*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

RIN2070-AJ22_EO12866_AgWPS_NPRM_EA-Appendix A_2013-09-12.docx 

Draft document as submitted for review under EO 12866. 

Page 1 of 148

ECONOMIC ANALYSIS OF 

PROPOSED REVISIONS TO THE WORKER PROTECTION 

STANDARD 

APPENDIX A 

Cost Estimation, Potential Regulations 

A.1. Training 

a. Worker Training (TRAIN-01, 02, 03, 04, 05, 06, 07) 

Baseline

Step 1. Calculate Baseline Costs, Farm 

 Four categories of trainers eligible to conduct worker safety training with differing costs 

(wage, from BLS (2008)): 

o trainers of handlers and certified applicators ($37.87/hr); 

o individuals who have completed a train the trainer program ($37.87/hr); 

o certified applicators ($28.21/hr); and 

o handlers ($20.83/hr). 

 EPA assumes training typically last 30 minutes, based on the length of training videos. 

 The annual frequency that a training is led by a certain category of trainer is a function of 

the proportion of trainings led by different categories and the total number of trainings 

per year. Based on conversations with state officials, certified applicators (frequently the 

agricultural employer) lead most training sessions while pesticide handlers (who lack 

certification) rarely conduct sessions. EPA assumes trainings are distributed among the 

groups: 

o trainers of handlers and certified applicators (14%); 

o individuals who have completed a train the trainer program (10%); 

o certified applicators (75%); and 

o handlers (1%). 

 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 data on the 

number of farm workers and farms hiring labor (NASS, 2008): 

o Large WPS farms (more than $750,000 in revenue/year) with more than 10 

employees hold an average of 4.5 training sessions per year. These farms include 

fruit, nut, and vegetable farms, nurseries, and greenhouses and average about 57 

workers/farm. Many workers will be temporary, hired for peak activities like 

thinning and harvesting and sessions will be conducted throughout the year. 

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

sessions per year. These farms primarily cultivate field crops such as grains,
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 2 of 148

oilseed, and cotton with more permanent workers and average about 5 

workers/farm. 

o Small WPS farms with more than 10 employees hold an average of 2.2 training 

sessions per year. Again, these farms include fruit, nut, and vegetable farms, 

nurseries, and greenhouses with an average of nearly 15 workers/farm, many of 

whom are temporary workers; sessions will be conducted throughout the year. 

o Small WPS farms with fewer than 10 employees hold an average of 0.71 training 

sessions per year (weighted average of 0.725 trainings/year by large-small farms 

and medium-small farms employing an average of 3.2 workers and 0.65 

trainings/year by small-small farms with 2.5 workers/farm). These farms 

primarily cultivate field crops such as grains, oilseed, and cotton or are very small 

fruit, nut, and vegetable farms, nurseries, and greenhouses (those with less than 

$100,000 in revenue/year) with an average of 3.0 workers/farm. 

Table A.1.a-1. Baseline Cost, per WPS farm, by size, Worker Training 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Large WPS farm, ≥ 10 workers 

Training by Handler Trainer 37.87 0.5 0.630 11.93

Training by Train-the-Trainer 37.87 0.5 0.450 8.52

Training by Certified Applicator 28.21 0.5 3.375 47.61

Training by WPS Handler 20.83 0.5 0.045 0.47

Expected per-farm Cost (costr,i,a

B

) 4.50 68.53

Large WPS farm, < 10 workers 

Training by Handler Trainer 37.87 0.5 0.126 2.39

Training by Train-the-Trainer 37.87 0.5 0.090 1.70

Training by Certified Applicator 28.21 0.5 0.675 9.52

Training by WPS Handler 20.83 0.5 0.009 0.09

Expected per-farm Cost (costr,i,a

B

) 0.90 13.71

Small WPS farm, ≥ 10 workers 

Training by Handler Trainer 37.87 0.5 0.308 5.83

Training by Train-the-Trainer 37.87 0.5 0.220 4.17

Training by Certified Applicator 28.21 0.5 1.650 23.28

Training by WPS Handler 20.83 0.5 0.022 0.23

Expected per-farm Cost (costr,i,a

B

) 2.20 33.50

Small WPS farm, < 10 workers 

Training by Handler Trainer 37.87 0.5 0.099 1.87

Training by Train-the-Trainer 37.87 0.5 0.071 1.34

Training by Certified Applicator 28.21 0.5 0.530 7.47

Training by WPS Handler 20.83 0.5 0.007 0.07

Expected per-farm Cost (costr,i,a

B

) 0.71 10.76

 

 For simplicity, EPA calculates the weighted average across all WPS farms and obtains 

and average of one training per year. The more detailed baseline is used to compare 

options for annual training (TRAIN-03 and 05) and for evaluating the total incremental 

cost (Appendix B). Table A.1.a-2 presents the simplified estimation of the cost per WPS 

farm. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 3 of 148

Table A.1.a-2. Baseline Cost, per WPS farm, Worker Training 

Action/Material 

wage/price 

 (aݓ)

unit 

time/quantity 

௝,a,௜,௥ܪ)

஻) 

annual 

frequency 

(Prob௧ሺ݆|݅ሻ) cost 

Training by Handler Trainer 37.87 0.5 0.14 2.65

Training by Train-the-Trainer 37.87 0.5 0.10 1.89

Training by Cert. Applicator 28.21 0.5 0.75 10.58

Training by WPS Handler 20.83 0.5 0.01 0.10

Expected per-farm Cost (costr,i,farm

B

) 15.23

Step 1. Calculate Baseline Costs, Worker

 Worker wages, including 30% for benefits, are $13.43/hr (BLS, 2008). 

 Workers trained each year account for 48.9% of the total workforce. 

o Excludes workers employed less than five days, which EPA calculates to be less 

than 1.4% of total workforce, assuming 5% of part-time employees are employed 

less than five days; part-time employees are estimated to be 27.5% of total 

workforce (NASS, 2007 and 2008a). 

o Includes 15.8% of total workforce who are new hires employed more than five 

days – based on a 16% new hire rate (DOL, 2005) out of remaining 98.6% of 

workforce. 

o Includes 33.1% of total workforce who are returning workers – based on 40% 

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

training cannot be verified) out of remaining 82.8% of total workforce. 

 EPA assumes an abbreviated training takes 3 minutes. 

 Workers taking an abbreviated training account for 5.3% of total workforce 

o Includes workers employed less than five days (less than 1.4%, as above) 

o Includes less than 4.0% of total workforce who are new hires receiving 

abbreviated training prior to full training – based on 25% of new hires employed 

more than five days (15.8% of total workforce, as above). 

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

time is valued at $28.21/hr, including benefits (BLS, 2008). 

Table A.1.a-3. Baseline Cost, per worker, Worker Training 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Full training session 13.43 0.5 0.489 3.28 

Abbreviated training session 13.43 0.05 0.053 0.04 

Trainer, abbreviated session 28.21 0.05 0.053 0.08 

Expected per-worker Cost (costr,i,workr

B

) 3.40 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 4 of 148

New Regulations

TRAIN-01. Require Full Training prior to workers entering treated areas. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Per-farm parameters are as in the baseline (Table A.1.a-2), except for the probability of 

conducting a training. 

 EPA assumes that, on average, each WPS farm will conduct 1.5 trainings per year, 

because farms will not be allowed to delay training of new hires until other workers who 

need training can be assembled. 

 Trainings are distributed across training groups as in baseline. 

Table A.1.a-4. Potential Cost, per WPS farm, Require Full Training prior to use of pesticides 

(TRAIN-01) 

Action/Material wage/price 

unit 

time/quantity 

annual 

frequency cost 

Training by Handler Trainer 37.87 0.5 0.210 3.98

Training by Train-the-Trainer 37.87 0.5 0.150 2.84

Training by Cert. Applicator 28.21 0.5 1.125 15.87

Training by WPS Handler 20.83 0.5 0.015 0.16

Expected per-farm cost (costr,i,a

P

) 1.5 22.84

 

 Worker wages are as in the baseline. 

 Workers trained each year will account 49.6% of total workforce 

o New hires – 16% of workforce (DOL, 2005) 

o Returning workers (remaining 84% of workforce) whose training has expired 

after 5 years (around 20%) or whose training cannot be verified (another 20%), 

i.e., 33.6% of workforce. 

 In the first year, trainees will account for 50.8% of total workforce 

o Includes returning workers who have worked less than five days per year in the 

past and have received only a summary training. EPA calculates that this group 

accounts for 1.2% of total workforce, i.e., 5% of part-time employees, who are 

27.5% of total workforce (NASS, 2007 and 2008a), of whom 16% are new hires. 

Table A.1.a-5. Potential Cost, per worker, Require Full Training prior to use of pesticides 

(TRAIN-01) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability 

cost 

(costr,i,a

P

)

Full training session (YR 1) 13.43 0.5 0.508 3.41 

Full training session (YR 2+) 13.43 0.5 0.496 3.33 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Table A.1.a-6. Regional Costs, Year 1, Require Full Training prior to use of pesticides (TRAIN01) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

(costr,i,a

B

) $ 15.23 $ 3.40 

(costr,i,a

P

) $ 22.84 $ 3.41 

South 58,804 274,068 1,826,019 2,277,657

California 24,469 394,844 1,713,170 1,904,875

Southwest 12,629 78,969 460,435 557,702

Subtropical 9,866 111,485 528,760 605,419

Midwest 85,641 299,617 2,321,458 2,977,876

Northeast 40,650 278,713 1,565,317 1,878,724

Ohio Valley 91,166 353,037 2,586,968 3,286,194

Texas/Mountain West 48,543 185,809 1,370,103 1,742,389

Northwest 22,890 346,069 1,523,534 1,702,557

US 394,658 2,322,610 $13,895,763 $16,933,393

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Calculating the present value (PV) of the baseline and potential cost streams follows the 

methodology presented in Chapter 3.3.1 of the Economic Analysis. In this case, we consider two 

factors that change over time. First, under the potential regulation, the per-worker cost declines 

to $3.33 in Years 2 through 10. Second, the number of farms in the U.S. is declining at a rate of 

0.47% per year and the number of farm workers is declining at 2.14% per year. 

Table A.1.a-7. Regional Costs, PV (3% discount rate) and Incremental Cost, Require Full 

Training prior to use of pesticides (TRAIN-01) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 18,920 15,183 3,737

California 15,403 13,972 1,431

Southwest 4,603 3,809 794

Subtropical 4,931 4,333 598

Midwest 24,886 19,400 5,486

Northeast 15,472 12,929 2,544

Ohio Valley 27,405 21,580 5,825

Texas/Mountain West 14,534 11,432 3,103

Northwest 13,784 12,435 1,349

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.a-8. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Require Full Training prior to use of pesticides (TRAIN-01) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 139,939 115,073 24,866

2,830 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 7.17
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Page 6 of 148

Table A.1.a-7a. Regional Costs, PV (7% discount rate) and Incremental Cost, Require Full 

Training prior to use of pesticides (TRAIN-01) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 16,243 13,039 3,203

California 13,246 12,017 1,229

Southwest 3,953 3,272 681

Subtropical 4,238 3,725 513

Midwest 21,357 16,654 4,702

Northeast 13,290 11,109 2,181

Ohio Valley 23,522 18,529 4,993

Texas/Mountain West 12,474 9,815 2,659

Northwest 11,853 10,694 1,158

 

Table A.1.a-7a. National and Per-WPS Farm Costs, PV and Annualized (7% discount rate), 

Require Full Training prior to use of pesticides (TRAIN-01) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 120,176 98,855 21,321

2,837 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 7.19

 

TRAIN-02. Full Training prior to pesticide use w/ Exception/Right-to-Know. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Per-farm parameters are as in the baseline, except for the probability of conducting a 

training. 

 EPA assumes that, on average, each WPS farm will conduct 1.3 trainings per year, given 

the shorter period before training is required. 

 Trainings are distributed across trainer categories as in baseline. 

Table A.1.a-8. Potential Cost, per WPS farm, Full Training prior to pesticide use w/ 

Exception/Right-to-Know (TRAIN-02) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Training by Handler Trainer $37.87 0.5 0.182 $3.45 

Training by Train-the-Trainer $37.87 0.5 0.130 $2.46 

Training by Cert. Applicator $28.21 0.5 0.975 $13.75 

Training by WPS Handler $20.83 0.5 0.013 $0.14 

Expected per-farm Cost (costr,i,a

P

) 1.300 19.80

 Worker wages are as in the baseline. 

 EPA assumes it will take 10 minutes to provide hazard information. 

 Workers trained each year will account 49.2% of total workforce 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 7 of 148

o Excludes workers employed 2 days or less, which EPA assumes account for under 

0.83% of total workforce, i.e., 3% of part-time employees, who are 27.5% of total 

workforce (NASS, 2007 and 2008a). 

o Includes 15.9% of total workforce who are new hires – based on a 16% new hire 

rate (DOL, 2005) out of remaining 99.2% of workforce 

o Includes 33.3% of total workforce who are returning workers (remaining 83.3% 

of total workforce) whose training has expired after 5 years (assumed to be 20%) 

or whose training cannot be verified (assumed to be another 20%). 

 Workers obtaining hazard information under exception account for 4.8% of total 

workforce 

o Workers employed two days or less (0.83%). 

o Additional 3.975% of workforce. EPA assumes 25% of other new hires, who are 

15.9% of total workforce, receive hazard information prior to full training. 

 Hazard information is provided individually to each worker by the owner/operator whose 

time is valued at $28.21/hr, including benefits (BLS, 2008). 

Table A.1.a-9. Potential Cost, per worker, Full Training prior to pesticide use w/ 

Exception/Right-to-Know (TRAIN-02) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Full training session 13.43 0.5 0.492 3.3

Receive Safety Information 13.43 0.167 0.048 0.11

Provide Safety Information 28.21 0.167 0.048 0.23

Written Information 0.09 1 0.048 0.004

Expected per-worker Cost (costr,i,a

P

) 3.64

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.1.a-10. Regional Costs, Year 1, Full Training prior to pesticide use w/ Exception/Rightto-Know (TRAIN-02) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 15.23 $ 3.40 

costr,i,a

P $ 19.80 $ 3.64 

South 58,804 274,068 1,826,019 2,161,789

California 24,469 394,844 1,713,170 1,921,646

Southwest 12,629 78,969 460,435 537,471

Subtropical 9,866 111,485 528,760 601,137

Midwest 85,641 299,617 2,321,458 2,786,094

Northeast 40,650 278,713 1,565,317 1,819,283

Ohio Valley 91,166 353,037 2,586,968 3,089,928

Texas/Mountain West 48,543 185,809 1,370,103 1,637,381

Northwest 22,890 346,069 1,523,534 1,712,854

US 394,658 2,322,610 $13,895,763 $16,267,583
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 8 of 148

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Calculating the present value (PV) of the baseline and potential cost streams follows the 

methodology presented in Chapter 3.3.1 of the Economic Analysis. This accounts for the fact 

that the number of farms in the U.S. is declining at 0.47% per year and the number of farm 

workers is declining at 2.14% per year. 

Table A.1.a-11. Regional Costs, PV (3% discount rate) and Incremental Cost, Full Training 

prior to pesticide use w/ Exception/Right-to-Know (TRAIN-02) 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 18,036 15,183 2,853

California 15,711 13,972 1,739

Southwest 4,461 3,809 652

Subtropical 4,940 4,333 607

Midwest 23,358 19,400 3,959

Northeast 15,076 12,929 2,147

Ohio Valley 25,862 21,580 4,281

Texas/Mountain West 13,707 11,432 2,275

Northwest 14,016 12,435 1,581

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.a-12. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), Full 

Training prior to pesticide use w/ Exception/Right-to-Know (TRAIN-02) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 135,168 115,073 20,095

2,287 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 5.80

TRAIN-03. Annual training of workers. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes that, on average, a WPS farm conducts 1.5 trainings per year because all 

workers need to be trained and some farms will not be able to schedule all workers for 

training at the same time. 

o EPA assumes that, on average, a large WPS farm with ten or more workers 

conducts 6.25 training sessions per year, as under TRAIN-03 (a 38.9% increase 

over baseline). 

o EPA assumes that, on average, a large WPS farm with fewer than 10 workers 

conducts 1.3 training sessions per year (44.4% increase over baseline). 

o EPA assumes that, on average, a small WPS farm with ten or more workers 

conducts 3.1 training sessions per year (40.9% increase over baseline). 

o EPA assumes that, on average, a small WPS farm with fewer than 10 workers 

conducts 1.1 training sessions per year (56.1% increase over baseline). 

 Trainings are distributed across training groups as in baseline. 

 On average, per-farm costs are equivalent to TRAIN-01, Require Full Training prior to 

use of pesticides. See Table A.1.a-4. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 9 of 148

Table A.1.a-13. Potential Cost, per WPS farm, Annual Worker Training 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Large WPS farm, ≥ 10 workers 

Training by Handler Trainer 37.87 0.5 0.875 16.57

Training by Train-the-Trainer 37.87 0.5 0.625 11.83

Training by Certified Applicator 28.21 0.5 4.688 66.13

Training by WPS Handler 20.83 0.5 0.063 0.65

Expected per-farm Cost (costr,i,a

B

) 6.25 95.18

Large WPS farm, < 10 workers 

Training by Handler Trainer 37.87 0.5 0.182 3.45

Training by Train-the-Trainer 37.87 0.5 0.130 2.46

Training by Certified Applicator 28.21 0.5 0.975 13.75

Training by WPS Handler 20.83 0.5 0.013 0.14

Expected per-farm Cost (costr,i,a

B

) 1.30 19.80

Small WPS farm, ≥ 10 workers 

Training by Handler Trainer 37.87 0.5 0.434 8.22

Training by Train-the-Trainer 37.87 0.5 0.310 5.87

Training by Certified Applicator 28.21 0.5 2.325 32.80

Training by WPS Handler 20.83 0.5 0.031 0.32

Expected per-farm Cost (costr,i,a

B

) 3.10 47.21

Small WPS farm, < 10 workers 

Training by Handler Trainer 37.87 0.5 0.154 2.92

Training by Train-the-Trainer 37.87 0.5 0.110 2.09

Training by Certified Applicator 28.21 0.5 0.827 11.67

Training by WPS Handler 20.83 0.5 0.011 0.11

Expected per-farm Cost (costr,i,a

B

) 1.10 16.79

 Trainees account for 89.8% of the total workforce. 

o Excludes workers employed less than five days, which EPA assumes account for 

under 1.4% of total workforce, i.e., 5% of part-time employees, who are 27.5% of 

total workforce (NASS, 2007 and 2008a). 

o Excludes returning handlers, approximately 10.7% of work force, whose handler 

training meets WPS standards for worker training. 

 Abbreviated trainings occur as in the baseline 

Table A.1.a-14. Potential Cost, per worker, Annual training of workers (TRAIN-03) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Full training session 13.43 0.50 0.898 6.03 

Abbreviated training session 13.43 0.05 0.053 0.04 

Trainer, abbreviated session 28.21 0.05 0.053 0.08 

Expected per-worker Cost (costr,i,a

P

) 6.14 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 10 of 148

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.1.a-15. Regional Costs, Year 1, Annual Worker Training 

Region (large WPS Farm) 

N lrg farm ≥ 10 

wrkrs

N lrg farm < 10 

wrkrs N workers

RC B

($) 

RC P

($) 

costr,i,a

B $ 68.53 $ 13.71 $ 3.40 

costr,i,a

P $ 95.18 $ 19.80 $ 6.14 

South 3,311 4,778 127,926 726,733 1,195,069

California 1,378 1,988 184,301 747,393 1,301,876

Southwest 711 1,026 36,860 187,943 314,277

Subtropical 556 802 52,038 225,736 388,198

Midwest 4,822 6,958 139,852 900,670 1,455,281

Northeast 2,289 3,303 130,095 643,820 1,081,874

Ohio Valley 5,134 7,407 164,786 1,012,801 1,646,851

Texas/Mountain West 2,733 3,944 86,730 535,842 870,671

Northwest 1,289 1,860 161,534 662,248 1,151,119

US 22,224 32,066 1,084,121 $5,643,187 $9,405,217

Region (Small WPS farm) 

N sml farm ≥ 10 

wrkrs

N sml farm < 10 

wrkrs N workers

RC B

($) 

RC P

($) 

costr,i,a

B $ 33.50 $ 10.76 $ 3.40 

costr,i,a

P $ 47.21 $ 16.79 $ 6.14 

South 2,699 48,016 146,142 1,103,146 1,830,845

California 1,123 19,980 210,543 967,384 1,680,995

Southwest 580 10,312 42,109 273,321 459,024

Subtropical 453 8,056 59,447 303,672 521,596

Midwest 3,931 69,929 159,765 1,426,410 2,340,603

Northeast 1,866 33,192 148,619 924,166 1,557,787

Ohio Valley 4,185 74,441 188,250 1,580,152 2,603,198

Texas/Mountain West 2,228 39,637 99,079 837,448 1,379,009

Northwest 1,051 18,691 184,535 862,788 1,496,271

US 18,116 322,254 1,238,489 $8,278,487 $13,869,328

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.1.a-16. Regional Costs, PV (3% discount rate) and Incremental Cost, Annual Worker 

Training 

Region (Large WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 9,834 6,005 3,829

California 10,552 6,072 4,480

Southwest 2,575 1,546 1,029

Subtropical 3,157 1,841 1,316

Midwest 12,032 7,480 4,553
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 11 of 148

Northeast 8,851 5,287 3,564

Ohio Valley 13,593 8,396 5,197

Texas/Mountain West 7,188 4,443 2,745

Northwest 9,335 5,383 3,952

Region (Small WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 15,244 9,211 6,033

California 13,723 7,914 5,809

Southwest 3,802 2,270 1,532

Subtropical 4,279 2,498 1,782

Midwest 19,586 11,968 7,618

Northeast 12,884 7,665 5,219

Ohio Valley 21,745 13,236 8,509

Texas/Mountain West 11,522 7,016 4,505

Northwest 12,225 7,065 5,160

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.a-17. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Annual training of workers (TRAIN-03) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Farm, Large 77,116 46,453 30,664

WPS Farm, Small 115,010 68,843 46,167

US 192,116 115,296 76,831

8,745 (௥ܥܫܣ) Annualized

per-entity ($/large WPS farm) 64.29

per-entity ($/small WPS farm) 15.44

TRAIN-04. Biennial training of workers. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes that, on average, a WPS farm conducts 1.3 trainings per year to account for 

the larger number of workers to be trained. 

 Trainings are distributed across training groups as in baseline (Table A.1.a-2). 

 See Table A.1.a-8: Potential Cost, per WPS farm, Full Training prior to pesticide use w/ 

Exception/Right-to-Know (TRAIN-02) 

 Trainees account for 59.0% of the total workforce. 

o Excludes workers employed less than five days, which EPA assumes account for 

under 1.4% of total workforce, i.e., 5% of part-time employees, who are 27.5% of 

total workforce (NASS, 2007 and 2008a); 

o Includes new hires, i.e., 16% of remaining workforce or 15.8% of workers 

o Includes 55% of the remaining workforce returning from the previous year 

(46.2%), less 25% of returning handlers who are covered by handler training 

(2.9%), or 43.3% of total workforce 

 Abbreviated trainings occur as in the baseline 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 12 of 148

Table A.1.a-18. Potential Cost, per worker, Biennial training of workers (TRAIN-04) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Full training session 13.43 0.50 0.590 3.96

Abbreviated training session 13.43 0.05 0.053 0.04

Trainer, abbreviated session 28.21 0.05 0.053 0.08

Expected per-worker Cost (costr,i,a

P

) 4.08

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.1.a-19. Regional Costs, Year 1, Biennial training of workers (TRAIN-04) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 15.23 $ 3.40 

costr,i,a

P $ 19.80 $ 4.08 

South 58,804 274,068 1,826,019 2,281,125

California 24,469 394,844 1,713,170 2,093,571

Southwest 12,629 78,969 460,435 571,856

Subtropical 9,866 111,485 528,760 649,680

Midwest 85,641 299,617 2,321,458 2,916,554

Northeast 40,650 278,713 1,565,317 1,940,641

Ohio Valley 91,166 353,037 2,586,968 3,243,649

Texas/Mountain West 48,543 185,809 1,370,103 1,718,287

Northwest 22,890 346,069 1,523,534 1,863,541

US 394,658 2,322,610 $13,895,763 $17,278,903

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.1.a-20. Regional Costs, PV (3% discount rate) and Incremental Cost, Biennial training 

of workers (TRAIN-04) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000)

South 18,994 15,183 3,811

California 17,091 13,972 3,119

Southwest 4,737 3,809 928

Subtropical 5,330 4,333 997

Midwest 24,406 19,400 5,006

Northeast 16,051 12,929 3,122

Ohio Valley 27,096 21,580 5,515

Texas/Mountain West 14,357 11,432 2,925

Northwest 15,226 12,435 2,791
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.a-21. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Biennial training of workers (TRAIN-04) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 143,287 115,073 28,215

3,211 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 8.14

TRAIN-05. Annual Training of Workers, Small Farm Exception. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Provision would require annual training except for farms with fewer than 10 workers, if 

there were no new employees and the same pesticides were used on the farm as in years 

with training. 

 EPA assumes that, on average, a WPS farm conducts 1.4 trainings per year, compared to 

1.5 trainings in the annual training without exceptions (TRAIN-03). Trainings are 

distributed across trainer categories as in baseline. 

o EPA assumes that, on average, a large WPS farm with ten or more workers 

conducts 6.25 training sessions per year, as under TRAIN-03. 

o EPA assumes that, on average, a large WPS farm with fewer than 10 workers 

conducts 1.15 training sessions per year (27.8% increase over baseline), compared 

to 1.3 sessions per year without the exception (44.4% increase over baseline). 

o EPA assumes that, on average, a small WPS farm with ten or more workers 

conducts 3.1 training sessions per year, as under TRAIN-03. 

o EPA assumes that, on average, a small WPS farm with fewer than 10 workers 

conducts 0.99 training sessions per year (40.7% increase over baseline), compared 

to 1.10 sessions per year without the exception (56.1% increase over baseline). 

Table A.1.a-22. Potential Cost, per WPS farm, Annual Worker Training, Small Farm Exception 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Large WPS farm, ≥ 10 workers 

Training by Handler Trainer 37.87 0.5 0.875 16.57

Training by Train-the-Trainer 37.87 0.5 0.625 11.83

Training by Certified Applicator 28.21 0.5 4.688 66.13

Training by WPS Handler 20.83 0.5 0.063 0.65

Expected per-farm Cost (costr,i,a

P

) 6.25 95.18

Large WPS farm, < 10 workers 

Training by Handler Trainer 37.87 0.5 0.161 3.05

Training by Train-the-Trainer 37.87 0.5 0.115 2.18

Training by Certified Applicator 28.21 0.5 0.863 12.17

Training by WPS Handler 20.83 0.5 0.012 0.12

Expected per-farm Cost (costr,i,a

P

) 1.15 17.51
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 14 of 148

Small WPS farm, ≥ 10 workers 

Training by Handler Trainer 37.87 0.5 0.434 8.22

Training by Train-the-Trainer 37.87 0.5 0.310 5.87

Training by Certified Applicator 28.21 0.5 2.325 32.80

Training by WPS Handler 20.83 0.5 0.031 0.32

Expected per-farm Cost (costr,i,a

P

) 3.10 47.21

Small WPS farm, < 10 workers 

Training by Handler Trainer 37.87 0.5 0.139 2.64

Training by Train-the-Trainer 37.87 0.5 0.099 1.88

Training by Certified Applicator 28.21 0.5 0.746 10.52

Training by WPS Handler 20.83 0.5 0.010 0.10

Expected per-farm Cost (costr,i,a

P

) 0.99 15.14

 There is an overall reduction of 4.9% in the number of workers trained each year 

compared to TRAIN-03. 

o Large farms with less than 10 workers hold 11.5% fewer trainings compared to 

TRAIN-03 equivalent to 11.5% fewer workers trained on such farms. This 

implies about 1.8% decrease in workers on all large WPS farms who are trained, 

i.e., 89.8% (from TRAIN-03) times 98.2% of workers or 88.2% of workers on 

large farms will be trained annually. 

o Small farms with less than 10 workers hold 9.7% fewer trainings compared to 

TRAIN-03, thus 9.7% fewer workers trained on such farms. This implies about 

7.6% decrease in workers on all small WPS farms who are trained, i.e., 89.8% 

times 92.4% of workers or 82.8% of workers on small farms will be trained 

annually. 

 Abbreviated trainings occur as in the baseline. 

Table A.1.a-23. Potential Cost, per worker, Annual Worker Training, Small Farm Exception 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Worker, Large WPS farm 

Full training session 13.43 0.5 0.882 5.92

Abbreviated training session 13.43 0.05 0.053 0.04

Trainer, abbreviated session 28.21 0.05 0.053 0.08

Expected per-worker Cost (costr,i,a

P

) 6.03

Worker, Small WPS farm 

Full training session 13.43 0.5 0.828 5.56

Abbreviated training session 13.43 0.05 0.053 0.04

Trainer, abbreviated session 28.21 0.05 0.053 0.08

Expected per-worker Cost (costr,i,a

P

) 5.67

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers; there are 54,289 large farms 

employing 1,084,121 workers and 340,369 small farms employing 1,238,489 workers (NASS, 

2008). WPS farms, defined as those hiring labor, are distributed across regions in the same 

proportion as all farms. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 15 of 148

Table A.1.a-24. Regional Costs, Year 1, Annual Handler Training 

Region (large WPS Farm) 

N lrg farm ≥ 10 

wrkrs

N lrg farm < 10 

wrkrs N workers

RC B

($) 

RC P

($) 

costr,i,a

B $ 68.53 $ 13.71 $ 3.40 

costr,i,a

P $ 95.18 $ 17.51 $ 6.03 

South 3,311 4,778 127,926 726,733 1,170,259

California 1,378 1,988 184,301 747,393 1,277,316

Southwest 711 1,026 36,860 187,943 307,929

Subtropical 556 802 52,038 225,736 380,715

Midwest 4,822 6,958 139,852 900,670 1,424,196

Northeast 2,289 3,303 130,095 643,820 1,060,199

Ohio Valley 5,134 7,407 164,786 1,012,801 1,612,031

Texas/Mountain West 2,733 3,944 86,730 535,842 852,241

Northwest 1,289 1,860 161,534 662,248 1,129,324

US 22,224 32,066 1,084,121 $5,643,187 $9,214,210

Region (Small WPS farm) 

N sml farm ≥ 10 

wrkrs

N sml farm < 10 

wrkrs N workers

RC B

($) 

RC P

($) 

costr,i,a

B $ 33.50 $ 10.76 $ 3.40 

costr,i,a

P $ 47.21 $ 15.14 $ 5.67 

South 2,699 48,016 146,142 1,103,146 1,683,233

California 1,123 19,980 210,543 967,384 1,549,726

Southwest 580 10,312 42,109 273,321 422,320

Subtropical 453 8,056 59,447 303,672 480,537

Midwest 3,931 69,929 159,765 1,426,410 2,150,381

Northeast 1,866 33,192 148,619 924,166 1,433,545

Ohio Valley 4,185 74,441 188,250 1,580,152 2,392,225

Texas/Mountain West 2,228 39,637 99,079 837,448 1,267,213

Northwest 1,051 18,691 184,535 862,788 1,379,266

US 18,116 322,254 1,238,489 $8,278,487 $12,758,446

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.1.a-25. Regional Costs, PV (3% discount rate) and Incremental Cost, Annual Worker 

Training, Small Farm Exception 

Region (Large WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 9,628 6,005 3,623

California 10,352 6,072 4,280

Southwest 2,522 1,546 977

Subtropical 3,096 1,841 1,255

Midwest 11,773 7,480 4,294

Northeast 8,673 5,287 3,386

Ohio Valley 13,303 8,396 4,907

Texas/Mountain West 7,035 4,443 2,592

Northwest 9,158 5,383 3,774
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 16 of 148

Region (Small WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 14,013 9,211 4,802

California 12,650 7,914 4,735

Southwest 3,498 2,270 1,227

Subtropical 3,942 2,498 1,444

Midwest 17,991 11,968 6,023

Northeast 11,854 7,665 4,189

Ohio Valley 19,980 13,236 6,744

Texas/Mountain West 10,586 7,016 3,570

Northwest 11,268 7,065 4,203

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.a-26. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Annual Worker Training, Small Farm Exception 

PV(NC P)

($1,000)

PV(NC B)

($1,000)

PV(NIC)

($1,000)

Large WPS Farm 75,540 46,453 29,087

Small WPS Farm 105,780 68,843 36,937

Total 181,320 115,296 66,024

7,515 (௥ܥܫܣ) Annualized

per-entity ($/large WPS farm) 60.98

per-entity ($/small WPS farm) 12.35

TRAIN-06. Expand Worker Training Content 

Step 1. Baseline 

Other State Baselines -- California: same as potential regulation, see Step 2 below. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes that, on average, a WPS farm conducts 1 training per year as in baseline. 

 Trainings are distributed across training groups as in baseline. 

 EPA assumes training will last 45 minutes. 

Table A.1.a-27. Potential Cost, per WPS farm, Expand Worker Training Content (TRAIN-06) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Training by Handler Trainer 37.87 0.75 0.14 3.98

Training by Train-the-Trainer 37.87 0.75 0.10 2.84

Training by Cert. Applicator 28.21 0.75 0.75 15.87

Training by WPS Handler 20.83 0.75 0.01 0.16

Expected per-farm Cost (costr,i,a

P

) 1.00 22.84

 Trainees account for 48.9% of the total workforce, as in baseline. 

 Abbreviated trainings occur as in the baseline. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 17 of 148

Table A.1.a-28. Potential Cost, per worker, Expand Worker Training Content (TRAIN-06) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Full training session 13.43 0.75 0.489 4.93

Abbreviated training session 13.43 0.05 0.053 0.04

Trainer, abbreviated session 28.21 0.05 0.053 0.08

Expected per-worker Cost (costr,i,a

P

) 5.04

Step 3. Estimate Regional Level Baseline and Compliance Costs 

California currently requires an expanded worker training similar to TRAIN-05. Baseline costs 

are, therefore, the same as in Table A.1.a-16 and 17. There are 394,658 WPS farms employing 

2,322,610 workers (NASS, 2008 [Census of Ag]). WPS farms, defined as those hiring labor, are 

distributed across regions in the same proportion as all farms. 

Table A.1.a-29. Regional Costs, Year 1, Expand Worker Training Content (TRAIN-06) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 15.23 $ 3.40 

costr,California,a

P $ 22.84 $ 5.04 

costr,i,a

P $ 22.84 $ 5.04 

South 58,804 274,068 1,826,019 2,729,605

California 24,469 394,844 2,547,837 2,550,247

Southwest 12,629 78,969 460,435 687,513

Subtropical 9,866 111,485 528,760 787,924

Midwest 85,641 299,617 2,321,458 3,473,989

Northeast 40,650 278,713 1,565,317 2,336,507

Ohio Valley 91,166 353,037 2,586,968 3,869,833

Texas/Mountain West 48,543 185,809 1,370,103 2,049,621

Northwest 22,890 346,069 1,523,534 2,268,345

US 394,658 2,322,610 $14,730,430 $20,753,583

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Calculating the present value (PV) of the baseline and potential cost streams follows the 

methodology presented in Chapter 3.3.1 of the Economic Analysis. In this case, we consider two 

factors that change over time. First, the requirement would be delayed two years to allow for the 

training content to be developed. Thus, baseline costs are used in the first two years and 

potential compliance costs in years three through ten. Second, the number of farms in the U.S. is 

declining at 0.47% per year and the number of farm workers is declining at 2.14% per year. 

