May 6, 2005 

Dear Colleagues, 

 As Director of the Office of Pesticide Programs, I am grateful to all who donated 

their time and energy to participate in the National Assessment of EPA’s Pesticide Worker Safety 

Program. This effort was a large undertaking that combined an assessment of the 

implementation of the agricultural worker protection regulation, as well as an assessment of the 

pesticide applicator certification regulation and training program. It was a necessary process 

that advanced the Agency’s mission to protect all pesticide workers and illustrated the value of 

public input in guiding our priorities. 

The assessment has prompted many improvements in the Agency’s pesticide 

worker safety program and has helped identify key activities for EPA to pursue in further 

improving the program. The assessment report findings can be grouped in broad areas, such as, 

the need to: 

• expand and to upgrade applicator and worker competency 

• increase activities to promote safer work practices 

• improve worker training and communication with workers 

• focus on enforcement efforts and improve the training of inspectors 

• train health care providers and monitor pesticide incidents 

• focus on operational efficiencies 

The Agency has already responded to those suggestions that could be addressed in the 

near term. In addition, we have developed a long-term strategy, a post assessment action plan, to 

follow up on other findings. I hope that in our follow-up efforts, we can work together with the 

same positive spirit and energy that was so apparent in the assessment activities. 

The pesticide worker safety program is a key component of EPA’s efforts to protect 

human health and to safeguard the environment. I look forward to cooperating with program 

stakeholders as we initiate our post assessment action plan to continue to improve the pesticide 

worker safety program. 

 /s/

 Jim Jones, Director 

 Office of Pesticide Programs 
U.S. Environmental Protection Age

U.S. Environmental Protection Age

Office of Pesticide Programs Office of Pesticide Programs
Acknowledgement 

As Director of the Office of Pesticide Programs, I am grateful to all who donated thei

the National Assessment of EPA’s Pesticide Worker Safety Program. This effort was a largassessment of the implementation of the agricultural worker protection regulation, as well aapplicator certification regulation and training program. It was a necessary process that a

protect all pesticide workers and illustrated the value of public input in guiding our prioritimany improvements in the Agency’s pesticide worker safety program and has helped identifin further improving the program. The assessment would not have been successful without the program’s stakeholders and regulatory partners. Thank you. 

Jam

Offi

U.S. Environmental Protection Agency Office of Pesticide Programs Washington, D.C. www.epa.gov/pesticides 
Table of Contents 

Executive Summary ........................................................................Introduction ...................................................................................Results of the Assessment .................................................................

Agricultural Worker Protection Program Suggested Improvements .....Certification and Training Program Suggested Improvements ............

Post-Assessment Action Plan .............................................................Conclusion ......................................................................................Appendix I: Summary of EPA Pesticide Worker Safety Projects.................
Executive Summar

1 

“EPA is committed to assuring safe working conditions and adequate workplace protections for all pesticide workers in the United States. Pesticide worker safety is one of OPP’s highest priorities.” 

—Jim Jones 

Director of the 

Office of 

Pesticide 

Programs 

This report provides the findings from the national assessment of the Un

Agency’s (EPA) pesticide worker safety field program. EPA conducted an in-dfield program to gauge the status of implementation and identify areas for improassessment consisted of : 1) the national assessment of the agricultural worker pprogram activities; and 2) an assessment of the pesticide applicator certification Certification and Training Assessment Group (CTAG). 

Attendees at the three agricultural worker assessment meetings numbere

farmworker advocates, the cooperative extension service, commodity organizatiofederal agency representatives, pesticide industry and individual growers met witwith the implementation of the WP. The certification program for pesticide appl

whose membership includes our state and tribal partners, USDA, and cooperativ

The various individual opinions and suggestions made during the course 

improvement areas: the expansion and upgrade of applicator and worker compepractices, improved training of and communication with all pesticide workers, intraining of inspectors, training of health care providers and monitoring of pestici

efficiency and funding. When feasible, the Agency has pursued some of the suggestions received before following are complete or underway: • Revision and development of improved outreach and compliance assistance m

training resources and a central point of distribution for these materials

• Improved guidance and expanded training for enforcement inspectors, and inc

offices

• Improved training materials for train-the-trainer programs which will promote • Continued funding of worker training • Conducting research into appropriate methods for risk communication to work• Expanded funding of pesticide incident monitoring • Revised grant guidance to states for improved enforcement tracking, incident 
• Pesticide worker safety train-the-trainer programs in Mexico and Central America 

• Held and will continue to hold public pesticide worker safety forums for stakeholder input • Developed a reporting template for state certification programs to facilitate improved program management • Continued funding of the health care provider initiative 

Additionally, the Agency plans to pursue: • Development of training materials tailored to specific pesticide using sectors and the labor force employed b

sectors.

• Support of the development of diagnostic tools for health care providers to better care for individuals who w

around pesticides.

• Revision of regulations which govern the prescribed work practices, training and competency gauges of pes

workers, including applicators, mixers, loaders, handlers, crop advisors, and agricultural field workers.

• Improvement of methods to gather information on pesticide-related incidents to be used to improve regulati

products.

A number of the suggestions for improvement would require rule change in order to implement. The Agency 

these and plans to initiate rule revisions to the Worker Protection, Certification of Pesticide Applicators and 

Requirements for Pesticides and Devices regulations. The Agency is considering: 

• Strengthening the worker training provisions, including content, grace period, retraining interval, trainer re

verification system. 

• Establishing a hazard communication program for workers including training and field notification and po

the central posting requirements. 

• Reconsidering the retaliation provisions of the worker protection regulation. • Expanding the scope of the applicator rule to include all individuals that mix, load or apply any pesticide a

occupation, including handlers as currently defined in the worker protection regulation.

• Establishing minimum standards for all occupational users, including competency gauges and levels of lice

risk profiles. 

• Standardizing applicator competency and licensing programs administered at the state, tribal, or federal lev• Developed, with Canada, valid exams for core applicator competencies. 

