information available.

### 17 o EPA assumes it takes 6 minutes to retrieve and copy the appropriate record , including the

application information sheet and SDS.

o EPA assumes that there will be one request for every 20 applications, on average, or

about one request per establishment using pesticides.



### Subtropics, and Midw est

Table B.2.a

- 3 . Subtropics and Midwest Baseline Cost, per WPS farm, Information on Pesticide

Applications

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Obtain SDS 33.44 0.067 9.2 20.46

SDS 0.02 3.3 9.2 0.62

Post Information and SDS 33.44 0.017 18.4 10.23

Expected per

- farm Cost ( 

### cost r, (Subtrpc, Midwest)

, a B ) 82.84

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Obtain SDS 33.44 0.067 7.8 17.45

SDS 0.02 3.3 7.8 0.52

Post Information and SDS 33.44 0.017 15.7 8.73

Expected per

- farm Cost ( 

### cost r, (Subtrpc, Midwest)

, a B ) 70.65



### • See Table B.2.a

- 1 for explanation of wage/price, time/quantity, and annual probability.

• State s require employers to post the product’s Safety Data Sheet (SDS).

o EPA assumes the agricultural employer spends about 4 minutes obtain the SDS, based on

internet search times

. Most SDS are available with the product from the pesticide dealer.

o EPA assumes one SDS is needed for every two applications, on average, because the

same product is often used on multiple fields on an establishment.

o EPA estimates that 3.3 pages will be needed for the average SDS based on a sample of

SDS, which ranged in length from 2 to 10 pages, single sided. The average length was

6.7 pages.

### 18 Texas/Mountain West region

Table B.2.a

- 4 . Texas/Mountain West Baseline Cost, per WPS farm, Information on Pesticide

Applications

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Obtain SDS 33.44 0.067 9.2 20.46

SDS 0.02 3.3 9.2 0.62

Post Information and SDS 33.44 0.017 18.4 10.23

Store Records 33.44 0.017 18.4 10.23

Copy of Information Sheet 0.02 1 18.4 0.37

Copy of SDS 0.02 3.3 9.2 0.62

Folder 0.20 1 0.918 0.18

Retrieve/Copy Record 33.44 0.1 0 0.918 3.07

Record copy 0.02 4.3 0.918 0.08

Expected per

- farm Cost ( 

### cost r, (TX/Mt W)

, a B ) 97.38

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Post Application Information 33.44 0.017 15.7 8.73

Expected per

- farm Cost ( 

### cost r, (TX/Mt W)

, a B ) 52.67



### • State require s employers to post the product’s Safety Data Sheet (SDS)

, maintain records of

application information and SDS, and make records available on request

. EPA interprets the

requirement to apply only to large farms (pesticide use of 55 gallon/500 lb or more and employers

with payroll of $15,000 per year or more). Se e Table B.2.a

- 2 for explanation of large farm costs.

See Table B.2.1

- 1 for explanation of small farm costs.



### Table B.2.a

- 5. Texas/Mountain West Baseline Cost, per WPS worker/handler, Information on

Pesticide Applications

Action/Material wage/price unit time/quantity annual

probability cost

Employer verifies request

information 33.44 0.10 0.005 0.02

Retrieve/Copy Record 33.44 0.10 0.005 0.02

E

- mail records 33.44 0.10 0.003 0.01

Mail Records 33.44 0.20 0.003 0.02

Record copy 0.02 4.3 0.003 0.00

Envelope & Postage 3.88 1 0.003 0.01

Expected per

- employee Cost ( 

### cost r, (TX/Mt W)

, a B ) 0.07



### • State requires employers to make records available to former employees or to their designated

representatives

. EPA assumes that about 1 in 100 workers or handlers will make such a request.

EPA estimates there are 87,075 workers and/or handlers on large farms in the Texas/Mountain

West Region out of 163,682 total workers and handlers in the region, i.e., about 53 % of workers

### 19 and handlers are employed on large farms. The probability of a request is thus about 0.53 out of

100 total workers and handlers in the region.

o EPA assumes the employer spends 6 minute s, on average, verifying the validity of the

request

.

o EPA a ssume the employer spends 6 minutes, o n av e rag e , retrieving an d copying the

record.

o Records can be sent electronically in about half the cases, taking 6 minutes.

o Records are mailed in about half the cases, taking 12 minutes.

 A copy of the record i s m a de at $0. 0 2 per page (Staples, 2014).

 An envelope costs $0.20 (Staples, 2015) and postage with return receipt costs

$3.68 (USPS, 2015) for total mailing costs of $3.88.



## b. Final Rule

Table B.2.b

- 1. Cost under Final Rule, per WPS farm, Information on Pesticide Applications

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Obtain SDS 33.44 0.067 9.2 20.46

SDS 0.02 3.3 9.2 0.62

Post Information and SDS 33.44 0.017 18.4 10.23

Store Records 33.44 0.017 18.4 10.23

Copy of Information Sheet 0.02 1 18.4 0.37

Copy of SDS 0.02 3.3 9.2 0.62

Folder 0.20 1 0.918 0.18

Retrieve/Copy Record 33.44 0.1 0.918 3.07

Record copy 0.02 4.3 0.918 0.08

Expected per

- large farm Cost ( 

### cost r, CA

, a B ) 97.38

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Obtain SDS 33.44 0.067 7.8 17.45

SDS 0.02 3.3 7.8 0.52

Post Information and SDS 33.44 0.017 15.7 8.73

Store Records 33.44 0.017 15.7 8.73

Copy of Information Sheet 0.02 1 15.7 0.31

Copy of SDS 0.02 3.3 7.8 0.52

Folder 0.20 1 0.783 0.16

Retrieve/Copy Record 33.44 0.10 0.783 2.62

Record copy 0.02 4.3 0.783 0.07

Expected per

- small farm Cost ( 

### cost r, CA

, a B ) 83.05



### • See Table B.2.a

- 2 for explanation.

### 20 Table B.2.b

- 2. Cost under Final Rule, per WPS worker/handler, Information on Pesticide

Applications

Action/Material wage/price unit

time/quantity annual

probability cost

Employer verifies request information 33.44 0.10 0.010 0.03

Retrieve/Copy Record 33.44 0.10 0.010 0.03

E

- mail records 33.44 0.10 0.005 0.02

Mail Records 33.44 0.20 0.005 0.03

Record copy 0.02 4.3 0.005 0.00

Envelope & Postage 3.88 1 0.005 0.02

Expected per

- employee Cost ( 

### cost r, (TX/Mt W)

, a B ) 0.14



### • See Table B.2.a

- 5 for explanation. EPA assumes that 1 in 100 workers and handlers will request

information each year with half of the responses made via e

- mail and half of responses via regular

mail

.



## B

. 3 . Notification

a. Baseline

Agricultural Establishments , Notification of REIs

Non

- greenhouse farms, including nurseries, may either provide oral notification or post warnings

except for certain products requiring both types of notification; both activities are conducted by

the owner/operator. Greenhouses are required to post warnings in all situations and provide oral

notification for double notification products.

• EPA assumes WPS farms typically provide oral notification when given the choic e, which is

assumed to take 3 minutes. However, if there are a high number of workers per farm, it may be

less costly to post the information rather than inform workers orally. EPA calculates annual

average frequencies for oral notification by farm size, based on 20 applications per year, if

pesticides are used. EPA also assumes that 1.1 oral notifications will be made, on average, for

each application to account for workers in different locations or at different times.

• EPA assumes that 2 signs are usual ly posted at a time and these signs can be reused. WPS farms

with worker housing adjacent to a field will need to post a third sign. Farms will likely only need

2 or 3 signs due to few simultaneous postings. EPA assumes that it takes 10 minutes to post a

sign and later take it down, which is done by the owner/operator. Posting two signs takes 20

minutes; posting three signs takes 30 minutes.

• EPA assumes that 80% of workers will be informed of each application and REI since some REIs

are very short and w orkers may not be present on

- farm while it is in effect.



### Table B .3.a

- 1. Baseline Cost, Large WPS Farm excluding greenhouses, REI Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Large WPS farm 1

Oral Notification 33.44 0.05 14.6 24.36

Warning Signs 7.35 4 0.339 9.96

### 21 Post 2 Signs 33.44 0.333 5.42 60.42

Warning Signs 7.35 6 0.134 5.92

Post 3 Signs 33.44 0.50 2.15 35.91

Expected per

- Large farm Cost ( cost r,i, a B ) 136.58

1 

### Excluding greenhouses.

• The employer’s time is valued at $33.44/hr, consisting of the wage and benefits (BLS, 2014b).

• Warning signs cost $ 7.35 each (Gemplers)

• On average, large WPS farms will make 18.9 applications per year given that 94.6% of large

farms report using pesticides in 2012. They will make oral notifications to their workers in 70%

of cases, or 13.2 applications, implying 14.6 oral notifications per year, on average, assuming 1.1

notifications per application.

• Large WPS farms will post REI warning signs in 40% of applications, or 7.6 times/year,

assuming 10% of applications require double notification.

• EPA assumes signs last two years, implying that 47.3% of the farms will purchase signs each

year, i.e. , half of the 94.6% of large WPS farms that reported using pesticides in 2012. EPA

assumes that 30% of large WPS farms applying pesticides have worker housing near a field, or

28.4% of all large WPS farms.

o Four REI signs are purchased with an annual frequency of 0.339

, i.e.

, 71.6% of large

farms without worker housing near fields

.

o Six signs are purchased with annual frequency of 0.1 34, that is, 28.4% of large farms

with worker housing near fields

.

• Therefore, 2 signs will be posted (20 minutes) 5.4 times/year, i.e

. , 71.6% of the 7.6 postings, and

3 signs will be posted (30 minutes) 2.2 times/year.