Table A.1.a-30. Regional Costs, PV (3% discount rate) and Incremental Cost, Expand Worker 

Training Content (TRAIN-06) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 20,933 15,183 5,750

California 20,798 20,782 16

Southwest 5,245 3,809 1,436

Subtropical 5,951 4,333 1,619

Midwest 26,780 19,400 7,381
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 18 of 148

Northeast 17,794 12,929 4,866

Ohio Valley 29,777 21,580 8,197

Texas/Mountain West 15,775 11,432 4,343

Northwest 17,063 12,435 4,628

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.a-31. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Expand Worker Training Content (TRAIN-06) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

160,117 121,883 38,234

4,352 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 11.03

TRAIN-07. Expand Worker Training (crop sheet variant) 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes that, on average, a WPS farm conducts 1 training session per year as in the 

baseline. 

 Trainings are distributed across training groups as in baseline. 

 EPA assumes training will last 48 minutes. 

Table A.1.a-32. Potential Cost, per WPS farm, Expand Worker Training (crop sheet variant) 

(TRAIN-07) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Training by Handler Trainer 37.87 0.8 0.14 4.26

Training by Train-the-Trainer 37.87 0.8 0.10 3.04

Training by Cert. Applicator 28.21 0.8 0.75 17.00

Training by WPS Handler 20.83 0.8 0.01 0.17

Expected per-farm Cost (costr,i,a

P

) 1.00 24.47

Table A.1.a-33. Potential Cost, per worker, Expand Worker Training (crop sheet variant) 

(TRAIN-07) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Full training session 13.43 0.8 0.49 5.25

Summary training session 13.43 0.05 0.05 0.04

Summary trainer 28.21 0.05 0.05 0.08

Expected per-farm Cost (costr,i,a

P

) 5.37

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. California already covers additional material; baseline is as for TRAIN-06 (Table 

A.1.a-27 and 28). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 19 of 148

Table A.1.a-36. Regional Costs, Year 1, Expand Worker Training (crop sheet variant) (TRAIN07) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 15.23 $ 3.40 

costr,California,a

P $ 22.84 $ 5.04 

costr,i,a

P $ 24.37 $ 5.37 

South 58,804 274,068 1,826,019 2,909,551

California 24,469 394,844 2,547,837 2,717,341

Southwest 12,629 78,969 460,435 732,763

Subtropical 9,866 111,485 528,760 839,627

Midwest 85,641 299,617 2,321,458 3,703,370

Northeast 40,650 278,713 1,565,317 2,490,212

Ohio Valley 91,166 353,037 2,586,968 4,125,209

Texas/Mountain West 48,543 185,809 1,370,103 2,184,887

Northwest 22,890 346,069 1,523,534 2,417,006

US 394,658 2,322,610 $14,730,430 $22,119,965

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Calculating the present value (PV) of the baseline and potential cost streams follows the 

methodology presented in Chapter 3.3.1 of the Economic Analysis. In this case, we consider two 

factors that change over time. First, the requirement would be delayed two years to allow for the 

training content to be developed. Thus, baseline costs are used in the first two years and 

potential compliance costs in years three through ten. Second, the number of farms in the U.S. is 

declining at 0.47% per year and the number of farm workers is declining at 2.14% per year. 

Table A.1.a-37. Regional Costs, PV (3% discount rate) and Incremental Cost, Expand Worker 

Training (crop sheet variant) (TRAIN-07) 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 22,078 15,183 6,895

California 21,835 20,782 1,053

Southwest 5,531 3,809 1,722

Subtropical 6,274 4,333 1,941

Midwest 28,249 19,400 8,849

Northeast 18,764 12,929 5,835

Ohio Valley 31,409 21,580 9,829

Texas/Mountain West 16,639 11,432 5,207

Northwest 17,986 12,435 5,551

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.a-38. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Expand Worker Training (crop sheet variant) (TRAIN-07) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 168,765 121,883 46,882

5,336 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 13.52
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 20 of 148

b. Increase Worker Trainer Qualifications (TRAIN-08, 09) 

Baseline

Step 1. Calculate Baseline Costs 

 Baseline is the same as for worker training. See A.1.a. 

Table A.1.b-1. Baseline Cost, per WPS farm, Worker Trainer Qualifications 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Training by Handler Trainer 37.87 0.5 0.14 2.65

Training by Train-the-Trainer 37.87 0.5 0.10 1.89

Training by Cert. Applicator 28.21 0.5 0.75 10.58

Training by WPS Handler 20.83 0.5 0.01 0.10

Expected per-farm Cost (costr,i,a

B

) 15.23

Table A.1.b-2. Baseline Cost, per worker, Worker Trainer Qualifications 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Full training session 13.43 0.50 0.489 3.28

Abbreviated training session 13.43 0.05 0.053 0.04

Trainer, abbreviated session 28.21 0.05 0.053 0.08

Expected per-worker Cost (costr,i,a

B

) 3.40

New Regulations

TRAIN-08. Limit Who Can Be a Trainer/Improve Worker Trainer Competency 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Only handler trainers and worker trainers who have completed a Train-the-Trainer 

program will lead training sessions. 

o EPA assumes that handler trainers will lead 85% of sessions. 

o EPA assumes that people taking a Train-the-Trainer program will lead 15% of 

sessions. 

Table A.1.b-3. Potential Cost, per WPS farm, Limit Who Can Be a Trainer/Improve Worker 

Trainer Competency (TRAIN-08) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Training by Handler Trainer 37.87 0.5 0.85 16.16

Training by Train-the-Trainer 37.87 0.5 0.15 2.85

Expected per-farm Cost (costr,i,a

P

) 1.00 19.02

 Per-worker costs are as in the baseline. See Table A.1.b-2. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 21 of 148

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.1.b-5. Regional Costs, Year 1, Limit Who Can Be a Trainer/Improve Worker Trainer 

Competency (TRAIN-08) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 15.23 $ 3.40 

costr,i,a

P $ 19.02 $ 3.40 

South 58,804 274,068 1,826,019 2,048,785

California 24,469 394,844 1,713,170 1,805,865

Southwest 12,629 78,969 460,435 508,278

Subtropical 9,866 111,485 528,760 566,137

Midwest 85,641 299,617 2,321,458 2,645,889

Northeast 40,650 278,713 1,565,317 1,719,309

Ohio Valley 91,166 353,037 2,586,968 2,932,330

Texas/Mountain West 48,543 185,809 1,370,103 1,553,997

Northwest 22,890 346,069 1,523,534 1,610,248

US 394,658 2,322,610 $13,895,763 $15,390,837

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Calculating the present value (PV) of the baseline and potential cost streams follows the 

methodology presented in Chapter 3.3.1 of the Economic Analysis. In this case, we consider two 

factors that change over time. First, the requirement would be delayed two years to allow for 

trainers to obtain the necessary qualifications. Thus, baseline costs are used in the first two years 

and potential compliance costs in years three through ten. Second, the number of farms in the 

U.S. is declining at 0.47% per year and the number of farm workers is declining at 2.14% per 

year. 

Table A.1.b-5. Regional Costs, PV (3% discount rate) and Incremental Cost, Limit Who Can Be 

a Trainer/Improve Worker Trainer Competency (TRAIN-08) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 16,664 15,183 1,481

California 14,588 13,972 616

Southwest 4,127 3,809 318

Subtropical 4,581 4,333 248

Midwest 21,556 19,400 2,156

Northeast 13,952 12,929 1,023

Ohio Valley 23,876 21,580 2,295

Texas/Mountain West 12,654 11,432 1,222

Northwest 13,012 12,435 576
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 22 of 148

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.b-6. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), Limit 

Who Can Be a Trainer/Improve Worker Trainer Competency (TRAIN-08) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

125,009 115,073 9,936

1,131 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 2.87

TRAIN-09. Limit Who Can Be a Trainer/Improve Worker Trainer Competency (Trainthe-Trainers option) 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 All training sessions will be lead by those completing a Train-the-Trainer program. 

Table A.1.b-7. Potential Cost, per WPS farm, Limit Who Can Be a Trainer/Improve Worker 

Trainer Competency (Train-the-Trainers option) (TRAIN-09) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Training by Train-the-Trainer 37.87 0.50 1.00 19.02

Expected per-farm Cost (costr,i,a

P

) 1.00 19.02

 Per-worker costs are as in the baseline. See Table A.1.b-2. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.1.b-8. Regional Costs, Year 1, Limit Who Can Be a Trainer/Improve Worker Trainer 

Competency (Train-the-Trainers option) (TRAIN-09) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 15.23 $ 3.40 

costr,i,a

P $19.02 $ 3.40 

South 58,804 274,068 1,826,019 2,048,785

California 24,469 394,844 1,713,170 1,805,865

Southwest 12,629 78,969 460,435 508,278

Subtropical 9,866 111,485 528,760 566,137

Midwest 85,641 299,617 2,321,458 2,645,889

Northeast 40,650 278,713 1,565,317 1,719,309

Ohio Valley 91,166 353,037 2,586,968 2,932,330

Texas/Mountain West 48,543 185,809 1,370,103 1,553,997

Northwest 22,890 346,069 1,523,534 1,610,248

US 394,658 2,322,610 $13,895,763 $15,390,837
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 23 of 148

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Calculating the present value (PV) of the baseline and potential cost streams follows the 

methodology presented in Chapter 3.3.1 of the Economic Analysis. In this case, we consider two 

factors that change over time. First, the requirement would be delayed two years to allow for 

trainers to obtain the necessary qualifications. Thus, baseline costs are used in the first two years 

and potential compliance costs in years three through ten. Second, the number of farms in the 

U.S. is declining at 0.47% per year and the number of farm workers is declining at 2.14% per 

year. 

Table A.1.b-9. Regional Costs, PV (3% discount rate) and Incremental Cost, Limit Who Can Be 

a Trainer/Improve Worker Trainer Competency (Train-the-Trainers option) (TRAIN-09) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 16,664 15,183 1,481

California 14,588 13,972 616

Southwest 4,127 3,809 318

Subtropical 4,581 4,333 248

Midwest 21,556 19,400 2,156

Northeast 13,952 12,929 1,023

Ohio Valley 23,876 21,580 2,295

Texas/Mountain West 12,654 11,432 1,222

Northwest 13,012 12,435 576

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.b-10. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Limit Who Can Be a Trainer/Improve Worker Trainer Competency (Train-the-Trainers option) 

(TRAIN-09) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 125,009 115,073 9,936

1,131 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 2.87

c. Record Keeping, Worker Training (TRAIN-10, 11) 

Baseline

Step 1. Calculate Baseline Costs 

None. No records are currently required. 

New Regulations

TRAIN-10. Record Keeping, Worker Training for 2 years. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Owner/Operator must receive, organize, and store acknowledgements of training for 

workers. On average, these tasks would be done once per year, following the training, 

and take about 7 minutes. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 24 of 148

 A single sheet is needed to record the workers acknowledgement of training per training. 

 A folder is needed each year to store the records. Cost is $0.20 (Staples, 2008). 

 An average of one training per year is held per WPS farm. 

Table A.1.c-1. Potential Cost, per WPS farm, Record Keeping, Worker Training for 2 years 

(TRAIN-10) 

Action/Material wage/price

unit 

time/quantity

annual 

probability cost 

Receive/Collect/Store 

Acknowledgement 28.21 0.117 1 3.31

Training Acknowledgement 0.09 1 1 0.09

Folder 0.2 1 1 0.2

Expected per-farm Cost (costr,i,a

P

) 3.60

 EPA assumes that it will take a worker about 30 seconds to mark acknowledgement of 

training. 

 As in the baseline of worker training, 48.9% of all workers receive full training and 5.3% 

of all workers receive a summary training. See Table A.1.a-2. 

Table A.1.c-2. Potential Cost, per worker, Record Keeping, Worker Training for 2 years 

(TRAIN-10) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Acknowledge full training 13.43 0.008 0.489 0.05

Acknowledgement 0.09 1 0.489 0.04

Acknowledge abbreviated training 13.43 0.008 0.053 0.01

Acknowledgement 0.09 1 0.053 0.00

Expected per-worker Cost (costr,i,a

P

) 0.11

 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.1.c-3. Regional Costs, Year 1, Record Keeping, Worker Training for 2 years (TRAIN10) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 

costr,i,a

P $ 3.60 $ 0.11 

South 58,804 274,068 0 241,541

California 24,469 394,844 0 131,260

Southwest 12,629 78,969 0 54,077

Subtropical 9,866 111,485 0 47,701

Midwest 85,641 299,617 0 340,873

Northeast 40,650 278,713 0 176,747

Ohio Valley 91,166 353,037 0 366,599

Texas/Mountain West 48,543 185,809 0 194,964
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 25 of 148

Northwest 22,890 346,069 0 120,240

US 394,658 2,322,610 0 $1,674,001

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.1.c-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Record Keeping, 

Worker Training for 2 years (TRAIN-10) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 2,063 0 2,063

California 1,105 0 1,105

Southwest 461 0 461

Subtropical 404 0 404

Midwest 2,917 0 2,917

Northeast 1,504 0 1,504

Ohio Valley 3,135 0 3,135

Texas/Mountain West 1,667 0 1,667

Northwest 1,013 0 1,013

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.c-5. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Record Keeping, Worker Training for 2 years (TRAIN-10) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

14,269 0 14,269

1,624 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 4.11

TRAIN-11. Record keeping for worker training (5 years). 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 See TRAIN-10 (Table A.1.c-1). 

 A storage box is needed to store 5 years of records. Cost is $4.23 (Staples, 2008). 

 A storage box is expected to last 5 years, so in any given year, about 20% of farms will 

need to purchase a box. 

Table A.1.c-6. Potential Cost, per WPS farm, Worker training records (5 years) (TRAIN-11) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Receive/Collect/Store 

Acknowledgement 28.21 0.117 1 3.31

Training Acknowledgement 0.09 1 1 0.09

Folder 0.20 1 1 0.20

Storage Box 4.23 1 0.2 0.85

Expected per-farm Cost (costr,i,a

P

) 4.44
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 26 of 148

 Requirements per worker are as for TRAIN-10. See Table A.1.c-2. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.1.c-7. Regional Costs, Year 1, Worker training records (5 years) (TRAIN-11) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 

costr,i,a

P $ 4.44 $ 0.11 

South 58,804 274,068 0 291,289

California 24,469 394,844 0 151,961

Southwest 12,629 78,969 0 64,761

Subtropical 9,866 111,485 0 56,048

Midwest 85,641 299,617 0 413,325

Northeast 40,650 278,713 0 211,136

Ohio Valley 91,166 353,037 0 443,725

Texas/Mountain West 48,543 185,809 0 236,031

Northwest 22,890 346,069 0 139,605

US 394,658 2,322,610 $ 0 $2,007,882

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.1.c-8. Regional Costs, PV (3% discount rate) and Incremental Cost, Worker training 

records (2 years) (TRAIN-11) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 2,491 0 2,491

California 1,284 0 1,284

Southwest 553 0 553

Subtropical 476 0 476

Midwest 3,541 0 3,541

Northeast 1,801 0 1,801

Ohio Valley 3,799 0 3,799

Texas/Mountain West 2,021 0 2,021

Northwest 1,180 0 1,180
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 27 of 148

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.c-9. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Worker training records (2 years) (TRAIN-11) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

17,144 0 17,144

1,951 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 4.94

d. Handler Training (TRAIN-12, 13, 14, 15) 

Baseline

Step 1. Calculate Baseline Costs 

 Three groups are eligible to conduct worker safety training at differing wage rates, 

including 30% additional cost for benefits (BLS, 2008): 

o trainers of handlers and certified applicators ($37.87/hr); 

o individuals who have completed a train the trainer program ($37.87/hr); and 

o certified applicators ($28.21/hr). 

 EPA assumes training typically last 45 minutes. 

 EPA estimates that large WPS farms conduct 0.525 handler trainings per year, on 

average. 

o Large WPS farms, employing two handlers on average, have a 65.6% chance of 

employing a handler who needs trained, given that 32.8% of handlers will be 

trained each year (see below). 

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

trained, as some farms are able to share resources. 

 EPA estimates that large-small WPS farms conduct 0.246 handler trainings per year, on 

average. 

o Large-small WPS farms, with one handler on average, have a 32.8% chance of 

employing a handler who needs trained, given that 32.8% of handlers will be 

trained each year (see below). 

o 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. 

 CHPEs, employing over six handlers on average, likely have about two handlers to train 

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

 The annual probability of a training conducted by a given type of trainer is the frequency 

of trainings derived above multiplied by the distribution of training among the types of 

trainer, which EPA assumes is as follows: 

o trainers of handlers and certified applicators (14%); 

o individuals who have completed a train the trainer program (10%); and 

o certified applicators (76%). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 28 of 148

Table A.1.d-1. 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 37.87 0.75 0.073 2.09

Training by Train-the-Trainer 37.87 0.75 0.052 1.49

Training by Certified Applicator 28.21 0.75 0.399 8.44

Expected per-farm Cost (costr,i,a

B

) 0.525 12.02

Large-Small WPS farm 

Training by Handler Trainer 37.87 0.75 0.034 0.98

Training by Train-the-Trainer 37.87 0.75 0.025 0.70

Training by Certified Applicator 28.21 0.75 0.187 3.96

Expected per-farm Cost (costr,i,a

B

) 0.246 5.63

CPHE 

Training by Handler Trainer 37.87 0.75 0.140 3.98

Training by Train-the-Trainer 37.87 0.75 0.100 2.84

Training by Certified Applicator 30.30 0.75 0.760 17.27

Expected per-firm Cost (costr,i,a

B

) 1.000 24.09

 WPS and CHPE handler wages, including 30% for benefits, are $20.83/hr and $20.10/hr, 

respectively (BLS, 2008). 

 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 A.1.d-2. Baseline Cost, per WPS handler, Handler Training 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability 

cost 

(costr,i,a

B

) 

WPS farm handler 20.83 0.75 0.328 5.12

CPHE handler 20.10 0.75 0.328 4.94

New Regulations

TRAIN-12. Annual training of handlers. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters for WPS farms or CPHEs will be the same as in the baseline except for the 

number of trainings per year per farm or firm. 

 EPA estimates that large WPS farms conduct 0.8 handler trainings per year, on average. 

o Large WPS farms will have, on average, two handlers to train. 

o EPA assumes that, as in the baseline, there are 4 trainings for every 5 farms that 

need a handler trained, as some farms are able to share resources. 

 EPA estimates that large-small WPS farms conduct 0.5 handler trainings per year, on 

average. 

o Large-small WPS farms will have, on average, one handlers to train. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 29 of 148

o EPA assumes that there are 2 trainings for every 4 farms that need a handler 

trained, as some farms are able to share resources and more farms will have 

handlers to train than in the baseline. 

 EPA assumes that CPHEs will conduct, on average, 1.3 handler trainings each year, to 

account for the larger number of handlers that must be trained. 

 The distribution of trainers will be as in the baseline. 

Table A.1.d-3. Potential Cost, per WPS farm or CPHE, Annual Handler Training (TRAIN-12) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Large WPS farm 

Training by Handler Trainer 37.87 0.75 0.112 3.18

Training by Train-the-Trainer 37.87 0.75 0.080 2.27

Training by Certified Applicator 28.21 0.75 0.608 12.87

Expected per-farm Cost (costr,i,a

P

) 0.800 18.32

Large-Small WPS farm 

Training by Handler Trainer 37.87 0.75 0.070 1.99

Training by Train-the-Trainer 37.87 0.75 0.050 1.42

Training by Certified Applicator 28.21 0.75 0.380 8.04

Expected per-farm Cost (costr,i,a

P

) 0.500 11.45

CPHE 

Training by Handler Trainer 37.87 0.75 0.182 5.17

Training by Train-the-Trainer 37.87 0.75 0.130 3.69

Training by Certified Applicator 30.30 0.75 0.988 22.45

Expected per-firm Cost (costr,i,a

P

) 1.300 31.31

 Parameters for per-handler cost will be the same as the baseline except that all handlers 

will be trained with a probability of 1. 

Table A.1.d-4. Potential Cost, per WPS handler, Annual Handler Training (TRAIN-12) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability 

cost 

(costr,i,a

P

) 

WPS farm handler 20.83 0.75 1 15.62

CPHE handler 20.10 0.75 1 15.08

Step 3. Estimate Regional Level Baseline and Compliance Costs 

California already requires annual training of handlers; thus, baseline costs are the same as for 

the potential requirement. There are 54,289 large WPS farms and 139,237 large-small WPS 

farms (NASS, 2008 [Census of Ag]). Given EPA assumptions that large farms employ 2 

handlers, on average, and large-small establishments employ 1, there are a total of 247,815 

handlers. WPS farms and handlers are distributed across regions in the same proportion as total 

farms. There are 2,793 CPHEs employing 17,080 handlers, also distributed across regions in the 

same proportion as total farms (Dun & Bradstreet, 2010; NAAA, 2008). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 30 of 148

Table A.1.d-5. Regional Costs, Year 1, Annual Handler Training (TRAIN-12) 

Region (WPS Farm) N lrg farm N lrg-sml farm N hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $12.02 $ 5.63 $ 5.12

costr,California,a

B $18.32 $11.45 $15.62

costr,i,a

P $18.32 $11.45 $15.62

South 8,089 20,746 36,924 403,271 962,532

California 3,366 8,633 15,365 400,517 400,517

Southwest 1,737 4,456 7,930 86,609 206,718

Subtropical 1,357 3,481 6,195 67,663 161,499

Midwest 11,781 30,214 53,776 587,314 1,401,809

Northeast 5,592 14,341 25,525 278,771 665,375

Ohio Valley 12,541 32,164 57,245 625,206 1,492,248

Texas/Mountain West 6,678 17,126 30,481 332,902 794,574

Northwest 3,149 8,076 14,373 156,978 374,677

US 54,289 139,237 247,815 $2,939,230 $6,459,949

Region (CPHE) N CPHE N hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $24.09 $ 4.94

costr,California,a

B $31.31 $15.08

costr,i,a

P $31.31 $15.08

South 416 2,545 22,608 51,396

California 173 1,059 21,386 21,386

Southwest 89 547 4,855 11,038

Subtropical 70 427 3,793 8,624

Midwest 606 3,706 32,926 74,852

Northeast 288 1,759 15,628 35,529

Ohio Valley 645 3,945 35,050 79,682

Texas/Mountain West 344 2,101 18,663 42,428

Northwest 162 991 8,800 20,007

US 2,793 17,080 $163,710 $344,942

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of CPHEs is growing at 4.27% per year and the number of handlers employed by CPHEs 

is growing at 0.17% per year. 

Table A.1.d-6. Regional Costs, PV (3% discount rate) and Incremental Cost, Annual Handler 

Training (TRAIN-12) 

Region (WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 7,953 3,363 4,590

California 3,309 3,309 0

Southwest 1,708 722 986

Subtropical 1,334 564 770

Midwest 11,583 4,897 6,685

Northeast 5,498 2,325 3,173

Ohio Valley 12,330 5,213 7,117

Texas/Mountain West 6,565 2,776 3,789

Northwest 3,096 1,309 1,787
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 31 of 148

Region (CPHE) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 477 217 260

California 199 199 0

Southwest 103 47 56

Subtropical 80 36 44

Midwest 695 317 379

Northeast 330 150 180

Ohio Valley 740 337 403

Texas/Mountain West 394 179 215

Northwest 186 85 101

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.d-7. National and Per-Entity Costs, PV and Annualized (3% discount rate), Annual 

Handler Training (TRAIN-12) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 53,376 24,478 28,897

CPHE 3,203 1,567 1,637

Total 56,579 26,045 30,534

3,475 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 17.54

per-entity ($/CPHE) 66.69

TRAIN-13. Biennial training of handlers. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters for WPS farms or CPHEs will be the same as in the baseline except for the 

number of trainings per year per farm or firm. 

 EPA estimates that large WPS farms conduct 0.8 handler trainings per year, on average. 

o Large WPS farms will have, on average, more than one handler to train, 

accounting for new hires as well as returning employees. 

o EPA assumes that, as in the baseline, there are 4 trainings for every 5 farms that 

need a handler trained, as some farms are able to share resources. 

 EPA estimates that large-small WPS farms conduct 0.387 handler trainings per year, on 

average. 

o Large-small WPS farms will have, on average, 0.58 handlers to train, accounting 

for new hires as well as returning employees (see below). 

o EPA assumes that there are 2 trainings for every 3 farms that need a handler 

trained, as some farms are able to share resources and more farms will have 

handlers to train than in the baseline. 

 EPA assumes that CPHEs will conduct, on average, 1.2 handler trainings each year, to 

account for the somewhat larger number of handlers that must be trained. 

 The distribution of trainers will be as in the baseline. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 32 of 148

Table A.1.d-8. Potential Cost, per WPS farm or CPHE, Biennial Handler Training (TRAIN-13) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Large WPS farm 

Training by Handler Trainer 37.87 0.75 0.112 3.18

Training by Train-the-Trainer 37.87 0.75 0.080 2.27

Training by Certified Applicator 28.21 0.75 0.608 12.87

Expected per-farm Cost (costr,i,a

P

) 0.800 18.32

Large-Small WPS farm 

Training by Handler Trainer 37.87 0.75 0.054 1.54

Training by Train-the-Trainer 37.87 0.75 0.039 1.10

Training by Certified Applicator 28.21 0.75 0.294 6.22

Expected per-farm Cost (costr,i,a

P

) 0.387 8.85

CPHE 

Training by Handler Trainer 37.87 0.75 0.168 4.77

Training by Train-the-Trainer 37.87 0.75 0.120 3.41

Training by Certified Applicator 30.30 0.75 0.912 20.73

Expected per-firm Cost (costr,i,a

P

) 1.200 28.91

 Parameters for per-handler cost will be the same as the baseline except for the annual 

probability that a handler will be trained. 

 EPA calculates that 58.0% of handlers will be trained each year 

o 16% of handlers are new hires 

o 42% of handlers, representing 50% of the remaining 84% of handlers returning to 

work 

Table A.1.d-9. Potential Cost, per WPS handler, Biennial Handler Training (TRAIN-13) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability 

cost 

(costr,i,a

P

)

WPS farm handler 20.83 0.75 0.580 9.06

CPHE handler 20.10 0.75 0.580 8.74

Step 3. Estimate Regional Level Baseline and Compliance Costs 

California requires annual training of handlers. To avoid appearance of cost reduction, baseline 

cost is constrained to equal potential cost. There are 54,289 large WPS farms and 139,237 largesmall WPS farms (NASS, 2008 [Census of Ag]). Given EPA assumptions that large farms 

employ 2 handlers, on average, and large-small establishments employ 1, there are a total of 

247,815 handlers. WPS farms and handlers are distributed across regions in the same proportion 

as total farms. There are 2,793 CPHEs employing 17,080 handlers, also distributed across 

regions in the same proportion as total farms (Dun & Bradstreet, 2010; NAAA, 2008). 

Table A.1.d-10. Regional Costs, Year 1, Biennial Handler Training (TRAIN-13) 

Region (WPS Farm) N lrg farm N lrg-sml farm N hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $12.02 $ 5.63 $ 5.12

costr,California,a

B $18.32 $ 8.85 $ 9.06

costr,i,a

P $18.32 $ 8.85 $ 9.06

South 8,089 20,746 36,924 403,271 666,430
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 33 of 148

California 3,366 8,633 15,365 277,306 277,306

Southwest 1,737 4,456 7,930 86,609 143,126

Subtropical 1,357 3,481 6,195 67,663 111,817

Midwest 11,781 30,214 53,776 587,314 970,573

Northeast 5,592 14,341 25,525 278,771 460,687

Ohio Valley 12,541 32,164 57,245 625,206 1,033,190

Texas/Mountain West 6,678 17,126 30,481 332,902 550,140

Northwest 3,149 8,076 14,373 156,978 259,416

US 54,289 139,237 247,815 $2,816,020 $4,472,685

Region (CPHE) N CPHE N hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $24.09 $ 4.94

costr,California,a

B $28.91 $ 8.74

costr,i,a

P $28.91 $ 8.74

South 416 2,545 22,608 34,281

California 173 1,059 14,264 14,264

Southwest 89 547 4,855 7,362

Subtropical 70 427 3,793 5,752

Midwest 606 3,706 32,926 49,926

Northeast 288 1,759 15,628 23,697

Ohio Valley 645 3,945 35,050 53,147

Texas/Mountain West 344 2,101 18,663 28,299

Northwest 162 991 8,800 13,344

US 2,793 17,080 $156,588 $230,072

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of CPHEs is growing at 4.27% per year and the number of handlers employed by CPHEs 

is growing at 0.17% per year. 

Table A.1.d-11. Regional Costs, PV (3% discount rate) and Incremental Cost, Biennial Handler 

Training (TRAIN-13) 

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 5,544 3,363 2,182

California 2,307 2,307 0

Southwest 1,191 722 469

Subtropical 930 564 366

Midwest 8,075 4,897 3,177

Northeast 3,833 2,325 1,508

Ohio Valley 8,595 5,213 3,382

Texas/Mountain West 4,577 2,776 1,801

Northwest 2,158 1,309 849

Region (CPHE) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 324 217 107

California 135 135 0

Southwest 70 47 23

Subtropical 54 36 18
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 34 of 148

Midwest 472 317 155

Northeast 224 150 74

Ohio Valley 502 337 166

Texas/Mountain West 268 179 88

Northwest 126 85 42

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.d-12. National and Per-Entity Costs, PV and Annualized (3% discount rate), Biennial 

Handler Training (TRAIN-13) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 37,210 23,476 13,734

CPHE 2,175 1,503 672

Total 39,385 24,979 14,406

1,640 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 8.30

per-entity ($/CPHE) 27.39

TRAIN-14. Expand Handler Training Content. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA anticipates that training will last 60 minutes, rather than 45 minutes. 

 All other parameters are as in the baseline. 

Table A.1.d-13. Potential Cost, per WPS farm or CPHE, Expand Handler Training Content 

(TRAIN-14) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Large WPS farm 

Training by Handler Trainer 37.87 1 0.073 2.78

Training by Train-the-Trainer 37.87 1 0.052 1.99

Training by Certified Applicator 28.21 1 0.399 11.25

Expected per-farm Cost (costr,i,a

P

) 0.525 16.02

Large-Small WPS farm 

Training by Handler Trainer 37.87 1 0.034 1.30

Training by Train-the-Trainer 37.87 1 0.025 0.93

Training by Certified Applicator 28.21 1 0.187 5.27

Expected per-farm Cost (costr,i,a

P

) 0.246 7.51

CPHE 

Training by Handler Trainer 37.87 1 0.140 5.30

Training by Train-the-Trainer 37.87 1 0.100 3.79

Training by Certified Applicator 30.30 1 0.760 23.03

Expected per-firm Cost (costr,i,a

P

) 1.000 32.12

Table A.1.d-14. Potential Cost, per handler, Expand Handler Training Content (TRAIN-14) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability 

cost 

(costr,i,a

P

) 

WPS farm handler 20.83 1 0.328 6.83

CPHE handler 20.10 1 0.328 6.59
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 35 of 148

Step 3. Estimate Regional Level Baseline and Compliance Costs 

California requires handler training equivalent to the potential requirement; thus baseline costs 

are the same as for the potential requirement. There are 54,289 large WPS farms and 139,237 

large-small WPS farms (NASS, 2008 [Census of Ag]). Given EPA assumptions that large farms 

employ 2 handlers, on average, and large-small establishments employ 1, there are a total of 

247,815 handlers. WPS farms and handlers are distributed across regions in the same proportion 

as total farms. There are 2,793 CPHEs employing 17,080 handlers, also distributed across 

regions in the same proportion as total farms (Dun & Bradstreet, 2010; NAAA, 2008). 

Table A.1.d-15. Regional Costs, Year 1, Expand Handler Training Content (TRAIN-14) 

Region (WPS Farm) N lrg farm N lrg-sml farm N hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $12.02 $ 5.63 $ 5.12

costr,California,a

B $16.02 $ 7.51 $ 6.83

costr,i,a

P $16.02 $ 7.51 $ 6.83

South 8,089 20,746 36,924 403,271 537,695

California 3,366 8,633 15,365 223,739 223,739

Southwest 1,737 4,456 7,930 86,609 115,478

Subtropical 1,357 3,481 6,195 67,663 90,217

Midwest 11,781 30,214 53,776 587,314 783,086

Northeast 5,592 14,341 25,525 278,771 371,695

Ohio Valley 12,541 32,164 57,245 625,206 833,607

Texas/Mountain West 6,678 17,126 30,481 332,902 443,869

Northwest 3,149 8,076 14,373 156,978 209,304

US 54,289 139,237 247,815 $2,762,452 $3,608,690

Region (CPHE) N CPHE N hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $24.09 $ 4.94

costr,California,a

B $32.12 $ 6.59

costr,i,a

P $32.12 $ 6.59

South 416 2,545 22,608 30,144

California 173 1,059 12,543 12,543

Southwest 89 547 4,855 6,474

Subtropical 70 427 3,793 5,058

Midwest 606 3,706 32,926 43,901

Northeast 288 1,759 15,628 20,838

Ohio Valley 645 3,945 35,050 46,733

Texas/Mountain West 344 2,101 18,663 24,884

Northwest 162 991 8,800 11,734

US 2,793 17,080 $154,867 $202,308

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Calculating the present value (PV) of the baseline and potential cost streams follows the 

methodology presented in Chapter 3.3.1 of the Economic Analysis. In this case, we consider two 

factors that change over time. First, the requirement would be delayed two years to allow for the 

development of training material. Thus, baseline costs are used in the first two years and 

potential compliance costs in years three through ten. Second, the number of farms in the U.S. is 

declining at 0.47% per year and the number of farm workers is declining at 2.14% per year. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 36 of 148

Table A.1.d-16. Regional Costs, PV (3% discount rate) and Incremental Cost, Expand Handler 

Training Content (TRAIN-14) 

Region (WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 4,220 3,363 858

California 1,866 1,866 0

Southwest 906 722 184

Subtropical 708 564 144

Midwest 6,146 4,897 1,249

Northeast 2,917 2,325 593

Ohio Valley 6,543 5,213 1,330

Texas/Mountain West 3,484 2,776 708

Northwest 1,643 1,309 334

Region (CPHE) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 275 217 57

California 121 121 0

Southwest 59 47 12

Subtropical 46 36 10

Midwest 400 317 84

Northeast 190 150 40

Ohio Valley 426 337 89

Texas/Mountain West 227 179 47

Northwest 107 85 22

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.d-17. National and Per-Entity Costs, PV and Annualized (3% discount rate), Expand 

Handler Training Content (TRAIN-14) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 28,434 23,035 5,399

CPHE 1,851 1,489 362

Total 30,284 24,524 5,761

656 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 3.27

per-entity ($/CPHE) 14.74

TRAIN-15. Expand Handler Training (crop sheet variant) 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA anticipates that training will last 63 minutes, rather than 45 minutes. 