Over the next few years, the Agency will pursue the development of regulations that enable the impro

outlined here, improve the monitoring of pesticide incidents to better link to the pesticide regulatory system, dimproved pesticide occupational training materials and competency testing, as funding allows. The National AEPA’s Pesticide Worker Safety Program has already led to improvements and has helped the Agency to identiactivities on which to focus for future improvement. 
Introduction 

The combined national assessment is the product of workshop sessions and workgroup meetings designed to assess the status of program implementation and to identify suggested areas of improvement, and involved a diverse collection of stakeholders. 

3 

This report summarizes the findings from the national assessmen

Protection Agency’s (EPA) pesticide worker safety field program. The pconsists of several elements, including: the worker safety regulations; thregulations; and the science policy, worker risk assessment and risk miticritical component of EPA’s mission to protect human health and the envthe first two elements - the worker safety regulations and related field pr

provides the results of a review of the national pesticide worker safety pr

to evaluate individual state programs. 

EPA conducted the review of its pesticide worker safety regulatio

of implementation and identify areas for improvement. The worker safetwo parts: the national assessment of the agricultural worker protection rcomponents, and an assessment of the pesticide applicator certification rthe Certification and Training Assessment Group (CTAG). For both parincluded representatives from a diverse set of interested parties. 

The national assessment for the agricultural worker protection pr

brought forward by stakeholders, by a planned program evaluation, and (GAO) and Children’s Health Protection Advisory Committee (CHPAC

The national assessment for the agricultural worker protection pr

interested public an opportunity to share their concerns in a workshop seinterest, the workshops were held in states with significant agricultural pthe three agricultural worker protection program assessment workshops n

Representatives from farm worker advocacy groups, the coopera

organizations, our state regulatory partners, and individual growers met iCalifornia, and Florida in 2000 and 2002 to voice their concerns and issuagricultural worker protection regulation. From these sessions, workgroprimary concerns. The Agency acted quickly to implement changes basein Washington, DC in 2003, the assessment workgroups and EPA presensessions. The work groups’ activity continued through 2004. 
The certification regulation and training program for pesticide applicators was reviewed by the Certi

Training Assessment Group (CTAG). Established in 1996 to assess the status of the C&T program, CTAG twice a year; membership includes our state lead agency and tribal partners, USDA, and cooperative extensithe regulatory and the extension-led education and training aspects were examined as part of the process. 

A wide array of stakeholders participated in several focused workgroup sessions to identify the full r

implementation issues and suggest strategies for improving the C&T program. The CTAG effort resulted in extensive report entitled, “Pesticide Safety in the 21st Century.” For a copy of the CTAG report, or for more information about CTAG and its activities, visit the official CTAG website: http://pep.wsu.edu/ctag. 

The process resulted in a variety of suggested improvements. The Agency moved quickly to implem

critical changes, and began work on other suggestions which would contribute to continued program improvThis report contains a description of the process, a listing of the key findings, an action plan, and supplemeninformation on EPA’s worker safety field program. 

EPA’s Role in Pesticide Worker Safety 

EPA’s Office of Pesticide Programs (OPP) evaluates data and information to ensure pesticides meet 

federal safety standards designed to protect human health and the environment. In connection with its mandsafeguard public health and the environment from the risks posed by pesticides, EPA is responsible for assuoccupational safety of pesticide workers—those people whose jobs require them to work with or around pesThis includes private and commercial pesticide applicators, millions of agricultural farm workers, and other make or assist with pesticide applications as part of their job. 

The task of protecting pesticide workers from occupational exposure to pesticides presents a challeng

the complexity of the science and policy issues involving pesticide use, the variability of pesticide use pattediversity of the labor population being served. To meet this challenge, EPA has developed a robust pesticide safety program and is committed to assuring safe working conditions and adequate workplace protections fo

pesticide workers in the United States. OPP has made pesticide worker safety one of its highest priorities. 

As mentioned previously, the EPA pesticide worker safety program includes a sound science compo

involves occupational risk assessment and risk management decision-making that culminate in product regislabeling provisions for worker safety. This report, however, covers the pesticide worker safety field componprogram – the two major worker safety regulations - the agricultural worker protection regulation and the pe

applicator certification regulation - and their complementary field components. These, along with a special for health care providers, constitute the strategic framework for the pesticide worker safety field program. Tthese elements provide a range of protections for pesticide workers. The major components of this program described in detail in the following section. 
5 

The Role of States, Tribes, Territories, and State Cooper

EPA’s strategic plan is to ensure healthy communities and ecosystem

protecting human health and the environment from risks posed by pesticides control. To achieve this mission, EPA has developed a comprehensive stratmanagement principles. The states, tribes, territories, and state cooperative risk management through their pesticide worker safety programs. The lead ragencies, and EPA work cooperatively to minimize risk to the public and to pesticides. EPA helps support lead regulatory and safety training agency proagreements. EPA and its grant and cooperator partners are responsible for athrough these vehicles achieve the health and environmental objectives estab

These efforts include assuring that the programs make efficient use of resourappropriately conducted to reduce the risks associated with pesticide use. 

The Major Components of EPA’s Worker Safety Progra

EPA’s pesticide worker safety field program is made up of three majo

applicator competency, protections for agricultural labor, and a health care inworks with an extensive network of partners including EPA’s Office of Enfo(OECA) and regional offices, state and tribal pesticide regulatory agencies, tother stakeholders to implement the field program components of the pesticiits regulatory efforts, EPA funds a variety of collaborative field projects and governmental and non-governmental organizations. 