### Table B.3.a

- 2. Baseline Cost, Large

- Small WPS Farm excluding greenhouses, REI Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Large

- Small WPS farm 1

Oral Notification 33.44 0.05 20.8 34.70

Warning Signs 7.35 2 0.383 5.63

Post 2 Signs 33.44 0.333 1.53 17.06

Warning Signs 7.35 3 0.089 1.96

Post 3 Signs 33.44 0.50 0.36 5.95

Expected per

- Lrg

- Sml farm Cost ( cost r,i, a B ) 65.31



### • Large

- small farms will make 18.9 applications per year given that 94.3% of large

- small farms

report using pesticides in 2012. They will make oral notifications to their workers for all

applications, implying 20.8 oral notifications per year, on average, assuming 1.1 notifications per

application.

• Large

- small WPS farms will post REI warning signs in 10% of applications, or 1.9 times/year,

assuming 10% of applications require double notification.

• EPA assumes signs last two years, implying that 47.2 % of the farms will purchase signs each

year, i.e. , half of the 94.3% of large

- small WPS farms that reported using pesticides in 2012.

EPA assumes that 20% of large

- small WPS farms applying pesticides have worker housing near a

field, or 18.9% of all larg e

- small WPS farms.

o Two REI signs are purchased with an annual frequency of 0.383, i.e. , 81.1% of large

small farms without worker housing near fields.

### 22 o Three signs are purchased with annual frequency of 0.089, that is, 18.9% of large

- small

farms with worker housing near fields.

• Therefore, 2 signs will be posted (20 minutes) 1.5 times/year, i.e. , 81.1% of the 1.9 postings, and

3 signs will be posted (30 minutes) 0.4 times/year.



### Table B .3.a

- 3 . Baseline Cost, Medium

- Smal l WPS Farm excluding greenhouses, Notif ication of

REIs

Action/Material wage/price unit time/quantity annual

frequency cost

Medium

- Small WPS farm 1

Oral Notification 33.44 0.05 17.5 29.24

Warning Signs 7.35 2 0.366 5.38

Post 2 Signs 33.44 0.333 1.46 16.31

Warning Signs 7.35 3 0.032 0.70

Post 3 Signs 33.44 0.50 0.13 2.11

Expected per

- Med

- Small farm Cost ( cost r,i, a B ) 53.75

1 

### Excluding greenhouses.

• Medium

- small farms will make 15.9 applications per year given that 79.5 % of medium

- small

farms report using pesticides in 2012. They will make oral notifications to their workers for all

applications, implying 17.5 oral notifications per year, on average, assuming 1.1 notifications per

application.

• Medium

- small WPS farms will post REI warning signs in 10% of applications, or 1.6 times/year,

assuming 10% of applications require double notification.

• EPA assumes signs last two years, implying that 39.8% of the farms will purchase signs each

year, i.e. , half of the 79.5% of medium

- small WPS farms that reported using pesticides in 2012.

EPA assumes that 10% of medium

- small WPS farms applying pesticides have worker housing

near a field, or 7.9% of all medium

- small WPS farms.

o Two REI signs are purchased with an annual frequency of 0.366, i.e.

, 92.1% of medium

small farms without worker housing near fields.

o Three signs are purchased with annual frequency of 0.032, that is, 7.9% of medium

- small

farms with worker housing near fields.

• Therefore, 2 signs will be posted (20 minutes) 1.5 times/year, i .e. , 92.1% of the 1.6 postings, and

3 signs will be posted (30 minutes) 0.1 times/year.



### Table B.3.a

- 4. Baseline Cost, Small

- Small WPS Farm excluding greenhouses, REI Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Small

- Small WPS farm 1

Oral Notification 33.44 0.05 11.6 19.38

Warning Signs 7.35 2 0.256 3.77

Post 2 Signs 33.44 0.333 1.03 11.43

Warning Signs 7.35 3 0.007 0.15

Post 3 Signs 33.44 0.50 0.03 0.46

Expected per

- Small

- Small farm Cost ( cost r,i, a B ) 35.20

1 

### Excluding greenhouses.

• Small

- small farms will make 10.5 applications per year given that 52.7% of small

- small farms

report using pesticides in 2012. They will make oral notifications to their workers for all

### 23 applications, implying 11.6 oral notifications per year, on average, assuming 1.1 notifications per

application.

• Small

- small WPS farms will post REI warning signs in 10% of applications, or less than 1.1

times/year, assuming 10% of applications require double notification.

• EPA assumes sig ns last two years, implying that 26.4 % of the farms will purchase signs each

year, i.e. , half of the 5 2.7 % of small

- small WPS farms that reported using pesticid es in 2012.

EPA assumes that 5 % of small

- small WPS farms applying pesticides have worker housin g near a

field, or 2.6 % of all small

- small WPS farms.

o Two REI signs are purchased with an annual frequency of 0. 25 6, i.e. , 9 7.4 % of small

small farms without worker housing near fields.

o Three signs are purchased with annual frequency of 0.0 07 , that is, 2.6 % of small

- small

farms with worker housing near fields.

• Therefore, 2 signs will be posted (20 minutes) 1.03 times/year, i.e. , 97.4% of the 1.1 postings, and

3 signs will be posted (30 minutes) 0.03 times/year.



### Table B.3.a

- 5. Baseline Cost, Large WPS Gree nhouse, per actor, REI Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Large WPS Greenhouse

Oral Notification 33.44 0.05 1.64 2.74

Signs 7.35 4 0.372 10.95

Posting Signs 33.44 0.333 14.9 166.07

Expected per

- Greenhouse Cost ( cost r,i, a B ) 179.76



### • Large WPS greenhouses will make 14.9 applications per year given that 74.5% of large WPS

greenhouses report using pesticides in 2012. Greenhouses will make oral notifications to their

workers for 10% of applications, i.e. , double notification products, im plying 1.6 oral notifications

per year, on average, assuming 1.1 notifications per application.

• EPA assumes signs last two years, implying that 37.2% of the greenhouses will purchase signs

each year, i.e. , half of the 74.5% of large WPS greenhouses that re ported using pesticides in 2012.

Large WPS greenhouses will need 4 signs.

• REI warning signs must be posted for all applications. Therefore, 2 signs (20 minutes) will be

posted 14.9 times/year.



### Table B.3.a

- 6 . Baseline Cost, Small WPS Greenhouse, per act or, REI Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Small WPS Greenhouse

Oral Notification 33.44 0.05 1.20 2.01

Signs 7.35 4 0.273 8.02

Posting Signs 33.44 0.333 10.9 121.62

Expected per

- Greenhouse Cost ( cost r,i, a B ) 131.64



### • Small WPS greenhouses will make 10.9 applications per year given that 59.2% of small WPS

greenhouses report using pesticides in 2012. Greenhouses will make oral notifications to their

workers for 10% of applications, i.e. , double notification products, implying 1. 2 oral notifications

per year, on average, assuming 1.1 notifications per application.

### 24 • EPA assumes signs last two years, implying that 27.3% of the greenhouses will purchase signs

each year, i.e. , half of the 59.2% of smal l WPS greenhouses that reported using pesticides in

2012. Small WPS greenhouses will need 4 signs.

• REI warning signs must be posted for all applications. Therefore, 2 signs (20 minutes) will be

posted 10.9 times/year.



### Workers, Notification of REIs

Tabl e B.3.a

- 7 . Baseline Cost, WPS Workers, Notification of REI

Actor, Receives Notification wage/price unit time/quantity annual

frequency cost

( cost r,i, a B )

Large Farm worker 1 14.64 0.05 10.6 7.74

Lrg

- Sml Farm worker 1 14.64 0.05 15.1 11.04

Med/Sml Farm worker 1 14.64 0.05 13.1 9.63

Large Greenhouse worker 14.64 0.05 1.3 0.92

Small Greenhouse worker 14.64 0.05 0.8 0.59

1 

### Excluding greenhouses.

• The employee’s time is valued at $14.64/hr, consisting of the wage and benefits (BLS, 2014b).

• EPA assumes that oral notification of a REI takes 3 minutes.

• EPA calculates the frequency with which each worker receives oral notification of REI, based on

farm size.

o Workers on large farms receive 10.6 notifications per year. Large farms make oral

notifications for 14 of 20 applications (Table B.3.a

- 1), there is an 80% chance a worker

will be on

- farm during the REI, and 94.4% of workers are employed on large WPS farms

making a pesticide application (Appendix A) (14 ∙ 0.8 ∙ 0.944).

o Workers on large

- small farms receive 15.1 notifications per year. Large

- small farms

make oral notifications for all 20 applications, there is an 80% chance a worker will be

on

- farm during the REI, and 94.2% of workers are employed on large

- small WPS farms

making a pesticide applicati on (NASS, 2008b) (20 ∙ 0.8 ∙ 0.942).

o Workers on medium and small

- small farms receive 13.1 notifications per year. Small

farms make oral notifications for all 20 applications, there is an 80% chance a worker

will be on

- farm during the REI, and 82.2% of wor kers are employed on WPS farms

making a pesticide application (NASS, 2008b) (20 ∙ 0.8 ∙ 0.822).

o Workers in large greenhouses receive 1.3 notifications per year. Large greenhouses make

oral notifications for 2 of 20 applications, there is an 80% chance a w orker will be on

farm during the REI, and 78.5% of workers are employed on large WPS greenhouses

making a pesticide application (Appendix A) (2 ∙ 0.8 ∙ 0.785).

o Workers in small greenhouses receive 0.8 notifications per year. Small greenhouses

make oral no tifications for 2 of 20 applications, there is an 80% chance a worker will be

on

- farm during the REI, and 50.8% of workers are employed on large WPS greenhouses

making a pesticide application (Appendix A) (2 ∙ 0.8 ∙ 0.508).



### Agricultural Establishments, E arly Entry Notification

All WPS agricultural establishments may, under certain circumstances, direct workers into a

field under a REI. The employer is required to inform the worker of the labeling requirement s

related to hazard or safety.

