1

ECONOMIC ANALYSIS OF

FINAL REVISIONS TO 

THE WORKER PROTECTION STANDARD

APPENDIX A

Estimating Farms and Workers Covered by the WPS

Table of Contents

A.1. Farms................................................................................................................................. 1

A.2. Employees .........................................................................................................................10

A.3. Comparison of Estimates....................................................................................................15

A critical component in the estimation of costs and benefits of the WPS is the number of entities 

affected by revisions to the rule. The WPS is designed to provide protection to workers and 

handlers on agricultural establishments that use pesticides. To estimate the impacts of proposed 

revisions to the WPS, EPA obtained a special tabulation, based on the 2007 Census of 

Agriculture, which identified the number of farms, by type and economic category, that used 

pesticides and/or hired labor, along with the number of employees. This special tabulation also 

provided information about different farm structure, particularly the number of employees per 

farm, which varies by type and economic class.

The 2012 Census of U.S. Agriculture was published in May 2014, as EPA began work on the 

final revisions to the WPS. This appendix describes the methods and results for estimating the 

number of farms and employees based on publicly available information from the 2012 Census, 

given the information from the special tabulation conducted in 2008. In May 2015, more 

detailed data from the 2012 Census of Agriculture was provided to EPA, which allows us to

confirm the validity of these estimates.

A.1. Farms

Table A.1-1 presents data on farm numbers from the special tabulation for all farms in the U.S.

based on the 2007 Census of Agriculture (NASS, 2008). The data are organized by economic 

category and by primary production or NAICS category. The economic categories are based on 

the Small Business Administration definition of a small farm, which is an entity with revenue 

less than $750,000 per year ($2,500,000 for feedlots). OPP developed additional categories 

within the SBA definitions to better understand the distribution of impacts since over 95% of 

U.S. farms meet the definition of a small business. NAICS category indicate the main source of 

farm revenue, but not the exclusive source of revenue. Oilseed and grain farms are in NAICS 

1111; vegetable, fruit, and nut are in NAICS 1112 and 1113; nurseries and greenhouses are in 

NAICS 1114, where greenhouses are categorized as NAICS 11141; cotton and tobacco farming 
2

are in NAICS 11192 and 11191; other crop farms are in NAICS 11193, 11194, and 11199; 

bovine, ovine, and swine establishments are classified in NAICS 112111 (beef cattle), 11212 

(dairy), 1124 (sheep and goat), and 1122 (hog and pig); poultry production is in NAICS 1123; 

other livestock comprises NAICS 1125 and 1129; and feedlots are NAICS 112112.

Table A.1-1. All Farms, by economic category and primary production, 2007.

Farm Type

Size (defined by gross revenue)

< $10,000 $10 – 100,000 $100 - $750,000 > $750,000 Total

Grain and Oilseed 48,982 129,688 135,492 24,075 338,237

Vegetable, Fruit, 

and Nut 60,078 53,233 18,215 7,344 138,870

Nursery 22,759 17,566 9,050 3,470 52,845

Greenhouses 472 1,079 319 174 2,044

Cotton and 

Tobacco 2,703 7,477 7,133 2,281 19,594

Other Crop Farms 395,948 88,302 12,798 3,251 500,299

Bovine, Ovine, 

Swine 475,086 234,056 82,524 19,927 811,593

Poultry 37,348 2,114 10,273 14,835 64,570

Other Livestock 214,860 24,019 5,324 1,472 245,675

< $50,000 $50 – 500,000

$500,000 -

$2,500,000 > $2,500,000

Feedlots 20,620 6,172 2,957 1,316 31,065

Total 1,278,856 563,706 284,085 78,145 2,204,792

Source: 2007 Census of U.S. Agriculture (NASS, 2008), special tabulation.

Table A.1-2 presents data on the number of farms that hired labor in 2007, in contrast to 

operations that used family labor. Overall, about 22% of farms hire labor, but that varies by type 

of production and economic size, denoted as ‘small-small’ for farms with revenue less than 

$10,000 and feedlots with revenue less than $50,000, ‘medium-small’ for farms with revenue 

between $10,000 and $100,000 and feedlots with revenue between $50,000 and $500,000, 

‘large-small’ for farms with revenue between $100,000 and $750,000 and feedlots with revenue 

between $500,000 and $1,000,000, and ‘large’ for farms with revenue greater than $750,000 and 

feedlots with revenue greater than $1,000,000. Only about 10% of small-small entities hired

labor while almost 80% of large entities do so. Across farm types, the proportion of farms hiring 

labor ranges from about 11% for other farming to over 55% of cotton and tobacco farms.
3

Table A.1-2. Farms that hire labor, by economic category and primary production, 2007.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 3,792 22,775 58,684 18,502 103,753

Vegetable, Fruit, 

and Nut 10,436 18,959 13,794 6,746 49,935

Nursery 3,866 7,087 8,357 3,426 22,736

Greenhouses 78 341 286 174 879

Cotton and 

Tobacco 1,001 3,312 4,639 1,970 10,922

Other Crop Farms 27,006 16,140 7,365 2,948 53,459

Bovine, Ovine, 

Swine 53,144 61,632 45,748 16,272 176,796

Poultry 3,097 565 4,197 8,829 16,688

Other Livestock 25,696 7,335 3,199 1,216 37,446

Feedlots 3,342 2,705 2,269 1,256 9,572

Total 131,458 140,851 148,538 61,339 482,186

Source: 2007 Census of U.S. Agriculture (NASS, 2008), special tabulation.