Agricultural Worker Protection. The agricultural worker protection reguwho enter fields after pesticide application to perform crop-related tasks, sufor those who mix, load, and handle pesticides. The regulation has provisioentry restrictions and protective equipment. Ensuring compliance is the resPesticide Applicator Certification. The regulation for the certification of with intentions to apply restricted use products to demonstrate competency pesticides. This requirement is designed to assure that certified applicators human health and/or the environment from misapplication and exposure to Health Care Providers Initiative. EPA and interested partners developed Providers: Pesticides Initiative in response to a need for increased skills in tand treating pesticide poisoning. The initiative is a collaborative effort desimedical community regarding proper diagnosis and effective treatment of p
Strategic Framework for Pesticide Worker Safety Field Programs 

The integration of the components described on the previous pages - the agricultural worker protec

applicator certification regulations, the respective field program components, and the health care provider icreates the basic strategic framework for EPA’s pesticide worker safety field program. When these elemen

linked appropriately, they provide a comprehensive network of field-based protections that work in combinprotect America’s pesticide workers. 

Sound Science 

Risk Assessment 

Risk Mitigation Decisions Product Labeling 

Agricultural Worker Protection Regulation and Field Programs 

Certified Pesticide 

Application Regulation 

and Training Program 

Health Care 

Provider Initiative 

Pesticide Workers 

The above diagram illustrates how regulatory and non-regulatory components integrate to create the strategic framework for EPA’s pesticide worker safety program. 
7 

The above diagram illustrates the role and the importance of field data a means to allow pesticide field data to be incorporated into basic progrfuture science decisions, regulatory decisions, and training / outreach msafety. 
The Agricultural Worker Protection National Assessment 

The worker protection assessment focused on the effectiveness of EPA’s field implementation of the WP rThe worker protection assessment was initiated by OPP for the reasons described here: 

EPA’s Planned Program Evaluation. Early in the agricultural worker protection regulation’s field implementation effort issues arose regarding of the regulation and conflicts with field realities. Although ad

at the time, EPA committed to re-evaluate its field implementation effort more completely after the regulatthe early revisions had been in full effect for a longer period of time. 

The Government Accountability Office conducted a study of EPA’s agricultural worker protection progrissued a report entitled, “Pesticides: Improvements Needed to Ensure the Safety of Farmworkers and their Children.” The report identified several areas of concern regarding the program, and included recommenfor program improvements. In response, EPA committed to review the agricultural worker protection progand take steps to address the concerns that were raised. Children’s Health Protection Advisory Committee identified areas of concern with the agricultural workprotection program in its evaluation of the potential risks to farmworker children from pesticides. The Ageagreed to assess certain science aspects of its agricultural worker safety program to assure that its regulator

decisions were adequately protective of farmworker children that may be working in agricultural areas. 

The WP assessment effort consisted of three EPA-led public workshops held in Austin, Texas; Sacra

California; and Orlando, Florida. The workshops included broad stakeholder participation from all segmentregulated and protected community, including EPA’s regulatory partners. The workshops led to the formatifollow-up workgroups. The facilitated workgroups discussed the full range of issues identified during the fithe process; identified key implementation issues and regulatory problems; and developed suggestions for primprovements. The worker protection assessment culminated in a final meeting held in Washington, DC wh

various assessment workgroups presented their findings to EPA. 
9 

The Certification and Training Assessment Group 

The Certification and Training Assessment Group (CTAG) was form

assess the operation of the applicator certification regulation and training com

The review encompassed the regulatory aspects of the program as well as th

aspects of the program. 

A wide array of stakeholders participated in focused workgroup sess

implementation issues and to suggest strategies for improving the C&T progeffort resulted in an extensive report entitled, “Pesticide Safety in the 21st Cor for more information about CTAG and their activities, you can visit the ohttp://pep.wsu.edu/ctag. 
Results of the Assessment 

The workshop and workgroup processes resulted in numerous suggestions and the identification of 

number of important issues, as a result of the commitment of time and energy by stakeholders and agency Conducting the national assessment required a substantial investment of resources by the Agency and partstakeholders. Given the importance of the effort and the results, it was a valuable resource investment. Sothe immediate results from the assessment include: 

 Actions Taken - Suggestions being addressed through workgroup efforts and workshops; funding p

where possible to support important initiatives; and programs developed to further improve the qualiworker protections. 

 Greater Transparency – EPA made clear its approach to worker protections; involved stakeholders 

workshops and in developing new materials; and has generally made its efforts and processes more accessible through meetings and public forums. 

 Increased Awareness – The assessment raised awareness of the program and the array of activities 

associated with it, and focused attention on funding, the existing infrastructure, and the difficult issue

by EPA and its state and tribal regulatory partners. 

 Better Program Coordination – The assessment results indicated that an integrated approach to wor

safety was needed. Efforts in this area have improved coordination across the pesticide enforcement programmatic functions at EPA, and there is now better coordination with regulatory partners on field implementation. 

 Worker Safety Network - The assessment process helped to establish a pesticide worker safety “net

This network of interested and engaged stakeholders has strengthened the program and produced opportunities for partnership and collaboration. 

 Identification of Areas for Program Improvement – The assessment highlighted problems with cu

methodologies and resulted in suggestions for program improvements and research. It also highlighteneed to more closely link risk assessment and risk management processes with field implementation rThe assessment resulted in identification of specific field implementation concerns and weaknesses woperational improvements or regulatory changes might be considered. 
11 

One of the major products of the national assessment effort was the developmimprovements. The intent of the assessment meetings and subsequent works

rather to capture the full range of suggestions from all stakeholders. This dosample, highlighting the most important and pressing issues related to the cosafety program. The suggestions are grouped according to key theme areas—the course of the assessment process. 

The assessment process helped to establish a pesticide worker safety network of interested and engaged stakeholders that has strengthened the program and produced new opportunities for partnership and collaboration. 

• Program Outreach and Communications • Agricultural Worker Protection Training • Agricultural Worker Protection and Label Regulations • Incident Monitoring and Health Care • Hazard Communication • General Program Issues • Compliance and Enforcement 

Agricultural Worker Protection Program Su

Key of Status Terms: Done: EPA has completed its actions on this suggestion. Doing: Work is currently underway to address this suggested 

completed in the near future. 