### 25 Table B .3.a

- 8

. Baseline Cost, per WPS farm, Early Entry Notification

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm 1

Gather Information 33.44 0.017 0.378 0.21

Provide Information 33.44 0.05 0.378 0.63

Expected per

- farm Cost ( cost r,i, a B ) 0.84

Large

- Small WPS farm 1

Gather Information 33.44 0.017 0.377 0.21

Provide Information 33.44 0.05 0.377 0.63

Expected per

- farm Cost ( cost r,i, a B ) 0.84

Medium

- Small WPS farm 1

Gather Information 33.44 0.017 0.318 0.18

Provide Information 33.44 0.05 0.318 0.53

Expected per

- farm Cost ( cost r,i, a B ) 0.71

Small

- Small WPS farm 1

Gather Information 33.44 0.017 0.211 0.12

Provide Information 33.44 0.05 0.211 0.35

Expected per

- farm Cost ( cost r,i, a B ) 0.47

Large WPS Greenhouse

Gather Information 33.44 0.017 0.298 0.17

Provide Information 33.44 0.05 0.298 0.50

Expected per

- farm Cost ( cost r,i, a B ) 0.66

Small WPS Greenhouse

Gather Information 33.44 0.017 0.218 0.12

Provide Information 33.44 0.05 0.218 0.36

Expected per

- farm Cost ( cost r,i, a B ) 0.49

1 

### Excluding greenhouses.

• EPA assumes that gathering the currently required information takes 1 minute as it comes directly

from the pesticide label.

• EPA assumes that providing the information takes 3 minutes.

• Annual probability varies by farm size and type, given that the likelihood of pesticides varies

across farms (Appendix A) . EPA assumes an early entry event occurs about once in every 50

applications, which implies a 40% chance of occurrence on an establishment that makes 20

applications.

o EPA estimates that 94.6 % of large WPS farms, excluding greenhouses, apply pesticides,

implying an annual frequency of 0.378 across all such farms.

o EPA estimates that 94.3 % of large

- small WPS farms, excluding greenhouses, apply

pesticides, implying an annual frequency of 0.377 across all such farms.

o EPA estimates that 79. 5 % of medium

- small WPS farms, excluding greenhouses, apply

pesticides, implying an annual frequency of 0.318 across all such farms.

o EPA estimates that 52.7 % of small

- small WPS farms, excluding greenhouses, apply

pesticides, implying an annual frequency of 0.211 across all such farms.

o EPA estimates that 74.5% of large WPS greenhouses apply pesticides, implying an

annual frequency of 0.298 across all such farms.

### 26 o EPA estimates that 54.5% of small WPS greenhouses apply pesticides, implying an

annual frequency of 0.218 across all such farms.



### Workers, Early Entry Notification

Table B.3.a

- 9. Baseline Cost, WPS Workers, Early Entry Notifi cation

Actor, Receive Notification wage/price unit time/quantity annual

frequency cost

( cost r,i, a B )

Large Farm worker 1 14.64 0.05 0.189 0.14

Lrg

- Sml Farm worker 1 14.64 0.05 0.188 0.14

Med/Sml Farm worker 1 14.64 0.05 0.164 0.12

Large Greenhouse worker 14.64 0.05 0.157 0.12

Small Greenhouse worker 14.64 0.05 0.102 0.07

1 

### Excluding greenhouses.

• The employee’s time is valued at $14.64/hr, consisting of the wage and benefits (BLS, 2014b).

• EPA assumes that hazard information at early entry takes 3 minutes.

• EPA calculates the frequency with which each worker participates in an early entry task and

receives hazard information, based on farm size. There is a 40% chance of an event and EPA

assumes 50% of the workforce will be involved, implying a 20% c hance if employed on an

establishment using pesticides.

o EPA estimates that 18.9% of workers on large farms participate in an early entry task

since 94.4% of workers are employed on large WPS farms making a pesticide application

(Appendix A) (0.2 ∙ 0.944).

o EPA estimates that 18.8% of workers on large

- small farms participate in an early entry

task since 94.2% of workers are employed on large

- small WPS farms making a pesticide

application (Appendix A) (0.2 ∙ 0.942).

o EPA estimates that 16.4% of workers on other small farms participate in an early entry

task since 82.2% of workers are employed on large WPS farms making a pesticide

application (Appendix A) (0.2 ∙ 0.822).

o EPA estimates that 15.7% of workers on large greenhouses participate in an early entry

task si nce 78.5% of workers are employed on large WPS greenhouses making a pesticide

application (Appendix A) (0.2 ∙ 0.785).

o EPA estimates that 10.2% of workers on large farms participate in an early entry task

since 50.8% of workers are employed on large WPS far ms making a pesticide application

(Appendix A) (0.2 ∙ 0.508).



### Agricultural Establishments, Safety Displays

A safety poster is required to be displayed at a central location at all agricultural establishments

, including those that only employ handlers, if pesticides have been used.

Table B.3.a

- 10 . Baseline Cost, per WPS farm, Safety posters

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm 1

Central Poster 6.25 1 0.315 1.97

Post Sign 33.44 0.033 0.94 6 1.05

Expected per

- farm Cost ( cost r,i, a B ) 3 .03

### 27 Large

- Small WPS farm 1

Central Poster 6.25 1 0.314 1.97

Post Sign 33.44 0.033 0.943 1.05

Expected per

- farm Cost ( cost r,i, a B ) 3.02

Medium

- Small WPS farm 1

Central Poster 6.25 1 0.265 1.66

Post Sign 33.44 0.033 0.795 0.89

Expected per

- farm Cost ( cost r,i, a B ) 2.54

Small

- Small WPS farm 1

Central Poster 6.25 1 0.176 1.10

Post Sign 33.44 0.033 0.527 0.59

Expected per

- farm Cost ( cost r,i, a B ) 1.68

Large WPS Greenhouse

Central Poster 6.25 1 0.248 1.55

Post Sign 33.44 0.033 0.745 0.83

Expected per

- farm Cost ( cost r,i, a B ) 2.38

Small WPS Greenhouse

Central Poster 6.25 1 0.182 1.14

Post Sign 33.44 0.033 0.545 0.61

Expected per

- farm Cost ( cost r,i, a B ) 1.74

Large Handler

- Only Farm

Central Poster 6.25 1 0.283 1.77

Post Sign 33.44 0.033 0.849 0.95

Expected per

- farm Cost ( cost r,i, a B ) 2.72

Small Handler

- Only Farm

Central Poster 6.25 1 0.269 1.68

Post Sign 33.44 0.033 0.807 0.90

Expected per

- farm Cost ( cost r,i, a B ) 2.58

1 

### Excluding greenhouses.

• According to an on

- line source of WPS materials, a safety poster costs $6.25 (Gempler’s, 2014).

• EPA assumes it takes 2 minutes to set up the safety poster.

• EPA assumes poster lasts about 3 years, so one

- third of WPS farms will need to purchase a sign

each year.

o EPA estimates that 94.6% of large WPS farms, excluding greenhouses, apply pesticides

and will post a sign; this implies 31.5% will purchase a sign each year.

o EPA estimates that 94.3 % of large

- s mall WPS farms, excluding greenhouses, apply

pesticides and will post a sign; this implies 31.4% will purchase a sign each year.

o EPA estimates that 79. 5 % of medium

- small WPS farms, excluding greenhouses, apply

pesticides and will post a sign; this implies 26.5 % will purchase a sign each year.

o EPA estimates that 52.7% of small

- small WPS farms, excluding greenhouses, apply

pesticides and will post a sign; this implies 17.6% will purchase a sign each year.

o EPA estimates that 74.5% of large WPS greenhouses apply pesticides and will post a

sign; this implies 24.8% will purchase a sign each year.

o EPA estimates that 54.5% of small WPS greenhouses apply pesticides and will post a

sign; this implies 18.2% will purchase a sign each year.

o EPA estimates that 84.9 % o f large handler

- only farms apply pesticides and will post a

sign; this implies 28.3 % will purchase a sign each year.

### 28 o EPA estimates that 80.7% of small handler

- only farms apply pesticides and will post a

sign; this implies 26.9% will purchase a sign each ye ar.



## b. Final Rule

Agricultural Establishments , Notification of REIs

Non

- greenhouse farms, including nurseries, will now be required to post warnings if the REI is

greater than 48 hours. This may result in fewer oral notifications and more posting , whi ch may

mean the farm needs to purchase additional signs . Greenhouses will now have the option of

providing oral notification if the REI is 4 hours or less.

Table B.3. b

- 1. Cost under Final Rule , Large WPS Farm excluding greenhouses, REI

Notification

Acti on/Material wage/price unit time/quantity annual

frequency cost

Large WPS farm 1

Oral Notification 33.44 0.05 14.6 24.36

Warning Signs 7.35 4 0.339 9.96

Post 2 Signs 33.44 0.333 5.42 60.42

Warning Signs 7.35 6 0.134 5.92

Post 3 Signs 33.44 0.50 2.15 35.91

Expected per

- Large farm Cost ( cost r,i, a B ) 136.58

1 

### Excluding greenhouses.

• EPA does not expect changes on large farms and nurseries. Given the number of workers,

posting is probably already preferred in many situations.



### Table B.3.b

- 2. Cost under Final Rule, Large

- Small WPS Farm excluding greenhouses, REI

Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Large

- Small WPS farm 1

Oral Notification 33.44 0.05 14.5 24.29

Warning Signs 7.35 4 0.383 11.25

Post 2 Signs 33.44 0.333 6.12 68.26

Warning Signs 7.35 6 0.089 3.92

Post 3 Signs 33.44 0.50 1.42 23.81

Expected per

- Lrg

- Sml farm Cost ( cost r,i, a B ) 131.53



### • Large

- small farms will make 18.9 applications per year given that 94.3% of large

- small farms

report using pesticides in 2012. They will make oral notifications to their workers for 70% of

applications, implying 14.5 oral notifications per year, on average, assuming 1.1 notifications per

application.

• Large

- small WPS farms will post REI warning sig ns in 40% of applications, or 7.5 times/year,

assuming 10% of applications require double notification and 30% with REIs greater than 48

hours.

### 29 • EPA assumes signs last two years, implying that 47.2% of the farms will purchase signs each

year, i.e. , half of the 94.3% of large

- small WPS farms that reported using pesticides in 2012.