The WPS only covers workers in crop production. Table A.1-3 presents the number of farms 

hiring labor that produced crops in 2007. This excludes many livestock operations. While over 

70% of animal farms (beef cattle, dairy, swine, sheep, and goat) also produce crops, less than 

30% of other livestock operations (e.g., aquaculture facilities) do so.

Table A.1-3. Crop-producing farms that hire labor, 2007.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 3,792 22,775 58,684 18,502 103,753

Vegetable, Fruit, 

and Nut 10,436 18,959 13,794 6,746 49,935

Nursery 3,866 7,087 8,357 3,426 22,736

Greenhouses 78 341 286 174 879

Cotton and 

Tobacco 1,001 3,312 4,639 1,970 10,922

Other Crop Farms 27,006 16,140 7,365 2,948 53,459

Bovine, Ovine, 

Swine 25,474 47,530 40,590 13,564 127,158

Poultry 1,045 255 2,261 5,482 9,043

Other Livestock 6,129 2,868 1,310 629 10,936

Feedlots 1,082 1,956 1,951 848 5,837

Total 79,909 121,223 139,237 54,289 394,658

Source: 2007 Census of U.S. Agriculture (NASS, 2008), special tabulation.

Thus, OPP estimated that 394,658 farms and feedlots would be impacted by revisions to the 

WPS, referred to as ‘WPS farms,’ given 2007 data. Most provisions of the WPS, however, are 

only triggered if the entity uses pesticides and often only if workers are physically present. 

Table A.1-4 presents the number of crop producing farms that hire labor that also used pesticides 
4

sometime during the course of 2007. Given these data, we can see that pesticide use varies by 

economic size and production type. Just over half the small-small WPS farms used pesticides 

while about 90% of large WPS farms do so. Across production types, the proportion of WPS 

farms using pesticides varied from 53% of other livestock operations to 97% of cotton and 

tobacco farms.

Table A.1-4. Crop-producing farms that hire labor and use pesticides, 2007.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 2,905 20,817 56,266 17,476 97,464

Vegetable, Fruit, 

and Nut 7,591 16,760 13,465 6,710 44,526

Nursery 2,685 5,697 6,702 2,956 18,040

Greenhouses 29 191 169 130 519

Cotton and 

Tobacco 867 3,134 4,631 1,969 10,601

Other Crop Farms 11,292 9,757 6,566 2,799 30,414

Bovine, Ovine, 

Swine 11,656 29,753 32,913 11,431 85,753

Poultry 434 123 1,611 4,236 6,404

Other Livestock 2,695 1,607 986 539 5,827

Feedlots 726 1,720 1,651 703 4,800

Total 40,880 89,559 124,960 48,949 304,348

Source: 2007 Census of U.S. Agriculture (NASS, 2008), special tabulation.

In order to estimate the number of farms across economic categories and production types as in 

Tables A.1-3 and 4.1- for 2012, we rely on publicly available data and the observed proportions 

of farms in 2007 as described below. Table A.1-5 presents the number of all U.S. farms, by 

economic category and type from the 2012 Census. Note that the same information is available 

for the 2007 Census. Compared to 2007, the total number of farms in the U.S. has declined 

about 4% with considerable variation across different farms types and sizes. The number of 

feedlots has fallen over 50% and livestock operations in general are down as are cotton and 

tobacco farms. The number of farms whose primary income is derived from grains and oilseed, 

however, has increased about 9%. By economic size, the number of small-small farms and 

feedlots has decreased about 10%, the number of those in the medium-small category is 

essentially unchanged, and the number of farms, excluding feedlots, with revenues over 

$1,000,000 has increased over 40%.
5

Table A.1-5. All Farms, by economic category and primary production, 2012.

Farm Type

Size (defined by gross revenue)

< $10,000 Total

$10 –

100,000

$100 -

500,000

$500,000 -

$1,000,000

> 

$1,000,000

Grain and 

Oilseed 43,993 130,819 118,839 42,150 33,531 369,332

Vegetable, 

Fruit, and 

Nut

60,165 49,483 15,506 4,119 6,768 136,041

Nursery and 

Greenhouses 20,467 21,233 6,903 1,718 2,456 52,777

Cotton and 

Tobacco 741 4,918 4,826 2,061 1,501 14,047

Other Crop 

Farms 361,302 100,622 13,565 3,537 3,764 482,790

Bovine, Ovine, 

Swine 439,843 221,905 66,485 14,628 17,275 760,136

Poultry 27,561 1,984 3,575 7,092 12,637 52,849

Other

Livestock 190,787 30,497 4,407 813 1,093 227,597

< $50,000

$50 –

500,000

$500,000 -

$2,500,000

> 

$2,500,000

Feedlots 4,601 5,054 2,737 1,342 13,734

Total 1,149,460 566,515 236,843 76,118 80,367 2,109,303

Source: 2012 Census of U.S. Agriculture (NASS, 2014).