 All other parameters are as in the baseline. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 37 of 148

Table A.1.d-18. Potential Cost, per WPS farm or CPHE, Expand Handler Training (crop sheet 

variant) (TRAIN-15) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Large WPS farm 

Training by Handler Trainer 37.87 1.05 0.073 2.92

Training by Train-the-Trainer 37.87 1.05 0.052 2.09

Training by Certified Applicator 28.21 1.05 0.399 11.82

Expected per-farm Cost (costr,i,a

P

) 0.525 16.82

Large-Small WPS farm 

Training by Handler Trainer 37.87 1.05 0.034 1.37

Training by Train-the-Trainer 37.87 1.05 0.025 0.98

Training by Certified Applicator 28.21 1.05 0.187 5.54

Expected per-farm Cost (costr,i,a

P

) 0.246 7.89

CPHE 

Training by Handler Trainer 37.87 1.05 0.140 5.57

Training by Train-the-Trainer 37.87 1.05 0.100 3.98

Training by Certified Applicator 30.30 1.05 0.760 24.18

Expected per-firm Cost (costr,i,a

P

) 1.000 33.72

Table A.1.d-19. Potential Cost, per handler, Expand Handler Training (crop sheet variant) 

(TRAIN-15) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability 

cost 

(costr,i,a

P

) 

WPS farm handler 20.83 1.05 0.328 7.17

CPHE handler 20.10 1.05 0.328 6.92

Step 3. Estimate Regional Level Baseline and Compliance Costs 

California requires expanded handler training, equivalent to an additional 15 minutes (see Table 

A.1.c-13 and 14). There are 54,289 large WPS farms and 139,237 large-small WPS farms 

(NASS, 2008 [Census of Ag]). Given EPA assumptions that large farms employ 2 handlers, on 

average, and large-small establishments employ 1, there are a total of 247,815 handlers. WPS 

farms and handlers are distributed across regions in the same proportion as total farms. There 

are 2,793 CPHEs employing 17,080 handlers, also distributed across regions in the same 

proportion as total farms (Dun & Bradstreet, 2010; NAAA, 2008). 

Table A.1.d-20. Regional Costs, Year 1, Expand Handler Training (crop sheet variant) (TRAIN15) 

Region (WPS Farm) N lrg farm N lrg-sml farm N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $12.02 $ 5.63 $ 5.12

costr,California,a

B $16.02 $ 7.51 $ 6.83

costr,i,a

P $16.82 $ 7.89 $ 7.17

South 8,089 20,746 36,924 403,271 564,580

California 3,366 8,633 15,365 223,739 234,926

Southwest 1,737 4,456 7,930 86,609 121,252

Subtropical 1,357 3,481 6,195 67,663 94,728

Midwest 11,781 30,214 53,776 587,314 822,240
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 38 of 148

Northeast 5,592 14,341 25,525 278,771 390,280

Ohio Valley 12,541 32,164 57,245 625,206 875,288

Texas/Mountain West 6,678 17,126 30,481 332,902 466,062

Northwest 3,149 8,076 14,373 156,978 219,769

US 54,289 139,237 247,815 $2,762,452 $3,789,124

Region (CPHE) N CPHE N CPHE hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $24.09 $ 4.94

costr,California,a

B $32.12 $ 6.59

costr,i,a

P $33.72 $ 6.92

South 416 2,545 22,608 31,651

California 173 1,059 12,543 13,170

Southwest 89 547 4,855 6,798

Subtropical 70 427 3,793 5,311

Midwest 606 3,706 32,926 46,096

Northeast 288 1,759 15,628 21,880

Ohio Valley 645 3,945 35,050 49,070

Texas/Mountain West 344 2,101 18,663 26,128

Northwest 162 991 8,800 12,321

US 2,793 17,080 154,867 212,424

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Calculating the present value (PV) of the baseline and potential cost streams follows the 

methodology presented in Chapter 3.3.1 of the Economic Analysis. In this case, we consider two 

factors that change over time. First, the requirement would be delayed two years to allow for the 

development of training material. Thus, baseline costs are used in the first two years and 

potential compliance costs in years three through ten. Second, the number of farms in the U.S. is 

declining at 0.47% per year and the number of farm workers is declining at 2.14% per year. 

Table A.1.d-21. Regional Costs, PV (3% discount rate) and Incremental Cost, Expand Handler 

Training (crop sheet variant) (TRAIN-15) 

Region (WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 4,392 3,363 1,029

California 1,937 1,866 71

Southwest 943 722 221

Subtropical 737 564 173

Midwest 6,396 4,897 1,499

Northeast 3,036 2,325 711

Ohio Valley 6,809 5,213 1,595

Texas/Mountain West 3,625 2,776 850

Northwest 1,710 1,309 401

Region (CPHE) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 286 217 69

California 125 121 5

Southwest 61 47 15

Subtropical 48 36 12

Midwest 417 317 100
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 39 of 148

Northeast 198 150 48

Ohio Valley 444 337 107

Texas/Mountain West 236 179 57

Northwest 111 85 27

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.d-22. National and Per-Entity Costs, PV and Annualized (3% discount rate), Expand 

Handler Training (crop sheet variant) (TRAIN-15) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 29,585 23,035 6,550

CPHE 1,928 1,489 439

Total 31,513 24,524 6,989

795 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 3.97

per-entity ($/CPHE) 17.88

e. Record Keeping, Handler Training (TRAIN-16, 17) 

Baseline

Step 1. Calculate Baseline Costs 

None. No records are currently required under federal regulations. California requires records 

of handler training, which must be retained for two years. 

New Regulations

TRAIN-16. Record keeping for handler training (2 years). 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes that the WPS owner/operator spends about 3 minutes collecting and 

recording information, and 1 minute storing information, i.e., 4 minutes or 0.067 hours. 

 To keep the records, each operation will require at most one folder costing about $0.20 

(Staples, 2008). 

 The annual probability of collecting/storing the information is the frequency at which a 

farm or firm has a handler undertake training. From the baseline (Table A.1.c-2), there is 

a 0.328 probability that an individual handler takes the training 

o Large WPS farms, employing two handlers on average, have a 65.6% chance of 

having a handler take a training. 

o Large-small WPS farms, employing one handler on average, have a 32.8% chance 

of having a handler take training. 

o CPHE will likely have one training with an average of about 2 handlers trained 

each year. 

Table A.1.e-1. Potential Cost, per WPS farm or CPHE, Handler Training Records (2 years) 

(TRAIN-16) 

Action/Material wage/price 

unit 

time/quantity 

annual 

frequency cost 

Large WPS farm 

Collect/Store Acknowledgement 28.21 0.067 0.656 1.23
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 40 of 148

Folder 0.20 1 0.656 0.13

Expected per-farm Cost (costr,i,a

P

) 1.37

Large-Small WPS farm 

Collect/Store Acknowledgement 28.21 0.067 0.328 0.62

Folder 0.20 1 0.328 0.07

Expected per-farm Cost (costr,i,a

P

) 0.68

CPHE 

Collect/Store Acknowledgement 30.30 0.067 1 2.02

Folder 0.20 1 1 0.20

Expected per-firm Cost (costr,i,a

P

) 2.22

 Each handler marks a separate acknowledgement. 

 EPA assumes that it will take a handler about 30 seconds to mark acknowledgement of 

training. 

 EPA assumes that the handler trainer spends 45 seconds obtaining the acknowledgements 

from the trainees and, if necessary, sending them to the handler’s employer. 

 As in the baseline, 32.8% of all handlers receive training. 

 The probability of a category of trainer obtaining an acknowledgement from a given 

handler is the probability of the handler receiving training (32.8%) times the probability 

of the category of trainer administering the training, which, from the baseline, is as 

follows. 

o trainers of handlers and certified applicators (14%); 

o individuals who have completed a train the trainer program (10%); and 

o certified applicators (76%). 

Table A.1.e-2. Potential Cost, per handler, Handler Training Records (2 years) (TRAIN-16) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

WPS farm handler 

Acknowledgement 0.09 1 0.328 0.03

Acknowledge Training 20.83 0.008 0.328 0.06

Handler Trainer Receives 

Acknowledgement 37.87 0.013 0.046 0.02

Trainer of Trainers Receives 

Acknowledgement 37.87 0.013 0.033 0.02

Certified Applicator Receives 

Acknowledgement 28.21 0.013 0.249 0.09

Expected per-handler Cost (costr,i,a

P

) 0.21

CPHE handler 

Acknowledgement 0.09 1 0.328 0.03

Acknowledge Training 20.10 0.008 0.328 0.05

Handler Trainer Receives 

Acknowledgement 37.87 0.013 0.046 0.02

Trainer of Trainers Receives 

Acknowledgement 37.87 0.013 0.033 0.02

Certified Applicator Receives 

Acknowledgement 30.30 0.013 0.249 0.09

Expected per-worker Cost (costr,i,a

P

) 0.22
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 41 of 148

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large WPS farms and 139,237 large-small WPS farms (NASS, 2008 [Census of 

Ag]). Given EPA assumptions that large farms employ 2 handlers, on average, and large-small 

establishments employ 1, there are a total of 247,815 handlers. WPS farms and handlers are 

distributed across regions in the same proportion as total farms. There are 2,793 CPHEs 

employing 17,080 handlers, also distributed across regions in the same proportion as total farms 

(Dun & Bradstreet, 2010; NAAA, 2008). Current California requirements exceed the potential 

requirement; thus baseline costs are constrained to equal the cost of the potential requirement. 

Table A.1.e-3. Regional Costs, Year 1, Handler Training Records (2 years) (TRAIN-16) 

Region (WPS Farm) N lrg farm N lrg-sml farm N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 $ 0.00

costr,California,a

B $ 1.37 $ 0.68 $ 0.21

costr,i,a

P $ 1.37 $ 0.68 $ 0.21

South 8,089 20,746 36,924 0 33,028

California 3,366 8,633 15,365 13,739 13,743

Southwest 1,737 4,456 7,930 0 7,093

Subtropical 1,357 3,481 6,195 0 5,542

Midwest 11,781 30,214 53,776 0 48,101

Northeast 5,592 14,341 25,525 0 22,831

Ohio Valley 12,541 32,164 57,245 0 51,204

Texas/Mountain West 6,678 17,126 30,481 0 27,264

Northwest 3,149 8,076 14,373 0 12,856

US 54,289 139,237 247,815 $13,739 $221,663

Region (CPHE) N CPHE N CPHE hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00

costr,California,a

B $ 2.22 $ 0.22

costr,i,a

P $ 2.22 $ 0.22

South 416 2,545 0 1,474

California 173 1,059 613 613

Southwest 89 547 0 317

Subtropical 70 427 0 247

Midwest 606 3,706 0 2,147

Northeast 288 1,759 0 1,019

Ohio Valley 645 3,945 0 2,285

Texas/Mountain West 344 2,101 0 1,217

Northwest 162 991 0 574

US 2,793 17,080 $ 613 $9,892

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of CPHEs is growing at 4.27% per year and the number of handlers employed by CPHEs 

is growing at 0.17% per year. 

Table A.1.e-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Handler Training 

Records (2 years) (TRAIN-16) 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 42 of 148

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 215 0 215

California 116 116 0

Southwest 46 0 46

Subtropical 36 0 36

Midwest 313 0 313

Northeast 149 0 149

Ohio Valley 333 0 333

Texas/Mountain West 178 0 178

Northwest 84 0 84

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 12 0 12

California 6 6 0

Southwest 3 0 3

Subtropical 2 0 2

Midwest 17 0 17

Northeast 8 0 8

Ohio Valley 18 0 18

Texas/Mountain West 10 0 10

Northwest 5 0 5

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.e-5. National and Per-Entity Costs, PV and Annualized (3% discount rate), Handler 

Training Records (2 years) (TRAIN-16) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 1,470 116 1,354

CPHE 80 6 74

Total 1,550 123 1,428

162 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 0.80

per-entity ($/CPHE) 3.00

TRAIN-17. Record keeping for handler training (5 years). 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 As above, except that each operation will also need a storage box costing about $4.23 

(Staples, 2008) for the records. 

 The storage box lasts five years, giving an annual probability of 0.2 that a farm or firm 

purchases one. 

Table A.1.e-6. Potential Cost, per WPS farm or CPHE, Handler Training Records (5 years) 

(TRAIN-17) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Large WPS farm 

Collect/Store Acknowledgement 28.21 0.067 0.656 1.23

Folder 0.20 1 0.656 0.13
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 43 of 148

Storage Box 4.23 1 0.2 0.85

Expected per-farm Cost (costr,i,a

P

) 2.22

Large-Small WPS farm 

Collect/Store Acknowledgement 28.21 0.067 0.328 0.62

Folder 0.20 1 0.328 0.07

Storage Box 4.23 1 0.2 0.85

Expected per-farm Cost (costr,i,a

P

) 1.53

CPHE 

Collect/Store Acknowledgement 30.30 0.067 1 2.02

Folder 0.20 1 1 0.20

Storage Box 4.23 1 0.2 0.85

Expected per-firm Cost (costr,i,a

P

) 3.07

 Per-handler costs as in Table A.1.e-2: Potential Cost, per handler, Handler Training 

Records (2 years) (TRAIN-16) 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large WPS farms and 139,237 large-small WPS farms (NASS, 2008 [Census of 

Ag]). Given EPA assumptions that large farms employ 2 handlers, on average, and large-small 

establishments employ 1, there are a total of 247,815 handlers. WPS farms and handlers are 

distributed across regions in the same proportion as total farms. There are 2,793 CPHEs 

employing 17,080 handlers, also distributed across regions in the same proportion as total farms 

(Dun & Bradstreet, 2010; NAAA, 2008). Current California requirements are equivalent to the 

potential requirement. 

Table A.1.e-7. Regional Costs, Year 1, Handler Training Records (5 years) (TRAIN-17) 

Region (WPS Farm) N lrg farm N lrg-sml farm N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 $ 0.00

costr,California,a

B $ 1.37 $ 0.68 $ 0.21

costr,i,a

P $ 2.21 $ 1.53 $ 0.21

South 8,089 20,746 36,924 0 57,528

California 3,366 8,633 15,365 13,739 23,938

Southwest 1,737 4,456 7,930 0 12,355

Subtropical 1,357 3,481 6,195 0 9,652

Midwest 11,781 30,214 53,776 0 83,782

Northeast 5,592 14,341 25,525 0 39,767

Ohio Valley 12,541 32,164 57,245 0 89,187

Texas/Mountain West 6,678 17,126 30,481 0 47,489

Northwest 3,149 8,076 14,373 0 22,393

US 54,289 139,237 247,815 $ 13,739 $386,091

Region (CPHE) N CPHE N CPHE hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00

costr,California,a

B $ 2.22 $ 0.22

costr,i,a

P $ 3.07 $ 0.22

South 416 2,545 0 1,833

California 173 1,059 613 763

Southwest 89 547 0 394

Subtropical 70 427 0 308
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 44 of 148

Midwest 606 3,706 0 2,669

Northeast 288 1,759 0 1,267

Ohio Valley 645 3,945 0 2,842

Texas/Mountain West 344 2,101 0 1,513

Northwest 162 991 0 713

US 2,793 17,080 $ 613 $12,302

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of CPHEs is growing at 4.27% per year and the number of handlers employed by CPHEs 

is growing at 0.17% per year. 

Table A.1.e-8. Regional Costs, PV (3% discount rate) and Incremental Cost, Handler Training 

Records (5 years) (TRAIN-17) 

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 378 0 378

California 184 116 68

Southwest 81 0 81

Subtropical 63 0 63

Midwest 550 0 550

Northeast 261 0 261

Ohio Valley 586 0 586

Texas/Mountain West 312 0 312

Northwest 147 0 147

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 15 0 15

California 7 6 1

Southwest 3 0 3

Subtropical 2 0 2

Midwest 21 0 21

Northeast 10 0 10

Ohio Valley 23 0 23

Texas/Mountain West 12 0 12

Northwest 6 0 6

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.e-9. National and Per-Entity Costs, PV and Annualized (3% discount rate), Handler 

Training Records (5 years) (TRAIN-17) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 2,563 116 2,447

CPHE 100 6 94

Total 2,663 123 2,541

289 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 1.44

per-entity ($/CPHE) 3.84
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 45 of 148

f. Training Verification (TRAIN-18, 19, 20) 

Baseline

Step 1. Calculate Baseline Costs 

 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. 

 Trainers must fill out and distribute the cards; tests by EPA staff indicate it takes about 2 

minutes per card to enter the name, date of training, and other pertinent information. 

 Trainers belong to different categories as explained in Appendix A.1. The probability a 

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

that a worker or handler receives training times the probability that the training is led by a 

trainer in that category. 

 EPA calculates that 48.9% of WPS workers and 32.8% of WPS and CPHE handlers 

receive training each year. See Baselines for worker training (A.1.a) and handler training 

(A.1.d). 

Table A.1.f-1. Baseline Costs, per employee, Training Verification Program 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

WPS worker 

Certificate of Training 0.06 1 0.489 0.03

Distribute Certificates (hndlr trnr) 37.87 0.033 0.068 0.09

Distribute Certificates (trn-thetrnr) 37.87 0.033 0.049 0.06

Distribute Certificates (cert. app) 28.21 0.033 0.367 0.35

Distribute Certificates (handler) 20.83 0.033 0.005 0.00

Expected per-worker Cost (costr,i,a

B

) 0.489 0.53

WPS handler 

Certificate of Training 0.06 1 0.328 0.02

Distribute by Handler Trainer 37.87 0.033 0.046 0.06

Distribute by Train-the-Trainer 37.87 0.033 0.033 0.04

Distribute by Cert. App. 28.21 0.033 0.249 0.23

Expected per-WPS handler Cost (costr,i,a

B

) 0.35

CPHE 

Certificate of Training 0.06 1 0.328 0.02

Distribute by Handler Trainer 37.87 0.033 0.046 0.06

Distribute by Train-the-Trainer 37.87 0.033 0.033 0.04

Distribute by Cert. App. 30.30 0.033 0.249 0.25

Expected per-CHPE handler Cost (costr,i,a

B

) 0.37

Baseline, Subtropical, Northeast, and Northwest

Given the number of states requesting EPA-issued verification cards from these regions in 2010, 

EPA treats them as if half the states participate in the program. Thus, the probability of a worker 

or handler in these regions receiving a verification card is half that shown in Table A.1.f-1 and 

baseline costs are also half. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 46 of 148

Baseline, Midwest, Ohio Valley, and Texas/Mountain West

Given the small number of states requesting EPA-issued verification cards from these regions in 

2010, EPA treats them as if these states do not participate in the program. The probability of all 

actions is zero and the baseline costs are also zero. 

New Regulation

TRAIN-18. Eliminate training verification program. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 All per-employee costs are zero. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 2,322,610 WPS workers (NASS, 2008 [Census of Ag]). There are 54,289 large WPS 

farms and 139,237 large-small WPS farms (NASS, 2008 [Census of Ag]). Given EPA 

assumptions that large farms employ 2 handlers, on average, and large-small establishments 

employ 1, there are a total of 247,815 handlers. There are 17,080 CPHE handlers (Dun & 

Bradstreet, 2010; NAAA, 2008). 

Table A.1.f-2. Regional Costs, Year 1, Eliminate Training Verification Program (TRAIN-18) 

Region (WPS Farm) N WPS wrkr N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.53 $ 0.35 

costr,(Subt, NE, NW),a

B $ 0.26 $ 0.18 

costr,(MW,OH Val,TX/Mt NW),a

B $ 0.00 $ 0.00 

costr,i,a

P $ 0.00 $ 0.00 

South 274,068 36,924 157,194 0

California 394,844 15,365 213,093 0

Southwest 78,969 7,930 44,336 0

Subtropical 111,485 6,195 30,412 0

Midwest 299,617 53,776 0 0

Northeast 278,713 25,525 77,804 0

Ohio Valley 353,037 57,245 0 0

Texas/Mountain West 185,809 30,481 0 0

Northwest 346,069 14,373 93,545 0

US 2,322,610 247,815 $616,385 $ 0

Region (CPHE) N CPHE hndlr 

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.37 

costr,(Subt, NE, NW),a

B $ 0.19 

costr,(MW,OH Val,TX/Mt NW),a

B $ 0.00 

costr,i,a

P $ 0.00 

South 2,545 944 0

California 1,059 393 0

Southwest 547 203 0

Subtropical 427 79 0

Midwest 3,706 0 0

Northeast 1,759 326 0

Ohio Valley 3,945 0 0

Texas/Mountain West 2,101 0 0

Northwest 991 184 0

US 17,080 $ 2,128 $ 0
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 47 of 148

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farm workers is declining at 2.14% per year. The number of farms in the U.S., 

and therefore handlers, is declining at 0.47% per year. The number of handlers employed by 

CPHEs is growing at 0.17% per year. 

Table A.1.f-3. Regional Costs, PV (3% discount rate) and Incremental Cost, Eliminate Training 

Verification Program (TRAIN-18) 

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 0 1,270 -1,270

California 0 1,714 -1,714

Southwest 0 358 -358

Subtropical 0 245 -245

Midwest 0 0 0

Northeast 0 627 -627

Ohio Valley 0 0 0

Texas/Mountain West 0 0 0

Northwest 0 753 -753

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 0 8 -8

California 0 3 -3

Southwest 0 2 -2

Subtropical 0 1 -1

Midwest 0 0 0

Northeast 0 3 -3

Ohio Valley 0 0 0

Texas/Mountain West 0 0 0

Northwest 0 2 -2

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.f-4. National and Per-Entity Costs, PV and Annualized (3% discount rate), Eliminate 

Training Verification Program (TRAIN-18) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 0 4,966 -4,966

CPHE 0 19 -19

Total 0 4,985 -4,985

-567 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 1 -1.43

per-entity ($/CPHE) 1 -0.77

1

 Average over states currently participating in voluntary program. 

TRAIN-19. Require Employees Receive Verification (Card) of Training 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 All per-employee costs are equivalent to baseline costs shown in Table A.1.f-1. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 48 of 148

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 2,322,610 WPS workers (NASS, 2008 [Census of Ag]). There are 54,289 large WPS 

farms and 139,237 large-small WPS farms (NASS, 2008 [Census of Ag]). Given EPA 

assumptions that large farms employ 2 handlers, on average, and large-small establishments 

employ 1, there are a total of 247,815 handlers. There are 17,080 CPHE handlers (Dun & 

Bradstreet, 2010; NAAA, 2008). 

Table A.1.f-5. Regional Costs, Year 1, Require Employees Receive Verification (Card) of 

Training (TRAIN-19) 

Region (WPS Farm) N WPS wrkr N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.53 $ 0.35 

costr,(Subt, NE, NW),a

B $ 0.26 $ 0.18 

costr,(MW,OH Val,TX/Mt NW),a

B $ 0.00 $ 0.00 

costr,i,a

P $ 0.53 $ 0.35 

South 274,068 36,924 157,194 157,194

California 394,844 15,365 213,093 213,093

Southwest 78,969 7,930 44,336 44,336

Subtropical 111,485 6,195 30,412 60,824

Midwest 299,617 53,776 0 176,588

Northeast 278,713 25,525 77,804 155,608

Ohio Valley 353,037 57,245 0 205,910

Texas/Mountain West 185,809 30,481 0 108,498

Northwest 346,069 14,373 93,545 187,091

US 2,322,610 247,815 $616,385 $1,309,143

Region (CPHE) N CPHE hndlr 

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.37 

costr,(Subt, NE, NW),a

B $ 0.19 

costr,(MW,OH Val,TX/Mt NW),a

B $ 0.00 

costr,i,a

P $ 0.37 

South 2,545 944 944

California 1,059 393 393

Southwest 547 203 203

Subtropical 427 79 158

Midwest 3,706 0 1,374

Northeast 1,759 326 652

Ohio Valley 3,945 0 1,463

Texas/Mountain West 2,101 0 779

Northwest 991 184 367

US 17,080 2,128 6,334

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farm workers is declining at 2.14% per year. The number of farms in the U.S., 

and therefore handlers, is declining at 0.47% per year. The number of handlers employed by 

CPHEs is growing at 0.17% per year. 

Table A.1.f-6. Regional Costs, PV (3% discount rate) and Incremental Cost, Require Employees 

Receive Verification (Card) of Training (TRAIN-19) 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 49 of 148

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,270 1,270 0

California 1,714 1,714 0

Southwest 358 358 0

Subtropical 490 245 245

Midwest 1,429 0 1,429

Northeast 1,255 627 627

Ohio Valley 1,665 0 1,665

Texas/Mountain West 877 0 877

Northwest 1,505 753 753

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 8 8 0

California 3 3 0

Southwest 2 2 0

Subtropical 1 1 1

Midwest 12 0 12

Northeast 6 3 3

Ohio Valley 13 0 13

Texas/Mountain West 7 0 7

Northwest 3 2 2

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.f-7. National and Per-Entity Costs, PV and Annualized (3% discount rate), Require 

Employees Receive Verification (Card) of Training (TRAIN-19) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 10,562 4,966 5,596

CPHE 56 19 37

Total 10,618 4,985 5,633

641 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 1 1.61

per-entity ($/CPHE) 1 1.52

1

 Average over states currently participating in voluntary program. 

TRAIN-20. Require Employees Receive Verification of Training 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 In lieu of verification cards, employers provide copies of the training record, typically a 

sheet of paper at a cost of $0.09. 

 Trainers distribute the copies; EPA assumes this will take about 30 seconds per 

employee. 

 Other parameters are as in Table A.1.f-1. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 50 of 148

Table A.1.f-8. Potential Cost, per employee, Training Verification Program 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

WPS worker 

Copy of Training record 0.09 1 0.489 0.04

Distribute Certificates (hndlr trnr) 37.87 0.008 0.068 0.02

Distribute Certs. (trn-the-trnr) 37.87 0.008 0.049 0.02

Distribute Certificates (cert. app) 28.21 0.008 0.367 0.09

Distribute Certificates (handler) 20.83 0.008 0.005 0.00

Expected per-worker Cost (costr,i,a

P

) 0.489 0.17

WPS handler 

Copy of Training record 0.09 1 0.328 0.03

Distribute by Handler Trainer 37.87 0.008 0.046 0.01

Distribute by Train-the-Trainer 37.87 0.008 0.033 0.01

Distribute by Cert. App. 28.21 0.008 0.249 0.06

Expected per-WPS handler Cost (costr,i,a

P

) 0.328 0.11

CPHE 

Copy of Training record 0.09 1 0.328 0.03

Distribute by Handler Trainer 37.87 0.008 0.046 0.01

Distribute by Train-the-Trainer 37.87 0.008 0.033 0.01

Distribute by Cert. App. 30.30 0.008 0.249 0.06

Expected per-CHPE handler Cost (costr,i,a

P

) 0.328 0.12

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 2,322,610 WPS workers (NASS, 2008 [Census of Ag]). There are 54,289 large WPS 

farms and 139,237 large-small WPS farms (NASS, 2008 [Census of Ag]). Given EPA 

assumptions that large farms employ 2 handlers, on average, and large-small establishments 

employ 1, there are a total of 247,815 handlers. There are 17,080 CPHE handlers (Dun & 

Bradstreet, 2010; NAAA, 2008). 

Table A.1.f-9. Regional Costs, Year 1, Provide Proof of Training 

Region (WPS Farm) N WPS wrkr N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.53 $ 0.35 

costr,(Subt, NE, NW),a

B $ 0.26 $ 0.18 

costr,(MW,OH Val,TX/Mt NW),a

B $ 0.00 $ 0.00 

costr,i,a

P $ 0.17 $ 0.11 

South 274,068 36,924 157,194 50,261

California 394,844 15,365 213,093 68,136

Southwest 78,969 7,930 44,336 14,176

Subtropical 111,485 6,195 30,412 19,448

Midwest 299,617 53,776 0 56,461

Northeast 278,713 25,525 77,804 49,754

Ohio Valley 353,037 57,245 0 65,837

Texas/Mountain West 185,809 30,481 0 34,691

Northwest 346,069 14,373 93,545 59,821

US 2,322,610 247,815 $616,385 $418,584
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 51 of 148

Region (CPHE) N CPHE hndlr 

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.37 

costr,(Subt, NE, NW),a

B $ 0.19 

costr,(MW,OH Val,TX/Mt NW),a

B $ 0.00 

costr,i,a

P $ 0.12 

South 2,545 944 299

California 1,059 393 124

Southwest 547 203 64

Subtropical 427 79 50

Midwest 3,706 0 435

Northeast 1,759 326 206

Ohio Valley 3,945 0 463

Texas/Mountain West 2,101 0 246

Northwest 991 184 116

US 17,080 2,128 2,004

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farm workers is declining at 2.14% per year. The number of farms in the U.S., 

and therefore handlers, is declining at 0.47% per year. The number of handlers employed by 

CPHEs is growing at 0.17% per year. 

Table A.1.f-10. Regional Costs, PV (3% discount rate) and Incremental Cost, Provide Proof of 

Training 

Region (WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 406 1,270 -864

California 548 1,714 -1,166

Southwest 114 358 -243

Subtropical 157 245 -88

Midwest 457 0 457

Northeast 401 627 -226

Ohio Valley 532 0 532

Texas/Mountain West 281 0 281

Northwest 481 753 -271

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 3 8 -6

California 1 3 -2

Southwest 1 2 -1

Subtropical 0 1 0

Midwest 4 0 4

Northeast 2 3 -1

Ohio Valley 4 0 4

Texas/Mountain West 2 0 2

Northwest 1 2 -1
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 52 of 148

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.1.f-11. National and Per-Entity Costs, PV and Annualized (3% discount rate), Provide 

Proof of Training 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 3,377 4,966 -1,589

CPHE 18 19 -1

Total 3,395 4,985 -1,590

-181 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) -0.46

per-entity ($/CPHE) -0.04

A.2. Hazard Communication 

a. Application information (HAZCOM-01)

Baseline

Step 1. Calculate Baseline Costs 

 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. 

 The operator’s time is valued at $28.21/hr, consisting of the wage and an additional 30% 

for benefits (BLS, 2008). 

 EPA assumes a single sheet of paper is sufficient to record the information about each 

application. 

 Paper costs $0.09/sheet (Staples, 2008). 

 Posting the information is assumed to take one minute. 

 EPA calculates that WPS farms make an average of 15.4 pesticide applications per year. 

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

pesticides 

o About 77.1 percent of WPS farms will make pesticide applications in any given 

year (NASS, 2008). 

Table A.2.a-1. Baseline Cost, per WPS farm, Information on Pesticide Applications 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Record Application Information 28.21 0.083 15.4 36.26

Information Sheet 0.09 1 15.4 1.39

Post Application Information 28.21 0.017 15.4 7.25

Expected per-farm Cost (costr,i,a

B

) 44.90

Baseline, California and Texas/Mountain West

 State requires information to be made available on request. 

 EPA assumes the agricultural employer spends about 6 minutes providing requested 

information. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 53 of 148

 EPA assumes request occur about once every 12 applications. 

Table A.2.a-2. California and Texas/Mountain West Baseline Cost, per WPS farm, Information 

on Pesticide Applications 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Record Application Information 28.21 0.083 15.4 36.26

Information Sheet 0.09 1 15.4 1.39

Post Application Information 28.21 0.017 15.4 7.25

Prove Information on Request 28.21 0.1 1.3 3.63

Expected per-farm Cost (costr,(CA, TX/Mt W),a

B

) 48.53

New Regulation

HAZCOM-01. Availability of Application Information. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 The owner/operator of a WPS farm spends the same amount of time gathering and 

recording the information as in the baseline. 

 The owner/operator spends about 6 minutes per request providing the information to an 

employee or an employee’s representative. 

 The frequency of applications is as in the baseline. 

 EPA assumes that there will be a request for information in about 25% of applications. 

Table A.2.a-3. Potential Cost, per WPS farm, Information on Pesticide Applications 

(HAZCOM-01) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Record Application Information 28.21 0.083 15.4 36.26

Information Sheet 0.09 1 15.4 1.39

Provide Information 28.21 0.1 3.9 10.88

Expected per-farm Cost (costr,i,a

P

) 48.53

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms in the United States (NASS, 2008 [Census of Ag]). WPS farms, 

defined as those hiring labor, are distributed across regions in the same proportion as all farms. 

Current requirements in California and in Texas are equivalent to the potential requirement. 

Thus, baseline costs are equivalent to potential costs for these two regions. 

Table A.2.a-4. Regional Costs, Year 1, Information on Pesticide Applications (HAZCOM-01) 

Region N WPS farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 44.90 

costr,(CA, TX/Mt W),a

B $ 48.53 

costr,i,a

P $ 48.53 

South 58,804 2,640,541 2,853,784

California 24,469 1,187,480 1,187,480

Southwest 12,629 567,096 612,893

Subtropical 9,866 443,044 478,823

Midwest 85,641 3,845,620 4,156,181
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 54 of 148

Northeast 40,650 1,825,340 1,972,750

Ohio Valley 91,166 4,093,724 4,424,322

Texas/Mountain West 48,543 2,355,808 2,355,808

Northwest 22,890 1,027,861 1,110,869

US 394,658 $17,986,514 $19,152,909

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. 

Table A.2.a-5. Regional Costs, PV (3% discount rate) and Incremental Cost, Information on 

Pesticide Applications (HAZCOM-01) 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 24,578 22,742 1,837

California 10,227 10,227 0

Southwest 5,279 4,884 394

Subtropical 4,124 3,816 308

Midwest 35,795 33,120 2,675

Northeast 16,990 15,721 1,270

Ohio Valley 38,104 35,257 2,847

Texas/Mountain West 20,289 20,289 0

Northwest 9,567 8,852 715

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.2.a-6. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Information on Pesticide Applications (HAZCOM-01) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 164,954 154,908 10,046

1,143 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 2.90

b. Pesticide information (HAZCOM-02, 03, 04)

Baseline, Pesticide-Specific Information

Step 1. Calculate Baseline Costs 

 No current requirements for pesticide information, but the agricultural employer will 

nearly always have access to a copy of the pesticide label. Even if the application is 

made by a CPHE, the grower will need a copy to ensure compliance with postapplication label requirements such as the REI. 

 The owner/operator of a WPS farm time is valued at $28.21/hour (BLS, 2008) 

 The owner/operator spends about 4 minutes obtaining the label either from the pesticide 

distributor or on-line (based on EPA internet searches). 

 EPA assumes that pesticide-specific information would be need for half the average 

number of application because the same pesticide is likely to be used on multiple fields. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 55 of 148

Thus, 10 applications weighted by 77.1% of WPS farms making an application in a given 

year. 

Table A.2.b-1. Baseline Cost, per WPS farm, Pesticide-Specific Information 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Obtain Label 28.21 0.067 7.7 14.51

Expected per-farm Cost (costr,i,a

B

) 14.51

 California, Subtropical, Midwest, and Texas/Mountain West region representative states 

require SDS and labels to be available as in proposed regulation (HAZCOM-02). 

New Regulation

HAZCOM-02. Pesticide Label and SDS. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 The owner/operator of a WPS farm spends an additional 4 minutes obtaining the SDS 

either from the pesticide distributor or on-line (based on EPA internet searches). 

 Based on a sample of products found on line, labels average 20.8 pages in length and 

SDS average 6.7 pages. Assuming double-sided printing, a copy of the label and SDS 

will require 13.7 pages, on average. 

 EPA assumes that pesticide-specific information would be need for half the average 

number of application because the same pesticide is likely to be used on multiple fields. 

 EPA assumes that half the WPS farms will pay for a copy at the pesticide distributor and 

half will print a copy from the internet. 