EPA assumes that 20% of large

- small WPS farms applying pesticides have worker housing near a

field, or 18.9% of all large

- small WPS farms.

o Four REI signs are purchased with an annu al frequency of 0.383, i.e. , 81.1% of large

small farms without worker housing near fields.

o Six signs are purchased with annual frequency of 0.089, that is, 18.9% of large

- small

farms with worker housing near fields.

• Therefore, 2 signs will be posted (20 m inutes) 6.1 times/year, i.e. , 81.1% of the 7.5 postings, and

3 signs will be posted (30 minutes) 1.4 times/year.



### Table B.3.b

- 3. Cost under Final Rule, Medium

- Small WPS Farm excluding greenhouses, REI

Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Medium

- Small WPS farm 1

Oral Notification 33.44 0.05 12.2 20.47

Warning Signs 7.35 4 0.366 10.76

Post 2 Signs 33.44 0.333 5.85 65.26

Warning Signs 7.35 6 0.032 1.39

Post 3 Signs 33.44 0.50 0.51 8.45

Expected per

- Med

- Small farm Cost ( cost r,i, a B ) 106.33

1 

### Excluding greenhouses.

• Medium

- small farms will make 15.9 applications per year given that 79.5% of medium

- small

farms report using pesticides in 2012. They will make oral notifications to their workers for 70%

of applications, implying 12.2 oral notifications per year, on average, assuming 1.1 notifications

per application.

• Medium

- small WPS farms will post REI warning signs in 40% of applications, or 6.4 times/year.

• EPA assumes signs last two years, impl ying that 39.8% of the farms will purchase signs each

year, i.e. , half of the 79.5% of medium

- small WPS farms that reported using pesticides in 2012.

EPA assumes that 10% of medium

- small WPS farms applying pesticides have worker housing

near a field, or 7 .9% of all medium

- small WPS farms.

o Four REI signs are purchased with an annual frequency of 0.366, i.e. , 92.1% of medium

small farms without worker housing near fields.

o Six signs are purchased with annual frequency of 0.032, that is, 7.9% of medium

- small

f arms with worker housing near fields.

• Therefore, 2 signs will be posted (20 minutes) 5 .9 times/year, i.e. , 92.1% of the 6.4 postings, and

3 signs will be poste d (30 minutes) 0.5 times/year.



### Table B.3.b

- 4. Cost under Final Rule, Small

- Small WPS Farm excluding greenhouses, REI

Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Small

- Small WPS farm 1

Oral Notification 33.44 0.05 8.1 13.56

Warning Signs 7.35 2 0.256 3.77

Post 2 Signs 33.44 0.333 4.10 45.73

Warning Signs 7.35 3 0.007 0.15

### 30 Post 3 Signs 33.44 0.50 0.11 1.86

Expected per

- Small

- Small farm Cost ( cost r,i, a B ) 65.07

1 

### Excluding greenhouses.

• Small

- small farms will make 10.5 applications per year given that 52.7% of small

- small farms

report using pesticides in 2012. They will make oral notifications to their workers for 70% of

applications, implying 8.1 oral notifications per year, on average, assuming 1.1 notifications per

application.

• Small

- small WPS farms will post REI warning signs in 40% of a pplications, or 4.2 times/year.

• EPA assumes signs last two years, implying that 26.4% of the farms will purchase signs each

year, i.e. , half of the 52.7% of small

- small WPS farms that reported using pesticides in 2012.

EPA assumes that 5% of small

- small W PS farms applying pesticides have worker housing near a

field, or 2.6% of all small

- small WPS farms.

o Two REI signs are purchased with an annual frequency of 0.256, i.e. , 97.4% of small

small farms without worker housing near fields.

o Three signs are purchas ed with annual frequency of 0.007, that is, 2.6% of small

- small

farms with worker housing near fields.

• Therefore, 2 signs will be posted (20 minutes) 4.1 times/year, i.e. , 97.4% of the 4.2 postings, and

3 signs will be posted (30 minutes) 0.1 times/year.



### Table B.3.b

- 5. Cost under Final Rule, Large WPS Greenhouse, per actor, REI Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Large WPS Greenhouse

Oral Notification 33.44 0.05 1.64 2.74

Signs 7.35 4 0.372 10.95

Posting Signs 33.44 0.333 14.9 166.07

Expected per

- Greenhouse Cost ( cost r,i, a B ) 179.76



### • EPA does not expect changes in large greenhouses. Given the number of workers, posting is

probably preferred in many situations.



### Table B.3.b

- 6. Cost under Final Rule, Small WPS Greenhouse, per actor, REI Notification

Action/Material wage/price unit time/quantity annual

frequency cost

Small WPS Greenhouse

Oral Notification 33.44 0.05 3.60 6.02

Signs 7.35 4 0.273 8.02

Posting Signs 33.44 0.333 8.73 97.29

Expected per

- Greenhouse Cost ( cost r,i, a B ) 111.33



### • Small WPS greenhouses will make 10.9 applications per year given that 59.2% of small WPS

greenhouses report using pesticides in 2012. Small greenhouses will make oral notifications to

their workers for 30% of applications, implying 3.6 oral notifications per year, on average,

assuming 1.1 notifications per application.

• EPA assumes signs last two years, implying that 27.3% of the greenhouses will purchase signs

each year, i.e. , half of the 59. 2% of small WPS greenhouses that reported using pesticides in

2012. Small WPS greenhouses will need 4 signs.

### 31 • REI warning signs will be posted 80% of applications. Therefore, 2 signs (20 minutes) will be

posted 8.7 times/year.



### Workers, Notification of RE Is

Table B.3.b

- 7. Cost under Final Rule, WPS Workers, Notification of REIs

Actor, Receives Notification wage/price unit time/quantity annual

frequency cost

( cost r,i, a B )

Large Farm worker 1 14.64 0.05 10.6 7.74

Lrg

- Sml Farm worker 1 14.64 0.05 10.6 7.73

Med/Sml Farm worker 1 14.64 0.05 9.2 6.74

Large Greenhouse worker 14.64 0.05 1.3 0.92

Small Greenhouse worker 14.64 0.05 2.4 1.78

1 

### Excluding greenhouses.

• EPA assumes that notification takes 6 minutes as in the baseline.

• EPA calculates the frequency with which each worker receives oral notification of REI, based on

farm size.

o Workers on large farms receive 10.6 notifications per year as in the baseline.

o Workers on large

- small farms receive 10.6 notifications/year. Large

- small farms make

oral notifica tions for 70% of 20 applications, there is an 80% chance a worker will be on

farm during the REI, and 94.2% of workers are employed on large

- small WPS farms

making a pesticide application (NASS, 2008b) (14 ∙ 0.8 ∙ 0.942).

o Workers on medium and small

- small farms receive 9.2 notifications per year. Small

farms make oral notifications for 70% of 20 applications, there is an 80% chance a

worker will be on

- farm during the REI, and 82.2% of workers are employed on WPS

farms making a pesticide application (NASS, 2008b) (14 ∙ 0.8 ∙ 0.822).

o Workers in large greenhouses receive 1.3 notifications per year as in the baseline.

o Workers in small greenhouses receive 2.4 notifications per year. Small greenhouses

make oral notifications for 6 of 20 applications, there is an 80% chance a worker will be

on

- farm during the REI, and 50.8% of workers are employed on large WPS greenhouses

making a pesticide application (Appendix A) (6 ∙ 0.8 ∙ 0.508).



### Agricultural Establishments, Early Entry Notification

For early entry situation s, the employer will be required to provide additional information to the

worker regarding the protections required, including PPE and limitations on activities and time in

the field

.

Table B.3.b

- 8 . Cost under Final Rule, per WPS farm, Early Entry Notification

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm 1

Gather Information 33.44 0.10 0.378 1.27

Provide Information 33.44 0.10 0.378 1.27

Expected per

- farm Cost ( cost r,i, a B ) 2.53

Large

- Small WPS farm 1

Gather Information 33.44 0.10 0.377 1.26

### 32 Provide Information 33.44 0.10 0.377 1.26

Expected per

- farm Cost ( cost r,i, a B ) 2.52

Medium

- Small WPS farm 1

Gather Information 33.44 0.10 0.318 1.06

Provide Information 33.44 0.10 0.318 1.06

Expected per

- farm Cost ( cost r,i, a B ) 2.13

Small

- Small WPS farm 1

Gather Information 33.44 0.10 0.211 0.70

Provide Information 33.44 0.10 0.211 0.70

Expected per

- farm Cost ( cost r,i, a B ) 1.41

Large WPS Greenhouse

Gather Information 33.44 0.10 0.298 1.00

Provide Information 33.44 0.10 0.298 1.00

Expected per

- farm Cost ( cost r,i, a B ) 1.99

Small WPS Greenhouse

Gather Information 33.44 0.10 0.218 0.73

Provide Information 33.44 0.10 0.218 0.73

Expected per

- farm Cost ( cost r,i, a B ) 1.46

1 

### Excluding greenhouses.

• EPA assumes that gathering the required information will take 6 minutes and that disseminating

the information takes 6 minutes.

• The probability of an occurrence is the same as in the baseline.



### Workers, Early Entry Notification

Table B.3.b

- 9. Cost under Final Rule, WPS Workers, Notification

Actor, Receive Notification wage/price unit time/quantity annual

frequency cost

( cost r,i, a B )

Large Farm worker 1 14.64 0.10 0.189 0.28

Lrg

- Sml Farm worker 1 14.64 0.10 0.188 0.28

Med/Sml Farm worker 1 14.64 0.10 0.164 0.24

Large Greenhouse worker 14.64 0.10 0.157 0.23

Small Greenhouse worker 14.64 0.10 0.102 0.15

1 

### Excluding greenhouses.

• EPA assumes that information at early entry takes 6 minutes.

• The frequency with which each worker participates in an early entry task is unchanged from the

baseline.



### Agricultural Establishments, Safety Display

A safety display is required at a central location at all agricultural establishments, including those

that only employ handlers, if pesticides have been used. Another display is required if

decontamination supplies are provided for a crew of 11 or more p eople. Under the final rule, the

### 33 employer will be required to provide contact information for a near

- by medical facility and for

the state agency responsibl e for the WPS on all displays

.