The publicly available data poses two problems. First, the Census publicly reports an economic 

category encompassing revenue between $500,000 and $1,000,000 while OPP, following the 

Small Business Administration definition of a small farm, distinguishes categories at the 

$750,000 threshold ($2,500,000 for feedlots). Second, the Census publicly combines the NAICS 

codes for Nurseries and Greenhouses while OPP in interested in separating the two types of 

production because indoor production (greenhouse) is subject to somewhat different posting and 

notification requirements than is outdoor production. Given the 2007 special tabulation, we can 

calculate that 65% of farms with revenue between $500,000 and $1,000,000 have revenue below 

the $750,000 SBA-defined. Poultry farms are most evenly split, with 55% having revenue below 

$750,000 and 45% above $750,000, while oilseed and grain farms are least evenly distributed 

with 66% having revenue below $750,000. To estimate the number of farms in the OPP 

categories, we apply these proportions to the 2012 data. We can similarly estimate the 

proportion of greenhouses within the nursery and greenhouse from the 2007 data, which indicate 

that about 4% are greenhouses. The results of this estimation is shown in Table A.1-6.
6

Table A.1-6. All Farms, by economic category and primary production, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 43,993 130,819 146,795 47,725 369,332

Vegetable, Fruit, 

and Nut 60,165 49,483 18,060 8,333 136,041

Nursery 20,031 20,004 7,727 2,932 50,694

Greenhouses 436 1,229 272 146 2,083

Cotton and 

Tobacco 741 4,918 6,105 2,283 14,047

Other Crop Farms 361,302 100,622 15,806 5,060 482,790

Bovine, Ovine, 

Swine 439,843 221,905 75,887 22,501 760,136

Poultry 27,561 1,984 7,452 15,852 52,849

Other Livestock 190,787 30,497 4,935 1,378 227,597

Feedlots 4,601 5,054 2,737 1,342 13,734

Total 1,149,460 566,515 285,776 107,552 2,109,303

Source: Census of U.S. Agriculture (NASS, 2014 and 2008), special tabulation (NASS, 2008).

Publicly available data from the 2012 Census provide the number of farms hiring labor by 

economic class or by production type, but not both. To estimate the number of farms hiring 

labor across both categories, we use a two-step procedure. First, we calculate the number of 

farms hiring labor in 2012 based on the proportion of farms with hired labor to total farms in 

each economic/production category in 2007. Second, we adjust these initial estimates so that 

totals in each economic class and production type equal the number of farms hiring labor from 

the 2012 Census.

In the first step, we calculate the proportion of farms with hired labor to total farms in 2007 from 

Tables A.1-1 and A.1-2. For example, there were 3,792 grain and oilseed farms with revenue 

less than $10,000 hiring labor in 2007 out of 48,982 farms in that category, or 7.7%. Given 

43,993 farms in that category in 2012, we calculate that there would be 3,406 of those farms 

hiring labor. Other categories are calculated the same way. Results of this step are presented in 

Table A.1-7. Table A.1-7 also shows the sum of farms, by production type and economic size, 

along with the total observed in the 2012 Census. Note that we had to estimate the number of 

farms with hired labor in the $500,000 to $1,000,000 size category between the two neighboring 

size categories as was done with the total number of farms in Table A.1-6. We also had to adjust 

the number of farms in each size category to account for the fact that feedlot categories are 

different from farms, in keeping with the SBA definition. Thus, the number of entities in the 

small-small and medium-small categories is larger than provided by the Census for entities with 

revenues of less than $100,000 while there are fewer entities in the two larger size categories 

than shown in the Census for entities with revenue greater than $100,000.
7

Table A.1-7. Initial estimates of farms hiring labor, 2012.

Farm Type

Size (defined by gross revenue)

Sum Total

smallsmallmediumsmall large-small large

Grain and 

Oilseed 3,406 22,974 63,579 36,678 126,636 133,209

Vegetable, 

Fruit, and Nut 10,451 17,623 13,676 7,655 49,406 55,497

Nursery 3,406 8,071 7,135 2,894 21,506 24,485

Greenhouses 69 388 244 147 848 947

Cotton and 

Tobacco 274 2,178 3,971 1,971 8,395 8,979

Other Crop 

Farms 24,643 18,392 9,096 4,588 56,719 89,449

Bovine, Ovine, 

Swine 49,202 58,432 42,069 18,373 168,076 178,337

Poultry 2,285 530 3,044 9,434 15,294 18,959

Other Livestock 22,817 9,313 2,965 1,138 36,234 50,718

Feedlots 746 2,215 2,100 1,281 6,342 5,889

Sum 117,299 140,117 147,880 84,160 489,457 566,469

Total 173,337 154,615 150,028 88,489 566,469

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014).

As seen in Table A.1-7, we have underestimated the number of farms hiring labor in 2012 in all 

sizes and types, with the exception of feedlots. Indeed, while the total number of farms has 

declined slightly since 2007, the number hiring labor has increased 17.5%. To adjust the 

estimated number of farms hiring labor, we use an iterative process. To begin, we take the ratio 

of observed values for each farm type to the sum of the calculated value. For example, 133,209 

grain and oilseed farms are observed to hire labor while we initially calculated that 126,636 

farms hired labor. The ratio of observed to calculated is 1.052, implying that we need to increase 

our estimate of farms of this type about 5%. We multiply our initial estimates for each farm type 

by these ratios to obtain the values shown in Table A.1-8, with three exceptions. The number of 

large nurseries, greenhouses, and other crop farms are not adjusted upward and the numbers of 

small farms of those types are increased instead. Otherwise, we end with more large farms of 

these types than are observed in the data. The sum for each farm type now equates to the 

observed number of farms hiring labor.
8

Table A.1-8. First iteration, estimates of farms hiring labor, 2012.