Ongoing: EPA is committed to maintaining continued efforts r

improvement. 

Planned: EPA will address this suggested improvement in the 

allow. 

Considering: EPA will consider this suggested improvement 

program. 
Program Outreach and Communication

Major Concern and Suggested Improvement Status Response 

Develop worker outreach 

material with information about how to 

file complaints and how to get information about pesticides. 

Ongoing EPA will continue to w

develop and 

make outr

Develop a centralized resource center for training materials and compliance assistance informatio

n. Use the web to facilitate 

public access. 

Ongoing EPA is using the Offic

Assistance’s Ag Centecompliance assistance accessible at 

http://

w

w

Work with stakeholders to evaluate existing compliance assistance and outreach materials and to develop new materials where needed. 

Ongoing EPA is updating the H

stakeh

older input. EPA 

other priorities for com

Alert the regulated com

munity of worker protectio

n label 

changes that result from re-registration decisions. 

Ongoing OPP’s Com

munication

com

municate pesticide 

Maintain a catalog of worker protection resources and training materials. 

Ongoing A list of EPA supporte

the Ag Center web site 

Develop outreach materials for both growers and workers in multiple languages. 

Ongoing EPA has supported tran

do so, as res

ources per

Develop focused outreach materials for different segments of the regulated co

m

munit

y — emplo

yers, labor co

ntractors, 

employees, health care providers, etc. 

Planned EPA will work to iden

segments of the regularesources permit. 

Agricultural Worker Protection Trainin

Develop and implement a national train-the-trainer (TT

T) 

pro

gram. 

Doing As a result of the asses

and piloted a national Tthe adoption of TTT prhttp://www.epa.gov/op

Support advocacy-based training progra

ms for farmworkers. Ongoing EPA funds a farmwork

trai

ning program. 

Encourage and promote interactive training programs Ongoing EPA supports activity 

and training 

programs. 
Major Concern and Suggested Improvement Status Response 

Develop better quality pesticide safety training materials that meet the needs of the different populations. [The general training workgroup report contains a list of suggested improvements.] 

Ongoing EPA will follow the su

assessment workgroupreviewing training mahttp://www.epa.gov/op

Develop and showcase model training programs. Ongoing EPA piloted a national 

pursue similar projects

Evaluate training programs to collect data on behavior change and risk reduction in order to determine outcome measures of program effectiveness. 

Ongoing EPA is developing pro

of evaluation tools. 

Develop training packages for specific agricultural sectors. Planned EPA is interested in pi

permit. 

Agricultural Worker Protection & Label Reg

Include additional information in worker training to improve the protection of workers. [See general training assessment workgroup report for details.] 

Considering 

Implementing these suEPA will consider thesrevisions of the pestici

Shorten the 5-yearworker re-training interval to between 1-3 years. 

Considering 

Eliminate the provisions which permit certified applicators and trained handlers to be trainers of workers. 

Considering 

Eliminate grace period before workers must be trained. Considering Require employers to document training of workers and handlers. Considering Move handler training from the WP regulation to the applicator regulation. 

Considering 

Implement a mandatory training verification system. Considering Establish more specific standards for the content and delivery of training programs to assure the quality of training. 

Considering 

13 
Major Concern and Suggested Improvement Status Response 

Require fit testing and medical monitoring for products with respirator requirements, consistent with OSHA and NIOSH requirements. 

Considering 

Implementing these suEPA will consider thesrevisions of the pestici

Impose label restrictions prohibiting children under the age of 16 from working in fields treated with pesticides that have high acute toxicity, or chronic or developmental concerns. 

Considering 

Address pesticide labeling problems that allow commercial agricultural operations to avoid WP coverage by using non-WP labeled products. 

Considering 

Consider changes to the warning sign, central information display, and field posting / notification provisions to find more effective ways to provide intended protections. 

Considering 

Expand the scope of worker protection regulation to cover nonagricultural operations. Considering Strengthen the retaliation provisions. Considering 

Incident Monitoring and Health Care 

Establish a national pesticide incident monitoring and reporting program, so that EPA will have accurate information on the occupational pesticide exposure and illness. 

Ongoing EPA is funding severa

monitoring and reportisources of data related 

Develop worker outreach materials focusing on pesticide related illness. Coordinate with migrant clinics to provide these materials to workers seeking medical attention. 

Ongoing In grant guidance, EPA 

migrant clinics to provthe pesticide regulatory incidents. 

Integrate the efforts of the National Strategy for Health Care Providers more closely with the worker safety program. Involve the migrant clinicians network to achieve better health care for pesticide workers. 

Considering EPA agrees that there i

considering sponsoring 
Major Concern and Suggested Improvement Status Response 

Require that acute and chronic hazards and risks to workers and handlers be listed on pesticide labels. 

Considering EPA will consider this i

for the improvement of 

Develop guidance for the health care provider community on appropriate diagnostic tools and other types of documentation to improve the diagnosis of pesticide poisonings and illnesses. 

Planned EPA agrees that there is 

considering sponsoring 

Hazard Communication 

Conduct hazard communication pilot projects to evaluate different regulatory approaches for carrying out pesticide- and site-specific hazard communication. 

Doing EPA will conduct hazar

designs will be based on assessment hazard comm

Establish training requirements for hazard communication on site-specific pesticide hazards and address the stakeholder concerns identified in the hazard communication working sessions. 

Considering EPA agrees with the ne

site-specific pesticide hregulation change. EPA planned amendments to regulations. 

General Program 

Convene periodic workshops on pesticide worker safety to provide a forum for the discussion of issues related to pesticide worker safety and occupational pesticide illness and exposure. 

Ongoing EPA plans to hold regu

Stress engineering controls as the primary risk management option for regulatory decisions that call for reducing exposure. 