Table B.3.b

- 10 . Cost under Final Rule, per WPS farm, Safety poster s

Action/Material wage/price unit time/quantity annual

probability cost

Large WPS farm 1

Central Poster 6.25 1 0.315 1.97

Add Contact Information 33.44 0.05 0.315 0.53

Post Display 33.44 0.033 0.946 1.05

Decontamination Display 6.25 1.5 0.048 0.45

Add Contact Information 33.44 0.05 0.048 0.12

Post Display 33.44 0.033 1.43 1.60

Expected per

- farm Cost ( cost r,i, a B ) 5.72

Large

- Small WPS farm 1

Central Poster 6.25 1 0.314 1.97

Add Contact Information 33.44 0.05 0.314 0.53

Post Display 33.44 0.033 0.943 1.05

Decontamination Display 6.25 1 0.044 0.28

Add Contact Information 33.44 0.05 0.044 0.07

Post Display 33.44 0.033 0.529 0.59

Expected per

- farm Cost ( cost r,i, a B ) 4.48

### 34 Action/Material wage/price unit time/quantity annual

probability cost

Medium

- Small WPS farm 1

Central Poster 6.25 1 0.265 1.66

Add Contact Information 33.44 0.05 0.265 0.44

Post Display 33.44 0.033 0.795 0.89

Expected per

- farm Cost ( cost r,i, a B ) 2.99

Small

- Small WPS farm 1

Central Poster 6.25 1 0.176 1.10

Add Contact Information 33.44 0.05 0.176 0.29

Post Display 33.44 0.033 0.527 0.59

Expected per

- farm Cost ( cost r,i, a B ) 1.98

Large WPS Greenhouse

Central Poster 6.25 1 0.248 1.55

Add Contact Information 33.44 0.05 0.248 0.42

Post Display 33.44 0.033 0.745 0.83

Decontamination Display 6.25 1.5 0.248 2.33

Add Contact Information 33.44 0.08 0.248 0.62

Post Display 33.44 0.033 7.45 8.30

Expected per

- farm Cost ( cost r,i, a B ) 14.05

Small WPS Greenhouse

Central Poster 6.25 1 0.182 1.14

Add Contact Information 33.44 0.05 0.182 0.30

Post Sign 33.44 0.033 0.545 0.61

Expected per

- farm Cost ( cost r,i, a B ) 2.05

Large Handler

- Only Farm

Central Poster 6.25 1 0.283 1.77

Add Contact Information 33.44 0.05 0.283 0.47

Post Sign 33.44 0.033 0.849 0.95

Expected per

- farm Cost ( cost r,i, a B ) 3.19

Small Handler

- Only Farm

Central Poster 6.25 1 0.269 1.68

Add Contact Information 33.44 0.05 0.269 0.45

Post Sign 33.44 0.033 0.807 0.90

Expected per

- farm Cost ( cost r,i, a B ) 3.03

1 

### Excluding greenhouses.

• EPA assumes it takes 3 minutes to add the information to a safety poster, which can be done

when it is purchased.

• Large and large

- small fruit and vegetables and large greenhouses will potentially have work

crews of 11 or more people, especially at harvest.

o EPA estimates that there are about 8,100 large fruit and vegetable farms , implying 2,700

purchasing signs each year , or 4.8% of 56,532 large farms and nurseries. Farms will

need 1 to 2 displays.

o EPA estimates that there are about 13,500 large

- small fruit and vegetable farms, implying

almost 4,500 purchasing signs each year, or 4.4% of 102,024 large

- small farms and

nurseries. Farms are assumed to need 1 display.

o All large WPS greenhouses will need additional displays if pesticides are used.

### 35 • Large work crews will typically be associate d with harvest tasks

o EPA assumes that a large fruit/vegetable farm will have 10 occasions /year , on average,

employing a crew of 11 or more, since they may harvest a field multiple times over the

course of a year, or 81,000 displays or an average of 1.4 dis plays across all large farms

and nurseries.

o EPA assumes that a large

- small fruit/vegetable farm will have 4 occasions/year, on

average, employing a crew of 11 or more, based on information on the number of blocks

of fruit on a typical Washington fruit farm (NASS, 2008). Thus, EPA estimates almost

54,000 display or an average of 0.5 across all large

- small farms and nurseries.

o EPA assumes large greenhouses will have 10 occasions/year, on average, employing a

crew of 11 or more, on the 74.5% of greenhouses th at report using pesticides.



## B .4

. Age

A minimum age does not have direct regulatory costs, but it may effect labor costs.



## a. Baseline

The baseline considers the cost of hiring adolescents to conduct certain tasks, in particular,

handling pesticides and tasks associated with entry into a field under a REI.

Table B .4.b

- 1. Baseline Labor Cost, per WPS handler, Minimum Age

Action/Material wage/price unit time/quantity annual

probability cost

WPS Farm with workers

14

- 15 yr old WPS handler 12.03 50 0.004 2.33

16

- 17 yr old WPS handler 15.03 50 0.018 13.27

Expected per

- WPS handler cost ( cost r,i, a B ) 15.60

WPS Farm with handlers only

14

- 15 yr old WPS handler 12.03 50 0.003 2.04

16

- 17 yr old WPS handler 15.03 50 0.016 11.66

Expected per

- WPS handler cost ( cost r,i, a B ) 13.70

CPHE

16

- 17 yr old CPHE handler 17.45 640 0.013 145.15

Expected per

- CPHE handler cost ( cost r,i, a B ) 145.15



### • EPA assumes that 14

- 15 year old WPS handlers are paid $8.22 /hour, 6 0% of adult handlers

, somewhat higher than the federal minimum wage of $7.25/hour

. Loaded wages are calculated to

be $10.28/hour

• EPA assumes that 16

- 17 year old WPS handlers are paid $1 0.28 /hour, 75 % of adult handlers.

Loaded wages are calculated to be $15.03/hour.

• EPA assume s that 16

- 17 year old CPHE handlers are paid $11.93/hour, 75% of adult handlers.

Loaded wages are calculated to be $17.45/hour.

• WPS handlers under the age of 18 spend, on average, 50 hours per year in handling activities

(DOL, 2005).

• According to surveys of agricultural workers, 0.47% of pesticide handlers are under 16 and

1.87% are between 16 and 18 years old (DOL, 2005). These percentages are weighted by 94.4 %

### 36 and 82.9% , the proportion of handlers employed on WPS farms with workers and with handlers

only, respectively, making pesticide applications in a given year.

• EPA assumes CPHE handlers under the age of 18 spend 640 hours per year in handling activities:

40 hr/wk for 16 weeks.

• EPA assumes that 1 .3 % of CHPE handlers are under the age of 18. According to the Current

Population Survey (BLS, 2014a), in 2013, about 77,000 people were employed in pest control

occupations within the category of Building and Grounds Cleaning and Maintenance, of which

1,000 were aged 16 to 1 9, or 1.3 percent of the workforce

.



### Table B .4.a

- 2 . Baseline Labor Cost, per WPS worker, Minimum Age, Early Entry

Action/Material wage/price unit time/quantity annual

probability cost

14

- 15 yr old worker 7.32 4 0.006 0.18

16

- 17 yr old worker 8.79 4 0.008 0.29

Expected per

- worker Cost ( cost r,i, a B ) 0.47



### • EPA assumes that 14

- 15 year old WPS workers are paid $5.01 /hour, 50% of adult worker

, approximately the special minimum wage of $4.25 per hour for young workers during the first 90

days of employment with a given employer

. Loaded wage rate is $7.32/hour.

• EPA assumes that 16

- 17 year old WPS workers are paid $6 .01 /hour, 60% of adult worker s. Loaded wage rate is $8.79/hour.

• EPA assumes that early entry tasks take no more than 4 hours

.

• EPA cal culates the likelihood of a youth worker to participate in early entry activities to be 0.00 6

for 14

- 15 year olds and 0.00 8 for 16

- 17 year olds, given that about 27% of farm laborers are

under 25 (ERS, 2014) and assuming a near uniform distribution of ages

.

o According to USDA (ERS, 2014), 27% of farm laborers are under 25 (ERS, 2014).

Assuming a near uniform distribution of ages EPA assumes that 14

- 15 year old workers

make up 3.4 % of the workforce and 16

- 17 year old workers make up 4.5 % of the

workforce.

o EP A assumes th ere is a 4 0% chance that a WPS farm will have an early entry event each

year , or one event for every 50 applications

.

o EPA assumes that h alf the workforce will participate in an early entry event

.

o 91.3 % of workers are employed on a WPS farm that makes a pesticide application in a

given year ( Appendix A ).



## b. Final Rule

Under the final rule, tasks discussed above will have to be conducted by workers or handlers

who are at least 18 years of age, presumably at a higher wage.

Table B .4.b

- 1 . Labor Cost under Final Rule , per handler, Minimum Age (18)

Action/Material wage/price unit time/quantity annual

probability cost

( cost r, i

, a P )

Adult WPS handler, farm with

workers 20.04 50 0.022 21.57

Adult WPS handler, farm with

handlers only 20.04 50 0.019 18.95

Adult CPHE handler 23.26 640 0.013 193.54

### 37 • Loaded wages for on

- farm handlers are $20.04/hour and are $23.26/hour for CPHE handlers

(BLS, 2014b).

• Time worked is equivalent to the time spent by adolescent workers, i.e., adults are not assumed to

work more efficiently at handling tasks.

• The annual probability of an adult handler engaging in a task otherwise performed by an

adolescent is the total probability that the task is performed by an adolescent in the baseline

.



### Table B .4. b

- 2 . Labor Cost under Final Rule , per WPS worker, Minimum Age (18), Early Entry

Action/Material wage/price unit time/quantity annual

probability cost

Adult worker 14.64 4 0.014 0.84



### • Loaded wages for WPS fieldworkers are $14.64/hour (BLS, 2014b).

• Time worked is equivalent to the time spent by adolescent workers, i.e., adults are not assumed to

work more efficiently at handling tasks.