Farm Type

Size (defined by gross revenue)

Sum Total

smallsmallmediumsmall large-small large

Grain and 

Oilseed 3,583 24,166 66,879 38,581 133,209 133,209

Vegetable, 

Fruit, and Nut 11,740 19,796 15,363 8,598 55,497 55,497

Nursery 3,956 9,373 7,992 3,165 24,485 24,485

Greenhouses 78 443 278 147 947 947

Cotton and 

Tobacco 294 2,330 4,247 2,109 8,979 8,979

Other Crop 

Farms 40,115 29,939 14,807 4,588 89,449 89,449

Bovine, Ovine, 

Swine 52,205 61,999 44,637 19,495 178,337 178,337

Poultry 2,833 657 3,774 11,695 18,959 18,959

Other Livestock 31,938 13,036 4,151 1,593 50,718 50,718

Feedlots 692 2,057 1,950 1,189 5,889 5,889

Sum 147,433 163,797 164,079 91,161 566,469 566,469

Total 173,337 154,615 150,028 88,489 566,469

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014).

The sum for each farm type now equates to the observed number of farms hiring labor. By 

economic size, however, we now overestimate the number of farms hiring labor for by economic 

size, except for the small-small farms. We now calculate the ratio of observed to calculated 

farms by economic size and use that ratio to adjust the number of farms within each class. We 

then continue to iterate between adjusting the estimates by type and by economic size until all 

sums equal the observed values. The final estimates for farms hiring labor in 2012 are presented 

in Table A.1-9.

Table A.1-9. Estimated number of farms that hire labor, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 4,745 24,879 64,427 39,158 133,209

Vegetable, Fruit, 

and Nut 14,514 19,023 13,814 8,146 55,497

Nursery 4,972 9,158 7,307 3,048 24,485

Greenhouses 101 442 260 145 947

Cotton and 

Tobacco 387 2,388 4,073 2,131 8,979

Other Crop Farms 46,198 26,800 12,403 4,049 89,449
9

Bovine, Ovine, 

Swine 62,991 58,147 39,173 18,025 178,337

Poultry 3,569 644 3,458 11,289 18,959

Other Livestock 34,978 11,097 3,306 1,337 50,718

Feedlots 882 2,037 1,808 1,161 5,889

Total 173,337 154,615 150,028 88,489 566,469

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014). Rows and columns may not sum due to 

rounding.

Table A.1-10 presents the estimated number of crop producing farms that hire labor in 2012. 

Publicly available data from the 2012 Census of Agriculture enumerates the number of farms 

with cropland out of the total number of farms, but not for farms that hire labor. Therefore, we 

estimate the number of crop producing farms that hire labor in 2012 using the same proportion of 

such farms from 2007. For example, from Table A.1-3, we know that, in 2007, 25,474 animal 

farms with revenue less than $10,000 hire labor and have crop land out of 53,144 similar animal 

farms that hire labor from Table 2, or 48%. We therefore calculate that, in 2012, there are 

30,194 animal farms with revenue less than $10,000 hire labor and have crop land out of 62,991

similar animal farms. In total, we estimate that there were 466,579 crop producing farms hiring 

labor, or WPS farms, in 2012, an 18.2% increase over the number of WPS farms identified in 

2007.

Table A.1-10. Estimated number of crop producing farms that hire labor, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 4,745 24,879 64,427 39,158 133,209

Vegetable, Fruit, 

and Nut 14,514 19,023 13,814 8,146 55,497

Nursery 4,972 9,158 7,307 3,048 24,485

Greenhouses 101 442 260 145 947

Cotton and 

Tobacco 387 2,388 4,073 2,131 8,979

Other Crop Farms 46,198 26,800 12,403 4,049 89,449

Bovine, Ovine, 

Swine 30,194 44,843 34,756 15,026 124,819

Poultry 1,204 290 1,863 7,009 10,367

Other Livestock 8,343 4,339 1,354 692 14,727

Feedlots 286 1,473 1,554 784 4,097

Sum 110,944 133,635 141,811 80,187 466,576

Source: OPP calculations. Rows and columns may not sum due to rounding.

Finally, Table A.1-11 presents the estimated number of crop producing farms that hire labor and 

use pesticides in 2012. Again, publicly available data from the 2012 Census of Agriculture 

provides the number of farms that use pesticides out of the total number of farms, but not for 

farms that hire labor. Therefore, we estimate the number of crop producing farms that hire labor 

and use pesticides in 2012 using the same proportion of such farms from 2007. For example, 

from Table A.1-4, we know that, in 2007, 2,905 grain and oilseed farms with revenue less than 

$10,000 and hired labor used pesticides out of 3,792 similar grain and oilseed farms that hire 
10

labor from Table 3, or 76.6%. We therefore calculate that, in 2012, there are 3,635 grain and 

oilseed farms with revenue less than $10,000 that hire labor out of 4,745 similar grain and 

oilseed farms. In total, we estimate that there were 354,220 WPS farms that used pesticides in 

2012, a 16.5% increase over the number of WPS farms using pesticides in 2007. Over all WPS 

farms, this implies that 76.0% use pesticides in any given year.

Table A.1-11. Estimated number of crop-producing farms that hire labor and use 

pesticides, 2012.