Table A.2.b-2. Potential Cost, per WPS farm, Pesticide Label and SDS (HAZCOM-02) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Obtain Label 28.21 0.067 7.7 14.51

Obtain SDS 28.21 0.067 7.7 14.51

Copy of Label, SDS 0.09 13.7 3.9 4.77

Print Label, SDS 0.09 13.7 3.9 4.77

Expected per-farm Cost (costr,i,a

P

) 38.55

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms in the United States (NASS, 2008 [Census of Ag]). WPS farms, 

defined as those hiring labor, are distributed across regions in the same proportion as all farms. 

Current requirements in California, Florida, Iowa, and Texas are equivalent to the potential 

requirement. Thus, baseline costs are equivalent to potential costs for the four regions. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 56 of 148

Table A.2.b-3. Regional Costs, Year 1, Pesticide Label and SDS (HAZCOM-02) 

Region N WPS farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 14.51 

costr,(CA,Subt.,MW, TX/Mt W),a

B $ 38.55 

costr,i,a

P $ 38.55 

South 58,804 852,972 2,266,923

California 24,469 943,283 943,283

Southwest 12,629 183,189 486,856

Subtropical 9,866 380,356 380,356

Midwest 85,641 3,301,491 3,301,491

Northeast 40,650 589,638 1,567,067

Ohio Valley 91,166 1,322,392 3,514,491

Texas/Mountain West 48,543 1,871,352 1,871,352

Northwest 22,890 332,029 882,426

US 394,658 $ 9,776,702 $15,214,246

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. 

Table A.2.b-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Pesticide Label and 

SDS (HAZCOM-02) 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 19,524 7,346 12,178

California 8,124 8,124 0

Southwest 4,193 1,578 2,615

Subtropical 3,276 3,276 0

Midwest 28,434 28,434 0

Northeast 13,496 5,078 8,418

Ohio Valley 30,268 11,389 18,879

Texas/Mountain West 16,117 16,117 0

Northwest 7,600 2,860 4,740

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.2.b-5. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Pesticide Label (HAZCOM-02) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 131,032 84,201 46,831

5,330 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 13.51

HAZCOM-03. Pesticide Label only. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 The owner/operator of a WPS farm spends about 4 minutes obtaining the label either 

from the pesticide distributor or on-line (based on EPA internet searches). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 57 of 148

 Based on a sample of products found on line, labels average 20.8 pages in length. 

Assuming double-sided printing, a copy of the label will require 10.4 pages, on average. 

 EPA assumes that pesticide-specific information would be need for half the average 

number of application because the same pesticide is likely to be used on multiple fields. 

Table A.2.b-6. Potential Cost, per WPS farm, Pesticide Label (HAZCOM-03) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Obtain Label 28.21 0.067 7.7 14.51

Copy of Label 0.09 10.4 3.9 3.61

Print Label 0.09 10.4 3.9 3.61

Expected per-farm Cost (costr,i,a

P

) 21.73

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms in the United States (NASS, 2008 [Census of Ag]). WPS farms, 

defined as those hiring labor, are distributed across regions in the same proportion as all farms. 

Current requirements in California, Florida, Iowa, and Texas exceed the potential requirement. 

Thus, baseline costs are equivalent to potential costs for the four regions. 

Table A.2.b-7. Regional Costs, Year 1, Pesticide Label (HAZCOM-03) 

Region N WPS farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 14.51 

costr,(CA,Subt.,MW, TX/Mt W),a

B $ 21.73 

costr,i,a

P $ 21.73 

South 58,804 852,972 1,277,908

California 24,469 531,747 531,747

Southwest 12,629 183,189 274,450

Subtropical 9,866 214,414 214,414

Midwest 85,641 1,861,114 1,861,114

Northeast 40,650 589,638 883,386

Ohio Valley 91,166 1,322,392 1,981,186

Texas/Mountain West 48,543 1,054,917 1,054,917

Northwest 22,890 332,029 497,441

US 394,658 $ 6,942,411 $ 8,576,561

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. 

Table A.2.b-8. Regional Costs, PV (3% discount rate) and Incremental Cost, Pesticide Label 

(HAZCOM-03) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 11,006 7,346 3,660

California 4,580 4,580 0

Southwest 2,364 1,578 786

Subtropical 1,847 1,847 0

Midwest 16,029 16,029 0
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 58 of 148

Northeast 7,608 5,078 2,530

Ohio Valley 17,063 11,389 5,674

Texas/Mountain West 9,085 9,085 0

Northwest 4,284 2,860 1,425

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.2.b-9. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Pesticide Label (HAZCOM-03) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 73,865 59,791 14,074

1,602 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 4.06

HAZCOM-04. Pesticide crop sheets. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 The owner/operator of a WPS farm spends about 6 minutes gathering the appropriate 

crop sheet for the pesticide either from the pesticide distributor or on-line (based on EPA 

internet searches). 

 Based on a sample of crop sheets, only one page is needed. 

 EPA assumes that crop/pesticide-specific information would be need for three-fourths the 

average number of application because the same pesticide may be used on multiple fields 

of the same crop. 

Table A.2.b-10. Potential Cost, per WPS farm, Pesticide crop sheets (HAZCOM-04) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Obtain Label 28.21 0.067 7.7 14.51

Obtain crop sheet 28.21 0.1 11.6 32.64

Copy of crop sheet 0.09 1 5.8 0.52

Print crop sheet 0.09 1 5.8 0.52

Expected per-farm Cost (costr,i,a

P

) 48.18

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms in the United States (NASS, 2008 [Census of Ag]). WPS farms, 

defined as those hiring labor, are distributed across regions in the same proportion as all farms. 

Baseline costs for California, the Subtropics, Midwest, and Texas/Mountain West are the same 

as all other regions since the SDS would not meet the requirement. 

Table A.2.b-11. Regional Costs, Year 1, Pesticide crop sheets (HAZCOM-04) 

Region N WPS farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 14.51 

costr,i,a

P $ 48.18 

South 58,804 852,972 2,833,377

California 24,469 354,928 1,178,989

Southwest 12,629 183,189 608,510

Subtropical 9,866 143,116 475,399
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 59 of 148

Midwest 85,641 1,242,247 4,126,462

Northeast 40,650 589,638 1,958,643

Ohio Valley 91,166 1,322,392 4,392,685

Texas/Mountain West 48,543 704,131 2,338,962

Northwest 22,890 332,029 1,102,925

US 394,658 $ 5,724,641 $19,015,953

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. 

Table A.2.b-12. Regional Costs, PV (3% discount rate) and Incremental Cost, Pesticide crop 

sheets (HAZCOM-04) 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 24,402 7,346 17,056

California 10,154 3,057 7,097

Southwest 5,241 1,578 3,663

Subtropical 4,094 1,233 2,862

Midwest 35,539 10,699 24,840

Northeast 16,869 5,078 11,791

Ohio Valley 37,832 11,389 26,443

Texas/Mountain West 20,144 6,064 14,080

Northwest 9,499 2,860 6,639

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.2.b-13. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Pesticide Label (HAZCOM-04) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 163,774 49,303 114,471

13,029 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 33.01

c. Record keeping (HAZCOM-05 and 06)

Baseline, Pesticide-Specific Information

Step 1. Calculate Baseline Costs 

 No current requirements for pesticide information. 

 Texas/Mountain West region representative state requires require records be kept of 

application information (HAZCOM-05). 

New Regulation

HAZCOM-05. Record Keeping, 2 years. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 The owner/operator of a WPS farm spends about 1 minutes filing information sheets per 

application. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 60 of 148

 Application information takes 1 sheet of paper ($0.09). (See Table A.2-a.1) 

 The WPS farm will have one folder ($0.20) per season. 

 EPA calculates that WPS farms make an average of 15.4 pesticide applications per year. 

(See Table A.2-a.1) 

 About 77.1 percent of WPS farms will make pesticide applications in any given year 

(NASS, 2008) and will need a folder for records. 

Table A.2.c-1. Potential Cost, per WPS farm, Hazard Communication Record Keeping, 2 years 

(HAZCOM-05) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Store Records 28.21 0.017 15.4 7.25

Information Sheets 0.09 1 15.4 1.39

Folder 0.20 1 0.77 0.15

Expected per-farm Cost (costr,i,a

P

) 8.79

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms in the United States (NASS, 2008 [Census of Ag]). WPS farms, 

defined as those hiring labor, are distributed across regions in the same proportion as all farms. 

Current requirements in Texas are equivalent to the potential requirement. Thus, baseline costs 

are equivalent to potential costs for the region. 

Table A.2.c-2. Regional Costs, Year 1, Hazard Communication Record Keeping, 2 years 

(HAZCOM-05) 

Region N WPS farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 

costr,TX/Mt W,a

B $ 8.79 

costr,i,a

P $ 8.79 

South 58,804 0 517,181

California 24,469 0 215,203

Southwest 12,629 0 111,073

Subtropical 9,866 0 86,775

Midwest 85,641 0 753,211

Northeast 40,650 0 357,515

Ohio Valley 91,166 0 801,805

Texas/Mountain West 48,543 426,935 426,935

Northwest 22,890 0 201,319

US 394,658 $ 426,935 $3,471,016

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 61 of 148

Table A.2.c-3. Regional Costs, PV (3% discount rate) and Incremental Cost, Hazard 

Communication Record Keeping, 2 years (HAZCOM-05) 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 4,454 0 4,454

California 1,853 0 1,853

Southwest 957 0 957

Subtropical 747 0 747

Midwest 6,487 0 6,487

Northeast 3,079 0 3,079

Ohio Valley 6,906 0 6,906

Texas/Mountain West 3,677 3,677 0

Northwest 1,734 0 1,734

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.2.c-4. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Hazard Communication Record Keeping, 2 years (HAZCOM-05) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 29,894 3,677 26,217

2,984 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 7.56

HAZCOM-06. Record Keeping, 5 years. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 The owner/operator of a WPS farm spends about 1 minutes filing information sheets per 

application. 

 Application information takes 1 sheet of paper ($0.09). (See Table A.2-a.1) 

 The WPS farm will have one folder ($0.20) per season. 

 The WPS farm will need one storage box over the five-year retention period. 

 EPA calculates that WPS farms make an average of 15.4 pesticide applications per year. 

(See Table A.2-a.1) 

 About 77.1 percent of WPS farms will make pesticide applications in any given year 

(NASS, 2008) and will need a folder for records. 

 A storage box lasts five years and EPA assumes that every WPS farm will eventually 

have a record. 

Table A.2.c-5. Potential Cost, per WPS farm, Hazard Communication Record Keeping, 5 years 

(HAZCOM-06) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Store Records 28.21 0.017 15.4 7.25

Information Sheets 0.09 1 15.4 1.39

Folder 0.20 1 0.77 0.15

Storage Box 4.23 1 0.2 0.85

Expected per-farm Cost (costr,i,a

P

) 9.64
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 62 of 148

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms in the United States (NASS, 2008 [Census of Ag]). WPS farms, 

defined as those hiring labor, are distributed across regions in the same proportion as all farms. 

Current requirements in Texas are equivalent to the potential requirement HAZCOM-05, without 

the storage box. Thus, baseline costs for the region are equivalent to the potential costs shown in 

Table A.2.c-1. 

Table A.2.c-6. Regional Costs, Year 1, Hazard Communication Record Keeping, 5 years 

(HAZCOM-06) 

Region N WPS farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 

costr,TX/Mt W,a

B $ 8.79 

costr,i,a

P $ 9.64 

South 58,804 0 566,930

California 24,469 0 235,904

Southwest 12,629 0 121,757

Subtropical 9,866 0 95,122

Midwest 85,641 0 825,663

Northeast 40,650 0 391,904

Ohio Valley 91,166 0 878,931

Texas/Mountain West 48,543 426,935 468,002

Northwest 22,890 0 220,684

US 394,658 $ 426,935 $3,804,897

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. 

Table A.2.c-7. Regional Costs, PV (3% discount rate) and Incremental Cost, Hazard 

Communication Record Keeping, 5 years (HAZCOM-06) 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 4,883 0 4,883

California 2,032 0 2,032

Southwest 1,049 0 1,049

Subtropical 819 0 819

Midwest 7,111 0 7,111

Northeast 3,375 0 3,375

Ohio Valley 7,570 0 7,570

Texas/Mountain West 4,031 3,677 354

Northwest 1,901 0 1,901
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 63 of 148

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.2.c-8. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Hazard Communication Record Keeping, 5 years (HAZCOM-06) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 32,770 3,677 29,093

3,311 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 8.39

d. Crop Sheet (HAZCOM-07) 

Baseline

Step 1. Calculate Baseline Costs 

 In the baseline, registrants print a label for each product. Cost is national. 

 EPA previously found that the average cost of printing labels to be $4,589.50, based total 

printing costs that average $5,069, including $479.50 to produce a new printing plate 

(EPA, 2005). A new printing plate is not needed under baseline conditions. 

 Labels are assumed to be printed about every 3 years for each product. 

Table A.2.d-1. Baseline Cost, per pesticide product, Crop Sheets 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Reproduce Label 4,589.50 1 0.333 1529.83

Expected per-product Cost (costr,a

B

) 1529.83

New Regulation

HAZCOM-07. Print ‘crop sheet’ with label. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 A new printing plate with additional safety information would be needed for the initial 

printing. 

 EPA assumes that crop sheets would add about 5% to the cost of a printing plate and to 

the printing costs. Labels currently average about 20 pages while a crop sheet is about 

one page. This may be a substantial underestimate, however, because multiple crop 

sheets would be necessary for a single product that is registered for multiple crops and for 

crops grown under different production practices in different regions of the U.S. 

o A new printing plate would cost $503.48. 

o Printing costs would increase to $4,818.98. 

 Printing of crop sheets would be phased in over about three years in conjunction with 

normal label printing schedule. 

Table A.2.d-2. Potential Cost, per pesticide product, Crop Sheets (HAZCOM-07) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Produce Plate 503.48 1 0.333 167.83

Produce Label and Crop Sheet 4,818.98 1 0.333 1606.33

Expected per-product Cost (costr,a

P

) 1774.15
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 64 of 148

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are approximately 21,800 pesticide products on the market according to a search of EPA 

database (OPPIN). 

Table A.2.d-3. Regional Costs, Year 1, Crop Sheets (HAZCOM-07) 

Region N product

RC B

($) 

RC P

($) 

costr,a

B $ 1530 

costr,a

P $ 1774 

US 21,800 $33,350,367 $38,676,470

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

Printing of crop sheets would be phased in over about three years in conjunction with normal 

label printing schedule. After three years, cost per product would fall to the annual cost of 

reproduction, $1,606.33. 

Printing of crop sheets is a national-level activity. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.2.d-4. National and Per-Product Costs, PV and Annualized (3% discount rate), Crop 

Sheets (HAZCOM-07) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 318,330 293,020 25,310

2,881 (௥ܥܫܣ) Annualized

per-product 132.14

A.3. Notification 

a. Warning signs during REI (NOTIFY-01, 02, 03) 

Baseline, WPS farms excluding greenhouse

Step 1. Calculate Baseline Costs 

 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. 

 Warning signs cost $5.66 each (Gemplers) 

 EPA assumes WPS farms typically provide oral notification when given the choice, 

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 assumes that 2 signs are usually 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. 

o Farms will likely only need 2 or 3 signs due to few simultaneous postings. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 65 of 148

 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 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. 

o Large farms will make 13.9 oral notifications per year, on average (notify workers 

orally for 70% or 14 applications, 1.1 notifications per application, 90.2% chance 

of making an application). 

o Large-small farms will make 19.8 oral notifications per year, on average (notify 

workers orally for all applications, 1.1 notifications per application, 89.7% chance 

of making an application). 

o Medium and Small-small farms will make 14.3 oral notifications per year, on 

average (notify workers for all applications, 1.1 notifications per application, 

64.9% chance of making a pesticide application). 

 EPA calculates annual average frequencies for the purchase of signs by farm size. 

o Large farms are assumed to purchase 4 or 6 REI signs, for two simultaneous 

postings, depending on whether worker housing is adjacent to a field. 

 Six signs are purchased with annual frequency of 0.122 (90.2% of large 

farms make pesticide applications, 27.1% of large farms are assumed to 

need 6 signs due to adjacent worker housing, and signs are purchased 

every other year, i.e., 0.902 · 0.271 · 0.5) 

 Four signs are purchased with an annual frequency of 0.329 (90.2% of 

large farms make pesticide applications, 72.9% of large farms are assumed 

to need 4 signs, signs are purchased every other year, i.e., 0.902 · 0.729 · 

0.5). 

o Large-small farms are assumed to purchase 2 or 3 signs since simultaneous 

postings will be rare. 

 Three signs are purchased with annual frequency of 0.081 (89.8% of 

large-small farms make pesticide applications, 18.0% of large-small farms 

are assumed to need 3 signs due to adjacent worker housing, signs are 

purchased every other year, i.e., 0.898 · 0.180 · 0.5) 

 Two signs are purchased with an annual frequency of 0.368 (89.8% of 

large-small farms make pesticide applications, 82.0% of large-small farms 

are assumed to need 2 signs, signs are purchased every other year, i.e., 

0.898 · 0.820 · 0.5). 

o Medium and Small-small farms are assumed to purchase 2 or 3 signs since 

simultaneous postings will be rare. 

 Three signs are purchased with annual frequency of 0.071 (64.9% of small 

farms make pesticide applications, 5.5% of small farms are assumed to 

need 3 signs due to adjacent worker housing, signs are purchased every 

other year, i.e., 0.649 · 0.055 · 0.5) 

 Two signs are purchased with an annual frequency of 0.307 (64.9% of 

small farms make pesticide applications, 94.5% of small farms are 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 66 of 148

assumed to need 2 signs, signs are purchased every other year, i.e., 0.649 · 

0.945 · 0.5). 

 EPA similarly calculates annual average frequencies for posting signs by farm size. 

o Large farms are assumed to post 2 or 3 REI signs, depending on whether worker 

housing is adjacent to a field. 

 Three signs are posted, on average, 1.95 times per year (8 posting events 

out of 20 applications, 90.2% of large farms make pesticide applications, 

27.1% of large farms are assumed to post 3 signs due to adjacent worker 

housing, i.e., 8 · 0.902 · 0.271) 

 Two signs are posted, on average, 5.26 times per year (8 posting events 

out of 20 applications, 90.2% of large farms make pesticide applications, 

72.9% of large farms are assumed to post 2 signs, i.e., 8 · 0.902 · 0.729). 

o Large-small farms are assumed to post 2 or 3 REI signs, depending on whether 

worker housing is adjacent to a field. 

 Three signs are posted, on average, 0.323 times per year (2 posting events 

out of 20 applications, 89.8% of large-small farms make pesticide 

applications, 18.0% of large-small farms are assumed to post 3 signs due 

to adjacent worker housing, i.e., 2 · 0.898 · 0.180) 

 Two signs are posted, on average, 1.47 times per year (2 posting events 

out of 20 applications, 89.8% of large-small farms make pesticide 

applications, 82.0% of large-small farms are assumed to post 2 signs, i.e., 

2 · 0.898 · 0.820). 

o Medium and Small-small farms are assumed to post 2 or 3 REI signs, depending 

on whether worker housing is adjacent to a field. 

 Three signs are posted, on average, 0.071 times per year (2 posting events 

out of 20 applications, 64.9% of small farms make pesticide applications, 

5.5% of small farms are assumed to post 3 signs due to adjacent worker 

housing, i.e., 2 · 0.649 · 0.055) 

 Two signs are posted, on average, 1.23 times per year (2 posting events 

out of 20 applications, 64.9% of small farms make pesticide applications, 

94.5% of large-small farms are assumed to post 2 signs, i.e., 2 · 0.649 · 

0.945);. 

Table A.3.a-1. Baseline Cost, WPS Farm excluding greenhouses, Post REI Signs 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Oral Notification 28.21 0.05 13.9 19.60

Warning Signs 5.66 4 0.329 7.45

Post 2 Signs 28.21 0.333 5.26 49.51

Warning Signs 5.66 6 0.122 4.15

Post 3 Signs 28.21 0.5 1.95 27.55

Expected per-Large farm Cost (costr,i,a

B

) 108.25

Large-Small WPS farm 1

Oral Notification 28.21 0.05 19.8 27.87

Warning Signs 5.66 2 0.368 4.17

Post 2 Signs 28.21 0.333 1.47 13.86
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 67 of 148

Warning Signs 5.66 3 0.081 1.37

Post 3 Signs 28.21 0.5 0.323 4.55

Expected per-Lrg-Sml farm Cost (costr,i,a

B

) 51.82

Med/Sml-Small WPS farm 1

Oral Notification 28.21 0.05 14.3 20.14

Warning Signs 5.66 2 0.307 3.47

Post 2 Signs 28.21 0.333 1.23 11.54

Warning Signs 5.66 3 0.018 0.30

Post 3 Signs 28.21 0.5 0.07 1.00

Expected per-Med/Sml farm Cost (costr,i,a

B

) 36.45

1

 Excluding greenhouses. 

 For per-worker costs, EPA assumes that oral notification 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 applications, there is an 80% chance a worker will be onfarm during the REI, and 94.6% of workers are employed on large WPS farms 

making a pesticide application (NASS, 2008b) (14 · 0.8 · 0.946). 

o Workers on large-small farms receive 14.6 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 91.3% of workers are employed on 

large-small WPS farms making a pesticide application (NASS, 2008b) (20 · 0.8 · 

0.913). 

o Workers on medium and small-small farms receive 11.3 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 70.6% of workers are 

employed on WPS farms making a pesticide application (NASS, 2008b) (20 · 0.8 

· 0.706). 

Table A.3.a-2. Baseline Cost, WPS Workers excluding greenhouses, Post REI Signs 

Action/Material wage/price unit time/quantity 

annual 

frequency 

cost 

(costr,i,a

B

) 

Receive Information 

Large Farm worker 1 13.43 0.05 10.6 7.12

Lrg-Sml Farm worker 1 13.43 0.05 14.6 9.79

Med/Sml Farm worker 1 13.43 0.05 11.3 7.59

1

 Excluding greenhouses.

New Regulation

NOTIFY-01. Post warning signs if REI is greater than 48 hours (outdoor production). 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are as in the baseline unless otherwise noted. 

 EPA assumes that there will be some overlap in posting, implying that non-greenhouse 

WPS farms will need 4 or 6 signs available at a time. 

 EPA assumes that 8 pesticides of 20 applications will have REIs greater than 48 hours, 

including the 2 ‘double notification’ applications. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 68 of 148

o A large non-greenhouse WPS farm will not be affected by the revision as they 

already post for some applications. 

o A large-small non-greenhouse WPS farm will make 13.8 oral notifications. There 

will be 14 occasions for oral notification (including 2 double notifications), each 

occasion averages 1.1 notifications to reach all workers on-site, and 89.8% of 

large-small non-greenhouse WPS farms make pesticide applications (NASS, 

2008). 

o Large-small farms are assumed to post 2 or 3 REI signs, depending on whether 

worker housing is adjacent to a field. Two signs are posted, on average, 5.89 

times per year (8 posting events out of 20 applications, 89.8% of large-small 

farms make pesticide applications, and 82.0% of large-small farms are assumed to 

post 2 signs, i.e., 8 · 0.898 · 0.820); 3 signs are posted, on average, 1.29 times per 

year (8 posting events out of 20 applications, 89.8% of large-small farms make 

pesticide applications, 18.0% of large-small farms are assumed to post 3 signs due 

to adjacent worker housing, i.e., 8 · 0.898 · 0.180). 

o A medium or small-small non-greenhouse WPS farm will make 10.0 oral 

notifications. There will be 14 occasions for oral notification (including 2 double 

notifications), each occasion averages 1.1 notifications to reach all workers onsite, and 64.9% of large-small non-greenhouse WPS farms make pesticide 

applications (NASS, 2008b). 

o Medium and Small-small farms are assumed to post 2 or 3 REI signs, depending 

on whether worker housing is adjacent to a field. Two signs are posted, on 

average, 4.91 times per year (8 posting events out of 20 applications, 64.9% of 

small farms make pesticide applications, and 94.5% of large-small farms are 

assumed to post 2 signs, i.e., 8 · 0.649 · 0.945); 3 signs are posted, on average, 

0.284 times per year (8 posting events out of 20 applications, 64.9% of small 

farms make pesticide applications, 5.5% of small farms are assumed to post 3 

signs due to adjacent worker housing, i.e., 8 · 0.649 · 0.055). 

Table A.3.a-3. Potential Cost, WPS Farm excluding greenhouses, Post Signs if REI > 48 hours. 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm (see Table A.3.a-1) 

Large-Small WPS farm 1

Oral Notification 28.21 0.05 13.8 19.51

Warning Signs 5.66 4 0.368 8.34

Post 2 Signs 28.21 0.333 5.89 55.43

Warning Signs 5.66 6 0.081 2.74

Post 3 Signs 28.21 0.5 1.29 18.21

Expected per-Lrg-Sml farm Cost (costr,i,a

P

) 104.23

Med/Sml-Small WPS farm 1

Oral Notification 28.21 0.05 10.0 14.09

Warning Signs 5.66 4 0.307 6.94

Post 2 Signs 28.21 0.333 4.91 46.14
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 69 of 148

Warning Signs 5.66 6 0.018 0.60

Post 3 Signs 28.21 0.5 0.284 4.01

Expected per-Med/Sml farm Cost (costr,i,a

P

) 71.79

1

 Excluding greenhouses.

 EPA calculates the frequency that each WPS worker receives oral notification based on 

farm size. 

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

o Workers on large-small farms receive 10.2 notifications; large-small farms make 

14 oral notifications out of 20 applications, there is an 80% chance a worker will 

be on-farm during the REI, and 91.1% of workers are employed on large-small 

WPS farms making a pesticide application (NASS, 2008b) (14 · 0.8 · 0.911). 

o Workers on medium and small-small farms receive 7.9 notifications per year. 

Small farms make 14 oral notifications out of 20 applications, there is an 80% 

chance a worker will be on-farm during the REI, and 70.7% of workers are 

employed on WPS farms making a pesticide application (NASS, 2008b) (14 · 0.8 

· 0.707). 

Table A.3.a-4. Potential Cost, per worker, Post Signs if REI > 48 hours 

Action/Material wage/price unit time/quantity 

annual 

frequency 

cost 

(costr,i,a

P

) 

Receive Information 

Large Farm worker 1 13.43 0.05 10.6 7.12

Lrg-Sml Farm worker 1 13.43 0.05 10.2 6.85

Med/Sml Farm worker 1 13.43 0.05 7.9 5.32

1

 Excluding greenhouses. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 393,779 non-greenhouse WPS farms including 54,115 large, 138,951 large-small, and 

200,713 medium- and small-small enterprises. These WPS farms and nurseries employ 

2,297,773 workers, of which 1,063,629 are employed on large farms, 647,896 are employed on 

large-small farms, and 586,248 are employed on medium- and small farms (NASS, 2008 [Census 

of Ag]). WPS farms, defined as those hiring labor, are distributed across regions in the same 

proportion as all farms. 

Table A.3.a-5. Regional Costs, Year 1, Post Signs if REI > 48 hours 

Region (Large WPS 

Farm) 1 N lrg farm N wrkr lrg frm

 

RC B

($) 

RC P

($) 

costr,i,a

B $ 108.25 $ 7.12 

costr,i,a

P $ 108.25 $ 7.12 

South 8,063 125,508 1,766,049 1,766,049

California 3,355 180,817 1,650,006 1,650,006

Southwest 1,732 36,163 444,820 444,820

Subtropical 1,353 51,054 509,785 509,785

Midwest 11,743 137,208 2,247,663 2,247,663

Northeast 5,574 127,635 1,511,716 1,511,716

Ohio Valley 12,501 161,672 2,503,774 2,503,774
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 70 of 148

Texas/Mountain West 6,656 85,090 1,326,100 1,326,100

Northwest 3,139 158,481 1,467,615 1,467,615

US (Large WPS 

Farm) 1 54,115 1,063,629 $13,427,529 $13,427,529

Region (Small WPS 

Farm) 1 N lrg-sml farm N med & sml N wrkr lrg-sml

N wrkr med 

&sml frm

RC B

($) 

RC P

($) 

costr,i,a

B $ 51.82 $ 36.45 $ 9.79 $ 7.59

costr,i,a

P $ 104.23 $ 71.79 $ 6.85 $ 5.32

South 20,704 29,906 76,452 69,177 3,436,402 5,196,341

California 8,615 12,444 110,142 99,662 2,734,755 3,075,626

Southwest 4,446 6,423 22,028 19,932 831,460 1,181,401

Subtropical 3,474 5,018 31,099 28,140 880,949 1,084,929

Midwest 30,152 43,555 83,579 75,626 4,542,196 7,244,078

Northeast 14,312 20,673 77,748 70,350 2,790,262 3,882,435

Ohio Valley 32,098 46,365 98,480 89,110 4,993,651 7,822,325

Texas/Mountain West 17,091 24,688 51,832 46,900 2,648,865 4,158,070

Northwest 8,059 11,641 96,537 87,351 2,450,043 2,801,405

US (Small WPS 

Farm) 1 138,951 200,713 647,896 586,248 $25,308,582 $36,446,609

1

 Excluding greenhouses. 

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.3.a-6. Regional Costs, PV (3% discount rate) and Incremental Cost, Post Signs if REI > 

48 hours 

Region (Large Farm) 1 PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 14,689 14,689 0

California 13,459 13,459 0

Southwest 3,681 3,681 0

Subtropical 4,178 4,178 0

Midwest 18,788 18,788 0

Northeast 12,489 12,489 0

Ohio Valley 20,892 20,892 0

Texas/Mountain West 11,067 11,067 0

Northwest 11,981 11,981 0

Region (Small Farm) 1 PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 44,233 28,852 15,380

California 25,739 22,482 3,257

Southwest 10,025 6,947 3,078

Subtropical 9,132 7,285 1,848

Midwest 61,820 38,307 23,514

Northeast 32,908 23,275 9,633
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 71 of 148

Ohio Valley 66,699 42,050 24,649

Texas/Mountain West 35,458 22,309 13,149

Northwest 23,470 20,162 3,308

1

 Excluding greenhouses. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.a-7. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), Post 

Signs if REI > 48 hours 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS, large 111,225 111,225 0

WPS, small 309,484 211,668 97,816

Total 420,709 322,892 97,816

11,133 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 1 28.27

per-entity ($/lrg WPS) 1 0.00

per-entity ($/sml WPS) 1 32.78

1

 Excluding greenhouses. 

NOTIFY-02. Post warning signs if REI is greater than 72 hours. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are as in the baseline unless otherwise noted. 

 EPA assumes that there will be some overlap in posting, implying that non-greenhouse 

WPS farms will need 4 or 6 signs available at a time. 

 EPA assumes that 6 pesticides of 20 applications will have REIs greater than 72 hours, 

including the 2 ‘double notification’ applications. 

o A large non-greenhouse WPS farm will be unaffected by the revision. 

o A large-small non-greenhouse WPS farm will make 15.8 oral notifications. There 

will be 16 occasions for oral notification (including 2 double notifications), each 

occasion averages 1.1 notifications to reach all workers on-site, and 89.8% of 

large-small non-greenhouse WPS farms make pesticide applications (NASS, 

2008b). 

o Large-small farms are assumed to post 2 or 3 REI signs, depending on whether 

worker housing is adjacent to a field. Two signs are posted, on average, 4.42 

times per year (6 posting events out of 20 applications, 89.8% of large-small 

farms make pesticide applications, and 82.0% of large-small farms are assumed to 

post 2 signs, i.e., 6 · 0.898 · 0.820); 3 signs are posted, on average, 0.968 times per 

year (6 posting events out of 20 applications, 89.8% of large-small farms make 

pesticide applications, 18.0% of large-small farms are assumed to post 3 signs due 

to adjacent worker housing, i.e., 6 · 0.898 · 0.180). 

o A medium or small-small non-greenhouse WPS farm will make 11.4 oral 

notifications. There will be 16 occasions for oral notification (including 2 double 

notifications), each occasion averages 1.1 notifications to reach all workers onsite, and 64.9% of large-small non-greenhouse WPS farms make pesticide 

applications (NASS, 2008b). 

o Medium and Small-small farms are assumed to post 2 or 3 REI signs, depending 

on whether worker housing is adjacent to a field. Two signs are posted, on 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 72 of 148

average, 3.68 times per year (6 posting events out of 20 applications, 64.9% of 

small farms make pesticide applications, and 94.5% of large-small farms are 

assumed to post 2 signs, i.e., 8 · 0.649 · 0.945); 3 signs are posted, on average, 

0.213 times per year (6 posting events out of 20 applications, 64.9% of small 

farms make pesticide applications, 5.5% of small farms are assumed to post 3 

signs due to adjacent worker housing, i.e., 8 · 0.649 · 0.055). 

Table A.3.a-8. Potential Cost, WPS Farm excluding greenhouses, Post Signs if REI > 72 hours. 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm (see Table A.3.a-1) 

Large-Small WPS farm 1

Oral Notification 28.21 0.05 15.8 22.30

Warning Signs 5.66 4 0.368 8.34

Post 2 Signs 28.21 0.333 4.42 41.58

Warning Signs 5.66 6 0.081 2.74

Post 3 Signs 28.21 0.5 0.968 13.65

Expected per-Lrg-Sml farm Cost (costr,i,a

P

) 88.61

Med/Sml-Small WPS farm 1

Oral Notification 28.21 0.05 11.4 16.11

Warning Signs 5.66 4 0.307 6.94

Post 2 Signs 28.21 0.333 3.68 34.61

Warning Signs 5.66 6 0.018 0.60

Post 3 Signs 28.21 0.5 0.213 3.00

Expected per-Med/Sml farm Cost (costr,i,a

P

) 61.26

1

 Excluding greenhouses. 

 EPA calculates the frequency that each WPS worker receives oral notification based on 

farm size. 

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

o Workers on large-small farms receive 11.7 notifications; large-small farms make 

16 oral notifications out of 20 applications, there is an 80% chance a worker will 

be on-farm during the REI, and 91.1% of workers are employed on large-small 

WPS farms making a pesticide application (NASS, 2008b) (16 · 0.8 · 0.911). 

o Workers on medium and small-small farms receive 9.0 notifications per year. 

Small farms make 16 oral notifications out of 20 applications, there is an 80% 

chance a worker will be on-farm during the REI, and 70.7% of workers are 

employed on WPS farms making a pesticide application (NASS, 2008b) (16 · 0.8 

· 0.707). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 73 of 148

Table A.3.a-9. Potential Cost, per worker, Post Signs if REI > 72 hours 

Action/Material wage/price unit time/quantity 

annual 

frequency 

cost 

(costr,i,a

P

) 

Receive Information 

Large Farm worker1 13.43 0.05 10.6 7.12

Lrg-Sml Farm worker1 13.43 0.05 11.7 7.83

Med/Sml Farm worker1 13.43 0.05 9.0 6.08

1

 Excluding greenhouses. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 393,779 non-greenhouse WPS farms including 54,115 large, 138,951 large-small, and 

200,713 medium- and small-small enterprises. These WPS farms and nurseries employ 

2,297,773 workers, of which 1,063,629 are employed on large farms, 647,896 are employed on 

large-small farms, and 586,248 are employed on medium- and small farms (NASS, 2008 [Census 

of Ag]). WPS farms, defined as those hiring labor, are distributed across regions in the same 

proportion as all farms. 