• The annual probability of an adult handler engaging in a task otherwise performed by an

adolescent is the total probability that the task is perf ormed by an adolescent in the baseline.



## B .5

. Entry

No measurable impacts anticipated. See Economic Analysis, Chapter 3, Section 3.5.



## B .6

. Personal Protective Equipment (PPE)

a. Baseline

Respirator Fit Test

EPA foresees two likely routes for a farm operator or CPHE to conduct respirator fit tests for

him/herself or employees: On

- site testing or Off

- site testing. In the former, the operator

purchases an OSHA

- approved fit testing kit and administers the test and training on the farm or

within the fi rm. In the latter, the handler travels to a central location to obtain an OSHA

approved tes t; this appears to be a common method for those required under fumigant labels to

obtain a fit test. EPA assumes that more on

- farm handlers will opt for off

- site t esting and that

most CPHEs will opt for on

- site testing.

### 38 Table B .6. a

- 1. Cost, per WPS farm handler, Off

- farm Respirator Fit

Action/Material wage/price unit

time/quantity annual

probability cost

Medical evaluation, on

- line 27.00 1 1.0 27.00

Medical evaluation, time 20.04 0.5 1.0 10.02

Follow

- up examination 72.12 1 0.25 18.03

Follow

- up examination, time 20.04 2.0 0.25 10.02

Fit test and training, fee 50.00 1 1.0 50.00

Fit test and training, time 20.04 1.5 1.0 30.06

Employer oversight 33.44 1 1.0 33.44

Expected per

- handler Cost ( cost r, i

, a B ) 178.57



### • Handler wages are $20.04/hour, including benefits (BLS, 2014b).

• On

- line medical evaluations are available for $27.00 (Affordable Safety Training, 2015).

• EPA assumes the handler will spend about 30 minutes filling out the medical evaluation.

• A follow

- up examination may be needed to ensure that a respirator can be worn safely. A

medical examination costs $72.12 and takes about two hours, including travel.

• EPA assumes that a follow

- up examination is n eeded in 25% of the cases.

• Fit tests and training fees are assumed to cost $50, ranging from $35 to $80, according to

information from state lead agencies

.

• The fit test and training takes about 90 minutes, including travel.

• The employer ’s time is valued at $33.44/hour, including wages and benefits (BLS, 2014b), and

the employer spends about one hour of time arranging the medical evaluation and fit test.



### Table B.6. a

- 2. Cost, per CPHE handler, On

- site Respirator Fit

Action/Material wage/price unit

time/quantity annual

probability cost

Medical evaluation, on

- line 27.00 1 1.0 27.00

Medical evaluation, time 23.26 0.5 1.0 11.63

Follow

- up examination 72.12 1 0.25 18.03

Follow

- up examination, time 23.26 2.0 0.25 11.63

Fit test compliance kit 130.93 1 0.25 32.73

Fit test and training, time 23.26 0.5 1.0 11.63

Employer administration 32.65 0.5 1.0 16.33

Expected per

- handler Cost ( cost r, i

, a B ) 128.98



### • Handler wages are $23.26/hour, including benefits (BLS, 2014b).

• On

- line medical evaluations are available for $27.00 (Affordable Safety Training, 2015).

• EPA assumes the handler will spend about 30 minutes filling out the medical evaluation.

• A follow

- up examination may be needed to ensure that a respirator can be worn safely. A

medical examination co sts $72.12 (citation) and takes about two hours, including travel.

• EPA assumes that a follow

- up examination is needed in 25% of the cases.

• Fit test compliance kits cost $130.93 , including shipping (Allegro Safety, 2014). They contain

s ufficient solution t o test 4 handlers.

• The fit test and training takes about 30 minutes and is administered by the employer, whose time

is valued at $32.65/hour (BLS, 2014b).

### 39 Agricultural Establishments, Respirator Fit

Table B .6.a

- 3. Baseline Cost, per WPS Farm, Respirator Fit

Action/Material wage/price unit

time/quantity annual

probability cost

WPS Farm with Handler

Employer assures proper fit 33.44 0.1 0.390 1.31

Handler assures proper fit 20.04 0.1 0.390 0.78

Respirator fit test, off

- farm 178.57 1 0.004 0.80

Expected per

- WPS handler Cost ( cost r, i

, a B ) 2.88



### • The employer’s time is valued at $33.44/hour, including wages and benefits and handler wages

are $20.04/hour, including benefits (BLS, 2014b).

• EPA assumes that agricultural e mployers and handlers spend about 6 minutes checking the fit of

a respirator together , assuming one handler per farm is trained to work with a respirator

.

• EPA calculates that 39.0 % of WPS farms will have one handler fit tested.

o Assumes that WPS farms using a pesticide that requires a respirator are concentrated in

crop

- production, not livestock operations , accounting for 71.4% of farms

.

o Assumes that 60% of farms would use such a product

.

o Assumes fit adjustment occurs when product is used (91.2% of farms with handlers use

pesticides in any given year)

.

• A respirator fit test, taken at a central location, is estimated to cost $178.57, as detailed in Table

B.6.a

- 1.

• EPA estimates that 0. 4 % of WPS farms currently obtain an OSHA

- type respirator fit test for a

handler because they handle fumig ants. EPA’s estimate is based on proprietary market survey

data on the projected number of farms reporting fumigant applications , averaged over 20 11 to

2013 , multiplied by the proportion of farms that use pesticides that also hire labor

.

o Data are reported for farmer

- applied fumigants in field crops.

o Data are reported on type of fumigant applied for tree, fruit, and vegetable crops.

 EPA assumes all chemigations are farmer

- applied.

 EPA assumes that all applications of 1,3

- D (including chloropicrin mixes)

, metam sodium, and metam potassium are farmer applied while all applications of

chloropicrin and chloropicrin mixed with methyl bromide and methyl iodide are

applied by commercial applicators.



### Agricultural Establishments, Respirator Fit, California and N orthwest

Table B.6.b

- 4. Cost under Final Rule, per farm, Respirator Fit, California and Northwest

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Respirator fit test, off

- farm 178.57 1 0.535 95.57

Large

- small WPS farm

Respirator fit test, off

- farm 178.57 1 0.135 24.05



### • California and Washington, the representative state for the Northwest region, currently require

OSHA

- style respirator fit testing for products requiring a respirator.

### 40 • A respirator fit test, taken at a central location, is estimated to cost $178.57, as detailed in Table

B.6.a

- 1.

• EPA estimates that 53.5% of large WPS farms will have a handler obtain a fit test, assuming 75 %

of large WPS farms that primarily produce crops or 40,190 large WPS fa rms out of 79,434 (Table

3.2

- 3, Economic Analysis) . This proportion is based on national

- level data and is not adjusted for

the numbers of farms in each NAICS within California and the Northwest.

• EPA estimates that 13.5% of large

- small WPS farms will have a handler obtain a fit test,

assuming 75 % of large

- small WPS farms that primarily produce nuts, fruits, and vegetable crops,

and cotton, as well as nurseries and greenhouses, or 17,673 large

- small WPS farms out of

141,753 ( Table 3.2

- 3, Economic Analysis ). This proportion is based on national

- level data and is

not adjusted for the numbers of farms in each NAICS within California and the Northwest.



### CPHEs, Respirator Fit

Table B.6.a

- 5 . Baseline Cost, per CPHE, Respirator Fit

Action/Material wage/price unit

time/quantity annual

probability cost

Fit test compliance kit 130.93 1 0.5 65.47

Replacement solution 21.69 1 1 21.69

Employer administration 32.65 3.5 1.0 114.29

Expected per

- CPHE handler Cost ( cost r, i

, a B ) 201.44



### • Most CPHEs will conduct respirator fit test under OSHA requirements

.

• A fit test compliance kit costs $130.93, including shipping, and additional or replacement solution

costs $21.69 (Allegro Safety, 2014).

• EPA assumes that the kit will last two years, thus half the CPHE s are lik ely to purchase a kit each

year

.

• EPA assumes the CPHE employer will spend about 3.5 hours per year administering the test and

training, assuming about half the firms handlers work with products requiring a respirator.



### CPHE Handlers, Respirator Fit

Table B .6 .a

- 6 . Baseline Cost, per CPHE handler, Respirator Fit

Action/Material wage/price unit

time/quantity annual

probability cost

Medical evaluation, on

- line 27.00 1 0.5 13.50

Medical evaluation, time 23.26 0.5 0.5 5.82

Follow

- up examination 72.12 1 0.13 9.02

Follow

- up examination, time 23.26 2.0 0.13 5.82

Fit test and training, time 23.26 0.5 0.5 5.82

Expected per

- CPHE handler Cost ( cost r, i

, a B ) 39.97



### • Handler wages are $23.26/hour, including benefits (BLS, 2014b).

• On

- line medical evaluations are available for $27.00 (Affordable Safety Training, 2015).

• EPA assumes the handler will spend about 30 minutes filling out the medical evaluation.

• A follow

- up examination may be needed to ensure that a respirator can be worn safely. A

medical examination co sts $72.12 (citation) and takes about two hours, including travel.

### 41 • EPA assumes that a half of CPHE handlers will receive fit tests and training to work with

pesticides requiring a respirator. Follow

- up examination is needed in 25% of these cases or

12.5% of CPHE handlers.

• The fit test and training takes about 30 minutes and is administered by the employer, whose time

captured under establishment costs.