Farm Type

Size (defined by gross revenue)

< $10,000 $10 – 100,000 $100 - $750,000 > $750,000 Total

Grain and Oilseed 3,635 22,740 61,772 36,772 124,919

Vegetable, Fruit, 

and Nut 10,557 16,817 13,484 8,102 48,960

Nursery 3,453 7,362 5,860 2,630 19,305

Greenhouses 37 247 154 108 546

Cotton and 

Tobacco 335 2,260 4,066 2,130 8,791

Other Crop Farms 19,317 16,201 11,057 3,844 50,419

Bovine, Ovine, 

Swine 13,816 28,071 28,183 12,663 82,733

Poultry 500 140 1,327 5,416 7,383

Other Livestock 3,668 2,431 1,019 593 7,711

Feedlots

< $50,000 $50 – 500,000

$500,000 -

$2,500,000 > $2,500,000

Feedlots 192 1,296 1,315 650 3,453

Total 55,510 97,565 128,237 72,908 354,220

Source: OPP calculations. Rows and columns may not sum due to rounding.

A.2. Employees

Table A.2-1 presents data on the number of people employed in agriculture from the special 

tabulation for all farms in the U.S. based on the 2007 Census of Agriculture. Like the number of 

farms, the data are organized by economic category and by primary production or NAICS 

category.
11

Table A.2-1. Agricultural Employees, by economic category and primary production, 

2007.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 7,996 51,743 150,231 89,328 299,298

Vegetable, Fruit, 

and Nut 31,347 107,936 212,775 517,771 869,829

Nursery 11,384 31,778 76,721 206,344 326,227

Greenhouses 381 1,307 2,657 20,492 24,837

Cotton and 

Tobacco 4,357 19,064 24,122 20,475 68,018

Other Crop Farms 64,586 45,347 33,366 53,592 196,891

Bovine, Ovine, 

Swine 118,591 150,952 147,368 167,731 584,642

Poultry 7,953 2,016 13,069 61,974 85,012

Other Livestock 66,661 23,321 18,849 21,495 130,326

Feedlots 7,899 7,420 8,856 27,254 51,429

Total 321,155 440,884 688,014 1,186,456 2,636,509

Source: 2007 Census of U.S. Agriculture (NASS, 2008), special tabulation.

Table A.2-2 presents the number of employees on farms that produced crops in 2007; the WPS 

only covers workers in crop production activities, not those working solely with livestock. 

Similar to farm numbers, about 75% of employees on animal farms (beef cattle, dairy, swine, 

sheep, and goat) are employed on farms that also produce crops while less than 30% of 

employees on other livestock operations (e.g., aquaculture facilities) are working on crop 

producing establishments.

Table A.2-2. Agricultural Employees on crop-producing farms, 2007.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 7,996 51,743 150,231 89,328 299,298

Vegetable, Fruit, 

and Nut 31,347 107,936 212,775 517,771 869,829

Nursery 11,384 31,778 76,721 206,344 326,227

Greenhouses 381 1,307 2,657 20,492 24,837

Cotton and 

Tobacco 4,357 19,064 24,122 20,475 68,018

Other Crop Farms 64,586 45,347 33,366 53,592 196,891

Bovine, Ovine, 

Swine 58,127 116,352 129,840 129,032 433,351

Poultry 2,614 884 7,074 7,328 12,675

Other Livestock 16,364 8,561 6,439 6,395 37,759

Feedlots 2,613 5,195 7,328 12,675 27,811

Total 199,769 388,167 650,533 1,084,121 2,322,610

Source: 2007 Census of U.S. Agriculture (NASS, 2008), special tabulation.
12

Table A.2-3 presents the number of employees on crop producing farms that used pesticides 

sometime during the course of 2007. As with the number of farms, the number of employees 

associated with pesticide use varies by economic size and production type. In general, however, 

farms that used pesticides appear to employ more labor than do similar farms that did not use 

pesticides. For example, just over half the small-small WPS farms used pesticides while almost 

two-thirds of the workers on small-small WPS farms worked on farms using pesticides. 

Similarly, about the 90% of large WPS farms that used pesticides employed 92% of the labor. 

Across production types we see the same pattern, where the proportion of employees on WPS 

farms using pesticides is greater than the proportion of farms using pesticides. The exceptions 

are cotton and tobacco farms, where the ratios are approximately equal, and feedlots, where 82% 

of feedlots use pesticides but those establishments employ 79% of the workers.

Table A.2-3. Agricultural Employees on crop-producing farms that use pesticides, 2007.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 6,424 47,355 143,504 58,065 282,166

Vegetable, Fruit, 

and Nut 23,302 99,849 209,157 516,897 849,205

Nursery 8,325 26,363 62,703 186,387 283,778

Greenhouses 99 709 1,435 16,095 18,338

Cotton and 

Tobacco 3,893 18,350 24,082 18,907 65,323

Other Crop Farms 52,876 28,996 28,992 29,079 139,943

Bovine, Ovine, 

Swine 27,793 74,529 106,147 109,058 317,527

Poultry 1,101 375 4,925 22,585 28,986

Other Livestock 7,339 5,073 4,661 5,231 22,304

Feedlots 1,874 4,573 6,067 9,568 22,082

Total 132,844 306,172 591,673 998,872 2,029,561

Source: 2007 Census of U.S. Agriculture (NASS, 2008), special tabulation.

To estimate the number of employees across farm type and economic category in 2012, we 

follow the same two-step approach as used to determine the number of farms with hired labor. 

Publicly available data from the 2012 Census provide the number of employees by economic 

class of the farm or by production type, but not both. First, we calculate the number of 

employees on farms of each type and economic category based on the average employee per 

farm observed in 2007. Second, we adjust these initial estimates so that totals in each economic 

class and production type equal the number of employees from the 2012 Census.