Table A.3.a-10. Regional Costs, Year 1, Post Signs if REI > 72 hours 

Region (Large WPS Farm) 1 N lrg farm N wrkr lrg frm

RC B

($) 

RC P

($) 

costr,i,a

B $ 108.25 $ 7.12 

costr,i,a

P $ 108.25 $ 7.12 

South 8,063 125,508 1,766,049 1,766,049

California 3,355 180,817 1,650,006 1,650,006

Southwest 1,732 36,163 444,820 444,820

Subtropical 1,353 51,054 509,785 509,785

Midwest 11,743 137,208 2,247,663 2,247,663

Northeast 5,574 127,635 1,511,716 1,511,716

Ohio Valley 12,501 161,672 2,503,774 2,503,774

Texas/Mountain West 6,656 85,090 1,326,100 1,326,100

Northwest 3,139 158,481 1,467,615 1,467,615

US (Large WPS Farm) 1 54,115 1,063,629 $13,427,529 $13,427,529

Region (Small WPS 

Farm) 1

N lrg-sml 

farm

N med/sml 

frm

N wrkr lrg-sml 

frm

N wrkr med 

& sml frm

RC B

($) 

RC P

($) 

costr,i,a

B $ 51.82 $ 36.45 $ 9.79 $ 7.59

costr,i,a

P $ 88.61 $ 61.26 $ 7.83 $ 6.08

South 20,704 29,906 76,452 69,177 3,436,402 4,685,533

California 8,615 12,444 110,142 99,662 2,734,755 2,993,559

Southwest 4,446 6,423 22,028 19,932 831,460 1,081,042

Subtropical 3,474 5,018 31,099 28,140 880,949 1,029,660

Midwest 30,152 43,555 83,579 75,626 4,542,196 6,453,900

Northeast 14,312 20,673 77,748 70,350 2,790,262 3,570,802

Ohio Valley 32,098 46,365 98,480 89,110 4,993,651 6,997,009

Texas/Mountain West 17,091 24,688 51,832 46,900 2,648,865 3,717,606

Northwest 8,059 11,641 96,537 87,351 2,450,043 2,713,805

US (Small WPS Farm) 1 138,951 200,713 647,896 586,248 $25,308,582 $33,242,917

1

 Excluding greenhouses. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 74 of 148

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.3.a-11. Regional Costs, PV (3% discount rate) and Incremental Cost, Post Signs if REI 

> 48 hours 

Region (Large Farm) 1 PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 14,689 14,689 0

California 13,459 13,459 0

Southwest 3,681 3,681 0

Subtropical 4,178 4,178 0

Midwest 18,788 18,788 0

Northeast 12,489 12,489 0

Ohio Valley 20,892 20,892 0

Texas/Mountain West 11,067 11,067 0

Northwest 11,981 11,981 0

Region (Small Farm) 1 PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 39,759 28,852 10,907

California 24,925 22,482 2,443

Southwest 9,139 6,947 2,192

Subtropical 8,626 7,285 1,341

Midwest 54,934 38,307 16,627

Northeast 30,148 23,275 6,874

Ohio Valley 59,495 42,050 17,445

Texas/Mountain West 31,614 22,309 9,305

Northwest 22,621 20,162 2,459

1

 Excluding greenhouses. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.a-12. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), Post 

Signs if REI > 72 hours 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS, large 1 111,225 111,225 0

WPS, small 1 281,262 211,668 69,594

Total 392,487 322,892 69,594

7,921 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 1 20.12

per-entity ($/lrg WPS) 1 0.00

per-entity ($/sml WPS) 1 23.32

1

 Excluding greenhouses. 

Baseline, WPS greenhouses (indoor production)

Step 1. Calculate Baseline Costs 

 Greenhouse operations are required to post warnings for all applications. 

 Oral notification is provided for double notification products. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 75 of 148

 Warning signs cost $5.66 each (Gemplers) 

 EPA assumes oral notification takes 3 minutes. 

 EPA assumes that 2 signs are usually posted at a time and these signs can be reused. 

Farms will likely need 4 signs due to simultaneous postings. 

 EPA assumes that it takes 10 minutes to post a sign, which is done by the owner/operator. 

Posting two signs takes 20 minutes. 

 EPA calculates there will be, on average, 1.64 oral notifications per large greenhouse per 

year and 1.21 oral notifications per year per small greenhouse. EPA assumes 2 

applications out of 20 require oral notification and 1.1 oral notifications will be made, on 

average, for each application to account for workers in different locations; 74.7% of large 

greenhouses and 55.2% of small greenhouses make pesticide applications in a year 

(NASS, 2008). 

 EPA calculates an annual average frequency of 0.374 and 0.276 for the purchase of signs 

by large and small greenhouses, respectively. Signs last for two seasons and 74.7% of 

large greenhouses and 55.2% of small greenhouses make pesticide applications in a year 

(NASS, 2008). 

 EPA similarly calculates that large greenhouses will post signs, on average, 14.9 times 

per year (20 applications and 74.7% of large greenhouses make pesticide applications) 

and that small greenhouses will post signs 11.0 times per year (20 applications and 55.2% 

of large greenhouses make pesticide applications). 

 Workers in large greenhouses receive 1.26 oral notifications, on average, per year and 

workers in small greenhouses receive 0.83 oral notifications per year. There are 2 

notification events, 80% of workers are on-site to receive notification, and 78.5% of large 

greenhouse workers and 51.6% of small greenhouse workers are employed on 

greenhouses making pesticide applications (NASS, 2008). 

Table A.3.a-13. Baseline Cost, per actor, Post REI Signs (Indoor Production) 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS Greenhouse 

Oral Notification 28.21 0.05 1.64 2.32

Signs 5.66 4 0.374 8.46

Posting Signs 28.21 0.333 14.9 140.53

Expected per-Greenhouse Cost (costr,i,a

B

) 151.31

Small WPS Greenhouse 

Oral Notification 28.21 0.05 1.21 1.71

Signs 5.66 4 0.276 6.25

Posting Signs 28.21 0.333 11.0 103.79

Expected per-Greenhouse Cost (costr,i,a

B

) 111.74

Receive Information 

Large Greenhouse worker 13.43 0.05 1.26 0.84

Small Greenhouse worker 13.43 0.05 0.83 0.55

New Regulation

NOTIFY-03. Permit oral notification if REI is less than 4 hours (indoor production). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 76 of 148

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are as in the baseline unless otherwise noted. 

 Large greenhouses will find it cheaper to post REIs than to notify the large number of 

empoyees. 

 EPA calculates there will be, on average, 3.64 oral notifications per small greenhouse per 

year. As in the baseline, EPA assumes 2 applications out of 20 require oral notification 

(double notification products) and another 4 oral notifications will be made for products 

with a REI less than 4 hours; 1.1 oral notifications will be made, on average, for each 

application to account for workers in different locations; and 55.2% of small greenhouses 

make pesticide applications in a year (NASS, 2008) [6 · 1.1 · .552]. 

 EPA calculates that small greenhouses will post signs, on average, 8.8 times per year (16 

applications and 55.2% of small greenhouses make pesticide applications). 

 Workers receive 1.65 oral notifications, on average, per year. There are 6 double 

notification events, 80% of workers are on-site to receive notification, and 55.2% of 

greenhouse workers are employed on greenhouses making pesticide applications (NASS, 

2008) [6 · 0.8 · 0.552]. 

Table A.3.a-14. Potential Cost, per actor, Oral Notification if REI < 4 hours (Indoor Production) 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Small Greenhouse 

Oral Notification 28.21 0.05 3.64 5.14

Signs 5.66 4 0.276 6.25

Posting Signs 28.21 0.333 8.8 83.03

Expected per-Greenhouse Cost (costr,i,a

P

) 94.41

Small Greenhouse worker 

Receive Information 13.43 0.05 1.65 1.11

Expected per-worker Cost (costr,i,a

P

) 1.11

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 879 WPS greenhouses employing 24,837 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.3.a-15. Regional Costs, Year 1, Oral Notification if REI < 4 hours (Indoor Production) 

Region (Large WPS GH) N lrg GH N wrkr lrg GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 151.31 $ 0.84

costr,i,a

P $ 151.31 $ 0.84

South 26 2,418 5,963 5,963

California 11 3,484 4,572 4,572

Southwest 6 697 1,430 1,430

Subtropical 4 984 1,488 1,488

Midwest 38 2,643 7,944 7,944

Northeast 18 2,459 4,787 4,787

Ohio Valley 40 3,115 8,710 8,710

Texas/Mountain West 21 1,639 4,622 4,622
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 77 of 148

Northwest 10 3,053 4,103 4,103

US (Large WPS GH) 174 20,492 $43,618 $43,618

Region (Small WPS GH) N sml GH N wrkr sml GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 111.74 $ 0.55

costr,i,a

P $ 94.41 $ 1.11

South 105 513 12,023 10,486

California 44 739 5,294 4,946

Southwest 23 148 2,603 2,294

Subtropical 18 209 2,085 1,895

Midwest 153 561 17,406 15,065

Northeast 73 521 8,403 7,434

Ohio Valley 163 660 18,564 16,108

Texas/Mountain West 87 348 9,883 8,572

Northwest 41 647 4,928 4,579

US (Small WPS Farm) 705 4,345 $81,189 $71,380

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.3.a-16. Regional Costs, PV (3% discount rate) and Incremental Cost, Oral Notification 

if REI < 4 hours (Indoor Production) 

Region (Large Greenhouse) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 50 50 0

California 38 38 0

Southwest 12 12 0

Subtropical 12 12 0

Midwest 67 67 0

Northeast 40 40 0

Ohio Valley 73 73 0

Texas/Mountain West 39 39 0

Northwest 34 34 0

Region (Small Greenhouse) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 90 104 -13

California 43 46 -3

Southwest 20 22 -3

Subtropical 16 18 -2

Midwest 130 150 -20

Northeast 64 72 -8

Ohio Valley 139 160 -21

Texas/Mountain West 74 85 -11

Northwest 39 42 -3

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.a-17. National and Per-WPS Greenhouse Costs, PV and Annualized (3% discount 

rate), Oral Notification if REI < 4 hours (Indoor Production) 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 78 of 148

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS GH, large 366 366 0

WPS GH, small 615 699 -84

Total 980 1,065 -84

-10 (௥ܥܫܣ) Annualized

per-entity ($/WPS GH) -1.84

per-entity ($/lrg WPS GH) 0.00

per-entity ($/sml WPS GH) -13.64

  

b. Record-Keeping, Oral Notification of REI (NOTIFY-04 and 05)

Baseline

Step 1. Calculate Baseline Costs 

 There are no baseline requirements 

New Regulation

NOTIFY-04. Keep record of oral notifications for 2 years. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 The employer must prepare a written copy of the warning, which takes one sheet of 

paper. The employer obtains the acknowledgement of the employees on the warning 

sheet and stores the acknowledgement, which requires a folder. 

 EPA assumes that preparing the warning takes 2 minutes, obtaining workers’ 

acknowledgement takes 6 minutes, and storing the acknowledgement takes one minute. 

 The annual frequency depends on farm size and type. 

o A large WPS farm (excluding greenhouses) is expected to have 12.6 oral 

notification events per year, on average. EPA assumes a large WPS will have 14 

oral notifications out of 20 applications (see A.3.a) and that 90.2% of large WPS 

non-greenhouse farms make pesticide application each year (NASS, 2008). 

Because workers may not be together or on site at the same time, EPA assumes 

that there will be 13.9 occasions to obtain acknowledgements, i.e., 10% more 

times than applications (Table A.3.a-1). 

o A small WPS farm (excluding greenhouses) is expected to have 15.0 oral 

notification events per year, on average. EPA assumes a large WPS will have 20 

oral notifications, i.e., all 20 applications (see A.3.a) and that 75.1% of small 

WPS non-greenhouse farms make pesticide application each year (NASS, 2008). 

Because workers may not be together or on site at the same time, EPA assumes 

that there will be 16.5 occasions to obtain acknowledgements, i.e., 10% more 

times than applications. 

o A WPS greenhouse is expected to have 1.18 oral notification events per year, on 

average. EPA assumes a WPS greenhouse will have 2 oral notifications out of 20 

applications (see A.3.a) and that 59.0% of WPS greenhouses make pesticide 

application each year (NASS, 2008). Because workers may not be together or on 

site at the same time, EPA assumes that there will be 1.30 occasions to obtain 

acknowledgements, i.e., 10% more times than applications. 

 Folders are needed with the same frequency as a farm of given size or type makes 

pesticide applications. 
** * EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 79 of 148

 Workers spend 30 seconds acknowledging receipt of information. 

 Workers on large and small WPS farms and nurseries acknowledge receipt of information 

10.6 times and 13.0 times, on average, each year. EPA assumes 16 oral notifications out 

of 20 applications, there is an 80% chance a worker will be on-farm during the REI, and 

94.6% of workers employed on large WPS farms and nurseries and 81.4% of workers 

employed on small WPS farms and nurseries are employed on establishments making a 

pesticide application (NASS, 2008b) (16 · 0.8 · 0.946 and 16 · 0.8 · 0.814). 

 Workers in greenhouses acknowledge receipt of information 1.18 times per year, on 

average. There are 2 notification events, 80% of workers are on-site to receive 

notification, and 73.8% of greenhouse workers are employed in greenhouses making 

pesticide applications (NASS, 2008). 

Table A.3.b-1. Potential Cost, by actors, Keep record of oral notifications, 2 years. 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Prepare copy of warning 28.21 0.033 12.6 11.88

Information sheet 0.09 1 12.6 1.14

Obtain acknowledgement 28.21 0.05 13.9 19.60

Store acknowledgement 28.21 0.017 12.6 5.94

Folder 0.20 1 0.902 0.18

Expected per-Large farm Cost (costr,i,a

P

) 38.73

Small WPS farm 1

Prepare copy of warning 28.21 0.033 15.0 14.12

Information sheet 0.09 1 15.0 1.35

Obtain acknowledgement 28.21 0.05 16.5 23.30

Store acknowledgement 28.21 0.017 15.0 7.06

Folder 0.20 1 0.751 0.15

Expected per-Small farm Cost (costr,i,a

P

) 45.98

WPS Greenhouse 

Prepare copy of warning 28.21 0.033 1.18 1.11

Information sheet 0.09 1 1.18 0.11

Obtain acknowledgement 28.21 0.05 1.30 1.83

Store acknowledgement 28.21 0.017 1.18 0.56

Folder 0.20 1 0.590 0.12

Expected per-Greenhouse Cost (costr,i,a

P

) 3.72

WPS Worker (costr,i,a

P

)

Large WPS farm 1 13.43 0.008 10.6 1.19

Small WPS farm 1 13.43 0.008 13.0 1.46

WPS Greenhouse 13.43 0.008 1.18 0.13

1

 Excluding greenhouses. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 393,779 non-greenhouse WPS farms (54,115 large and 339,664 small) employing 

2,297,476 workers (1,063,664 on large establishments and 1,234,144 on small establishments) 

and 879 WPS greenhouses employing 24,837 workers (NASS, 2008). WPS farms, defined as 

those hiring labor, are distributed across regions in the same proportion as all farms. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 80 of 148

Table A.3.b-2. Regional Costs, Year 1, Keep record of oral notifications, 2 years 

Region (WPS Farm) 1 N lrg farm N wrkr lrg frm N sml farm N wrkr sml frm

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 $ 0.00 $ 0.00

costr,i,a

P $ 38.73 $ 1.19 $ 45.98 $ 1.46

South 8,063 125,508 50,610 145,629 0 3,000,720

California 3,355 180,817 21,059 209,804 0 1,618,619

Southwest 1,732 36,163 10,869 41,961 0 670,946

Subtropical 1,353 51,054 8,492 59,239 0 589,783

Midwest 11,743 137,208 73,707 159,205 0 4,239,031

Northeast 5,574 127,635 34,985 148,097 0 2,191,932

Ohio Valley 12,501 161,672 78,462 187,590 0 4,557,436

Texas/Mountain West 6,656 85,090 41,779 98,732 0 2,423,825

Northwest 3,139 158,481 19,701 183,887 0 1,483,489

US (WPS Farm) 1 54,115 1,063,629 339,664 1,234,144 $ 0 $20,775,779

Region (WPS Greenhouse) N GH N wrkr GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00

costr,i,a

P $ 3.72 $ 0.13

South 131 2,931 0 875

California 54 4,222 0 761

Southwest 28 844 0 216

Subtropical 22 1,192 0 239

Midwest 191 3,204 0 1,134

Northeast 91 2,980 0 731

Ohio Valley 203 3,775 0 1,255

Texas/Mountain West 108 1,987 0 665

Northwest 51 3,701 0 679

US (Greenhouse) 879 24,837 $ 0 $6,556

1

 Excluding greenhouses. 

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.3.b-3. Regional Costs, PV (3% discount rate) and Incremental Cost, Keep record of oral 

notifications, 2 years 

Region (WPS Farm) 1 PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 25,633 0 25,633

California 13,637 0 13,637

Southwest 5,718 0 5,718

Subtropical 4,994 0 4,994

Midwest 36,278 0 36,278

Northeast 18,664 0 18,664

Ohio Valley 38,979 0 38,979

Texas/Mountain West 20,732 0 20,732

Northwest 12,510 0 12,510
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 81 of 148

Region (Greenhouse) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 7 0 7

California 6 0 6

Southwest 2 0 2

Subtropical 2 0 2

Midwest 10 0 10

Northeast 6 0 6

Ohio Valley 11 0 11

Texas/Mountain West 6 0 6

Northwest 6 0 6

1

 Excluding greenhouses. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.b-4. National and Per-WPS Greenhouse Costs, PV and Annualized (3% discount 

rate), Keep record of oral notifications, 2 years 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Farm 1 177,144 0 177,144

WPS Greenhouse 55 0 55

Total 177,198 0 177,198

20,168 (௥ܥܫܣ) Annualized

per-entity ($/all WPS farms) 51.10

per-entity ($/WPS farm) 1 51.20

per-entity ($/WPS GH) 7.06

1

 Excluding greenhouses. 

NOTIFY-05. Keep record of oral notifications for 5 years. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 All parameters are as in NOTIFY-04, plus a storage box to maintain the records for an 

extended period of time. 

 All farms will eventually need a storage box, which must be replaced every five years. 

Table A.3.b-5. Potential Cost, by actors, Keep record of oral notifications, 5 years. 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Prepare copy of warning 28.21 0.033 12.6 11.88

Information sheet 0.09 1 12.6 1.14

Obtain acknowledgement 28.21 0.05 13.9 19.60

Store acknowledgement 28.21 0.017 12.6 5.94

Folder 0.20 1 0.902 0.18

Storage box 4.23 1 0.2 0.85

Expected per-Large farm Cost (costr,i,a

P

) 39.58

Large-Small WPS farm 1

Prepare copy of warning 28.21 0.033 15.0 14.12

Information sheet 0.09 1 15.0 1.35

Obtain acknowledgement 28.21 0.05 16.5 23.30
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 82 of 148

Store acknowledgement 28.21 0.017 15.0 7.06

Folder 0.20 1 0.751 0.15

Storage box 4.23 1 0.2 0.85

Expected per-Small farm Cost (costr,i,a

P

) 46.83

WPS Greenhouse 

Prepare copy of warning 28.21 0.033 1.18 1.11

Information sheet 0.09 1 1.18 0.11

Obtain acknowledgement 28.21 0.05 1.30 1.83

Store acknowledgement 28.21 0.017 1.18 0.56

Folder 0.20 1 0.590 0.12

Storage box 4.23 1 0.2 0.85

Expected per-Greenhouse Cost (costr,i,a

P

) 4.57

WPS Worker (costr,i,a

P

)

Large WPS farm 1 13.43 0.008 10.6 1.19

Small WPS farm 1 13.43 0.008 13.0 1.46

WPS Greenhouse 13.43 0.008 1.2 0.13

1

 Excluding greenhouses. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 393,779 non-greenhouse WPS farms (54,115 large and 339,664 small) employing 

2,297,476 workers (1,063,664 on large establishments and 1,234,144 on small establishments) 

and 879 WPS greenhouses employing 24,837 workers (NASS, 2008). WPS farms, defined as 

those hiring labor, are distributed across regions in the same proportion as all farms. 

Table A.3.b-6. Regional Costs, Year 1, Keep record of oral notifications, 5 years 

Region (WPS Farm) 1 N lrg farm N wrkr lrg frm N sml farm N wrkr sml frm

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 $ 0.00 $ 0.00

costr,i,a

P $ 39.58 $ 1.19 $ 46.83 $ 1.46

South 8,063 50,610 125,508 145,629 0 3,050,357

California 3,355 21,059 180,817 209,804 0 1,639,273

Southwest 1,732 10,869 36,163 41,961 0 681,606

Subtropical 1,353 8,492 51,054 59,239 0 598,111

Midwest 11,743 73,707 137,208 159,205 0 4,311,322

Northeast 5,574 34,985 127,635 148,097 0 2,226,245

Ohio Valley 12,501 78,462 161,672 187,590 0 4,634,390

Texas/Mountain West 6,656 41,779 85,090 98,732 0 2,464,801

Northwest 3,139 19,701 158,481 183,887 0 1,502,811

US (WPS Farm) 1 54,115 339,664 1,063,629 1,234,144 0 $21,108,916

Region (WPS Greenhouse) N GH N wrkr GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00

costr,i,a

P $ 4.57 $ 0.13

South 131 2,931 0 986

California 54 4,222 0 807

Southwest 28 844 0 240

Subtropical 22 1,192 0 258

Midwest 191 3,204 0 1,295

Northeast 91 2,980 0 808

Ohio Valley 203 3,775 0 1,427
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 83 of 148

Texas/Mountain West 108 1,987 0 757

Northwest 51 3,701 0 722

US (Greenhouse) 879 24,837 0 $ 7,299

1

 Excluding greenhouses. 

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.3.b-7. Regional Costs, PV (3% discount rate) and Incremental Cost, Keep record of oral 

notifications, 5 years 

Region (WPS Farm) 1 PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 26,060 0 26,060

California 13,814 0 13,814

Southwest 5,810 0 5,810

Subtropical 5,065 0 5,065

Midwest 36,901 0 36,901

Northeast 18,959 0 18,959

Ohio Valley 39,642 0 39,642

Texas/Mountain West 21,085 0 21,085

Northwest 12,677 0 12,677

Region (Greenhouse) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 8 0 8

California 7 0 7

Southwest 2 0 2

Subtropical 2 0 2

Midwest 11 0 11

Northeast 7 0 7

Ohio Valley 12 0 12

Texas/Mountain West 6 0 6

Northwest 6 0 6

1

 Excluding greenhouses. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.b-8. National and Per-WPS Greenhouse Costs, PV and Annualized (3% discount 

rate), Keep record of oral notifications, 5 years 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Farm 1 180,013 0 180,013

WPS Greenhouse 61 0 61

Total 180,074 0 180,074

20,495 (௥ܥܫܣ) Annualized

per-entity ($/all WPS farms) 51.93

per-entity ($/WPS farm) 1 52.03

per-entity ($/WPS GH) 7.89

1

 Excluding greenhouses. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 84 of 148

c. Content of Warning Signs (NOTIFY-06 and 07) 

Baseline

Step 1. Calculate Baseline Costs 

 Baseline consists of the signs, as in Tables A.3.a-1 and A.3.a-13. 

Table A.3.c-1. Baseline Cost, per WPS farm, Revise Warning Signs 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Signs 5.66 4 0.329 7.45

Signs 5.66 6 0.122 4.15

Expected per-Large farm Cost (costr,i,a

B

) 11.59

Large-Small WPS farm 1

Signs 5.66 2 0.368 4.17

Signs 5.66 3 0.081 1.37

Expected per-Lrg Small farm Cost (costr,i,a

B

) 5.54

Med/Sml-Small WPS farm 1

Signs 5.66 2 0.307 3.47

Signs 5.66 3 0.018 0.30

Expected per-Med/Sml Small farm Cost (costr,i,a

B

) 3.77

WPS Greenhouse 

Signs 5.66 4 0.295 6.68

Expected per-greenhouse Cost (costr,i,a

B

) 6.68

1

 Excluding greenhouses. 

New Regulations

NOTIFY-06. Revise content of signs to, among other changes, read “Restricted Entry 

Area.” 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes revised signs will cost 5% more, or $5.94 each, as a result of changes in 

content, but not in lettering. 

 All other parameters are as in the baseline. 

Table A.3.c-2. Potential Cost, per WPS farm, Revise Warning Signs 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Signs 5.94 4 0.329 7.82

Signs 5.94 6 0.122 4.35

Expected per-Large farm Cost (costr,i,a

P

) 12.17

Large-Small WPS farm 1

Signs 5.94 2 0.368 4.38

Signs 5.94 3 0.081 1.44

Expected per-Lrg Small farm Cost (costr,i,a

P

) 5.82
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 85 of 148

Med/Sml-Small WPS farm 1

Signs 5.94 2 0.307 3.64

Signs 5.94 3 0.018 0.32

Expected per-Med/Sml Small farm Cost (costr,i,a

B

) 3.96

WPS Greenhouse 

Signs 5.94 4 0.295 7.02

Expected per-greenhouse Cost (costr,i,a

P

) 7.02

1

 Excluding greenhouses. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 393,779 non-greenhouse WPS farms and 879 WPS greenhouses (NASS, 2008 [Census 

of Ag]). California already requires additional content similar to the potential requirement. 

Table A.3.c-3. Regional Costs, Year 1, Revise Warning Signs 

Region (WPS Farm) 1 N lrg N lrg-sml N sml

RC B

($) 

RC P

($) 

costr,i,a

B $ 11.59 $ 5.54 $ 3.77

costr,California,a

B $ 12.17 $ 5.82 $ 3.96

costr,i,a

P $ 12.17 $ 5.82 $ 3.96

South 8,063 20,704 29,906 321,000 337,050

California 3,355 8,615 12,444 140,249 140,249

Southwest 1,732 4,446 6,423 68,940 72,387

Subtropical 1,353 3,474 5,018 53,859 56,552

Midwest 11,743 30,152 43,555 467,497 490,871

Northeast 5,574 14,312 20,673 221,899 232,994

Ohio Valley 12,501 32,098 46,365 497,658 522,541

Texas/Mountain West 6,656 17,091 24,688 264,987 278,236

Northwest 3,139 8,059 11,641 124,953 131,201

US 54,115 138,951 200,713 $2,161,041 $2,262,080

Region (Greenhouse) N WPS GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 6.68

costr,California,a

B $ 7.02

costr,i,a

P $ 7.02

South 131 875 919

California 54 382 382

Southwest 28 188 197

Subtropical 22 147 154

Midwest 191 1,275 1,339

Northeast 91 605 635

Ohio Valley 203 1,357 1,425

Texas/Mountain West 108 723 759

Northwest 51 341 358

US 879 $5,893 $6,169

1

 Excluding greenhouses. 

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. Data do not distinguish between 

greenhouses and other types of farms. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 86 of 148

Table A.3.c-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Revise Warning 

Signs 

Region (WPS Farm) 1 PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 2,903 2,765 138

California 1,208 1,208 0

Southwest 623 594 30

Subtropical 487 464 23

Midwest 4,228 4,026 201

Northeast 2,007 1,911 96

Ohio Valley 4,500 4,286 214

Texas/Mountain West 2,396 2,282 114

Northwest 1,130 1,076 54

Region (Greenhouse)

PV(RC P

) 

($1000)

PV(RC B) 

($1,000)

PV(IC) 

($1,000)

South 8 8 0.4

California 3 3 0.0

Southwest 2 2 0.1

Subtropical 1 1 0.1

Midwest 12 11 0.5

Northeast 5 5 0.3

Ohio Valley 12 12 0.6

Texas/Mountain West 7 6 0.3

Northwest 3 3 0.1

1

 Excluding greenhouses. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.c-5. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Revise Warning Signs 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS farm 1 19,482 18,612 870

WPS greenhouse 53 51 2

Total 19,535 18,663 873

99 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 0.25

per-entity ($/WPS farm) 1 0.25

per-entity ($/WPS greenhouse) 0.31

1

 Excluding greenhouses. 

NOTIFY-07. Revise signs (e.g., Skull and Cross-bones) and require application-specific 

information to be posted. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 A writable sign costs $7.15 (Gempler). 

 EPA assumes the owner/operator of the establishment will spend 3 minutes updating each 

sign with application information prior to posting, i.e., 6 minutes for updating 2 posters 

and 9 minutes for updating 3 posters. 

 Annual frequency of posting is as in the baseline. See Tables A.3.a-1 and A.3.a-13. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 87 of 148

Table A.3.c-6. Potential Cost, per WPS farm, Revise Warning Signs (variant) 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Writable Signs 7.15 4 0.329 9.41

Add Information 28.21 0.1 5.26 14.85

Writable Signs 7.15 6 0.122 5.24

Add Information 28.21 0.15 1.95 8.27

Expected per-Large farm Cost (costr,i,a

P

) 37.76

Large-Small WPS farm 1

Writable Signs 7.15 2 0.368 5.27

Add Information 28.21 0.1 1.47 4.16

Writable Signs 7.15 3 0.081 1.73

Add Information 28.21 0.15 0.323 0.91

Expected per-Lrg-Sml farm Cost (costr,i,a

P

) 12.07

Med/Sml-Small WPS farm 1

Writable Signs 7.15 2 0.307 4.39

Add Information 28.21 0.1 1.23 3.46

Writable Signs 7.15 3 0.018 0.38

Add Information 28.21 0.15 0.071 0.20

Expected per-Med/Sml-Small farm Cost (costr,i,a

P

) 8.43

WPS Greenhouse 

Writable Signs 7.15 4 0.295 8.44

Add Information 28.21 0.1 11.8 33.32

Expected per-greenhouse Cost (costr,i,a

P

) 41.76

1

 Excluding greenhouses. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 393,779 non-greenhouse WPS farms and 879 WPS greenhouses (NASS, 2008 [Census 

of Ag]). California already requires additional content similar to the potential requirement 

NOTIFY-06 (see Table A.3.c-2). 

Table A.3.c-7. Regional Costs, Year 1, Revise Warning Signs (variant) 

Region (WPS Farm) 1 N lrg farm N lrg-sml farm N med/sml-sml farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 11.59 $ 5.54 $ 3.77 

costr,California,a

B $ 12.17 $ 5.82 $ 3.96 

costr,i,a

P $ 37.76 $12.07 $ 8.43 

South 8,063 20,704 29,906 321,000 806,315

California 3,355 8,615 12,444 140,249 335,514

Southwest 1,732 4,446 6,423 68,940 173,168

Subtropical 1,353 3,474 5,018 53,859 135,288

Midwest 11,743 30,152 43,555 467,497 1,174,298

Northeast 5,574 14,312 20,673 221,899 557,386

Ohio Valley 12,501 32,098 46,365 497,658 1,250,059

Texas/Mountain West 6,656 17,091 24,688 264,987 665,616

Northwest 3,139 8,059 11,641 124,953 313,868

US 54,115 138,951 200,713 $2,161,041 $5,411,511
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 88 of 148

Region (Greenhouse) N WPS GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 6.68

costr,California,a

B $ 7.02 

costr,i,a

P $ 41.76

South 131 875 5,470

California 54 382 2,276

Southwest 28 188 1,175

Subtropical 22 147 918

Midwest 191 1,275 7,966

Northeast 91 605 3,781

Ohio Valley 203 1,357 8,480

Texas/Mountain West 108 723 4,515

Northwest 51 341 2,129

US 879 $5,893 $36,708

1

 Excluding greenhouses. 

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. Data do not distinguish between 

greenhouses and other types of farms. 

Table A.3.c-8. Regional Costs, PV (3% discount rate) and Incremental Cost, Revise Warning 

Signs (variant) 

Region (WPS Farm) 1 PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 6,944 2,765 4,180

California 2,890 1,208 1,682

Southwest 1,491 594 898

Subtropical 1,165 464 701

Midwest 10,114 4,026 6,087

Northeast 4,800 1,911 2,889

Ohio Valley 10,766 4,286 6,480

Texas/Mountain West 5,733 2,282 3,450

Northwest 2,703 1,076 1,627

Region (Greenhouse)

PV(RC P) 

($1000)

PV(RC B) 

($1,000)

PV(IC) 

($1,000)

South 47 8 40

California 20 3 16

Southwest 10 2 8

Subtropical 8 1 7

Midwest 69 11 58

Northeast 33 5 27

Ohio Valley 73 12 61

Texas/Mountain West 39 6 33

Northwest 18 3 15

1

 Excluding greenhouses. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 89 of 148

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.c-9. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Revise Warning Signs (variant) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS farm 1 46,606 18,612 27,995

WPS greenhouse 316 51 265

Total 46,923 18,663 28,260

3,216 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 8.15

per-entity ($/WPS farm) 1 8.09

per-entity ($/WPS greenhouse) 34.36

1

 Excluding greenhouses. 

d. Location of Warning Signs (NOTIFY-08 and 09) 

Baseline

Step 1. Calculate Baseline Costs 

 Posting is required at usual points of entrance to a field or at the corners and if near 

worker housing. Baseline consists of the signs and time to post, as in Tables A.3.a-1 and 

A.3.a-13. 

Table A.3.d-1. Baseline Cost, per actor, Location of REI Warning Signs 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Warning Signs 5.66 4 0.329 7.45

Post 2 Signs 28.21 0.333 5.26 49.51

Warning Signs 5.66 6 0.122 4.15

Post 3 Signs 28.21 0.5 1.95 27.55

Expected per-Large farm Cost (costr,i,a

B

) 88.65

Large-Small WPS farm 1

Warning Signs 5.66 2 0.368 4.17

Post 2 Signs 28.21 0.333 1.47 13.86

Warning Signs 5.66 3 0.081 1.37

Post 3 Signs 28.21 0.5 0.32 4.55

Expected per-Lrg Small farm Cost (costr,i,a

B

) 23.95

Med/Sml-Small WPS farm 1

Warning Signs 5.66 2 0.307 3.47

Post 2 Signs 28.21 0.333 1.23 11.54

Warning Signs 5.66 3 0.018 0.30

Post 3 Signs 28.21 0.5 0.07 1.00

Expected per-Med/Sml Small farm Cost (costr,i,a

B

) 16.31

WPS greenhouse 

Warning Signs 5.66 4 0.295 6.68

Post Sign 28.21 0.333 11.8 111.06

Expected per-greenhouse Cost (costr,i,a

B

) 117.74

1

 Excluding greenhouses. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 90 of 148

New Regulation

NOTIFY-08. REI warning signs if worker housing within 100 feet of treated area. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Revision specifies distance, but is unlikely to result in changes. Parameters are as in the 

baseline. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 393,779 non-greenhouse WPS farms and 879 WPS greenhouses (NASS, 2008). Since 

the revision provides clarity only, baseline and potential costs are the same (see baseline in Table 

A.3.d-3). 

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. Data do not distinguish between 

greenhouses and other types of farms. Since the revision provides clarity only, PV of baseline 

and potential cost are the same (see baseline in Table A.3.d-4). Incremental costs are zero. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

This revision is for clarity. Incremental costs are zero. 