### Agricultural Establishments, Closed Systems

Table B.6.a

- 7 . Ba seline Cost, per farm , Closed System

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Fully closed system 49.72 1 0.133 6.59

Partially closed system 22.32 1 0.199 4.44

PPE upkeep 6.93 1 0.331 2.29

Employer provides instruction 33.44 0.25 0.331 2.77

Employee receives instruction 2 0.04 0.25 0.331 1.66

Expected per

- farm Cost ( cost r, i

, a B ) 17.75

Large

- small WPS farm

Fully closed system 49.72 1 0.029 1.43

Partially closed system 22.32 1 0.043 0.96

PPE upkeep 6.93 1 0.072 0.50

Employer provides instruction 33.44 0.25 0.072 0.60

Employee receives instruction 2 0.04 0.25 0.072 0.36

Expected per

- farm Cost ( cost r, i

, a B ) 3.85

Large family farm

Fully closed system 49.72 1 0.075 3.75

Partially closed system 22.32 1 0.113 2.52

PPE upkeep 6.93 1 0.188 1.30

Operator provides instruction 33.44 0.25 0.188 1.58

2 nd Operator receives instruction 33.44 0.25 0.188 1.58

Expected per

- farm Cost ( cost r, i

, a B ) 10.72



### • A fully closed system costs $49.72/year, based on the depreciation over 10 years at 8% interest,

of equipment costs of $333.62 (Giles and Billing, 2013).

• A partially closed system, i.e. , lacking an adaptor for the pesticide container, costs $22.32/year,

based on the depreciation over 10 years at 8% interest, of equipment costs o f $149.75 (Giles and

Billing, 2013).

• PPE upkeep costs $6.93/year, based on depreciation over 5 years, of costs of $27.65 for coveralls,

overshoes, and gloves (Gempler’s, 2014).

• The time of farm employers and operators is valued at $33.44 /hour and handlers at $20.04 /hour

, including wages and benefits (BLS, 2014b).

• EPA assumes that instruction in operations take about 15 minutes and includes the employer and

one handler or, in the case of family farms, the operator and the 2 nd 

### operator.

• EPA assumes that 33.1% of large WPS farms (half the large WPS farms producing oilseeds and

grains, cotton and tobacco, fruits, nuts, and vegetables, as well as nurseries and greenhouses),

have a system; 40% of the systems, on 13.3% of farms, are fully closed and 60%, on 19.9% o f

farms, are partially closed.

### 42 • EPA assumes that 7.2% of large

- small WPS farms (40% the large

- small WPS farms producing

cotton and tobacco, fruits, nuts, and vegetables, as well as nurseries and greenhouses), have a

system; 40% of the systems, on 2.9% of fa rms, are fully closed and 60%, on 4.3% of farms, are

partially closed.

• EPA assumes that 18.8% of large family farms (one

- third of the large family farms producing

oilseeds and grains, cotton and tobacco, fruits, nuts, and vegetables, as well as nurseries a nd

greenhouses), have a system; 40% of the systems, on 7.5% of farms, are fully closed and 60%, on

11.3% of farms, are partially closed.



### CPHEs, Closed Systems

Table B.6.a

- 8 . Baseline Cost, per firm, Closed System

Action/Material wage/price unit

time/qua ntity annual

probability cost

CPHE

Fully closed system 49.72 2 0.70 69.61

Partially closed system 22.32 2 0.30 13.39

PPE upkeep 6.93 2 1.0 13.85

Employer provides instruction 32.65 0.25 1.0 8.16

Employee receives instruction 23.26 0.25 4.0 23.26

Expected per

- firm Cost ( cost r, i

, a B ) 128.27

CPHE, 1

- 2 person

Fully closed system 49.72 1 0.70 34.80

Partially closed system 22.32 1 0.30 6.70

PPE upkeep 6.93 1 1.0 6.93

Expected per

- firm Cost ( cost r, i

, a B ) 48.42



### • A fully closed system costs $49.72/year, based on the depreciation over 10 years at 8% interest,

of equipment costs of $333.62 (Giles and Billing, 2013).

• A partially closed system, i.e. , lacking an adaptor for the pesticide container, costs $22.32/year,

based on the depreciation ove r 10 years at 8% interest, of equipment costs of $149.75 (Giles and

Billing, 2013).

• PPE upkeep costs $6.93/year, based on depreciation over 5 years, of costs of $27.65 for coveralls,

overshoes, and gloves (Gempler’s, 2014).

• The time of CPHE employers and o perators is valued at $32.65/hour and handlers at $23.26/hour,

including wages and benefits (BLS, 2014b).

• EPA assumes that instruction in operations take about 15 minutes and includes the employer and

four handler s

. No instruction is needed for 1

- 2 person operations.

• EPA assumes that CPHEs have two system s ; 7 0% of the systems are fully closed and 3 0% are

partially closed.

• EPA assumes that all 1

- 2 person CPHEs have a system; 7 0% of the systems are fully closed and

3 0% are partially closed.

### 43 California, Closed Systems

Table B.6.a

- 9 . Baseline Cost, per farm, Closed System , California

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Fully closed system 49.72 1 0.331 16.47

PPE upkeep 6.93 1 0.331 2.29

Employer provides instruction 33.44 0.25 0.331 2.77

Employee receives instruction 20.04 0.25 0.331 1.66

Expected per

- farm Cost ( cost r, i

, a B ) 23.19

Large

- small WPS farm

Fully closed system 49.72 1 0.072 3.57

PPE upkeep 6.93 1 0.072 0.50

Employer provides instruction 33.44 0.25 0.072 0.60

Employee receives instruction 20.04 0.25 0.072 0.36

Expected per

- farm Cost ( cost r, i

, a B ) 5.03

Large family farm

Fully closed system 49.72 1 0.188 9.37

PPE upkeep 6.93 1 0.188 1.30

Operator provides instruction 33.44 0.25 0.188 1.58

2 nd Operator receives instruction 33.44 0.25 0.188 1.58

Expected per

- farm Cost ( cost r, i

, a B ) 13.19

CPHE

Fully closed system 49.72 2 1.0 99.44

PPE upkeep 6.93 2 1.0 13.85

Employer provides instruction 32.65 0.25 1.0 8.16

Employee receives instruction 23.26 0.25 4.0 23.26

Expected per

- firm Cost ( cost r, i

, a B ) 144.71

CPHE, 1

- 2 person

Fully closed system 49.72 1 1.0 49.72

PPE upkeep 6.93 1 1.0 6.93

Expected per

- firm Cost ( cost r, i

, a B ) 56.64



### • California requires closed systems to meet certain performance standards. Other parameters are

as provided above.

### 44 

## b. Final Rule

Agricultural Establishments, Respirator Fit

Table B.6.b

- 1. Cost under Final Rule, per farm, Respirator Fit

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Respirator fit test, off

- farm 178.57 1 0.535 95.57

Collect/Store documentation 33.44 0.067 0.535 1.19

Expected per

- farm Cost ( cost r, i

, a B ) 96.76

Large

- small WPS farm

Respirator fit test, off

- farm 178.57 1 0.135 24.05

Collect/Store documentation 33.44 0.067 0.135 0.30

Expected per

- farm Cost ( cost r, i

, a B ) 24.35

Large family farm

Medical evaluation, on

- line 27.00 1 0.226 6.10

Medical evaluation, time 33.44 0.5 0.226 3.78

Follow

- up examination 72.12 1 0.057 4.08

Follow

- up examination, time 33.44 2.0 0.057 3.78

Fit test and training, fee 50.00 1 0.226 11.30

Fit test and training, time 33.44 1.5 0.226 11.34

Collect/Store documentation 33.44 0.067 0.226 0.50

Expected per

- farm Cost ( cost r, i

, a B ) 40.89

Large

- small family farm

Medical evaluation, on

- line 27.00 1 0.023 0.62

Medical evaluation, time 33.44 0.5 0. 023 0.39

Follow

- up examination 72.12 1 0.006 0.42

Follow

- up examination, time 33.44 2.0 0.006 0.39

Fit test and training, fee 50.00 1 0.023 1.16

Fit test and training, time 33.44 1.5 0.023 1.16

Collect/Store documentation 33.44 0.067 0. 023 0.50

Expected per

- farm Cost ( cost r, i

, a B ) 4.18



### • The employer’s or operator’s time is valued at $33.44/hour, including wages and benefits and

handler wages are $20.04/hour, including benefits (BLS, 2014b).

• A respirator fit test, taken at a central location, is estimated to cost $178.57, as detailed in Table

B.6.a

- 1.

• Activities and time for respirator fit are the same for a family farm except for the oversight.

• Collecting and storing the documentation of the fit test is assumed to take 4 minutes.

• EPA estimates that 53.5% of large WPS farms will have a ha ndler obtain a fit test , assuming 75 %

of large WPS farms that primarily produce crops or 40,190 large WPS farms out of 79,434

(Appendix A).

• EPA estimates that 13.5% of large

- small WPS farms will have a handler obtain a fit test,

assuming 75 % of large

- small WPS farms that primarily produce nuts, fruits, and vegetable crops,

and cotton, as well as nurseries and greenhouses, or 17,673 large

- small WPS farms out of

141,753 (Appendix A).

### 45 • EPA estimates that 22.6% of large family farms will have an operator obtain a fit test, assuming

40 % of large family farms that primarily produce oilseeds and grains, nuts, fruits, and vegetable

crops, and cotton, as well as nurseries and greenhouses or 4,284 large family farms out of 18,949

(Appendix A).

• EPA estimates that 2.3% o f large

- small family farms will have an operator obtain a fit test,

assuming 40 % of large

- small family farms that primarily produce nuts, fruits, and vegetable

crops, and cotton, as well as nurseries and greenhouses or 6,704 large

- small family farms out of

115,950 (Appendix A).



### CPHEs, Respirator Fit

Table B.6.b

- 2. Cost under Final Rule , per CPHE, Respirator Fit

Action/Material wage/price unit

time/quantity annual

probability cost

Fit test compliance kit 130.93 1 0.5 65.47

Replacement solution 21.69 1 1 21.69

Employer administration 32.65 3.5 1.0 114.29

Expected per

- CPHE handler Cost ( cost r, i

, a B ) 201.44



### • The per

- CPHE costs are unchanged from the baseline. The recordkeeping requirement is

calculated per

- handler.



### CPHE Handlers, Respirator Fit

Table B.6.b

- 3. Cost under Final Rule , per CPHE handler, Respirator Fit

Action/Material wage/price unit

time/quantity annual

probability cost

Medical evaluation, on

- line 27.00 1 0.5 13.50

Medical evaluation, time 23.26 0.5 0.5 5.82

Follow

- up examination 72.12 1 0.13 9.02

Follow

- up examination, time 23.26 2.0 0.13 5.82

Fit test and training, time 23.26 0.5 0.5 5.82

Collect/Store documentation 32.65 0.067 0.5 1.09

Expected per

- CPHE handler Cost ( cost r, i

, a B ) 41.06



### • Per

- h andler costs are largely unchanged from the baseline.