In the first step, we calculate the average number of employees per farm by dividing the number 

of workers in Tables A.2-1 by the number of farms in Table A.1-2. For example, there were 

7,996 employees employed on 3,792 small-small grain and oilseed farms or 2.11 employees per 

farm in 2007. Given an estimated 4,745 farms in this category in 2012, we calculate that there 

would be 10,006 employees employed on such farms. Other categories are calculated the same 

way. Results of this step are presented in Table A.2-4. Table A.2-4 also shows the sum of 

employees, by production type and economic size of the farm, along with the total observed in 

the 2012 Census. Again, we had to allocate the number of employees in the $500,000 to 
13

$1,000,000 size category between the two neighboring size categories as was done with the 

number of farms for Table A.1-6. From the 2007 Census and special tabulation, we calculated 

that 41.4% of the employees on farms in this category were employed on farms making less than 

$750,000 gross revenue and 58.6% were employed on farms making $750,000 or more gross 

revenue. We also adjust the number of employees in each size category to account for the fact 

that feedlot categories are different from farms, in keeping with the SBA definition.

Table A.2-4. Initial estimates of agricultural employees, by farm type and size, 2012.

Farm Type

Size (defined by gross revenue)

Sum Total

smallsmallmediumsmall large-small large

Grain and 

Oilseed 10,006 56,523 164,933 189,055 420,517 382,559

Vegetable, 

Fruit, and Nut 43,596 108,302 213,082 625,219 990,199 904,400

Nursery 14,641 41,063 67,079 185,589 306,373 271,956

Greenhouses 491 1,693 2,414 17,045 51,644 20,705

Cotton and 

Tobacco 1,685 13,746 21,180 22,144 58,755 48,709

Other Crop 

Farms 110,484 75,297 56,189 73,605 315,574 281,726

Bovine, Ovine, 

Swine 140,565 142,417 126,188 185,804 594,975 555,076

Poultry 9,164 2,296 10,767 79,242 101,469 81,373

Other Livestock 90,740 35,282 19,481 23,633 169,137 160,975

Feedlots 2,086 5,589 7,055 25,203 39,933 28,938

Sum 423,458 482,210 688,369 1,424,538 3,018,575

Total 417,260 445,776 583,120 1,290,261 2,736,417

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014).

The sums of employees across farm sizes and across farm types are larger than the observed 

totals for all categories. To refine the estimates, we follow the iterative procedure described 

above, where we estimate the number of farms hiring labor through Tables A.1-7, A.1-8, and

A.1-9. Table A.2-5 presents the final estimates of labor employed by farms according to size 

and production type.
14

Table A.2-5. Estimated number of employees, by farm type and size, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 10,178 53,625 142,791 175,965 382,559

Vegetable, Fruit, 

and Nut 43,905 101,725 182,639 576,131 904,400

Nursery 14,322 37,464 55,847 164,232 271,956

Greenhouses 516 1,658 2,157 16,374 20,705

Cotton and 

Tobacco 1,554 11,829 16,632 18,694 48,709

Other Crop Farms 105,199 66,867 45,534 64,127 281,726

Bovine, Ovine, 

Swine 141,657 133,858 108,232 171,330 555,076

Poultry 8,021 1,875 8,020 63,458 81,373

Other Livestock 90,249 32,728 16,491 21,507 160,975

Feedlots 1,660 4,148 4,779 18,352 28,938

Total 417,260 445,776 583,120 1,290,261 2,736,417

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014). Rows and columns may not sum due to 

rounding.

To estimate the number of employees on farms producing crops in 2012, we follow the same 

procedure as for estimating the number of farms producing crops. That is, we calculate the 

proportion of employees on farms producing crops (Table A.2-2) out of all employees (Table 

A.2-1) in 2007, by farm type and size. For example, 46.5% of employees of large feedlots (more 

than $2.5 million in revenue) worked on feedlots that also produced crops in 2007 (12,675 

workers out of 27,254). We then multiply that proportion by the estimated number of employees 

in 2012 (Table A.2-5). We estimate that large feedlots employ 18,352 employees in 2012, of 

which 8,535 (46.5%) are employed on feedlots that also produce crops. Results for all farm 

types and sizes are shown in Table A.2-6. We estimate that there are 2,408,452 employees 

potentially covered by the WPS because they work on farms that produce crops. This is an 

increase of 3.7% over the number of employees in 2007. We estimate there are 466,576 cropproducing farms that hire labor, implying an average of 4.8 employees per farm.

Table A.2-6. Estimated number of employees on crop-producing farms, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 10,178 53,625 142,791 175,965 382,559

Vegetable, Fruit, 

and Nut 43,905 101,725 182,639 576,131 904,400

Nursery 14,322 37,464 55,847 164,323 271,956

Greenhouses 516 1,658 2,157 16,374 20,705

Cotton and 

Tobacco 1,554 11,829 16,632 18,694 48,709

Other Crop Farms 105,199 66,867 45,534 64,127 281,726
15

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Bovine, Ovine, 

Swine 69,432 103,176 95,358 131,801 399,768

Poultry 2,636 822 4,641 28,688 36,487

Other Livestock 22,154 12,014 5,633 6,399 46,201

Feedlots 549 2,904 3,954 8,535 15,942

Total 270,447 392,084 554,886 1,191,036 2,408,452

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014). Rows and columns may not sum due to 

rounding.