Ongoing EPA agrees that engine

workers and will strive 

Address the lack of adequate resources to properly implement and enforce the worker protection program. Make pesticide worker safety a high priority by allocating more resources to the program. 

Ongoing EPA has identified pest

funds generated by the have been allocated to e

Explore forming more collaborative partnerships and funding more innovative worker safety projects to help accomplish worker protection program goals. 

Ongoing EPA funds many innov

through grants to goverorganizations. EPA colenhance its core regulat

15 
Compliance and Enforcement 

Major Concern and Suggested Improvement Status Response 

Assure workers get information on how to report tips or file complaints regarding pesticide incidents or retaliation. 

Done Through the annual gra

to assure outreach to wcomplaints regarding p

Improve national guidance to state and tribal enforcement programs on how to conduct effective worker protection inspections, including development of a national checklist to promote thorough inspections. 

Done EPA revised worker pr

establishes clear nationprotection inspections, interviews, and a range stakeholders and regulconducting worker inte

Develop standard operating procedures for the complaint process to assure that complaints involving critical health effects are given priority response times. 

Done States and tribes agree 

inspection and enforcesignificant pesticide malleged health effects. 

Establish clear reporting guidelines for states and tribes regarding the information needed by EPA on worker protection enforcement. 

Done EPA established clear 

the revised inspection g

Place more emphasis on conducting interviews with workers and handlers during inspections. Develop material to help inspectors overcome cultural and language barriers when conducting interviews 

Ongoing EPA has made intervie

element of certain worsuch interviews in othe

Involve farmworker groups in the development of inspector training in this area. 

Ongoing Where appropriate, EP

representatives, when d

Develop a national inspection checklist to promote thorough inspections. 

Ongoing EPA is working with s

checklist. 

Develop material to help inspectors conduct interviews with workers such as how to overcome cultural and language barriers and how to work better with farmworkers on complaints to maximize cooperation and minimize retaliation potential. 

Ongoing EPA provides tips for c

inspection guidance. Etraining manual to help workers. This materia
Major Concern and Suggested Improvement Status Response 

Produce an annual national report on the results of state / tribal worker protection enforcement activities. 

Ongoing EPA compiled recent 

enforcement data in a nwebsite at http://www.

programs/fifra/wpsrepo

Reactivate the worker protection interpretive guidance workgroup (IGW) process to address worker protection enforcement policy issues. 

Ongoing EPA reactivated the IG

will be posted to EPA 

Increase the field presence of EPA staff, so they can work with inspectors on worker protection inspections. Provide training to federal oversight personnel. 

Ongoing As resources permit, re

more field visits with sprotection inspections. during annual training residential training (PIdeveloper training. 

Provide more worker protection inspection training opportunities for state and tribal inspectors. 

Ongoing Through the national p

(PIRT) program, EPA inspection focused traiand tribal personnel atttraining. Regions sponfor state and tribal persstates and tribes to proallow. 

Collect information on the number and type of worker protection related complaints states receive and the results of state responses. 

Ongoing EPA is now requiring 

the number of and resuor incident complaints 

Establish a national toll free hot-line for workers to call to file worker protection complaints and / or report pesticide incidents. 

Ongoing EPA is exploring oppo

provide this service. 

Compile information on state penalty policies for worker protection and make it publicly available. 

Considering EPA will consider this 

performance measures will look at effectivenepreventing future viola

17 
Major Concern and Suggested Improvement Status Response 

Establish an oversight committee, including farmworker representatives, to review state implementation of the worker protection program. 

See Response 

EPA has seen the overthat address general ovwork with stakeholder

Assure that state complaint response procedures preserve worker confidentiality to the maximum extent possible. 

See Response 

States must follow statinvestigation process fauthority in this area, bissues when respondin

Encourage appointment of worker advocates to state pesticide boards, so that consideration is given to worker issues in pesticide decisions. 

See Response 

EPA has no authority trepresentatives on state guidance, EPA does enadvocates. 

Maintain stronger oversight of states and tribes, make the oversight process more transparent, define clear performance standards for enforcement programs, and establish a clear policy for dealing with states and tribes that fail to meet standards. 

See response 

EPA conducted a detaithe worker protection pElement Review shoul

Promote adoption of penalty policies and enforcement remedies directing that fines for worker protection violations be used to fund worker protection safety activities. 

See Response 

EPA has no authority tfrom fines. EPA does that allow fines to be uthe violation. 
The Certification and Training Assessment Group (CTAG) conducte

applicator certification regulation and training (C&T) program which resulte

21st Century.” The CTAG report does not reflect consensus by the participa

issues with and suggestions for improving this portion of the worker safety pcapture each suggestion outlined in the report, but gives a sense of the criticarelated to the C&T program. 

The ongoing efforts of CTAG have resulted in a variety of reports a

for improving the operation and infrastructure of the pesticide applicator cer

full range of CTAG suggestions and issue papers is available on the CTAG 

Certification and Training Program Sugg

Assessment suggestions for the certification and training progrfollowing goal areas: 

• Provide Quality Training Programs • Improve Applicator Competency • Ensure Adequate and Equitable Program Funding • Improve Program Operation and Efficiency 

19 

The component assessments were conducted concurrently and shared the basic common approach of having an emphasis on public participation and stakeholder involvement in the assessment process.
Provide Quality Training Programs 

Major Concern and Suggested Improvement Status Response 

Provide 

mechanisms to improve the skills of trainers (such as 

train-the-trainer programs). 

Done EPA has supported the 

region Pesticide Safet

y 

efforts in other regions

Create a website as s

ource of information about new and revised 

training materials. 

Done EPA supported t

he dev

State University. [http

Develop a natio

nal core manual and trai

nin

g materials for 

categories that are nationally consistent. National materials sho

uld 

be developed in electronic and modular formats. 

Doing EPA collab

orated with 

manual in electronic anmaterials are being con

Establish pr

ocedures for coor

dinating regio

nal and / or natio

nal 

development and review of applicator training materials to make better use of program resources and to help assure national traini

ng 

q

uality an

d consistency. 