New Regulation

NOTIFY-09. REI warning signs placed every 100 feet around perimeter of field. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 As a representative case for non-greenhouse WPS farms, EPA takes a square, 40-acre 

field. Each side is 1,320 feet in length, necessitating 13 or 14 signs per side or about 53 

signs around the perimeter. 

o Smaller fields would require fewer signs, but less regularly shaped fields could 

require more. For example, if the field above is cut in half across opposite 

corners to form a triangular field of 20 acres, two sides would be 1,320 feet and 

the third would be 1,867 feet. The longer side would need 19 signs for a total of 

45 to 47 signs. 

 As a representative case for WPS greenhouses, EPA takes a rectangular 1-acre plot 66 

feet by 660 feet, requiring 7 signs on the longer sides or 14 signs total. To account for 

simultaneous posting, a greenhouse is assumed to need 28 signs. 

 At 10 minutes per sign, it would take a WPS farm nearly 9 hours to post and later remove 

53 signs around a field and it would take a WPS greenhouse 2 hours 20 minutes to 

post/remove 14 signs. 

 Annual frequency for the purchase of signs is as in the baseline, with no distinction for 

fields near worker housing. 

 Annual frequency for posting events is as in the baseline, with no distinction for fields 

near worker housing. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 91 of 148

Table A.3.d-2. Potential Cost, perWPS farm, Locate REI Warning Signs every 100 feet 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Warning Signs 5.66 106 0.451 270.62

Post 55 Signs 28.21 8.83 7.22 1798.68

Expected per-Large farm Cost (costr,i,a

P

) 2069.31

Large-Small WPS farm 1

Warning Signs 5.66 53 0.449 134.71

Post 55 Signs 28.21 8.83 1.80 447.66

Expected per-Lrg Small farm Cost (costr,i,a

P

) 582.36

Med/Sml-Small WPS farm 1

Warning Signs 5.66 53 0.324 97.31

Post 55 Signs 28.21 8.83 1.30 323.39

Expected per-Med/Sml Small farm Cost (costr,i,a

P

) 420.70

WPS greenhouse 

Warning Signs 5.66 28 0.295 46.79

Post 14 Signs 28.21 2.33 11.8 777.42

Expected per-greenhouse Cost (costr,i,a

P

) 824.20

1

 Excluding greenhouses. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 393,779 non-greenhouse WPS farms and 879 WPS greenhouses (NASS, 2008 [Census 

of Ag]). 

Table A.3.d-3. Regional Costs, Year 1, Locate REI Warning Signs every 100 feet 

Region (WPS Farm) 1 N lrg farm N lrg-sml farm N med/sml-sml farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 88.65 $ 23.95 $ 16.31

costr,i,a

P $2069.31 $582.36 $420.70

South 8,063 20,704 29,906 1,698,431 41,323,631

California 3,355 8,615 12,444 706,730 17,195,068

Southwest 1,732 4,446 6,423 364,764 8,874,874

Subtropical 1,353 3,474 5,018 284,972 6,933,495

Midwest 11,743 30,152 43,555 2,473,553 60,182,737

Northeast 5,574 14,312 20,673 1,174,083 28,566,000

Ohio Valley 12,501 32,098 46,365 2,633,137 64,065,494

Texas/Mountain West 6,656 17,091 24,688 1,402,060 34,112,796

Northwest 3,139 8,059 11,641 661,134 16,085,709

US 54,115 138,951 200,713 $11,398,863 $277,339,802

Region (Greenhouse) N WPS GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 117.74

costr,i,a

P $ 824.20

South 131 15,421 107,947

California 54 6,417 44,917

Southwest 28 3,312 23,183

Subtropical 22 2,587 18,112

Midwest 191 22,459 157,211

Northeast 91 10,660 74,621
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 92 of 148

Ohio Valley 203 23,908 167,354

Texas/Mountain West 108 12,730 89,110

Northwest 51 6,003 42,020

US 879 $103,497 $724,476

1

 Excluding greenhouses. 

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. Data do not distinguish between 

greenhouses and other types of farms. 

Table A.3.d-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Locate REI 

Warning Signs every 100 feet 

Region, WPS farms 1

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 355,898 14,628 341,271

California 148,092 6,087 142,005

Southwest 76,435 3,142 73,293

Subtropical 59,714 2,454 57,260

Midwest 518,322 21,303 497,018

Northeast 246,024 10,112 235,912

Ohio Valley 551,762 22,678 529,084

Texas/Mountain West 293,795 12,075 281,720

Northwest 138,538 5,694 132,844

Region, WPS greenhouses

PV(RC P) 

($1000)

PV(RC B) 

($1,000)

PV(IC) 

($1,000)

South 930 133 797

California 387 55 332

Southwest 200 29 171

Subtropical 156 22 134

Midwest 1,354 193 1,161

Northeast 643 92 551

Ohio Valley 1,441 206 1,235

Texas/Mountain West 767 110 658

Northwest 362 52 310

1

 Excluding greenhouses. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.d-5. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Locate REI Warning Signs every 100 feet 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS farm, excl. greenhouse 2,388,579 98,172 2,290,407

WPS greenhouse 6,240 891 5,348

Total 2,394,818 99,064 2,295,755

261,294 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 662.08

per-entity ($/WPS farm) 1 662.01

per-entity ($/WPS greenhouse) 692.50
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 93 of 148

e. Early Entry Notification Requirements (NOTIFY-10 and 11)

Baseline

Step 1. Calculate Baseline Costs 

 The operator’s time is valued at $28.21/hr, consisting of the wage and an additional 30% 

for benefits (BLS, 2008). 

 EPA assumes that gathering the currently required information takes 1 minute. 

 EPA assumes that providing the information takes 3 minutes. 

 EPA calculates the probability of an early entry event to be 30.8% 

o EPA assumes that there will be an early entry event about 1 every 50 applications 

or 2% of applications. 

o Assuming 20 applications farm per year, there is a 40% probability a WPS farm 

applying pesticides will have an early entry event. 

o 77.1% of WPS farms apply pesticides in any given year (NASS, 2008), there is a 

33.4% chance a WPS farm will have an early entry event. 

Table A.3.e-1. Baseline Cost, per WPS farm, Early Entry Notification 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Gather Information 28.21 0.017 0.308 0.15

Provide Information 28.21 0.05 0.308 0.44

Expected per-farm Cost (costr,i,a

B

) 0.58

 Workers spend 3 minutes receiving information from the owner/operator. 

 EPA calculates that there is a probability of 17.5% that any individual worker will be 

involved in an early entry event. 

o As above, 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 a particular early entry event 

o 87.4% of workers are employed on WPS farms that apply pesticides in any given 

year (NASS, 2008). 

Table A.3.e-2. Baseline Cost, per WPS worker, Early Entry Notification 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Receive Information 13.43 0.05 0.175 0.12

Expected per-worker Cost (costr,i,a

B

) 0.12

New Regulation

NOTIFY-10. Oral information provided before entry during the REI. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes that gathering the necessary information will take 6 minutes. 

 EPA assumes that providing the information will take 6 minutes. 

 All other parameters are as in the baseline. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 94 of 148

Table A.3.e-3. Potential Cost, per actor, Early Entry Oral Notification 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

WPS farm 

Gather Information 28.21 0.1 0.308 0.87

Provide Information 28.21 0.1 0.308 0.87

Expected per-farm Cost (costr,i,a

P

) 1.74

WPS Worker 

Receive Information 13.43 0.1 0.175 0.23

Expected per-worker Cost (costr,i,a

P

) 0.23

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.3.e-4. Regional Costs, Year 1, Early Entry Oral Notification 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.58 $ 0.12 

costr,i,a

P $ 1.74 $ 0.23 

South 58,804 274,068 66,298 166,715

California 24,469 394,844 60,557 135,311

Southwest 12,629 78,969 16,599 40,527

Subtropical 9,866 111,485 18,814 43,354

Midwest 85,641 299,617 84,869 219,427

Northeast 40,650 278,713 56,310 136,206

Ohio Valley 91,166 353,037 94,347 241,589

Texas/Mountain West 48,543 185,809 49,982 128,128

Northwest 22,890 346,069 53,914 121,109

US 394,658 2,322,610 $ 501,690 $1,232,366

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.3.e-5. Regional Costs, PV (3% discount rate) and Incremental Cost, Early Entry Oral 

Notification 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,398 552 846

California 1,111 494 617

Southwest 338 138 201

Subtropical 358 154 204

Midwest 1,849 710 1,138

Northeast 1,135 466 669

Ohio Valley 2,032 788 1,244
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 95 of 148

Texas/Mountain West 1,078 418 660

Northwest 996 441 555

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.e-6. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), Early 

Entry Oral Notification 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 10,296 4,162 6,134

698 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 1.77

NOTIFY-11. Oral and written information provided before entry during the REI. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes that gathering the necessary information will take 6 minutes. 

 EPA assumes that writing the information will take 6 minutes. 

 EPA assumes that providing the information orally will take 6 minutes. 

 Each worker entering the field will receive a 1-page written crop sheet. 

 All other parameters are as in the baseline. 

Table A.3.e-7. Potential Cost, per actor, Early Entry Oral and Written Notification 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

WPS farm 

Gather Information 28.21 0.1 0.308 0.87

Write Information 28.21 0.1 0.308 0.87

Provide Information 28.21 0.1 0.308 0.87

Expected per-farm Cost (costr,i,a

P

) 2.61

WPS Worker 

Receive Information 13.43 0.1 0.175 0.23

Information Sheet 0.09 1 0.175 0.02

Expected per-worker Cost (costr,i,a

P

) 0.25

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.3.e-8. Regional Costs, Year 1, Early Entry Oral and Written Notification 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.58 $ 0.12 

costr,i,a

P $ 2.61 $ 0.25 

South 58,804 274,068 66,298 222,207

California 24,469 394,844 60,557 162,821

Southwest 12,629 78,969 16,599 52,761

Subtropical 9,866 111,485 18,814 53,695

Midwest 85,641 299,617 84,869 298,678
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 96 of 148

Northeast 40,650 278,713 56,310 175,970

Ohio Valley 91,166 353,037 94,347 326,489

Texas/Mountain West 48,543 185,809 49,982 173,301

Northwest 22,890 346,069 53,914 146,478

US 394,658 2,322,610 $ 501,690 $1,612,399

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.3.e-9. Regional Costs, PV (3% discount rate) and Incremental Cost, Early Entry Oral 

and Written Notification 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,874 552 1,321

California 1,345 495 850

Southwest 443 138 305

Subtropical 446 154 292

Midwest 2,529 710 1,818

Northeast 1,475 466 1,009

Ohio Valley 2,760 788 1,972

Texas/Mountain West 1,465 418 1,048

Northwest 1,211 441 770

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.e-10. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Early Entry Oral and Written Notification 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 13,547 4,162 9,385

1,068 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 2.71

f. Early Entry Notification Record Keeping (NOTIFY-12 and 13)

Baseline

Step 1. Calculate Baseline Costs 

There are currently no federal or state requirements. 

New Regulation

NOTIFY-12. Records of information provided prior to early entry to be kept for 2 years. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 One record sheet is sufficient for all workers involved to indicate receipt of information. 

 Farm owner/operator is responsible for receiving and storing records. 

 EPA assumes it will take 3 minutes to collect the acknowledgments from workers. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 97 of 148

 EPA assumes it will take 4 minutes to sort and file the information and 

acknowledgements. 

 To keep the records, each operation will require a folder costing about $0.20 (Staples, 

2008). 

 There is a 30.8% probability that a WPS farm will have an early entry event and an 

17.5% probability that a worker will be part of an early entry event in any given year. 

(See A.2.d). 

Table A.3.f-1. Potential Cost, per actor, Early Entry Notification Record Keeping (2 years) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

WPS farm 

Record Sheet 0.09 1 0.308 0.03

Receive Acknowledgements 28.21 0.05 0.308 0.44

Collect/Store Record 28.21 0.067 0.308 0.58

Folder 0.20 1 0.308 0.06

Expected per-farm Cost (costr,i,a

P

) 1.10

WPS Worker 

Acknowledge Information 13.43 0.008 0.175 0.02

Expected per-worker Cost (costr,i,a

P

) 0.02

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 

Table A.3.f-2. Regional Costs, Year 1, Early Entry Notification Record Keeping (2 years) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 

costr,i,a

P $ 1.10 $ 0.02 

South 58,804 274,068 0 70,332

California 24,469 394,844 0 34,760

Southwest 12,629 78,969 0 15,498

Subtropical 9,866 111,485 0 13,082

Midwest 85,641 299,617 0 100,481

Northeast 40,650 278,713 0 50,365

Ohio Valley 91,166 353,037 0 107,631

Texas/Mountain West 48,543 185,809 0 57,268

Northwest 22,890 346,069 0 32,062

US 394,658 2,322,610 $ 0 $ 481,480

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 98 of 148

Table A.3.f-3. Regional Costs, PV (3% discount rate) and Incremental Cost, Early Entry 

Notification Record Keeping (2 years) 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 603 0 603

California 295 0 295

Southwest 133 0 133

Subtropical 111 0 111

Midwest 862 0 862

Northeast 431 0 431

Ohio Valley 923 0 923

Texas/Mountain West 491 0 491

Northwest 272 0 272

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.f-4. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), Early 

Entry Notification Record Keeping (2 years) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 4,120 0 4,120

469 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 1.19

NOTIFY-13. Records of information provided prior to early entry to be kept for 5 years. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 As above, but each operation will also need a storage box to hold files, which costs $4.23 

(Staples, 2008). 

 The storage box is replaced every five years. 

Table A.3.f-5. Potential Cost, per actor, Early Entry Notification Record Keeping (5 years) 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

WPS farm 

Record Sheet 0.09 1 0.308 0.03

Receive Acknowledgements 28.21 0.05 0.308 0.44

Collect/Store Record 28.21 0.067 0.308 0.58

Folder 0.20 1 0.308 0.06

Storage Box 4.23 1 0.2 0.85

Expected per-farm Cost (costr,i,a

P

) 1.95

WPS Worker 

Acknowledge Information 13.43 0.008 0.175 0.02

Expected per-worker Cost (costr,i,a

P

) 0.02

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 394,658 WPS farms employing 2,322,610 workers (NASS, 2008 [Census of Ag]). 

WPS farms, defined as those hiring labor, are distributed across regions in the same proportion 

as all farms. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 99 of 148

Table A.3.f-6. Regional Costs, Year 1, Early Entry Notification Record Keeping (5 years) 

Region N WPS farm N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 

costr,i,a

P $ 1.95 $ 0.02 

South 58,804 274,068 0 120,080

California 24,469 394,844 0 55,461

Southwest 12,629 78,969 0 26,182

Subtropical 9,866 111,485 0 21,429

Midwest 85,641 299,617 0 172,934

Northeast 40,650 278,713 0 84,755

Ohio Valley 91,166 353,037 0 184,758

Texas/Mountain West 48,543 185,809 0 98,335

Northwest 22,890 346,069 0 51,427

US 394,658 2,322,610 $ 0 $ 815,361

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.3.f-7. Regional Costs, PV (3% discount rate) and Incremental Cost, Early Entry 

Notification Record Keeping (5 years) 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,031 0 1,031

California 473 0 473

Southwest 225 0 225

Subtropical 183 0 183

Midwest 1,486 0 1,486

Northeast 727 0 727

Ohio Valley 1,587 0 1,587

Texas/Mountain West 845 0 845

Northwest 439 0 439

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.f-8. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), Early 

Entry Notification Record Keeping (5 years) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 6,996 0 6,996

796 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 2.02

g. Safety displays for decontamination (NOTIFY-14, 15, 16, and 17) 

Baseline

Step 1. Calculate Baseline Costs 

 A safety poster costs $6.08 (Gempler). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 100 of 148

 WPS establishments post 1 safety poster at a central location if an application is made. 

o The probability that a large WPS farm makes an application is 0.902 (NASS, 

2008b). 

o The probability that a small WPS farm makes an application is 0.750 (NASS, 

2008b). 

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

 A sign lasts about 3 years, so one-third of WPS farms will need to purchase a sign in a 

year that the farm posts. 

Table A.3.g-1. Baseline Cost, per WPS farm, Safety posters 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Large WPS farm 

Central Poster 6.08 1 0.301 1.83

Post sign 28.21 0.033 0.902 0.85

Expected per-large farm Cost (costr,i,a

B

) 2.68

Small WPS farm 

Central Poster 6.08 1 0.250 1.52

Post sign 28.21 0.033 0.750 0.71

Expected per-small farm Cost (costr,i,a

B

) 2.23

New Regulations

NOTIFY-14. Revise safety poster to include poisoning symptoms and contact information. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Owner/operator spends about 3 minutes adding additional information to display. 

 Information, such as emergency contacts, is unlikely to change frequently, so updating 

occurs with each new poster, implying the same annual probability as a purchase. 

Table A.3.g-2. Potential Cost, per WPS farm, Revise safety posters 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Large WPS farm 

Central Poster 6.08 1 0.301 1.83

Post sign 28.21 0.033 0.902 0.85

Update Poster 28.21 0.05 0.301 0.42

Expected per-farm Cost (costr,i,a

P

) 3.10

Small WPS farm 

Central Poster 6.08 1 0.250 1.52

Post sign 28.21 0.033 0.750 0.71

Update Poster 28.21 0.05 0.250 0.35

Expected per-farm Cost (costr,i,a

P

) 2.58

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large and 340,369 small WPS farms (NASS, 2008 [Census of Ag]). WPS 

farms, defined as those hiring labor, are distributed across regions in the same proportion as all 

farms. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 101 of 148

Table A.3.g-3. Regional Costs, Year 1, Revise safety poster 

Region N lrg frm N sml frm

RC B

($) 

RC P

($) 

costr,i,a

B $ 2.68 $ 2.23 

costr,i,a

P $ 3.10 $ 2.58 

South 8,089 50,715 134,554 155,878

California 3,366 21,103 55,989 64,862

Southwest 1,737 10,892 28,897 33,477

Subtropical 1,357 8,509 22,576 26,154

Midwest 11,781 73,860 195,961 227,017

Northeast 5,592 35,058 93,014 107,754

Ohio Valley 12,541 78,625 208,603 241,663

Texas/Mountain West 6,678 41,865 111,074 128,678

Northwest 3,149 19,741 52,377 60,677

US 54,289 340,369 $ 903,044 $1,046,160

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. This requirement would be 

phased in over two years to allow for WPS farms to purchase appropriate signs. Thus, the PV 

for the potential requirement is calculated using baseline costs for the first two years of the 10-

year time horizon. 

Table A.3.g-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Revise safety 

poster 

Region (Large WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 209 186 23

California 87 78 9

Southwest 45 40 5

Subtropical 35 31 4

Midwest 305 271 33

Northeast 145 129 16

Ohio Valley 324 289 35

Texas/Mountain West 173 154 19

Northwest 81 73 9

Region (Small WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,091 972 119

California 454 405 49

Southwest 234 209 26

Subtropical 183 163 20

Midwest 1,589 1,416 173

Northeast 754 672 82

Ohio Valley 1,692 1,508 184

Texas/Mountain West 901 803 98

Northwest 425 379 46
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 102 of 148

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.g-5. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Revise safety poster 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Farm, Large 1,404 1,251 153

WPS Farm, Small 7,325 6,527 798

Total 8,729 7,777 951

108 (௥ܥܫܣ) Annualized

per-entity ($/all WPS farms) 0.27

per-entity ($/large WPS farm) 0.32

per-entity ($/small WPS farm) 0.27

NOTIFY-15. Additional safety posters at worker decontamination site(s). 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are as in the baseline unless otherwise indicated. 

 Decontamination posters cost $7.95 (Gempler). 

 EPA assumes that large WPS establishments will have 2 locations for decontamination 

displays. 

 EPA assumes all small WPS establishments will have 1 or 2 locations for 

decontamination displays. 

 Annual frequency for large farms is as in NOTIFY-14 (Table A.3.g-2). 

 EPA calculates that 21.0% of small WPS farms will purchase two displays each year. 

o Posters last 3 years, implying a 33.3% replacement rate. 

o 63% of small WPS farms are large and medium small WPS farms that apply 

pesticides in a given year (NASS, 2008b), which is also the probability of posting 

two displays. 

 EPA calculates that 4.0% of small WPS farms will purchase posters each year. 

o Posters last 3 years, implying a 33.3 replacement rate. 

o 12% of small WPS farms are small-small WPS farms that apply pesticides in a 

given year (NASS, 2008b), which is also the probability of posting one display. 

Table A.3.g-6. Potential Cost, per WPS farm, Safety posters for worker decontamination sites 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 

Central Poster 6.08 1 0.301 1.83

Post sign 28.21 0.033 0.902 0.85

Decontamination Display 7.95 2 0.301 4.78

Post 2 Displays 28.21 0.067 0.902 1.70

Expected per-Small-small farm Cost (costr,i,a

P

) 9.15

Small WPS farm 

Central Poster 6.08 1 0.250 1.52

Post sign 28.21 0.033 0.750 0.71

Decontamination Display 7.95 2 0.210 3.34

Post 2 Displays 28.21 0.067 0.630 1.19

Decontamination Display 7.95 1 0.040 0.32
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Post 1 Display 28.21 0.033 0.120 0.11

Expected per-farm Cost (costr,i,a

P

) 7.18

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large and 340,369 small WPS farms (NASS, 2008 [Census of Ag]). WPS 

farms, defined as those hiring labor, are distributed across regions in the same proportion as all 

farms. 

Table A.3.g-7. Regional Costs, Year 1, Safety posters for worker decontamination sites 

Region N large WPS N small WPS

RC B

($) 

RC P

($) 

costr,i,a

B $ 2.68 $ 2.23 

costr,i,a

P $ 9.15 $ 7.18 

South 8,089 50,715 134,554 438,324

California 3,366 21,103 55,989 182,390

Southwest 1,737 10,892 28,897 94,137

Subtropical 1,357 8,509 22,576 73,544

Midwest 11,781 73,860 195,961 638,365

Northeast 5,592 35,058 93,014 303,003

Ohio Valley 12,541 78,625 208,603 679,550

Texas/Mountain West 6,678 41,865 111,074 361,838

Northwest 3,149 19,741 52,377 170,623

US 54,289 340,369 $ 903,044 $2,941,774

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. Data do not distinguish by farm 

size. 

Table A.3.g-8. Regional Costs, PV (3% discount rate) and Incremental Cost, Safety posters for 

worker decontamination sites 

Region (Large WPS farms) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 637 186 451

California 265 78 188

Southwest 137 40 97

Subtropical 107 31 76

Midwest 928 271 657

Northeast 441 129 312

Ohio Valley 988 289 699

Texas/Mountain West 526 154 372

Northwest 248 73 176

Region (Small WPS farms) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 3,138 972 2,165

California 1,306 405 901

Southwest 674 209 465

Subtropical 526 163 363

Midwest 4,570 1,416 3,153
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Northeast 2,169 672 1,497

Ohio Valley 4,864 1,508 3,357

Texas/Mountain West 2,590 803 1,787

Northwest 1,221 379 843

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.g-9. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Safety posters for worker decontamination sites 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Farm, Large 4,278 1,251 3,027

WPS Farm, Small 21,058 6,527 14,531

Total 25,336 7,777 17,558

1,998 (௥ܥܫܣ) Annualized

per-entity ($/all WPS farms) 5.06

per-entity ($/large WPS farm) 6.35

per-entity ($/small WPS farm) 4.86

NOTIFY-16. Additional safety posters at handler decontamination site(s). 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are as in the baseline unless otherwise indicated. 

 Decontamination posters cost $7.95 (Gempler). 

 EPA assumes that large WPS establishments will have 2 locations for handler 

decontamination displays. Parameters are the same as in NOTIFY-15. 

 EPA assumes that large-small WPS farms will have 1 site for a handler decontamination 

display. Medium and small-small WPS farms do not employ handlers and will not need a 

handler decontamination display. 

 EPA calculates that 12.2% of small WPS farms will purchase posters each year. 

o Posters last 3 years, implying a 33.3% replacement rate. 

o Large-small WPS farms that apply pesticides in a given year account for 36.7% of 

all small WPS farms (NASS, 2008b) , which is also the probability of posting one 

display. 

Table A.3.g-10. Potential Cost, per WPS farm, Safety posters for handler decontamination sites 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 

Central Poster 6.08 1 0.301 1.83

Post sign 28.21 0.033 0.902 0.85

Decontamination Display 7.95 2 0.301 4.78

Post 2 Displays 28.21 0.067 0.902 1.70

Expected per-Small-small farm Cost (costr,i,a

P

) 9.15

Small WPS farm 

Central Poster 6.08 1 0.250 1.52

Post sign 28.21 0.033 0.750 0.71
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 105 of 148

Decontamination Display 7.95 1 0.122 0.97

Post 1 Display 28.21 0.033 0.367 0.35

Expected per-farm Cost (costr,i,a

P

) 3.54

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large and 340,369 small WPS farms (NASS, 2008 [Census of Ag]). WPS 

farms are distributed across regions in the same proportion as total farms. 

Table A.3.g-11. Regional Costs, Year 1, Safety posters for handler decontamination sites 

Region N large WPS N small WPS

RC B

($) 

RC P

($) 

costr,i,a

B $ 2.68 $ 2.23 

costr,i,a

P $ 9.15 $ 3.54 

South 8,089 50,715 134,554 253,778

California 3,366 21,103 55,989 105,599

Southwest 1,737 10,892 28,897 54,503

Subtropical 1,357 8,509 22,576 42,580

Midwest 11,781 73,860 195,961 369,597

Northeast 5,592 35,058 93,014 175,431

Ohio Valley 12,541 78,625 208,603 393,442

Texas/Mountain West 6,678 41,865 111,074 209,495

Northwest 3,149 19,741 52,377 98,786

US 54,289 340,369 $ 903,044 $1,703,210

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. The number of CPHE handlers 

is increasing at a rate of 0.17% per year. 

Table A.3.g-12. Regional Costs, PV (3% discount rate) and Incremental Cost, Safety posters for 

handler decontamination sites 

Region (Large WPS farms) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 637 186 451

California 265 78 188

Southwest 137 40 97

Subtropical 107 31 76

Midwest 928 271 657

Northeast 441 129 312

Ohio Valley 988 289 699

Texas/Mountain West 526 154 372

Northwest 248 73 176

Region (Small WPS farms) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,548 972 576

California 644 405 240

Southwest 333 209 124

Subtropical 260 163 97

Midwest 2,255 1,416 839

Northeast 1,070 672 398
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 106 of 148

Ohio Valley 2,400 1,508 893

Texas/Mountain West 1,278 803 475

Northwest 603 379 224

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.g-13. National and Per-Entity Costs, PV and Annualized (3% discount rate), Safety 

posters for handler decontamination sites 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Farm, Large 4,278 1,251 3,027

WPS Farm, Small 10,391 6,527 3,864

Total 14,669 7,777 6,891

784 (௥ܥܫܣ) Annualized

per-entity ($/all WPS farms) 1.99

per-entity ($/large WPS farm) 6.35

per-entity ($/small WPS farm) 1.29

NOTIFY-17. Additional safety posters with REI signs. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Decontamination posters cost $7.95 (Gempler). 

 The number of displays is the same as REI signs noted in Table A.3.a-1. 

 EPA assumes it takes 2 minutes to place a display with a REI warning sign, therefore 4 

minutes to place 2 displays and 6 minutes to place 3 displays, etc. 

 EPA calculates the frequency of purchasing displays and placing displays as for Table 

A.3.a-1. 

Table A.3.g-14. Potential Cost, per WPS farm, Safety posters with REI signs 

Action/Material wage/price unit time/quantity 

annual 

frequency cost 

Large WPS farm 1

Central Poster 6.08 1 0.301 1.83

Post sign 28.21 0.033 0.902 0.85

Decon. Display 7.95 4 0.329 10.46

Place 2 Displays 28.21 0.067 5.26 9.90

Decon. Display 7.95 6 0.122 5.82

Place 3 Displays 28.21 0.10 1.95 5.51

Expected per-Large farm Cost (costr,i,a

P

) 34.37

Large WPS greenhouse 

Central Poster 6.08 1 0.249 1.51

Post sign 28.21 0.033 0.747 0.70

Decon. Display 7.95 4 0.374 11.88

Place 2 Displays 28.21 0.067 14.9 28.11

Expected per-Large GH Cost (costr,i,a

P

) 42.20

Small WPS farms 1

Central Poster 6.08 1 0.250 1.52

Post sign 28.21 0.033 0.751 0.71

Decon. Display 7.95 2 0.336 5.34

Place 2 Displays 28.21 0.067 1.34 2.53
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 107 of 148

Decon. Display 7.95 3 0.040 0.95

Place 3 Displays 28.21 0.10 0.16 0.45

Expected per-Small farm Cost (costr,i,a

P

) 11.49

Small WPS greenhouse 

Central Poster 6.08 1 0.184 1.12

Post sign 28.21 0.033 0.552 0.52

Decon. Display 7.95 4 0.276 8.77

Place 2 Displays 28.21 0.067 11.0 20.76

Expected per-Small GH Cost (costr,i,a

P

) 31.17

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large WPS farms, 174 large WPS greenhouses, 340,369 small WPS farms, and 

705 small WPS greenhouses (NASS, 2008). 

Table A.3.g-15. Regional Costs, Year 1, Safety posters with REI signs 

Region (Large WPS farms) N large WPS N large WPS GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 2.68 $ 2.68 

costr,i,a

P $ 34.37 $ 42.20 

South 8,089 26 21,641 278,242

California 3,366 11 9,005 115,778

Southwest 1,737 6 4,648 59,757

Subtropical 1,357 4 3,631 46,685

Midwest 11,781 38 31,517 405,225

Northeast 5,592 18 14,960 192,342

Ohio Valley 12,541 40 33,550 431,368

Texas/Mountain West 6,678 21 17,864 229,689

Northwest 3,149 10 8,424 108,309

US 54,289 174 $ 145,239 $1,867,394

Region (Small WPS farms) N small WPS N small WPS GH

RC B

($) 

RC P

($) 

costr,i,a

B $ 2.23 $ 2.23 

costr,i,a

P $ 11.49 $ 31.17 

South 50,715 105 112,913 584,568

California 21,103 44 46,984 243,243

Southwest 10,892 23 24,250 125,545

Subtropical 8,509 18 18,945 98,082

Midwest 73,860 153 164,444 851,351

Northeast 35,058 73 78,054 404,097

Ohio Valley 78,625 163 175,053 906,277

Texas/Mountain West 41,865 87 93,210 482,563

Northwest 19,741 41 43,953 227,550

US 340,369 705 $ 757,805 $3,923,276

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. Data do not distinguish by farm 

size. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 108 of 148

Table A.3.g-16. Regional Costs, PV (3% discount rate) and Incremental Cost, Safety posters 

with REI signs 

Region (Large WPS farms) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 2,396 186 2,210

California 997 78 920

Southwest 515 40 475

Subtropical 402 31 371

Midwest 3,490 271 3,219

Northeast 1,657 129 1,528

Ohio Valley 3,715 289 3,426

Texas/Mountain West 1,978 154 1,824

Northwest 933 73 860

Region (Small WPS farms) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 5,035 972 4,062

California 2,095 405 1,690

Southwest 1,081 209 872

Subtropical 845 163 682

Midwest 7,332 1,416 5,916

Northeast 3,480 672 2,808

Ohio Valley 7,805 1,508 6,298

Texas/Mountain West 4,156 803 3,353

Northwest 1,960 379 1,581

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.3.g-17. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Safety posters with REI signs 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Farm, Large 16,083 1,251 14,832

WPS Farm, Small 33,789 6,527 27,262

Total 49,872 7,777 42,094

4,791 (௥ܥܫܣ) Annualized

per-entity ($/all WPS farms) 12.14

per-entity ($/large WPS farm) 31.10

per-entity ($/small WPS farm) 9.12

h. Notification of farm by CPHE (NOTIFY-18) 

Baseline

Step 1. Calculate Baseline Costs 

 Commercial applicators must notify a farm, nursery, or greenhouse prior to an application 

and inform the operation when there are any changes in the schedule or the product used. 

EPA guidance has indicated that notification must be made so that agricultural employers 

can inform their employees of any areas under a REI. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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New Regulation

NOTIFY-18. Codify guidance on communication between CPHE and agricultural 

employer. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA anticipates no changes from codification of existing guidance. 

A.4. Age 

a. Minimum age for workers in early entry activities (AGE-01 and 02) 

Baseline

Step 1. Calculate Baseline Costs 

 EPA assumes that 14-15 year old WPS workers are paid $6.71/hour, 50% of adult 

worker. 

 EPA assumes that 16-17 year old WPS workers are paid $8.06/hour, 60% of adult 

workers. 

 EPA assumes that early entry tasks take no more than 8 hours. 

 EPA calculates the likelihood of a youth worker to participate in early entry activities to 

be 0.001 for 14-15 year olds and 0.007 for 16-17 year olds. 

o EPA assumes that 14-15 year old workers make up 0.82% of the workforce and 

16-17 year old workers make up 3.74% of the workforce, which is twice the 

proportion of handlers reported by the National Agricultural Worker Survey 

(DOL, 2005). 

o EPA assumes there is a 40% chance that a WPS farm will have an early entry 

event each year (see A.2.d). 

o EPA assumes that half the workforce will participate in an early entry event. 

o 87.4% of workers are employed on a WPS farm that makes a pesticide application 

in a given year (NASS, 2008b). 

Table A.4.a-1. 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 6.71 8 0.001 0.08

16-17 yr old worker 8.06 8 0.007 0.42

Expected per-worker Cost (costr,i,a

B

) 0.50

New Regulation

AGE-01. Minimum age of 16 for workers in early entry activities. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes all hours worked by workers under 16 are replaced by adult handlers. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Table A.4.a-2. Potential Labor Cost, per WPS worker, Minimum Age (16), Early Entry 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

18+ yr old worker 13.43 8 0.001 0.15

16-17 yr old worker 8.06 8 0.007 0.42

Expected per-worker Cost (costr,i,a

P

) 0.58

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 2,322,610 farm workers in the United States (NASS, 2008 [Census of Ag]). Florida 

statutes prohibit workers under the age of 18 from working around pesticides unless proper field 

entry allowances are observed. EPA assumes this applies to early entry activities in agriculture 

and sets baseline costs for the Subtropical region to the cost of the potential revision. 

Table A.4.a-3. Regional Labor Costs, Year 1, Minimum Age (16), Early Entry 

Region N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.50 

costr,Subtropical,a

B $ 0.58 

costr,i,a

P $ 0.58 

South 274,068 136,646 157,755

California 394,844 196,862 227,274

Southwest 78,969 39,372 45,455

Subtropical 111,485 64,172 64,172

Midwest 299,617 149,384 172,461

Northeast 278,713 138,962 160,429

Ohio Valley 353,037 176,018 203,210

Texas/Mountain West 185,809 92,641 106,953

Northwest 346,069 172,544 199,199

US 2,322,610 $1,166,600 $1,336,907

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 

Table A.4.a-4. Regional Labor Costs, PV (3% discount rate) and Incremental Cost, Minimum 

Age (16), Early Entry 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,267 1,097 169

California 1,825 1,581 244

Southwest 365 316 49

Subtropical 515 515 0

Midwest 1,385 1,199 185

Northeast 1,288 1,116 172

Ohio Valley 1,631 1,413 218

Texas/Mountain West 859 744 115

Northwest 1,599 1,385 214
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.4.a-5. National and Per-WPS Farm Labor Costs, PV and Annualized (3% discount 

rate), Minimum Age (16), Early Entry 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 10,734 9,366 1,367

156 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 0.39

AGE-02. Minimum age of 18 for workers in early entry activities. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes all hours worked by youth worker are replaced by adult handlers. 