• The time of CPHE employers is valued at $32.65/hour, including wages and benefits (BLS,

2014b).

• Collecting and storing the documentation of the fit test is assumed to take 4 minutes per handler.

### 46 Agricultural Establishments, C losed Systems

Table B.6. b

- 4 . Cost under Final Rule, per farm or firm , Closed System

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Fully closed system 49.72 1 0.331 16.47

PPE upkeep 6.93 1 0.331 2.29

Write operating instructions 33.44 2 0.066 4.43

Operating instructions 0.02 1 0.166 0.00

Employer provides instruction 33.44 0.25 0.331 2.77

Employee receives instruction 20.04 0.25 0.331 1.66

Expected per

- farm Cost ( cost r, i

, a B ) 27.63

Large

- small WPS farm

Fully closed system 49.72 1 0.072 3.57

PPE upkeep 6.93 1 0.072 0.50

Write operating instructions 33.44 2 0.014 0.96

Operating instructions 0.02 1 0.036 0.00

Employer provides instruction 33.44 0.25 0.072 0.60

Employee receives instruction 20.04 0.25 0.072 0.36

Expected per

- farm Cost ( cost r, i

, a B ) 5.99

Large family farm

Fully closed system 49.72 1 0.188 9.37

PPE upkeep 6.93 1 0.188 1.30

Write operating instructions 33.44 2 0.038 2.52

Operating instructions 0.02 1 0.094 0.00

Operator provides instruction 33.44 0.25 0.188 1.58

2 nd Operator receives instruction 33.44 0.25 0.188 1.58

Expected per

- farm Cost ( cost r, i

, a B ) 16.34

CPHE

Fully closed system 49.72 2 1.0 99.44

PPE upkeep 6.93 2 1.0 13.85

Write operating instructions 32.65 2 0.2 13.06

Operating instructions 0.02 2 0.5 0.02

Employer provides instruction 32.65 0.25 1.0 8.16

Employee receives instruction 23.26 0.25 4.0 23.26

Expected per

- firm Cost ( cost r, i

, a B ) 157.80

CPHE, 1

- 2 person

Fully closed system 49.72 1 1.0 49.72

PPE upkeep 6.93 1 1.0 6.93

Write operating instructions 32.65 2 0.2 13.06

Operating instructions 0.02 1 0.5 0.01

Expected per

- firm Cost ( cost r, i

, a B ) 69.72

### 47 

## B .7. Decontamination Supplies

a. Baseline

Decontamination Water, Workers

Employers are required to provide “sufficient” water for workers entering a field during the REI.

Guidance indicates that 1 gal is considered sufficient

.

Table B.7.a

- 1. Baseline Cost, per worker, Water for decontamination at early entry events

Action/Material wage/price unit

time/quantity annual

probability cost

Provide sufficient water (1 gal) 0.004 1 0.183 0.001

Expected per

- worker Cost ( cost r, i

, a B ) 0.00



### • EPA estimates 1 gal of water costs $0.004/gal, based on the average cost of irrigation water in

Kentucky (the state with the highest cost) of $1,258/acre

- foot (NASS, 2014 ).

• EPA estimates that there is an annual probability of 18.3% that a worker will be involved in an

early entry event (see B.3.a)

o An early event occurs about 1 in 50 applications, implying there is a 40% probability a

WPS farm applying pesticides will have an early entry event

o EPA assumes that, on average, 50% of the establishment’s workers will be involved in an

early entry event, implying 20% of the workers on WP S farm applying pesticides.

o Overall, EPA estimates that 91.3 % of workers are employed on WPS farms that apply

pesticides in any given year ( Appendix A ), resulting in a 18.3% chance a WPS worker

being involved in an early entry event.



### Eyeflush, WPS Handler s

Table B.7.a

- 2. Baseline Cost, per WPS farm, Eyewash

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Eyewash bottle 3.65 1 0.211 0.77

Water 0.004 0.125 3.10 0.00

Expected per

- farm Cost ( cost r, i

, a B ) 0.77

Large

- Small WPS farm

Eyewash bottle 3.65 1 0.159 0.58

Water 0.004 0.125 1.15 0.00

Expected per

- farm Cost ( cost r, i

, a B ) 0 .58



### • A pint bottle, with squirt top, cost s $3.65 at Gempler’s supply (2014).

• Water costs $0.004 per gallon, based on the average cost of irrigation water in Kentucky (the state

with the highest cost) of $1,258/acre

- foot (NASS, 2014).

• One bottle is needed per farm, given relatively low frequency that products requiring eye

protection are used.

• EPA calculates that 21.1% of lar ge WPS farms will purchase a bottle annually.

### 48 o EPA estimates that 84.4% of large WPS farms will use a product requiring eye protection

at some point, based on the proportion of large WPS farms primarily producing oilseeds

and grains, fruits and vegetables, cotton and tobacco, and cattle , sheep, goats, and hogs

, as well as nurseries and greenhouses

, i.e. , 67,077 out of 79,434 (Appendix A).

o EPA assumes that a bottle lasts about 4 years, implying one

- fourth of farms replace a

bottle each year.

• EPA calculates th at 15.9% of large

- small farms will purchase a bottle annually.

o EPA estimates that 63.4% of large

- small WPS farms will use a product requiring eye

protection at some point, based on the proportion of large WPS farms primarily

producing oilseeds and grains, fruits and vegetables, and cotton and tobacco, as well as

nurseries and greenhouses

, i.e. , 89,881 out of 141,753 (Appendix A).

o EPA assumes that a bottle lasts about 4 years, implying one

- fourth of farms replace a

bottle each year.

• EPA calculates that a pint of water (0.125 gal) is needed, on average, on 3.10 occasions/year per

large WPS farm and 1.15 occasions/year per large

- small WPS farm.

o Large farms have 4 occasions and 91.8% of large farms use pesticides in a given year

(Appendi x A).

o Large

- small farms have 2 occasions and 90.5% of large

- small farms use pesticides in a

given year (Appendix A).



### Eyeflush, CPHE Handlers

Table B.7.a

- 3. Baseline Cost, per CPHE handler, Eyewash

Action/Material wage/price unit

time/quantity annual

pro bability cost

Eyewash bottle 3.65 1 0.250 0.91

Water 0.004 0.125 36 0.02

Exp ected per

- handler Cost ( cost r, i

, a B ) 0.93



### • A pint bottle, with squirt top, cost s $3.65 at Gempler’s supply (2014).

• Water costs $0.004 per gallon, based on the average cost of irrigation water in Kentucky (the state

with the highest cost) of $1,258/acre

- foot (NASS, 2014).

• One bottle is needed per handler and a bottle lasts about 4 years

.

• EPA calculates that a pint of water (0.125 gal) is needed, on average, on 3 6 occasions/ye ar per

handler, assuming that 40% of applications made by a CPHE handler are of products requiring

protective eyewear and a CPHE handler makes 90 applications/year, on average.



## b. Final Rule

Decontamination Water, Workers

Employers are required to provide 3 gallons of water for workers entering a field during the REI

.

### 49 Table B.7.b

- 1. Cost under Final Rule, per worker, Water for decontamination at early entry

events

Action/Material wage/price unit

time/quantity annual

proba bility cost

Provide sufficient water (1 gal) 0.004 3 0.183 0.002

Expected per

- worker Cost ( cost r, i

, a B ) 0.00



### • Employers must provide 3 gallons of water per worker at each early entry event

.

• Prices and annual probability are as in baseline (see Table B. 7 .a

- 1 )

.



### Eyeflush, WPS Handlers

Table B.7.b

- 2. Cost under Final Rule , per WPS farm, Eyewash

Action/Material wage/price unit

time/quantity annual

probability cost

Large WPS farm

Water container/dispenser 20.65 1 0.106 2.18

Eyewash bottle 3.65 1 0.211 0.77

Water 0.004 6 3.10 0.07

Expected per

- farm Cost ( cost r, i

, a B ) 3.02

Large

- Small WPS farm

Water container/dispenser 20.65 1 0.063 1.31

Eyewash bottle 3.65 1 0.159 0.58

Water 0.004 6 1.15 0.03

Expected per

- farm Cost ( cost r, i

, a B ) 1.91



### • A 5

- gallon container , with a valve for controlling the flow of water , cost s $ 20. 65 at Gempler’s

supply (2014).

• A large farm is assumed to purchase a container every eight years; given the proportion of farms

using products requiring protective eyewear, 84.4% (see Table B.7.a

- 2) , 10.6% of large farms are

expected to purchase a container each year.

• A large

- small farm is assumed to purchase a container every ten years; given the proportion of

farms using products requiring protective eyewear, 63.4% (see Table B.7.a

- 2), 6.3% of large

small farms are expected to purchase a container each year.

• Farms will need to provide 6 gallons of water for eyeflush.

• All other parameters are as in the baseline (see Table B.7.a

- 2).

### 50 Eyeflush, CPHE Handlers

Table B.7.b

- 3. Cost under Final Rule , per CPHE handler, Eyewash

Action/Material wage/price unit

time/quantity annual

probability cost

Water container/dispenser 20.65 1 0.1 2.07

Eyewash bottle 3.65 1 0.250 0.91

Water 0.004 6 36 0.83

Exp ected per

- handler Cost ( cost r, i

, a B ) 3.81



### • A 5

- gallon container , with a valve for controlling the flow of water , cost s $ 20. 65 at Gempler’s

supply (2014).

• EPA calculates that one container is purchased annually for every 10 handlers.

o EPA assumes one container can be shared between two handlers.

o EPA assumes that a container lasts five years.

• The handler will need to be provided 6 gallons of water for each application requiring protective

eyewear.

• All other parameters are as in the baseline (Table B.7.a

- 3).