Ongoing EPA is working with s

can be gai

ned through 

developed in these areastructural pest control. 

Establish a natio

nal network of subject matter and technology 

experts to meet scarce res

ource needs. 

Ongoing EPA has pla

yed an act

Association of Pesticidneed. 

Update the national competency standar

ds for pesticide 

applicators and develop a 

new national model curriculum for 

trai

ning. 

Considering EPA will consider this 

pesticide worker safety 

Improve Applicator Competency 

Develop program policy or guidance related to the American Disabilities Act and share this with pro

gram partners. 

Done 

E

PA has develo

ped g

u

it relates to applicator cto our progra

m partner

Develop an updated, validated natio

nal core exam and manual for 

applicator training and certification. 

Doing The new core exam is 

core manual should be 

Facilitate reciprocity a

gree

ments between states. Ongoing 

E

PA 

plans t

o facilitate 
Major Concern and Suggested Improvement Status Response 

Require states to use accepted validation processes to develop certification exams. 

Considering 

EPA will consider thesamendments of the pe

Establish regulatory prerequisites for pesticide applicator certification (minimum age, English proficiency, job experience). 

Considering 

Establish a national recertification period (maximum of five years), and require continuing education for applicators to get recertified. 

Considering 

Require all certified applicators to pass proctored, closed-book, written exams to demonstrate competency. 

Considering 

Expand the scope of the certification of pesticide applicators regulation to include all who apply pesticides as part of their occupation. 

Considering 

Incorporate the agricultural worker protection regulation handler training requirements in an amended certification regulation. 

Considering 

Develop and implement a tiered classification system for pesticides, instead of the current single restricted use classification system. Establish different competency standards and training levels for users of higher risk chemicals or for applications with high potential for public exposure. 

Considering 

Ensure Adequate and Equitable Program F

Provide funds to buy electronic grading machines. Ongoing EPA has provided fund

do so as resources are 

Provide information to program partners on certification and training projects funded through the EPA regional offices. 

Ongoing EPA is collecting this i

interested program stak

Work with state programs to share information on successful, innovative funding strategies used to fund programs and activities related to applicator certification and training. 

Ongoing EPA is collaborating w

information through thcertification and trainin

21 
Major Concern and Suggested Improvement Status Response 

Change the federal funding formula for distributing EPA’s pesticide applicator certification and training grant funds to state regulatory agencies and state cooperative extension services. 

Considering EPA is evaluating pote

operation and accountawill consider this suggchanges. 

Assess a fee on pesticide registrations to help cover the costs of the applicator certification and training. Explore other nontraditional sources of funding for the applicator training programs. 

See Response 

EPA has not been authprogram. 

USDA should provide consistent annual funding to state extension service programs for pesticide safety education program activities. 

See Response 

EPA continues to encoto state extension serviprogram activities. 

Improve Program Operation and Efficien

Encourage monitoring of applicator training programs to help assure national quality and consistency of training. 

Done EPA requires monitori

of the conditions of the certification and trainin

Develop better tools and / or processes to evaluate the program and measure success so the Agency can improve its capability to demonstrate program outcomes. 

Doing EPA is working with s

performance measuresits field programs. 

Fund pilot projects that focus on developing program evaluation tools and / or valid program measures. 

Ongoing EPA is funding grants 

training programs. EPprojects. 

Identify ways to improve cooperation between the implementing agencies involved in the pesticide applicator certification and training programs. 

Ongoing EPA is evaluating pote

operation and accounta

Require annual updating and review of state and tribal plans for the certification of pesticide applicators. 

Ongoing EPA requires this of al

national state plan data
Post-Assessment Response and Follow-up 

EPA is committed to continued improvement of the worker safety pro

pesticide workers, and the Agency plans to undertake a variety of activities to further reduce the potential risks to workers from occupational pesticide expoassessment, OPP has developed a strategic plan that describes the worker safe

undertake in the coming years. The plan outlines both the short and long term identifies specific priorities and annual critical outputs designed to enhance exhuman health and the environment from pesticides and to contribute to the ach

The Agency’s priorities for worker safety are a direct reflection of EPA’s comidentified during the assessment process. The post-assessment follow-up actistrategic plan for worker safety are discussed in this section. 

Strategies for Program Improvements - Short Term Acti

EPA has already acted on many of the suggestions for improvements t

The immediate post-assessment follow-up was aimed at taking actions to makbe directly managed by the Agency and accomplished in the short term withoactions were relatively simple and easily accomplished, while other actions reinvestments and/or extensive coordination with our regulatory partners. Some to improve the worker safety program are highlighted below. 

Post-Assessment Action 

23 

In follow-up to the national assessment, OPP has developed a strategic plan to implement short- and long-term improvements to the worker safety program. 

Improved Program Coordination and Guidance. EPA developed updated program field implementation that established clear program priorities and repnational consistency. EPA also issued new inspection guidance that establishprotection inspections, clarified compliance and enforcement reporting requirinspectors to improve WP inspections. 
Improved Program Communication and Outreach. OPP has partnered with OECA’s Agricultural Com