Table A.4.a-6. Potential Labor Cost, per WPS worker, Minimum Age (18), Early Entry 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

18+ yr old worker 13.43 8 0.008 0.86

Expected per-worker Cost (costr,i,a

P

) 0.86

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 2,322,610 farm workers in the United States (NASS, 2008 [Census of Ag]). Florida 

statutes prohibit workers under the age of 18 from working around pesticides unless proper field 

entry allowances are observed. EPA assumes this applies to early entry activities in agriculture 

and sets baseline costs for the Subtropical region to the cost of the potential revision. 

Table A.4.a-7. Regional Labor Costs, Year 1, Minimum Age (18), Early Entry 

Region N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.50 

costr,Subtropical,a

B $ 0.86 

costr,i,a

P $ 0.86 

South 274,068 136,646 234,779

California 394,844 196,862 338,241

Southwest 78,969 39,372 67,648

Subtropical 111,485 95,503 95,503

Midwest 299,617 149,384 256,665

Northeast 278,713 138,962 238,758

Ohio Valley 353,037 176,018 302,427

Texas/Mountain West 185,809 92,641 159,172

Northwest 346,069 172,544 296,458

US 2,322,610 $1,197,932 $1,989,653

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year and the number of farm workers 

is declining at 2.14% per year. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Table A.4.a-8. Regional Labor Costs, PV (3% discount rate) and Incremental Cost, Minimum 

Age (18), Early Entry 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,885 1,097 788

California 2,716 1,581 1,135

Southwest 543 316 227

Subtropical 767 767 0

Midwest 2,061 1,199 861

Northeast 1,917 1,116 801

Ohio Valley 2,428 1,413 1,015

Texas/Mountain West 1,278 744 534

Northwest 2,380 1,385 995

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.4.a-9. National and Per-WPS Farm Labor Costs, PV and Annualized (3% discount 

rate), Minimum Age (18), Early Entry 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 15,974 9,618 6,356

723 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 1.83

b. Minimum age for handlers (AGE-03 and 04) 

Baseline

Step 1. Calculate Baseline Costs 

 EPA assumes that 14-15 year old WPS handlers are paid $10.41/hour, 50% of adult 

handlers. 

 EPA assumes that 16-17 year old WPS handlers are paid $12.50/hour, 60% of adult 

handlers. 

 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 89.9%, the proportion of handlers employed on WPS farms making pesticide 

applications in a given year. 

 EPA assumes that, of the 16 and 17 year old WPS handlers, 40% are 16 and 60% are 17, 

implying 0.75% of handlers are 16 and 1.12% are 17. 

 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% of CHPE handlers are 16 and 17 years old, with 0.4% age 16 and 

0.6% age 17. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Table A.4.b-1. Baseline Labor Cost, per WPS handler, Minimum Age 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

14-15 yr old WPS handler 10.41 50 0.004 1.91

16-17 yr old WPS handler 12.50 50 0.017 10.51

Expected per-WPS handler cost (costr,i,a

B

) 12.43

16-17 yr old CPHE handler 12.06 640 0.010 77.18

Expected per-CPHE handler cost (costr,i,a

B

) 77.18

New Regulations

AGE-03. Minimum age of 16 for handlers. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes all hours worked by handlers under 16 are replaced by adult handlers. 

Table A.4.b-2. Potential Labor Cost, per WPS handler, Minimum Age (16) 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

16-17 yr old handler 12.50 50 0.017 10.51

18+ yr old handler 20.83 50 0.004 3.84

Expected per-WPS handler cost (costr,i,a

P

) 14.35

16-17 yr old CPHE handler 12.06 640 0.010 77.18

Expected per-CPHE handler cost (costr,i,a

P

) 77.18

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large WPS farms and 139,237 large-small WPS farms (NASS, 2008 [Census of 

Ag]). Given EPA assumptions that large farms employ 2 handlers, on average, and large-small 

establishments employ 1, there are a total of 247,815 handlers. WPS farms and handlers are 

distributed across regions in the same proportion as total farms. There are 2,793 CPHEs 

employing 17,080 handlers, also distributed across regions in the same proportion as total farms 

(Dun & Bradstreet, 2010; NAAA, 2008). 

Table A.4.b-3. Regional Labor Costs, Year 1, Minimum Handler Age (16) 

Region (WPS Farm) N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 12.43 

costr,i,a

P $ 14.35 

South 36,924 458,897 529,789

California 15,365 190,950 220,449

Southwest 7,930 98,555 113,780

Subtropical 6,195 76,996 88,891

Midwest 53,776 668,326 771,572

Northeast 25,525 317,224 366,230

Ohio Valley 57,245 711,444 821,350

Texas/Mountain West 30,481 378,821 437,342

Northwest 14,373 178,631 206,227

US 247,815 $3,079,843 3,555,629
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Region (CPHE) N CPHE 

RC B

($) 

RC P

($) 

costr,i,a

B $ 77.18 

costr,i,a

P $ 77.18 

South 2,545 196,427 196,427

California 1,059 81,735 81,735

Southwest 547 42,186 42,186

Subtropical 427 32,958 32,958

Midwest 3,706 286,072 286,072

Northeast 1,759 135,785 135,785

Ohio Valley 3,945 304,528 304,528

Texas/Mountain West 2,101 162,151 162,151

Northwest 991 76,462 76,462

US 17,080 1,318,303 1,318,303

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of handlers employed by CPHEs is growing at 0.17% per year. 

Table A.4.b-4. Regional Labor Costs, PV (3% discount rate) and Incremental Cost, Minimum 

Handler Age (18) 

Region (WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 4,563 3,952 611

California 1,899 1,645 254

Southwest 980 849 131

Subtropical 766 663 102

Midwest 6,645 5,756 889

Northeast 3,154 2,732 422

Ohio Valley 7,074 6,127 947

Texas/Mountain West 3,767 3,263 504

Northwest 1,776 1,538 238

Region (CPHE) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,738 1,738 0

California 723 723 0

Southwest 373 373 0

Subtropical 292 292 0

Midwest 2,532 2,532 0

Northeast 1,202 1,202 0

Ohio Valley 2,695 2,695 0

Texas/Mountain West 1,435 1,435 0

Northwest 677 677 0
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.4.b-5. National and Per-Entity Labor Costs, PV and Annualized (3% discount rate), 

Minimum Handler Age (18) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 30,623 26,525 4,098

CPHE 11,667 11,667 0

Total 42,290 38,192 4,098

466 (௥ܥܫܣ) Annualized

per-entity ($/lrg lrg-sml WPS farm) 2.41

per-entity ($/CPHE) 0.00

AGE-04. Minimum age of 18 for handlers. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 EPA assumes all hours worked by youth handlers are replaced by adult handlers. 

Table A.4.b-6. Potential Labor Cost, per handler, Minimum Age (18) 

Action/Material wage/price unit time/quantity 

annual 

probability 

cost 

(costr,i,a

P

) 

18+ yr old WPS handler 20.83 50 0.021 21.35

18+ yr old CPHE handler 20.10 640 0.010 128.64

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large WPS farms and 139,237 large-small WPS farms (NASS, 2008 [Census of 

Ag]). Given EPA assumptions that large farms employ 2 handlers, on average, and large-small 

establishments employ 1, there are a total of 247,815 handlers. WPS farms and handlers are 

distributed across regions in the same proportion as total farms. There are 2,793 CPHEs 

employing 17,080 handlers, also distributed across regions in the same proportion as total farms 

(Dun & Bradstreet, 2010; NAAA, 2008). 

Table A.4.b-7. Regional Labor Costs, Year 1, Minimum Handler Age (18) 

Region (WPS Farm) N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 12.43 

costr,i,a

P $ 21.35 

South 36,924 458,897 788,458

California 15,365 190,950 328,083

Southwest 7,930 98,555 169,333

Subtropical 6,195 76,996 132,292

Midwest 53,776 668,326 1,148,292

Northeast 25,525 317,224 545,042

Ohio Valley 57,245 711,444 1,222,375

Texas/Mountain West 30,481 378,821 650,875

Northwest 14,373 178,631 306,917

US 247,815 $3,079,843 $5,291,668
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Region (CPHE) N CPHE 

RC B

($) 

RC P

($) 

costr,i,a

B $ 77.18 

costr,i,a

P $ 128.64 

South 2,545 196,427 327,379

California 1,059 81,735 136,225

Southwest 547 42,186 70,309

Subtropical 427 32,958 54,929

Midwest 3,706 286,072 476,786

Northeast 1,759 135,785 226,309

Ohio Valley 3,945 304,528 507,547

Texas/Mountain West 2,101 162,151 270,252

Northwest 991 76,462 127,436

US 17,080 $1,318,303 $2,197,171

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of employed by CPHEs is growing at 0.17% per year. 

Table A.4.b-8. Regional Labor Costs, PV (3% discount rate) and Incremental Cost, Minimum 

Handler Age (18) 

Region (WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 6,791 3,952 2,838

California 2,826 1,645 1,181

Southwest 1,458 849 610

Subtropical 1,139 663 476

Midwest 9,890 5,756 4,134

Northeast 4,694 2,732 1,962

Ohio Valley 10,528 6,127 4,400

Texas/Mountain West 5,606 3,263 2,343

Northwest 2,643 1,538 1,105

Region (CPHE) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 2,897 1,738 1,159

California 1,206 723 482

Southwest 622 373 249

Subtropical 486 292 194

Midwest 4,220 2,532 1,688

Northeast 2,003 1,202 801

Ohio Valley 4,492 2,695 1,797

Texas/Mountain West 2,392 1,435 957

Northwest 1,128 677 451
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.4.b-9. National and Per-Entity Labor Costs, PV and Annualized (3% discount rate), 

Minimum Handler Age (18) 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 45,574 26,525 19,049

CPHE 19,445 11,667 7,778

Total 65,019 38,192 26,827

3,053 (௥ܥܫܣ) Annualized

per-entity ($/lrg lrg-sml WPS farm) 7.76

per-entity ($/CPHE) 316.96

A.5. Entry 

a. Entry Restricted Area (ENTRY-01 and 02) 

Baseline

Step 1. Calculate Baseline Costs 

 None 

New Regulation

ENTRY-01. Expand restricted area. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 No measurable impacts 

ENTRY-02. Halt application in case of entry into restricted area. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 No measurable impacts 

b. Entry into Restricted Area in case of Emergencies (ENTRY-03, 04 and 05) 

Baseline

Step 1. Calculate Baseline Costs 

 None 

 Workers may be sent into a treated field during the REI to conduct certain critical tasks. 

 EPA assumes that double notification products comprise about 10 percent of applications. 

 Early entry events are assumed to occur about 1 out of 50 applications and EPA assumes 

50% of workers would be involved with activities in the treated field (see A.2.d, 

NOTIFY-07 and 08). Given 20 applications per year of which 2 are double notification 

products, there is a 4% probability a WPS farm applying pesticides will have an early 

entry event associated with a double notification product. Since 87.4% of WPS farms 

apply pesticides in any given year (NASS, 2008), there is a 1.7% chance a WPS 

farmworker will be involved in an early entry event involving a double notification 

product. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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New Regulation

ENTRY-03. Limit entry into restricted area treated with double notification products to 4 

hours. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 No measurable impacts. Most tasks (e.g., equipment repair, arranging frost protection) 

would not take more than 4 hours to accomplish. There may be some extra management 

effort to rotate workers if tasks go longer. 

ENTRY-04. Limit entry into restricted area treated with double notification products to 8 

hours. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 No measurable impacts. Rarely would tasks take more than 8 hours to accomplish. 

ENTRY-05. Eliminate early entry exemptions. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 This provision would affect WPS farms and family farms as the latter can use the 

exemptions in the WPS. 

 EPA assumes there could be a 5% yield loss due to an unmitigated emergency, which 

implies a $13,024 loss in average farm revenue. 

o Producers of vegetables, fruits, nursery, and greenhouse crops are most at risk of 

loss due to weather emergencies such as frost or to irrigation problems. WPS 

farms in these categories total 193,759 (NASS, 2008b). 

o The value of production of these WPS farms was $50.469 billion in 2007 (NASS, 

2008b). 

o Average revenue per farm is calculated to be $260,474. 

 EPA assumes that 25% of a farm’s acreage could be affected by an unmitigated 

emergency. 

 EPA calculates that there is a 9.8% likelihood that a WPS farm will be affected by an 

agricultural emergency and will be a producer of vegetable, fruit, nursery, or greenhouse 

crops. 

o There is an early entry event in 1 out of 50 applications, implying a 20% chance 

for a farm making an average of 20 applications. 

o 24.6% of all farms using pesticides, including family farms, produce vegetable, 

fruit, nursery, or greenhouse crops (NASS, 2008b). 

Table A.5.c-1. Potential Revenue Loss, per WPS farm, Eliminate Early Entry Exemptions 

Action/Material 

value of 

production 

proportion of 

affected acres 

annual 

probability cost 

5% yield loss 13,024 0.25 0.098 320.00

Expected per-farm Cost (costr,i,a

P

) 320.00

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 788,582 WPS and family farms using pesticides in a given year (NASS, 2008 [Census 

of Ag]). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Table A.5.c-2. Regional Revenue Loss, Year 1, Eliminate Early Entry Exemptions 

Region N pesticide-using farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 

costr,i,a

P $ 320.00 

South 117,499 0 37,599,517

California 48,892 0 15,645,437

Southwest 25,235 0 8,075,064

Subtropical 19,715 0 6,308,644

Midwest 171,122 0 54,759,028

Northeast 81,224 0 25,991,612

Ohio Valley 182,162 0 58,291,869

Texas/Mountain West 96,996 0 31,038,527

Northwest 45,738 0 14,636,054

US 788,582 $ 0 $252,345,751

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. 

Table A.5.c-3. Regional Labor Costs, PV (3% discount rate) and Incremental Cost, Eliminate 

Early Entry Exemptions 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 323,824 0 323,824

California 134,746 0 134,746

Southwest 69,546 0 69,546

Subtropical 54,333 0 54,333

Midwest 471,610 0 471,610

Northeast 223,852 0 223,852

Ohio Valley 502,037 0 502,037

Texas/Mountain West 267,318 0 267,318

Northwest 126,052 0 126,052

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.5.c-4. National and Per-WPS Farm Labor Costs, PV and Annualized (3% discount 

rate), Eliminate Early Entry Exemptions 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 2,173,318 0 2,173,318

247,358 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 313.68

d. Cholinesterase Monitoring (ENTRY-06 and 07) 

Baseline

Step 1. Calculate Baseline Costs 

 None. There is no federal requirement. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Baseline, Northwest

Step 1. Calculate Baseline Costs 

 Washington state requires monitoring of handlers who work with cholinesterase 

inhibitors (ChIs), especially those working with ChIs more than 30 hours in 30 days. 

 The cost per handler of the testing program is $55.14, given expenditures of $111,595 in 

2007 for 2,024 handlers (Furman, 2007), including handlers that decline testing. 

 EPA assumes that each handler spends 30 minutes to get the baseline blood test or to 

officially decline participation and 1 hour travel time, round trip, to the testing center. 

 EPA calculates that handlers requiring follow up tests because they work with ChIs at 

least 30 hours in 30 days will spend 2.07 hours, including travel time. 

o As for the baseline test, the handler spends 30 minutes for the test and 1 hour 

travel, round trip. 

o Handlers obtain an average of 1.4 follow-up tests (Furman, 2007). 

 There were 2,024 handlers in the program in 2007, which is 14.1% of all WPS handlers 

in the Northwest region. CPHE handlers do not appear to be included in the program. 

 Given that 19.1% of handlers tested in the baseline or declining tests receive follow-up 

tests because they work with ChIs more than 30 hours in 30 days, EPA calculates that 

2.7% of WPS handlers would get follow-up tests. 

Table A.5.d-1. Baseline Cost, Washington, per WPS handler, Cholinesterase Monitoring 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Testing cost 55.14 1 0.141 7.76

Baseline test, w/ travel 20.83 1.5 0.141 4.40

Follow-up test, w/ travel 20.83 2.07 0.027 1.16

Expected per-WPS handler cost (costr,i,a

B

) 13.32

Baseline, California

Step 1. Calculate Baseline Costs 

 EPA assumes that the California testing cost per handler is the same as that in 

Washington although California does not require baseline tests and only tests if handlers 

work with ChIs more than 30 hours in 30 days. 

 Time for tests is as calculated for Washington. 

 EPA calculates that 9.7% of WPS and CPHE handlers trigger the testing requirement. 

o 386 handlers involved in the program in Washington had follow-up tests, i.e., 

worked with ChIs at least 30 hours in 30 days, representing 9.7% of the estimated 

3,971 WPS handlers in the state working on farms that apply pesticides. 

o EPA calculates the number of WPS handlers in Washington assuming large farms 

hire two handlers and large-small farms hire one handler. There are 39,284 farms 

in Washington (NASS, 2008) of which, assuming the national distribution holds 

in Washington, 967 are large farms (sales of $750,000 or more) and 2,481 are 

large-small (sales between $100,000 and $750,000). This implies 4,415 WPS 

handlers, of which 89.9% are employed on WPS farms that make a pesticide 

application in a given year (NASS, 2008). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 121 of 148

Table A.5.d-2. Baseline Cost, California, per WPS handler, Cholinesterase Monitoring 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Testing cost 55.14 1 0.097 5.36

Test, w/ travel 20.83 2.07 0.097 4.19

Expected per-WPS handler cost (costr, California,a

B

) 9.55

Testing cost 55.17 1 0.097 5.36

Test, w/ travel 20.10 2.07 0.097 4.04

Expected per-CPHE handler cost (costr,California,a

B

) 9.40

New Regulation

ENTRY-04. Require Cholinestrase Inhibition monitoring. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are similar to Washington except for annual probability of testing. 

 EPA estimates that 45.8% of WPS handlers and 51.0% of CPHE handlers would be 

involved in a national program. 

o 2,024 handlers participate in the Washington program, including those who 

decline to be tested, or 45.8% of the estimated 4,415 WPS handlers in the state. 

o The probability of a CPHE handler’s involvement in the program is adjusted 

(divided by) to account for the fact that only 89.9% of WPS handlers are 

employed on farms that make a pesticide application (NASS, 2008). 

 Follow -up testing is needed for 19.1% of participating handlers (Furman, 2007) or 8.7% 

of WPS handlers and 9.7% of CPHE handlers, as in the California baseline. 

Table A.5.d-3. Potential Cost, per WPS handler, Cholinesterase Monitoring 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Testing cost 55.14 1 0.458 25.27

Baseline test, w/ travel 20.83 1.5 0.458 14.32

Follow-up test, w/ travel 20.83 2.07 0.087 3.76

Expected per-WPS handler cost (costr,i,a

P

) 43.36

Testing cost 55.14 1 0.510 28.10

Baseline test, w/ travel 20.10 1.5 0.510 15.37

Follow-up test, w/ travel 20.10 2.07 0.097 4.04

Expected per-CPHE handler cost (costr,i,a

P

) 47.51

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large WPS farms and 139,237 large-small WPS farms (NASS, 2008 [Census of 

Ag]). Given EPA assumptions that large farms employ 2 handlers, on average, and large-small 

establishments employ 1, there are a total of 247,815 WPS handlers. WPS farms and handlers 

are distributed across regions in the same proportion as total farms. There are 2,793 CPHEs 

employing 17,080 handlers, also distributed across regions in the same proportion as total farms 

(Dun & Bradstreet, 2010; NAAA, 2008) and 89,529 self-employed handlers (commercial 

applicators certified in plant protection) for a total of 106,609 CPHE handlers that would be part 

of a monitoring program. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 122 of 148

Table A.5.d-4. Regional Costs, Year 1, Cholinesterase Monitoring 

Region (WPS Farm) N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 

costr,California,a

B $ 9.55

costr,NW ,a

B $ 13.32

costr,i,a

P $ 43.36 

South 36,924 0 1,601,023

California 15,365 146,664 666,197

Southwest 7,930 0 343,844

Subtropical 6,195 0 268,628

Midwest 53,776 0 2,331,691

Northeast 25,525 0 1,106,747

Ohio Valley 57,245 0 2,482,123

Texas/Mountain West 30,481 0 1,321,650

Northwest 14,373 191,452 623,217

US 247,815 $ 338,116 $10,745,119

Region (CPHE) N CPHE 

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 

costr,California,a

B $ 9.40

costr,NW ,a

B $ 0.00

costr,i,a

P $ 47.51 

South 8,567 0 407,028

California 5,789 54,412 275,043

Southwest 3,391 0 161,091

Subtropical 1,323 0 62,858

Midwest 35,870 0 1,704,259

Northeast 15,092 0 717,057

Ohio Valley 16,548 0 786,245

Texas/Mountain West 7,509 0 356,757

Northwest 12,520 0 594,828

US 106,609 $ 54,412 $5,065,166

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of handlers employed by CPHEs is growing at 0.17% per year. 

Table A.5.d-5. Regional Costs, PV (3% discount rate) and Incremental Cost, Cholinesterase 

Monitoring 

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 13,789 0 13,789

California 5,738 1,263 4,474

Southwest 2,961 0 2,961

Subtropical 2,314 0 2,314

Midwest 20,082 0 20,082

Northeast 9,532 0 9,532

Ohio Valley 21,377 0 21,377
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 123 of 148

Texas/Mountain West 11,383 0 11,383

Northwest 5,367 1,649 3,719

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 3602 0 3,602

California 2434 482 1,953

Southwest 1426 0 1,426

Subtropical 556 0 556

Midwest 15083 0 15,083

Northeast 6346 0 6,346

Ohio Valley 6958 0 6,958

Texas/Mountain West 3157 0 3,157

Northwest 5264 0 5,264

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.5.d-6. National and Per-Entity Costs, PV and Annualized (3% discount rate), 

Cholinesterase Monitoring 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 92,542 2,912 89,630

CPHE 44,827 482 44,345

Total 137,368 3,394 133,975

15,248 (௥ܥܫܣ) Annualized

per-entity ($/lrg lrg-sml WPS farm) 52.71

per-entity ($/CPHE) 122.79

ENTRY-05. Limit time handling Cholinestrase inhibiting pesticides. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 In order to limit the time handling ChI pesticides to less than 30 hours in 30 days, the 

handler would have to record the time spent in any ChI application. EPA assumes this 

would take 2 minutes. 

 The handler employer would have to track the dates and time to keep a cumulative total 

over the past 30 days, which EPA assumes would take 3 minutes. 

 EPA calculates that, on average, a WPS handler will make 1.83 ChI pesticide 

applications per year. 

o EPA assumes that 20% of pesticide applications are of ChI pesticides, or on 

average, 4 applications per year per farm. 

o EPA calculates that 45.8% of WPS handlers work with ChI pesticides. See 

ENTRY-04 above. 

 EPA calculates that, on average, a CPHE handler will make 13.8 ChI pesticide 

applications per year. 

o EPA assumes that 30% of pesticide applications are of ChI pesticides, or on 

average, 27 applications per CHPE handler per year. 

o EPA calculates that 51.0% of CPHE handlers work with ChI pesticides. See 

ENTRY-04 above. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 124 of 148

Table A.5.d-7. Potential Cost, per WPS handler, Limit time handling ChI pesticides 

Action/Material wage/price unit time/quantity 

annual 

probability cost 

Record time 20.83 0.033 1.83 1.27

Track cumulative time 28.21 0.050 1.83 2.59

Expected per-WPS handler cost (costr,i,a

P

) 3.86

Record time 20.10 0.033 13.8 9.22

Track cumulative time 30.30 0.050 13.8 20.85

Expected per-CPHE handler cost (costr,i,a

P

) 30.07

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large WPS farms and 139,237 large-small WPS farms (NASS, 2008 [Census of 

Ag]). Given EPA assumptions that large farms employ 2 handlers, on average, and large-small 

establishments employ 1, there are a total of 247,815 handlers. WPS farms and handlers are 

distributed across regions in the same proportion as total farms. There are 2,793 CPHEs 

employing 17,080 handlers, also distributed across regions in the same proportion as total farms 

(Dun & Bradstreet, 2010; NAAA, 2008) and 89,529 self-employed handlers (commercial 

applicators certified in plant protection) for a total of 106,609 CPHE handlers that would be part 

of a program. For WPS handlers, Washington and California are assumed to be following a 

similar tracking scheme under the existing ChI monitoring programs. For CPHE handlers, we 

use the California baseline calculated in ENTRY-06. 

Table A.5.d-8. Regional Costs, Year 1, Limit time handling ChI pesticides 

Region (WPS Farm) N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 

costr,CA NWi,a

B $ 3.86 

costr,i,a

P $ 3.86 

South 36,924 0 142,515

California 15,365 59,302 146,664

Southwest 7,930 0 30,607

Subtropical 6,195 0 23,912

Midwest 53,776 0 207,556

Northeast 25,525 0 98,517

Ohio Valley 57,245 0 220,946

Texas/Mountain West 30,481 0 117,647

Northwest 14,373 55,476 191,452

US 247,815 $ 114,777 $1,179,816

Region (CPHE) N CPHE 

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 

costr,CA,a

B $ 9.40 

costr,i,a

P $ 30.07 

South 8,567 0 257,617

California 5,789 54,412 174,080

Southwest 3,391 0 101,958

Subtropical 1,323 0 39,784

Midwest 35,870 0 1,078,661

Northeast 15,092 0 453,840
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 125 of 148

Ohio Valley 16,548 0 497,631

Texas/Mountain West 7,509 0 225,799

Northwest 12,520 0 376,479

US 106,609 $ 54,412 $3,205,851

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of handlers employed by CPHEs is growing at 0.17% per year. 

Table A.5.d-9. Regional Costs, PV (3% discount rate) and Incremental Cost, Limit time 

handling ChI pesticides 

Region (WPS Farm) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,227 0 1,227

California 1,263 511 752

Southwest 264 0 264

Subtropical 206 0 206

Midwest 1,788 0 1,788

Northeast 848 0 848

Ohio Valley 1,903 0 1,903

Texas/Mountain West 1,013 0 1,013

Northwest 1,649 478 1,171

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 2280 0 2,280

California 1541 482 1,059

Southwest 902 0 902

Subtropical 352 0 352

Midwest 9546 0 9,546

Northeast 4016 0 4,016

Ohio Valley 4404 0 4,404

Texas/Mountain West 1998 0 1,998

Northwest 3332 0 3,332

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.5.d-10. National and Per-Entity Costs, PV and Annualized (3% discount rate), Limit 

time handling ChI pesticides 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 10,161 989 9,173

CPHE 28,372 482 27,890

Total 38,533 1,470 37,063

4,218 (௥ܥܫܣ) Annualized

per-entity ($/lrg lrg-sml WPS farm) 5.39

per-entity ($/CPHE) 77.23

A.6. Personal Protective Equipment (PPE) 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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a. Respirators (PPE-01) 

Baseline

Step 1. Calculate Baseline Costs 

 WPS Employers and handlers spend about 6 minutes checking the fit of a respirator 

together. 

 WPS Employers and handlers also spend about 6 minutes providing and receiving 

instruction on the use of a respirator. 

 Probability of 34.7% that a WPS handler currently has a respirator check. 

o Assumes that, on average, only half of WPS farms applying pesticides will use a 

pesticide that requires a respirator. 

o One handler per WPS farm, on average, would be responsible for applying a 

pesticide that requires a respirator. 

 EPA estimates that 0.4% of WPS handlers currently obtain an OSHA-type respirator fit 

test because they handle fumigants. EPA’s estimate is based on proprietary market 

survey data on the projected number of farms reporting fumigant applications, averaged 

over 2006 to 2010, 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. 

o 33.8% of farms primarily producing field crops that use pesticides also hire labor; 

47.5% of farms primarily producing specialty crops that use pesticides also hire 

labor (NASS, 2008b)1

. 

 Fit testing requires that the handler complete an initial medical survey, taking about 30 

minutes to complete (DOL, 2004) 

 The survey is evaluated by a registered nurse or a licensed health care provider whose 

time is valued at $42.91 per hour (BLS, 2008). 

 23% of those taking the medical screen will need a follow-up examination (DOL, 2004), 

or about 0.2% of all WPS handlers. 

 The follow-up exam takes 2 hours, including travel time. 

 Cost for the exam is $101, based on the average cost of an office visit to a general 

practitioner (Machlin and Carper, 2007). 

 The fit test takes about 1.5 hours, including travel time, and the material costs about $1 

(DOL, 2004). 

 WPS Employers and handlers subsequently spend about 6 minutes providing and 

receiving instruction on the use of a respirator. 

 

1

 This may underestimate the number of WPS farms using fumigants since fumigant use may be more likely on 

farms hiring labor. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 127 of 148

Table A.6.a-1. Baseline Cost, per WPS handler, Respirator Fit 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Employer assures proper fit 28.21 0.1 0.347 0.98

Handler assures proper fit 20.83 0.1 0.347 0.72

Employer instructs proper use 28.21 0.1 0.351 0.99

Handler receives instruction 20.83 0.1 0.351 0.73

Initial survey 20.83 0.5 0.004 0.04

Medical evaluation 42.91 0.083 0.004 0.01

Time for follow-up w/ travel 20.83 2 0.001 0.04

Medical exam 101.00 1 0.001 0.13

Time for fit test w/ travel 20.83 1.5 0.004 0.13

Fit test material 1.00 1 0.004 0.00

Expected per-WPS handler Cost (costr,i,a

B

) 3.74

 Parameters for CPHE handlers are similar to WPS handlers, except for wages and the 

probability of an action. 

 All CPHE handlers are likely to need to use a respirator at some point. CHPEs are 

already subject to OSHA regulations as they are classified as general industry rather than 

specifically as agriculture. Thus, all CPHE handlers will be fit tested in accordance with 

the proposed requirement. 

 Self-employed handlers do not provide or receive instruction on respirator use. 

 23% of those taking the medical screen will need a follow-up examination (DOL, 2004), 

or about 1.3% of all CPHE handlers. 

Table A.6.a-2. Baseline Cost, per CPHE handler, Respirator Fit 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

CPHE handler, employee 

Initial survey 20.10 0.5 1 10.05

Medical evaluation 42.91 0.083 1 3.58

Time for follow-up w/ travel 20.10 2 0.230 9.25

Medical exam 101.00 1 0.230 23.23

Time for fit test w/ travel 20.10 1.5 1 30.15

Fit test material 1.00 1 1 1.00

Employer instructs proper use 30.30 0.1 1 3.03

Handler receives instruction 20.10 0.1 1 2.01

Expected per-CPHE handler Cost (costr,i,a

B

) 82.29

CPHE handler, self-employed 

Initial survey 30.30 0.5 1 15.15

Medical evaluation 42.91 0.083 1 3.58

Time for follow-up w/ travel 30.30 2 0.230 13.94

Medical exam 101.00 1 0.230 23.23

Time for fit test w/ travel 30.30 1.5 1 45.45

Fit test material 1.00 1 1 1.00

Expected per-CPHE handler Cost (costr,i,a

B

) 102.34

New Regulation
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 128 of 148

PPE-01. Require a respirator fit test conforming to OSHA standards. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are identical to baseline respirator fit tests except for frequency/probability of 

action. 

 EPA assumes that, on average, each large WPS farm and each large-small WPS primarily 

engaged in crop production (i.e., not farms primarily engaged in livestock production) 

will have one handler obtain a fit test, implying 59.5% of handlers will be fit tested, 

including a medical screen. They will do this as a matter of course so that the handler is 

prepared if a pesticide requiring a respirator must be applied later in the season. 

 23% of those taking the medical screen will need a follow-up examination (DOL, 2004), 

or about 13.7% of all WPS handlers. 

 Instruction on use occurs only if pesticide is applied. 

 CPHE handler costs are as in the baseline (Table A.6.a-2). 

Table A.6.a-3. Potential Cost, per handler, Require a Respirator Fit Test 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

WPS handler 

Initial survey 20.83 0.5 0.595 6.19

Medical evaluation 42.91 0.083 0.595 2.13

Time for follow-up w/ travel 20.83 2 0.137 5.70

Medical exam 101.00 1 0.137 13.82

Time for fit test w/ travel 20.83 1.5 0.595 18.58

Fit test material 1.00 1 0.595 0.59

Employer instructs proper use 28.21 0.1 0.351 0.99

Handler receives instruction 20.83 0.1 0.351 0.73

Expected per-WPS handler Cost (costr,i,a

P

) 48.74

 Employers must maintain records of any fit test. EPA assumes it will take about 4 

minutes to file documents from the test. 

 Employers will need a folder in which to keep documentation. 

 76.2% of large and large-small WPS farms (all large and large-small primarily engaged 

in crop production) and all CPHEs will have a handler obtain a fit test. 

Table A.6.a-4. Potential Cost, per employing establishment, Require a Respirator Fit Test 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

WPS farm 

Collect/Store documentation 28.21 0.067 0.762 1.43

Folder 0.20 1 0.762 0.15

Expected per-WPS farm Cost (costr,i,a

P

) 1.59

CPHE 

Collect/Store documentation 30.30 0.067 1 2.02

Folder 0.20 1 1 0.20

Expected per-CPHE Cost (costr,i,a

P

) 2.22
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 129 of 148

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 54,289 large WPS farms and 139,237 large-small WPS farms (NASS, 2008 [Census of 

Ag]). Given EPA assumptions that large farms employ 2 handlers, on average, and large-small 

establishments employ 1, there are a total of 247,815 handlers. WPS farms and handlers are 

distributed across regions in the same proportion as total farms. There are 2,793 CPHEs 

employing 17,080 handlers, also distributed across regions in the same proportion as total farms 

(Dun & Bradstreet, 2010; NAAA, 2008). The requirement also applies to about 69,656 selfemployed commercial applicators working in about 38,311 businesses. California has imposed 

an OSHA-type requirement, thus baseline costs are the same as for the potential requirement. 