Finally, the number of employees on crop producing farms that used pesticides in 2012 is 

estimated using the same method. The proportion of workers on crop-producing farms that used 

pesticides in 2007, from Table A.2-3, out of all employees on crop-producing farms from Table 

A.2-2, is multiplied by the estimated employees on crop-producing farms in 2012 (Table A.2-6). 

Results are presented in Table A.2-7. We estimate a total of 2,098,272 people are employed on 

crop-producing farms that use pesticides. This is a 3.0% increase over the number of employees 

in 2007. Given an estimated 354,775 crop-producing farms using pesticides in 2012, the overall 

average workforce is 5.9 employees per farm.

Table A.2-7. Estimated number of employees on crop-producing farms that use pesticides,

2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Grain and Oilseed 7,945 49,077 136,397 167,568 360,987

Vegetable, Fruit, 

and Nut 32,367 94,104 179,533 575,159 881,432

Nursery 10,474 31,080 45,643 148,430 235,627

Greenhouses 134 899 1,165 12,860 15,059

Cotton and 

Tobacco 1,389 11,386 16,604 17,263 46,641

Other Crop Farms 86,125 42,756 39,565 34,795 203,241

Bovine, Ovine, 

Swine 33,199 66,089 77,958 111,398 288,644

Poultry 1,110 349 3,022 23,126 27,607

Other Livestock 9,936 7,119 4,078 5,234 26,367

Feedlots 394 2,556 3,274 6,443 12,667

Total 183,343 305,416 507,238 1,102,275 2,098,272

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014). Rows and columns may not sum due to 

rounding.

A.3. Comparison of Estimates

In May 2015, EPA obtained results of a special tabulation of data collected for the 2012 Census 

of Agriculture. The tabulation aggregates farms more than was done with data from the 2007 

Census. In the more recent tabulation, vegetable, fruit, and nut farms were combined with 
16

nurseries to form a ‘specialty crop’ category that is relatively labor intensive. Greenhouses 

remained separated and all other crop production (oilseed and grains, cotton and tobacco, and 

other crops) were combined into a ‘field crop’ category. Feedlots also remained as a separate 

category, but all other livestock operations were aggregated.

Table A.3-1 presents a comparison of the estimated number of crop producing farms that hire 

labor in 2012 with the actual number from the Census of Agriculture. In total, EPA’s approach 

overestimated the number of farms by over 45,000 farms or about 10 percent of the true number. 

Small farms were significantly overestimated while large farms were slightly (three percent) 

underestimated. Farms that primarily produce field crops and livestock operations were 

overestimated by 15 and 12 percent. The approach came within one percent of estimating the 

number of specialty crop establishments. The number of greenhouses and feedlots with crop 

production that hire workers is underestimated and, for these farm, especially underestimated for 

small economic classes.

Table A.3-1. Estimated and actual number of crop producing farms that hire labor, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Field Crops 1 est. 51,330 54,067 80,903 45,338 231,638

 actual 32,131 47,686 74,664 47,501 201,982

Specialty Crops 2 19,486 28,181 21,121 11,194 79,982

 actual 17,856 29,346 21,815 10,676 79,693

Greenhouses est. 101 442 260 145 947

 actual 240 567 248 176 1,231

Livestock 3 est. 39,741 49,472 37,973 22,727 149,913

 actual 28,772 42,881 38,528 23,320 133,501

Feedlots est. 286 1,473 1,554 784 4,097

 actual 732 1,508 1,623 956 4,819

Sum est. 110,944 133,635 141,811 80,187 466,576

 actual 79,731 121,988 136,878 82,629 421,226

Source: EPA calculations; 2012 Census of Agriculture, Special Tabulation. Rows and columns may not sum due to 

rounding. 1 Includes farms producing oilseeds and grains, cotton and tobacco, and other crop farms.

2 Includes vegetable, fruit, and nut farms and nurseries.

3 Includes bovine, ovine, and swine operations, poultry farms, and other livestock operations.

Table A.3-2 compares the estimated and actual number of crop-producing farms that hire labor 

and use pesticides in 2012. The number of these farms is a primary driver of the total cost of the 

WPS revisions. The total estimated number is about eight percent higher than the actual number. 

As with the number of crop-producing farms that hire labor, EPA estimated larger numbers of 

small farms hiring labor and using pesticides and slightly underestimated the number of large 

farms, although for greenhouses and feedlots, the pattern was largely reversed.
17

Table A.3-2. Estimated and actual number of crop-producing farms that hire labor and 

use pesticides, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Field Crops 1 est. 23,287 41,201 76,895 42,960 184,344

 actual 12,175 36,490 73,085 47,309 169,059

Specialty Crops 2 14,010 24,179 19,344 10,732 68,266

 actual 11,228 23,922 20,313 10,378 65,841

Greenhouses est. 37 247 154 108 547

 actual 109 368 159 131 767

Livestock 3 est. 17,984 30,642 30,529 18,672 97,827

 actual 12,294 25,697 30,721 20,312 89,024

Feedlots est. 192 1,296 1,315 650 3,453

 actual 412 1,278 1,542 908 4,140

Sum est. 55,511 97,564 128,238 73,123 354,436

 actual 36,218 87,755 125,820 79,038 328,831

Source: EPA calculations; 2012 Census of Agriculture, Special Tabulation. Rows and columns may not sum due to 

rounding. 1 Includes farms producing oilseeds and grains, cotton and tobacco, and other crop farms.