Assistance Center (Ag Center) to serve as the centralized resource to obtain WP training materials and comassistance information. OPP is working with the Ag Center to produce an updated WPS How To Comply mthat should be available in 2005, and plans to collaborate on the development of new WP compliance assisfact sheets. EPA also resumed operation of the WP Interpretive Guidance Workgroup (IGW) to address Wenforcement policy issues that have arisen over the last several years. The IGW has already provided policdecisions on a number of issues, which are available on EPA’s website. Better Coordination With Stakeholders. EPA has taken a number of steps to improve coordination with stakeholders in the program, including meeting regularly with stakeholders to review progress on key projeproviding regular updates to the Pesticide Program Dialogue Committee (PPDC) on worker safety issues. Tassessment process helped establish a solid network of interested and engaged stakeholders that has strengtthe program and produced new opportunities for collaboration. National Train-the-Trainer Materials. With the help of stakeholders, EPA developed and piloted the nattrain-the-trainer manual/program. The draft train-the-trainer manual is currently being revised based on the outcomes of the pilot evaluation. It should be ready for release and use in late 2005. EPA will promote thadoption of these materials and the train-the-trainer concept to improve trainer skills. Hazard Communication Program Development. OPP is collaborating with EPA’s Office of Research aDevelopment (ORD) to conduct several pilot projects and studies stemming from the proposals of the HazaCommunication Pilot Project Workgroup that arose out of the national assessment process. The pilot work begin in 2005 and involve testing symbols, training approaches, and methods for conveying site-specific hainformation. EPA has also provided grant funding to the Florida Department of Agriculture and Consumer Services to support work to develop hazard communication tools for Florida’s agricultural workers, and EPRegion 9 has provided grant funding to Farmworker Justice Fund to carry out a hazard communication proArizona citrus and lettuce workers. New National Core Exam and Manual for Pesticide Applicator Certification. EPA and Canada’s Pest Management Regulatory Agency (PMRA) completed the development of a new national pesticide applicatexam as part of a cooperative effort under NAFTA. The core exam addresses key tasks performed by all applicators, and was developed by a committee of pesticide applicators representing different regions of thand Canada and major applicator categories. The committee produced a scientifically validated exam of 90 

questions that can be used by pesticide State Lead Agencies and Canadian provinces. Additionally, a team 

pesticide safety educators and state pesticide regulatory staff are collaborating on the development of a new manual for pesticide applicators, based on the outline for the exam, which should be available in late 2005. 
25 

Long Term Strategies for Program Improvement 

Building on the improvements already in place, EPA’s long-term strate

three areas: 

• Rule Revision • Improved field data collection and use • Worker Safety Workshops 

A number of the suggested improvements from the assessments relate t

through revisions to the rules related to worker protection. Changes to the ruleintegrate the worker protection and applicator certification regulations, establisand provide increased protections. 

Improvements to field data collection and use are also underway. Occu

and enforcement data are important elements for identifying program strengths measure the success of our field programs, and point to areas for improvementmonitoring and compliance data can refine EPA’s regulatory approaches to wo

The final element of OPP’s strategic plan for the worker safety program 

workshops. These workshops will provide a public forum for discussion of pinformation on emerging issues related to pesticide worker safety, occupationa
The national assessment of EPA’s pesticide worker safety program was a large undertaking, but it 

necessary and extremely valuable effort that has advanced the Agency’s mission to protect workers. It ill

the value of public input in guiding our priorities. The national assessment has led to: 

 increased awareness of the pesticide worker safety program and worker risk issues;  greater transparency in EPA’s science decisions and policies related to pesticide worker safety;  better internal program coordination and communication, and better coordination with our regulato

partners on field program implementation;

 a solid network of interested and engaged stakeholders that has strengthened the program and prod

greater opportunities for partnership and collaboration; 

 and numerous suggestions for potential program improvements that have helped shape the Agency

term strategic plan for improving the program. 

The assessment has already led to many improvements in the Agency’s pesticide worker safety pr

and has helped EPA identify key activities to focus on in the future. The national assessment would not hpossible or successful without the dedication and contribution of all the EPA staff, program stakeholders, regulatory partners who participated in the process and assisted the Agency in this effort. EPA appreciateeveryone’s contributions to the effort and looks forward to future opportunities for collaboration on this improgram. 

Conclusion 
Appendix I: 

Summary of EPA Pesticide Worke

27 

This section captures the breadth of programs supported by EPA to improve SENSOR EPA has partnered with the National Institute for Occupational Safety and Hfor the Sentinel Event Notification System for Occupational Risk (SENSORstates (California, Massachusetts, Michigan, New Mexico, New York, OregoNIOSH funding and technical support to bolster pesticide-related illness and are unfunded SENSOR partners (Arizona, Florida, Iowa, and Louisiana). Surelated illness and injury is designed to protect workers by determining the mexposure to pesticides in the workplace. Surveillance also serves as an early detected by manufacturer testing of pesticides. Besides tabulating the number of acute occupational pesticide-related cases, systems perform in-depth investigations for case confirmation, and develop pindustries or pesticide hazards. The SENSOR program is useful for timely idpesticide problems. Hispanic Radio Network EPA has collaborated with the Self-Reliance Foundation and the Hispanic RSpanish that provide pesticide safety information targeted to Hispanic familiorganizations recognized by farmworkers to reinforce key pesticide safety in

Network provides a toll-free number for listeners to call for more informatioSelf-Reliance Foundation are also collaborating on a public awareness campfrom children. 

National Agricultural Worker Survey (NAWS) The Department of Labor commissioned this survey in an effort to collect deworkers in response to the Immigration Reform and Control Act of 1986. Sihave contributed funds to have questions pertinent to their programs included than ten years of data with a large sample size. The NAWS survey includes questions regarding how often workers handle pesticides, if the worker was e

the type of personal protective equipment worn, etc. 
AFOP/AmeriCorps 

EPA has partnered with AmeriCorps and the Association of Farmworker Opportunity Programs (AFOP) to pesticide safety training for agricultural workers in 17 states. Participants volunteer under the AmeriCorps for a 1or a 2 year commitment, after which they are eligible to receive an education award. After receiving AFOP/AmeriCorps orientation, participants are responsible for coordinating with the appropriate agency wtheir state to become a certified trainer under the worker protection regulation. Trainers then serve as resou

the farmworker community and farmworkers by providing pesticide safety training, as well as other comm

services. All training is conducted with the consent of the grower/outreach organization. 