Table A.6.a-5. Regional Costs, Year 1, Require a Respirator Fit Test 

Region (WPS Farm) N lrg, lrg-sml WPS farm N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 3.74 

costr,California,a

B $ 1.59 $ 48.74

costr,i,a

P $ 1.59 $ 48.77

South 28,835 36,924 138,142 1,845,428

California 11,999 15,365 767,896 767,896

Southwest 6,193 7,930 29,668 396,333

Subtropical 4,838 6,195 23,178 309,636

Midwest 41,995 53,776 201,186 2,687,636

Northeast 19,933 25,525 95,494 1,275,698

Ohio Valley 44,705 57,245 214,166 2,861,032

Texas/Mountain West 23,804 30,481 114,037 1,523,407

Northwest 11,225 14,373 53,773 718,354

US 193,526 247,815 $ 1,637,541 $12,385,421

Region (CPHE) N CPHE

N CPHE, 

self

N CPHE 

hndlr

N CPHE 

self-hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 $ 82.29 $102.34

costr,California,a

B $ 2.22 $ 2.22 $ 82.29 $102.34

costr,i,a

P $ 2.22 $ 2.22 $ 82.29 $102.34

South 416 1,684 2,545 3,061 522,693 527,354

California 173 1,924 1,059 3,498 449,785 449,785

Southwest 89 1,214 547 2,208 270,959 273,854

Subtropical 70 220 427 399 75,992 76,634

Midwest 606 15,318 3,706 27,852 3,155,438 3,190,791

Northeast 288 6,207 1,759 11,286 1,299,832 1,314,251

Ohio Valley 645 4,407 3,945 8,012 1,144,694 1,155,909

Texas/Mountain West 344 1,630 2,101 2,964 476,190 480,572

Northwest 162 5,707 991 10,376 1,143,479 1,156,508

US 2,793 38,311 17,080 69,656 $8,539,062 $8,625,657

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S., and therefore handlers, is declining at 0.47% per year. The 

number of CPHEs is growing at a rate of 4.27% per year and the number of handlers employed 

by CPHEs is growing at 0.17% per year. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 130 of 148

Table A.6.a-6. Regional Costs, PV (3% discount rate) and Incremental Cost, Require a 

Respirator Fit Test 

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 15,894 1,190 14,704

California 6,613 6,613 0

Southwest 3,413 256 3,158

Subtropical 2,667 200 2,467

Midwest 23,147 1,733 21,414

Northeast 10,987 822 10,164

Ohio Valley 24,641 1,844 22,796

Texas/Mountain West 13,120 982 12,138

Northwest 6,187 463 5,724

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 5,215 5,166 49

California 4,606 4,606 0

Southwest 2,818 2,787 31

Subtropical 750 743 7

Midwest 33,212 32,838 374

Northeast 13,647 13,494 152

Ohio Valley 11,662 11,544 119

Texas/Mountain West 4,783 4,737 46

Northwest 12,088 11,950 138

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.6.a-7. National and Per-Entity Costs, PV and Annualized (3% discount rate), Require a 

Respirator Fit Test 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 106,669 14,103 92,566

CPHE 88,781 87,865 916

Total 195,450 101,969 93,481

10,640 (௥ܥܫܣ) Annualized

per-entity ($/lrg lrg-sml WPS farm) 54.44

per-entity ($/CPHE) 2.54

b. Employees working under Certified Crop Advisors (PPE-02 and 03) 

Baseline/Current Practice

Step 1. Calculate Baseline Costs 

 Certified Crop Advisors (CCAs) can elect to enter fields during a REI for scouting 

purposes without PPE and those supervised by CCAs can similarly choose to forgo PPE. 

The farm or firm must have decontamination supplies and PPE available, however. 

 An employee of a crop advisory working under the supervision of a CCA is assumed to 

be paid $20.10 per hour, the same wage as a CPHE handler. 

 A worker/employee under the supervision of a CCA would generally carry a water bottle 

for rinsing eyes. A bottle costs $1.23 (Gemplers). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 131 of 148

 A worker/employee would also generally put on PPE (e.g., boots, gloves, etc.) before 

entering the field. EPA assumes this might take 10 minutes. 

 EPA assumes that there is a 9.0% chance that a WPS fieldworker might be directed to 

enter a field during a REI under the supervision of a CCA, a 10% occurrence weighted by 

a 90.2 % chance that a large WPS farm makes a pesticide application (NASS, 2008). A 

water bottle would have to be available. 

 EPA assumes that there is a 5% chance that the supervising CCA would suggest that the 

worker could forego wearing PPE. In the baseline, therefore, the worker puts on the PPE 

with a probability of 0.086 (90.2% chance of an application x 10% chance of entering the 

field x 95% chance of wearing PPE). 

 Similarly, EPA assumes that a non-certified employee of a crop advisory firm will have a 

90% chance of being directed into a field during a REI under the supervision of a CCA. 

A water bottle would have to be available. 

 EPA assumes there is a 1% chance that the supervising CCA would suggest the employee 

could forego wearing PPE. In the baseline, therefore, the employee puts on the PPE with 

a probability of 0.891 (90% chance of entering the field x 99% chance of wearing PPE). 

Table A.6.b-1. Baseline Cost, per actor, PPE for Certified Crop Advisors 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

WPS farm with CCA 

Decontamination supplies 19.78 1 1 19.78

PPE Equipment 91.23 1 1 91.23

Expected per-farm Cost (costr,i,a

B

) 111.01

WPS employee working under a CCA 

Eyewash bottle 1.23 1 0.090 0.11

Put on PPE 13.43 0.167 0.086 0.19

Expected per-worker Cost (costr,i,a

B

) 0.30

CCA Contracting Firm 

Decontamination supplies 19.78 1 1 19.78

PPE Equipment 91.23 1 1 91.23

Expected per-firm Cost (costr,i,a

B

) 111.01

CCA employee working under a CCA 

Eyewash bottle 1.23 1 0.900 1.11

Put on PPE 20.10 0.167 0.891 2.98

Expected per-worker Cost (costr,i,a

B

) 4.09

New Regulations

PPE-02. Eliminate exception for WPS employees working under a CCA. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are as in the baseline with the exception of the probability/frequency of 

wearing PPE, which occurs any time the worker is directed into the field. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 132 of 148

Table A.6.b-2. Potential Cost, per actor, PPE for WPS workers under the supervision of 

Certified Crop Advisors 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

WPS employee working under a CCA 

Eyewash bottle 1.23 1 0.090 0.11

Put on PPE 13.43 0.167 0.090 0.20

Expected per-worker Cost (costr,i,a

P

) 0.31

Step 3. Estimate Regional Level Baseline and Compliance Costs 

EPA assumes that only the largest farms will employ a CCA. There are 33,766 large WPS farms 

(NASS, 2008 [Census of Ag]) and EPA assumes there will be one employee working under the 

CCA per large WPS farm, on average. 

Table A.6.b-3. Regional Cost, Year 1, PPE for WPS workers under the supervision of Certified 

Crop Advisors 

Region N lrg WPS farm

N WPS farm worker 

supervised by CCA

RC B

($) 

RC P

($) 

costr,i,a

B $111.01 $ 0.30 

costr,i,a

P $111.01 $ 0.31 

South 8,089 8,089 900,442 900,524

California 3,366 3,366 374,681 374,715

Southwest 1,737 1,737 193,384 193,401

Subtropical 1,357 1,357 151,081 151,095

Midwest 11,781 11,781 1,311,382 1,311,501

Northeast 5,592 5,592 622,453 622,510

Ohio Valley 12,541 12,541 1,395,987 1,396,114

Texas/Mountain West 6,678 6,678 743,318 743,385

Northwest 3,149 3,149 350,508 350,539

US 54,289 54,289 $6,043,235 $6,043,783

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. 

Table A.6.b-4. Regional Costs, PV (3% discount rate) and Incremental Cost, PPE for WPS 

workers under the supervision of Certified Crop Advisors 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 7,756 7,755 0.703

California 3,227 3,227 0.292

Southwest 1,666 1,666 0.151

Subtropical 1,301 1,301 0.118

Midwest 11,295 11,294 1.024

Northeast 5,361 5,361 0.486

Ohio Valley 12,024 12,023 1.090

Texas/Mountain West 6,402 6,402 0.580

Northwest 3,019 3,019 0.274
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 133 of 148

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.6.b-5. National and Per-WPS Farm Labor Costs, PV and Annualized (3% discount 

rate), PPE for WPS workers under the supervision of Certified Crop Advisors 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 52,052 52,047 4.7

0.537 (௥ܥܫܣ) Annualized

per-entity ($/lrg WPS farm) 0.01

PPE-03. Eliminate exception for commercial enterprise employees working under a CCAs. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are as in the baseline with the exception of the probability/frequency of 

wearing PPE, which occurs any time the employee is directed into the field. 

Table A.6.b-6. Potential Cost, per actor, PPE for commercial employees under the supervision 

of Certified Crop Advisors 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Firm employee working under a CCA 

Eyewash bottle 1.23 1 0.900 1.11

Put on PPE 20.10 0.167 0.900 3.02

Expected per-worker Cost (costr,i,a

P

) 4.12

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 11,906 commercial consulting firms (Dun & Bradstreet, 2010) and EPA assumes there 

will be four employees under the supervision of a CCA per firm, on average. 

Table A.6.b-7. Regional Cost, Year 1, PPE for commercial employees under the supervision of 

Certified Crop Advisors 

Region N CCA firm N employee under CCA

RC B

($) 

RC P

($) 

costr,i,a

B $111.01 $ 4.09 

costr,i,a

P $111.01 $ 4.12 

South 1,119 4,477 142,560 142,695

California 452 1,810 57,631 57,685

Southwest 345 1,381 43,981 44,023

Subtropical 179 714 22,749 22,770

Midwest 3,858 15,430 491,377 491,842

Northeast 893 3,572 113,745 113,852

Ohio Valley 4,227 16,907 538,392 538,901

Texas/Mountain West 393 1,572 50,048 50,095

Northwest 441 1,762 56,114 56,167

US 11,906 47,624 $1,516,596 $1,518,032

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

EPA has no data on changes in the numbers of crop consulting firms. No changes are modeled. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 134 of 148

Table A.6.b-8. Regional Costs, PV (3% discount rate) and Incremental Cost, PPE for 

commercial Certified Crop Advisors 

Region 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,254 1,253 1.186

California 507 506 0.479

Southwest 387 386 0.366

Subtropical 200 200 0.189

Midwest 4,321 4,317 4.087

Northeast 1,000 999 0.946

Ohio Valley 4,735 4,730 4.479

Texas/Mountain West 440 440 0.416

Northwest 493 493 0.467

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.6.b-9. National and Per-WPS Farm Labor Costs, PV and Annualized (3% discount 

rate), PPE for commercial Certified Crop Advisors 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 13,338 13,325 12.6

1.4 (௥ܥܫܣ) Annualized

per-entity ($/ag service contractor) 0.12

c. Closed Systems (PPE-04) 

Baseline

Step 1. Calculate Baseline Costs 

 EPA assumes that large and large-small WPS farms and large family farms may own a 

closed system for mixing and loading pesticides that allows an exemption to the use of 

PPEs. Smaller farms would not typically own such a system. 

 Filters, costing $17.97/pair (Gemplers), are used in PPE and in closed systems. 

 If a farm relies on PPE, it will, on average need 5 filters per year2. 

 If a farm uses a closed system, one filter will last for a year. 

 A maintenance kit costs $86.50 (Cherlor Mfg. Co Inc., 2008). 

 EPA assumes that 25% of large and large-small WPS farms will not have a closed 

system, but will use PPE. However, 89.9% of large and large-small WPS farms make a 

pesticide application in a given year (NASS, 2008b), thus the probability of needing the 

filters is 0.225. 

 The remaining 75% of large and large-small WPS farms have a closed system, of which 

89.9%, or 67.4% of the total, will make a pesticide application and require a filter. 

 EPA assumes a 20% probability of a breakdown, thus 13.5% of all large and large-small 

WPS farms that a user will need a maintenance kit (20% of 67.4%). 

 

2

 This assumption is likely high. Given the probability of maintenance, a closed system would cost about $35/year 

or less than the cost of two filters. However, as farms relying on PPE are not affected by the rule, the assumption 

does not affect the estimate of the incremental cost. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 135 of 148

 EPA assumes that 50% of large family farms have a closed system; 70.2% percent of 

large family farms use pesticides, thus the probability of using filters is 0.351. 

 Given a 20% probability of a breakdown, there is a 7.0% chance that a large family farm 

will need a maintenance kit. 

 EPA assumes that CPHEs employing handlers have, on average, two closed systems, 

each requiring a filter every year; self-employed commercial handlers have one system. 

 Given a 20% probability of a breakdown, there is a 40% probability that a CPHE will 

need to purchase a maintenance kit and a 20% probability that a self-employed 

commercial handler will need to purchase a kit. 

Table A.6.c-1. Baseline Cost, per WPS farm or CPHE, Closed System 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

large/large-small WPS farm 

Filters 17.97 5 0.225 20.19

Filters 17.97 1 0.674 12.11

Maintenance Kit 86.50 1 0.135 11.66

Expected per-farm Cost (costr,i,a

B

) 43.96

large family farm 

Filters 17.97 5 0.351 31.55

Filters 17.97 1 0.351 6.31

Maintenance Kit 86.50 1 0.070 6.07

Expected per-farm Cost (costr,i,a

B

) 43.93

CPHE 

Filters 17.97 2 1 35.94

Maintenance Kit 86.50 2 0.20 34.60

Expected per-CPHE Cost (costr,i,a

B

) 70.54

self-employed CPHE 

Filters 17.97 1 1 17.97

Maintenance Kit 86.50 1 0.20 17.30

Expected per-CPHE Cost (costr,i,a

B

) 35.27

New Regulation

PPE-04. Revise standards for closed systems that allow PPE exemptions; keep record of 

maintenance. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 A closed system that meets the new standards costs $484.92 (Cherlor Mfg. Co Inc., 

2008). 

 EPA assumes that one-third of existing closed systems would meet the revised standards, 

one-third of would be replaced by a system that meets the new standards, and one third 

would not be replaced with those farms relying on PPE. 

 In case of breakdown, the establishment would need to keep a record of maintenance. 

 The owner operator would spend about 1 minute to file the record of maintenance (sheet 

of paper at $0.09) in a folder ($0.20). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 136 of 148

Table A.6.c-2. Potential Cost, per WPS farm or CPHE, Revised Standards for Closed System 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

large/large-small WPS farm 

Filters 17.97 5 0.449 40.37

Filters 17.97 1 0.449 8.07

Closed System 484.92 1 0.250 121.23

Maintenance Kit 86.50 1 0.090 7.77

Record of Maintenance 0.09 1 0.090 0.01

File Record of Maintenance 28.21 0.017 0.090 0.04

Folder 0.20 1 0.090 0.02

Expected per-farm Cost (costr,i,a

P

) 177.52

large family farm 

Filters 17.97 5 0.468 42.06

Filters 17.97 1 0.234 4.21

Closed System 484.92 1 0.117 56.75

Maintenance Kit 86.50 1 0.047 4.05

Record of Maintenance 0.09 1 0.047 0.00

File Record of Maintenance 28.21 0.017 0.047 0.02

Folder 0.20 1 0.047 0.01

Expected per-farm Cost (costr,i,a

P

) 107.11

CPHE 

Filters 17.97 10 0.333 59.90

Filters 17.97 2 0.667 23.96

Closed System 484.92 2 0.333 323.28

Maintenance Kit 86.50 2 0.20 34.60

Record of Maintenance 0.09 2 0.20 0.04

File Record of Maintenance 30.30 0.017 0.40 0.20

Folder 0.20 1 0.20 0.04

Expected per-CPHE Cost (costr,i,a

P

) 442.02

self-employed CPHE 

Filters 17.97 5 0.333 29.95

Filters 17.97 1 0.667 11.98

Closed System 484.92 1 0.333 161.64

Maintenance Kit 86.50 1 0.20 17.30

Record of Maintenance 0.09 1 0.20 0.02

File Record of Maintenance 30.30 0.017 0.20 0.10

Folder 0.20 1 0.20 0.04

Expected per-CPHE Cost (costr,i,a

P

) 221.03

Potential costs are slightly different for California where revised standards are already in place. 

Thus, no new investment is needed, but there will be additional costs of record keeping. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 137 of 148

Table A.6.c-3. Potential Cost, California, per WPS farm or CPHE, Revised Standards for Closed 

System 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

large/large-small WPS farm 

Filters 17.97 5 0.225 20.19

Filters 17.97 1 0.674 12.11

Maintenance Kit 86.50 1 0.135 11.66

Record of Maintenance 0.09 1 0.135 0.01

File Record of Maintenance 28.21 0.033 0.135 0.06

Record and Folder 0.29 1 0.135 0.03

Expected per-farm Cost (costr,California,a

P

) 44.06

large/large-small WPS farm 

Filters 17.97 5 0.351 31.55

Filters 17.97 1 0.351 6.31

Maintenance Kit 86.50 1 0.070 6.07

Record of Maintenance 0.09 1 0.070 0.01

File Record of Maintenance 28.21 0.017 0.070 0.03

Record and Folder 0.20 1 0.070 0.01

Expected per-farm Cost (costr,California,a

P

) 43.98

CPHE 

Filters 17.97 2 1 35.94

Maintenance Kit 86.50 2 0.20 34.60

Record of Maintenance 0.09 2 0.20 0.04

File Record of Maintenance 30.30 0.017 0.40 0.20

Record and Folder 0.20 1 0.20 0.04

Expected per-CPHE Cost (costr,California,a

P

) 70.82

self-employed CPHE 

Filters 17.97 1 1 17.97

Maintenance Kit 86.50 1 0.20 17.30

Record of Maintenance 0.09 1 0.20 0.02

File Record of Maintenance 30.30 0.017 0.20 0.10

Record and Folder 0.20 1 0.20 0.04

Expected per-CPHE Cost (costr,California,a

P

) 35.43

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 193,526 large and large-small WPS farms and 9,246 large family farms that use 

pesticide (NASS, 2008 [Census of Ag]). There are 2,793 CPHEs (Dun & Bradstreet, 2010; 

NAAA, 2008) and an estimated 38,311 self-employed commercial applicator operations. 

Table A.6.c-4. Regional Costs, Year 1, Revised Standards for Closed System 

Region (WPS Farm) N lrg, lrg-sml WPS farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 43.96 

costr,i,a

P $177.52

costr,California,a

P $ 44.06 

South 28,835 1,267,507 5,118,765

California 11,999 527,419 528,649

Southwest 6,193 272,216 1,099,332
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

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Subtropical 4,838 212,669 858,853

Midwest 41,995 1,845,967 7,454,845

Northeast 19,933 876,196 3,538,475

Ohio Valley 44,705 1,965,061 7,935,803

Texas/Mountain West 23,804 1,046,331 4,225,557

Northwest 11,225 493,392 1,992,539

US 193,526 $ 8,506,759 $32,752,818

Region (Family Farm) N lrg fam farm 

RC B

($) 

RC P

($) 

costr,i,a

B $ 43.93 

costr,i,a

P $107.11

costr,California,a

P $ 43.98 

South 1,378 60,521 147,555

California 573 25,183 25,214

Southwest 296 12,998 31,690

Subtropical 231 10,154 24,758

Midwest 2,006 88,141 214,896

Northeast 952 41,836 102,001

Ohio Valley 2,136 93,827 228,760

Texas/Mountain West 1,137 49,960 121,807

Northwest 536 23,558 57,438

US 9,246 $406,179 $954,119

Region (CPHE) N CPHE N self-CPHE

RC B

($) 

RC P

($) 

costr,i,a

B $ 70.54 $ 35.27 

costr,i,a

P $442.02 $221.03

costr,California,a

P $ 70.82 $ 35.43 

South 416 1,684 88,733 556,053

California 173 1,924 80,069 80,423

Southwest 89 1,214 49,138 307,931

Subtropical 70 220 12,669 79,390

Midwest 606 15,318 583,031 3,653,700

Northeast 288 6,207 239,226 1,499,162

Ohio Valley 645 4,407 200,939 1,259,210

Texas/Mountain West 344 1,630 81,723 512,126

Northwest 162 5,707 212,713 1,333,017

US 2,793 38,311 $1,548,240 $9,281,012

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. The number of CPHEs is 

growing at a rate of 4.27% per year. Investment in new closed systems is a one-time event. In 

Years 2 through 10, costr,i,a

P

 = $56.29 for large and large-small WPS farms, costr,i,a

P

 = $50.35 for 

large family farms, costr,i,a

P

 = $118.74 for CPHEs, and costr,i,a

P

 = $59.39 for self-employed 

CPHEs. 

Table A.6.c-5. Regional Costs, PV (3% discount rate) and Incremental Cost, Revised Standards 

for Closed System 

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 139 of 148

South 17,474 10,916 6,558

California 5,670 4,542 1,127

Southwest 3,753 2,344 1,408

Subtropical 2,932 1,832 1,100

Midwest 25,449 15,898 9,551

Northeast 12,079 7,546 4,533

Ohio Valley 27,091 16,924 10,167

Texas/Mountain West 14,425 9,011 5,414

Northwest 6,802 4,249 2,553

Region (Family Farm) 

South 676 521 154

California 217 217 0

Southwest 145 112 33

Subtropical 113 87 26

Midwest 984 759 225

Northeast 467 360 107

Ohio Valley 1,047 808 239

Texas/Mountain West 558 430 127

Northwest 263 203 60

Region (CPHE) 

PV(RC P

) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,986 938 1,048

California 850 847 4

Southwest 1,100 520 580

Subtropical 284 134 150

Midwest 13,052 6,165 6,887

Northeast 5,355 2,529 2,826

Ohio Valley 4,498 2,125 2,374

Texas/Mountain West 1,829 864 965

Northwest 4,762 2,249 2,513

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.6.c-6. National and Per-Entity Costs, PV and Annualized (3% discount rate), Revised 

Standards for Closed System 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Farms 115,675 73,264 42,411

Family Farms 4,470 3,498 972

CPHEs 33,717 16,370 17,347

Total 153,863 93,133 60,730

6,912 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 24.94

per-entity ($/family farm) 11.97

per-entity ($/CPHE) 48.03
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 140 of 148

d. Disposal of PPE (PPE-05) 

Baseline

Step 1. Calculate Baseline Costs 

 Employers must properly dispose of contaminated PPE. 

New Regulation

PPE-05. Contaminated PPE must be rendered unwearable. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Revision specifies action for proper disposal. No change from baseline. 

Step 3. Estimate Regional Level Baseline and Compliance Costs 

No costs from revision. 

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

No costs from revision. 

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

No costs from revision. 

A.7. Decontamination Supplies 

a. Water for routine decontamination, Field Workers (SUPPLY-01) 

Baseline

Step 1. Calculate Baseline Costs 

 Employers are required to provide “enough” water for workers. Guidance indicates that 

1 gal is considered sufficient. 

New Regulations

SUPPLY-01. Define “enough” water as 1 gal per worker. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Revision is definitional in nature and no impacts are anticipated. 

b. Water for decontamination at early entry events, Field Workers (SUPPLY02) 

Baseline

Step 1. Calculate Baseline Costs 

 Employers are required to provide “sufficient” water for workers entering a field during 

the REI. Guidance indicates that 1 gal is considered sufficient. 

 1 gal of water costs $0.003/gal, based on the average cost of irrigation water in Kentucky 

(the state with the highest cost) of $1,112/acre-foot (USDA, 2010). 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 141 of 148

 EPA assumes an early entry event occurs about 1 in 50 applications, implying there is a 

40% probability a WPS farm applying pesticides will have an early entry event (see 

A.2.d.) 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 WPS farm applying 

pesticides. Since 87.4% of workers are employed on WPS farms that apply pesticides in 

any given year (NASS, 2008), there is an 17.5% chance a WPS worker being involved in 

an early entry event. 

Table A.7.b-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) 0.003 1 0.175 0.001

Expected per-worker Cost (costr,i,a

B

) 0.00

New Regulations

SUPPLY-02. Define “sufficient” water as 3 gal per worker. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Parameters are as in the baseline except that 3 gallons of water will be required. 

Table A.7.b-2. Potential 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) 0.003 3 0.175 0.002

Expected per-worker Cost (costr,i,a

B

) 0.00

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 2,322,610 workers (NASS, 2008 [Census of Ag]). 

Table A.7.b-3. Regional Costs, Year 1, Water for decontamination at early entry events 

Region N wrkr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.001 

costr,i,a

P $ 0.002 

South 274,068 164 491

California 394,844 236 707

Southwest 78,969 47 141

Subtropical 111,485 67 200

Midwest 299,617 179 536

Northeast 278,713 166 499

Ohio Valley 353,037 211 632

Texas/Mountain West 185,809 111 333

Northwest 346,069 207 620

US 2,322,610 $1,386 $4,158

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farm workers is declining at 2.14% per year. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 142 of 148

Table A.7.b-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Water for 

decontamination at early entry events 

Region 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 4 1 3

California 6 2 4

Southwest 1 0 1

Subtropical 2 1 1

Midwest 4 1 3

Northeast 4 1 3

Ohio Valley 5 2 3

Texas/Mountain West 3 1 2

Northwest 5 2 3

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.7.b-5. National and Per-WPS Farm Costs, PV and Annualized (3% discount rate), 

Water for decontamination at early entry events 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

US 33 11 22

2.533 (௥ܥܫܣ) Annualized

per-entity ($/WPS farm) 0.006

c. Water for handler decontamination (SUPPLY-03 and 04) 

Baseline

Step 1. Calculate Baseline Costs 

 Employers are required to provide “enough” water for handlers. Guidance indicates that 

3 gal is considered sufficient. 

 No requirements for facilities. 

New Regulations

SUPPLY-03. Define “enough” water as 3 gal per handler. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Revision is definitional in nature and no impacts are anticipated. 

New Regulation

SUPPLY-04. Require showers for handler decontamination. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Shower construction is estimated to cost $105,000 (Gaylord Entertainment Company, 

2007). 

 All WPS farms employing handlers and CPHEs would have to construct shower 

facilities. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 143 of 148

Table A.7.c-1. Potential Cost, per large/large-small WPS farm or CPHE, Provide Showers 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Construct shower 105,000 1 1 105000.00

Expected per-farm/firm Cost (costr,California,a

P

) 105,000.00

New Regulation, California

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 California requires showers at WPS farms and CPHEs that handle organophosphate and 

carbamate pesticides, i.e., cholinesterase inhibitors (ChIs). 

 EPA calculates that 9.7% of large and large-small California WPS farms given the 

estimated percentage of handlers involved in the California ChI monitoring program. See 

A.5.d, Baseline, California. A larger percentage of CPHEs is likely to have showers and 

we calculate that 14.6% of California CPHEs have showers (50% higher than the farm 

percentage) given the assumption that 20% of farm applications are with ChIs and 30% 

of CPHE applications are with ChIs. 

Table A.7.c-2. Potential Cost, California, per large/large-small WPS farm or CPHE, Provide 

Showers 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Construct shower 

large/large-small WPS farm 105,000 1 0.903 94792.95

CPHE 105,000 1 0.854 89689.42

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 193,526 large and large-small WPS farms (NASS, 2008 [Census of Ag]) who are 

assumed to employ at least one handler. There are 2,793 CPHEs (Dun & Bradstreet, 2010; 

NAAA, 2008) and EPA estimates another 20,897 self-employed CPHEs may be affected. 

Table A.7.c-3. Regional Costs, Year 1, Provide Showers 

Region (WPS Farm) N lrg, lrg-sml WPS farm

RC B

($) 

RC P

($) 

costr,i,a

B $ 0 

costr,i,a

P $105,000

costr, California,a

P $ 94,793 

South 28,835 0 3,027,714,270

California 11,999 0 1,137,383,812

Southwest 6,193 0 650,247,360

Subtropical 4,838 0 508,005,750

Midwest 41,995 0 4,409,489,910

Northeast 19,933 0 2,092,983,690

Ohio Valley 44,705 0 4,693,973,130

Texas/Mountain West 23,804 0 2,499,388,290

Northwest 11,225 0 1,178,573,340

US 193,526 $ 0 $20,197,759,552
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 144 of 148

Region (CPHE) N CPHE N self-PHE

RC B

($) 

RC P

($) 

costr,i,a

B $ 0 $ 0 

costr,i,a

P $105,000 $105,000

costr, California,a

P $ 89,689 $ 89,689 

South 416 918 0 140,115,560

California 173 1,049 0 125,714,190

Southwest 89 662 0 78,938,496

Subtropical 70 120 0 19,905,638

Midwest 606 8,355 0 940,962,614

Northeast 288 3,386 0 385,717,847

Ohio Valley 645 2,404 0 320,132,831

Texas/Mountain West 344 889 0 129,425,657

Northwest 162 3,113 0 343,864,899

US 2,793 20,897 $ 0 $2,484,777,729

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. is declining at 0.47% per year. The number of CPHEs is 

growing at a rate of 4.27% per year. Construction of showers is a one-time event. No 

maintenance costs are included for Years 2 through 10, thus underestimating the cost of this 

potential requirement. 

Table A.7.c-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Provide Showers 

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 3,027,714 0 3,027,714

California 1,137,384 0 1,137,384

Southwest 650,247 0 650,247

Subtropical 508,006 0 508,006

Midwest 4,409,490 0 4,409,490

Northeast 2,092,984 0 2,092,984

Ohio Valley 4,693,973 0 4,693,973

Texas/Mountain West 2,499,388 0 2,499,388

Northwest 1,178,573 0 1,178,573

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 140,116 0 140,116

California 125,714 0 125,714

Southwest 78,938 0 78,938

Subtropical 19,906 0 19,906

Midwest 940,963 0 940,963

Northeast 385,718 0 385,718

Ohio Valley 320,133 0 320,133

Texas/Mountain West 129,426 0 129,426

Northwest 343,865 0 343,865

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.7.c-5. National and Per-Entity Costs, PV and Annualized (3% discount rate), Provide 

Showers 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 145 of 148

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 20,197,760 0 20,197,760

CPHE 2,484,778 0 2,484,778

Total 22,682,537 0 22,682,537

2,581,636 (௥ܥܫܣ) Annualized

per-entity ($/lrg lrg-sml WPS farm) 11,878.66

per-entity ($/CPHE) 11,937.94

d. Handler eyewash (SUPPLY-05 and 06) 

Baseline

Step 1. Calculate Baseline Costs 

 EPA assumes WPS and CPHE handlers will have a pint bottle for water to rinse his/her 

eyes if a pesticide application is made; 89.9% of large and large-small WPS farms, which 

are assumed to employ handlers, make an application in a given year (NASS, 2008). 

Table A.7.d-1. Baseline Cost, per handler, Eyewash 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Eyewash bottle 

WPS handler 1.23 1 0.899 1.11

CPHE handler 1.23 1 1 1.23

New Regulation

SUPPLY-05. Require source of running water at all permanent mixing/loading sites. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Mixing/loading sites, given their purpose, will have water source available. 

No additional cost to establishment. 

SUPPLY-06. Require portable eyewash station. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 A portable eyewash station costs $279.90, on average (Tuthill, 2008; Gempler’s, 2008). 

Table A.7.d-2. Potential Cost, per actor, Require Eyewash Station 

Action/Material wage/price 

unit 

time/quantity 

annual 

probability cost 

Portable eyewash station 

WPS farm with handler 279.90 1 1 279.90

CPHE 279.90 2 1 559.80

Self-employed CPHE 279.90 1 1 279.90

Eyewash bottle 

WPS handler 1.23 1 0.899 1.11

CPHE handler 1.23 1 1 1.23
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 146 of 148

Step 3. Estimate Regional Level Baseline and Compliance Costs 

There are 193,526 large and large-small WPS farms (NASS, 2008 [Census of Ag]). Given EPA 

assumptions that large farms employ 2 handlers, on average, and large-small establishments 

employ 1, there are a total of 247,815 handlers. WPS farms and handlers are distributed across 

regions in the same proportion as total farms. There are 2,793 CPHEs employing 17,080 

handlers (Dun & Bradstreet, 2010; NAAA, 2008) and EPA estimates another 38,311 selfemployed CPHEs, for whom we only consider the additional cost of the eyewash station. 

Table A.7.d-3. Regional Costs, Year 1, Require Eyewash Station 

Region (WPS Farm) N lrg, lrg-sml WPS farm N WPS hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 1.11 

costr,i,a

P $ 279.90 $ 1.11 

South 28,835 36,924 40,843 8,111,864

California 11,999 15,365 16,995 3,375,407

Southwest 6,193 7,930 8,772 1,742,145

Subtropical 4,838 6,195 6,853 1,361,051

Midwest 41,995 53,776 59,483 11,813,923

Northeast 19,933 25,525 28,234 5,607,530

Ohio Valley 44,705 57,245 63,321 12,576,112

Texas/Mountain West 23,804 30,481 33,716 6,696,371

Northwest 11,225 14,373 15,899 3,157,638

US 193,526 247,815 $ 274,115 $54,442,043

Region (CPHE) N CPHE N self-CPHE N CPHE hndlr

RC B

($) 

RC P

($) 

costr,i,a

B $ 0.00 $ 0.00 $ 1.23 

costr,i,a

P $ 559.80 $ 279.90 $ 1.23 

South 416 1,684 2,545 3,130 707,309

California 173 1,924 1,059 1,303 636,721

Southwest 89 1,214 547 672 390,625

Subtropical 70 220 427 525 101,064

Midwest 606 15,318 3,706 4,559 4,631,451

Northeast 288 6,207 1,759 2,164 1,900,642

Ohio Valley 645 4,407 3,945 4,853 1,599,486

Texas/Mountain West 344 1,630 2,101 2,584 651,132

Northwest 162 5,707 991 1,218 1,689,292

US 2,793 38,311 17,080 $ 21,008 $12,307,723

Step 4. Calculate the PV of Costs. 

Step 5. Estimate the Regional Incremental Cost of the Potential Requirement. 

The number of farms in the U.S. , and therefore the number of handlers employed on farms, is 

declining at 0.47% per year. The number of CPHEs is growing at a rate of 4.27% per year and 

the number of handlers employed by CPHEs is growing at 0.17% per year. Purchase of eyewash 

stations is a one-time event. Maintenance costs of 10% of the purchase price are included for 

Years 2 through 10. 

 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 147 of 148

Table A.7.d-4. Regional Costs, PV (3% discount rate) and Incremental Cost, Require Eyewash 

Station 

Region (WPS Farm) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 14,567 352 14,215

California 6,061 146 5,915

Southwest 3,128 76 3,053

Subtropical 2,444 59 2,385

Midwest 21,215 512 20,702

Northeast 10,070 243 9,827

Ohio Valley 22,583 545 22,038

Texas/Mountain West 12,025 290 11,735

Northwest 5,670 137 5,533

Region (CPHE) 

PV(RC P) 

($1000) 

PV(RC B) 

($1,000) 

PV(IC) 

($1,000) 

South 1,406 28 1,378

California 1,255 12 1,244

Southwest 769 6 763

Subtropical 201 5 197

Midwest 9,097 40 9,056

Northeast 3,735 19 3,716

Ohio Valley 3,164 43 3,121

Texas/Mountain West 1,292 23 1,269

Northwest 3,315 11 3,304

Step 6. Estimate National Level Incremental Cost of the Potential Requirement. 

Table A.7.d-5. National and Per-Entity Costs, PV and Annualized (3% discount rate), Require 

Eyewash Station 

PV(NC P) 

($1,000) 

PV(NC B) 

($1,000) 

PV(NIC) 

($1,000) 

WPS Establishment 97,764 2,361 95,403

CPHE 24,235 186 24,049

Total 121,999 2,547 119,452

13,596 (௥ܥܫܣ) Annualized

per-entity ($/lrg lrg-sml WPS farm) 56.11

per-entity ($/CPHE) 66.59

A.8. Emergency Response 

a. Field Workers (EMERG-01 and 02) 

Baseline

Step 1. Calculate Baseline Costs 

 Employers are required to provide “prompt” attention in case of a pesticide incident. 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review *** 

Page 148 of 148

New Regulations

EMERG-01. Define “prompt” as within 30 minutes for incidents involving field workers. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Revision is definitional in nature and no impacts are anticipated. 

EMERG-02. Define “prompt” as within 60 minutes for incidents involving field workers. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Revision is definitional in nature and no impacts are anticipated. 

b. Handlers (EMERG-03 and 04) 

Baseline

Step 1. Calculate Baseline Costs 

 Employers are required to provide “prompt” attention in case of a pesticide incident. 

New Regulations

EMERG-03. Define “prompt” as within 30 minutes for incidents involving a handler. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Revision is definitional in nature and no impacts are anticipated. 

EMERG-04. Define “prompt” as within 60 minutes for incidents involving a handler. 

Step 2. Calculate Per-Actor Costs of Potential Requirement 

 Revision is definitional in nature and no impacts are anticipated.