2 Includes vegetable, fruit, and nut farms and nurseries.

3 Includes bovine, ovine, and swine operations, poultry farms, and other livestock operations.

The number of workers and handlers is another important driver in the estimation of total costs 

of the WPS revisions. Table A.3-3 compares the estimated number of employees to the number 

of employees reported in the Census for farms that produce crops and hire labor. As with farms, 

the approach yielded a slight overestimate, of about four percent, compared to the actual number 

of employees. The number of people employed on the small-small farms is particularly 

overestimated, while estimated numbers of employees in greenhouses and on feedlots is 

underestimated.

Table A.3-3. Estimated and actual number of employees on crop-producing farms, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Field Crops 1 est. 116,931 132,321 204,957 258,786 712,994

 actual 75,069 120,729 201,440 246,723 643,961

Specialty Crops 2 58,227 139,189 238,486 740,454 1,176,356

 actual 55,763 141,439 261,464 715,622 1,174,288

Greenhouses est. 516 1,658 2,157 16,374 20,705

 actual 697 2,096 1,993 17,602 22,388
18

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Livestock 3 est. 94,223 116,012 105,333 166,887 482,455

 actual 67,511 99,608 109,838 173,400 450,357

Feedlots est. 549 2,904 3,954 8,535 15,942

 actual 1,657 3,452 4,768 9,631 19,508

Sum est. 270,447 392,084 554,886 1,191,036 2,408,452

 actual 200,697 367,324 579,503 1,162,978 2,310,502

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014). Rows and columns may not sum due to 

rounding.

1 Includes farms producing oilseeds and grains, cotton and tobacco, and other crop farms.

2 Includes vegetable, fruit, and nut farms and nurseries.

3 Includes bovine, ovine, and swine operations, poultry farms, and other livestock operations.

Table A.3-4 presents the estimated and actual number of employees on crop-producing farms 

that use pesticides. Overall, the estimate is about three percent greater than observed in the data. 

The estimated number of employees on small-small farms is nearly double the observed number 

and about ten percent greater for medium-small farms while we are six percent and two percent 

lower for large-small and large farms, respectively. By farm type, we overestimate the number 

of employees on farms producing field crops by almost 47,000 employees or about eight percent. 

We underestimate the number of employees in greenhouses and feedlots by a large percentage, 

but only by 3,000 to 4,000 total workers.

Table A.3-4. Estimated and actual number of employees on crop-producing farms that use 

pesticides, 2012.

Farm Type

Size (defined by gross revenue)

small-small medium-small large-small large Total

Field Crops 1 est. 95,459 103,219 192,566 219,625 610,870

 actual 28,976 93,110 196,736 245,132 563,954

Specialty Crops 2 43,111 125,183 225,176 723,589 1,117,059

 actual 37,071 120,987 249,600 699,250 1,106,908

Greenhouses est. 134 899 1,165 12,860 15,059

 actual 324 1,459 1,376 14,940 18,099

Livestock 3 est. 44,245 73,557 85,058 139,758 342,618

 actual 29,400 60,198 88,027 155,458 333,083

Feedlots est. 394 2,556 3,274 6,443 12,667

 actual 940 2,923 4,511 8,583 16,957

Sum est. 183,343 305,416 507,238 1,102,275 2,098,272

 actual 96,711 278,677 540,250 1,123,363 2,039,001

Source: EPA calculations, 2012 Census of U.S. Agriculture (NASS, 2014). Rows and columns may not sum due to 

rounding.

1 Includes farms producing oilseeds and grains, cotton and tobacco, and other crop farms.

2 Includes vegetable, fruit, and nut farms and nurseries.

3 Includes bovine, ovine, and swine operations, poultry farms, and other livestock operations.

Overall, EPA has slightly overestimated the number of agricultural establishments and 

employees that would be affected by revisions to the WPS. In estimating the total incremental 

impacts, EPA assumed that farms faced similar per-establishment and per-worker or handler 
19

costs, so basing costs on the estimated number of crop-producing farms and employees that hire 

labor and use pesticides will result in an overestimation of the total costs on the order of three to 

eight percent, which are the degree of overestimation of the number of employees and 

establishments, respectively. Within economic size categories, the cost estimates for small 

establishments, in aggregate, would be overestimated to a greater degree and the cost to large 

farms, in aggregate, would be underestimated.

The number of workers per farm is an important factor in the estimation of total perestablishment costs, which are key to understanding the distributional effects of the revisions to 

the WPS. According to the data from the special tabulation, crop-producing farms that hire labor 

and use pesticides average 6.2 workers per farm, ranging from 2.7 workers per small-small farm 

to 14.1 workers per large farm. EPA’s estimation results in an average of 5.9 workers per farm, 

a slight underestimation over all farms. The approach yields an estimate of 3.3 workers per 

small-small farm, however, indicating that total per-establishment costs would be slightly 

overestimated. Similarly, EPA estimates 15.1 workers per large farm. EPA estimates 4.0 

workers per large-small farm compared to an observed average of 4.3 workers per farm in that 

category.

In general, EPA concludes that the estimation is reasonably accurate or will lead to a slight 

overestimation of costs that are of most concern: total national incremental costs and perestablishment costs to the smallest entities. Further, the estimation provides more disaggregate 

information about the types of farms affected, separating for example, cotton and tobacco farms 

from other field crops. Therefore, EPA bases the cost analysis of the final WPS rule on the 

estimated number of farms and employees rather than the more aggregate information obtained 

from the 2012 Census of Agriculture.