National Pesticide Information Center (NPIC) The NPIC is a cooperative effort between the Extension Service at Oregon State University and EPA to optoll-free telephone service for callers in the United States, Puerto Rico, and the Virgin Islands. NPIC servesource of objective, science-based pesticide information on a wide variety of pesticide-related subjects inclrecognition and management of pesticide poisoning; pesticide chemistry; toxicology; and environmental faNPIC is a free service, via toll-free telephone, email, and the web, and is open to the public and industry. Nalso provides the medical community with diagnostic and crisis management assistance involving pesticide incidents. Pesticide Safety Education Program (PSEP) Through an inter-agency agreement with the USDA, EPA provides funding support to the state cooperativextension services (CES) to provide training to applicators seeking certification to use restricted use pesticiPSEP conducted applicator training helps ensure the safe and effective use of pesticides. EPA has provide$45 million to state extension service programs since the inception of the program. This funding is in addi

the cooperative agreement monies that go directly to state, territory and tribal governments to carry out cer

programs. Southern Region Pesticide Safety Education Center EPA has supported the operation of the Southern Region Pesticide Safety Education Center (SR-PSEC) prThe SR-PSEC is an important train-the-trainer program developed by the North Carolina Department of Agriculture and Consumer Services and the North Carolina Cooperative Extension Service, in cooperation EPA and USDA, to update the training skills of pesticide safety education and inspection staff. The primaobjective of the SR-PSEC is to improve the skills and capabilities of pesticide safety educators and applicatrainers through a train-the-trainer program. 
29 

Projects Supported by EPA Regional Offices 

EPA Region 1 Pesticide Program worked with the Cambodian American L

translate two WP training documents, the “WPS Worker Handbook” and the Pesticides,” into the Khmer language. EPA Region 2 coordinated with the New Jersey Department of EnvironmenHeadquarters, to sponsor a national Train the Trainer pilot that was instrumTrainer effort. NJDEP staff acted as a “Master Trainer” for the pilot, and NJfrom the inception of the idea all the way through to the finished product thaEPA Region 3 and the Pennsylvania Department of Agriculture, in cooperaUniversity Pesticide Education Program and the American Mushroom Instituvideo specific to mushroom workers. The video is designed to improve worindustry. EPA Region 4 has developed a training curriculum specifically designed fosouthern states. The curriculum focuses on culturally sensitive methods of a

and includes basic Spanish vocabulary that is specific to the agricultural worpesticides. The aim of the project is to break down barriers which prevent einspectors and farmworkers. The curriculum is being developed for nationaEPA Region 5 utilized local expertise to translate the "WPS Protect YourseAgricultural Workers" into Chinese (Mandarin), Filipino (Tagalog), and Korregulators, cooperative extension, and industry to approve several popularlyVideos, including: (1) the "Greenhouse Pesticide Safety Training" video for Floriculture Greenhouse Industry Alliance); (2) "Pesticide Handlers and the (MSU)); (3) "Pesticide Safety for You and Your Family's Health" (for WorkSafety - Help Workers Protect Themselves" (w/MSU). Region 5 worked witCommittee, composed of advocates, State regulators, cooperative extension, Training Resource Guide for Illinois Agricultural Employers". Region 5 cooAgriculture (MiDA) to produce the first WPS Pesticide Safety Train-the-TraRegion 5 funded MiDA for four years consecutively in a Nationally unique training to minority (African-American and Hispanic) agricultural farmers thand worked with the Community Health Partnership of Illinois (a prominent Illinois cooperative extension to develop and implement a State-wide interactraining program in Spanish. 
EPA Region 7 partnered with and provided a grant to Harvest America Corporation to identify and educa

migrant and seasonal farmworkers and their families about pesticide safety and exposure risks in SouthweKansas through a project known as Informing People on Pesticides (IPOP). The Harvest America projecon providing educational workshops, and culturally sensitive pesticide safety information to the target popRegion 8 Pesticide Program provided funding for the Migrant Farm Worker Drinking Water DemonstratiProject. The purpose of this project was to identify the number and location of migrant farmworker commColorado, determine the quality of the drinking water sources for each location, and provide a solution to improving the quality of the drinking water. The project led to the development of a state-wide database migrant farmworker camps in Colorado. It has also led to additional studies that are currently underway acamps throughout the State. Region 9 Worker Safety Team has developed a map of national WP inspection and enforcement data in rstate farmworker populations, using the National Agricultural Statistics Service data. Presenting existing geographic perspective has provided better context for the ongoing effort to determine reasonable 'measurprogram accomplishments and whether adequate WP monitoring is occurring nationwide. Region 9 also d

$100,000 to launch the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Special Project Gran

Stewardship Program. This program is intended to help strengthen industry compliance with the WP and worker exposure to pesticides. The first projects will begin in Fiscal year 2005. EPA Region 10 has worked with five Catholic parishes in the Diocese of Yakima (WA) to provide trainifarmworkers on protecting themselves from pesticide exposure on farms and in the home. Churches in RMattawa, Toppenish, Prosser and Yakima are participating in Protegiendo Nuestro Futuro/ Protecting Ouwhich targets the education specifically towards women and teen Hispanic farmworkers. Over one hundrfarmworkers have been reached using this venue since March. The training material for the effort was deby a number of agencies and organizations, including Washington State Department of Agriculture, WashDepartment of Health , Washington Labor & Industries, Radio Cadea, Fred Hutchinson Cancer Research and EPA Region 10. Parish volunteers are trained in the EPA Worker Protection Standard (WPS) and pr

material in Spanish, accompanied by a visual slide show. A verbal questionnaire is conducted during the this provides opportunity for open discussion. Farmworkers attending the class receive a WPS card, whirequirement for employment in areas where pesticides have been used. The National Religious Partnershi

Environment has provided funding for the project and receives in-kind assistance from agency and organi

staff. 

Pesticide worker safety program information: http://www.epa.gov/pesticides/health/worker.htm Training materials & compliance assistance information for employers: http://www.epa.gov/agriculture/tw

Thanks to Christine Cairns, Richard Pont, and Michelle DeVaux for this report’s design.