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RIN2070-AJ22_EO12866_AgWPS_FRM_EA AppendixB_2015-07-17.docx

Draft document as submitted for review under EO 12866

ECONOMIC ANALYSIS OF

FINAL REVISIONS TO THE WORKER PROTECTION STANDARD

APPENDIX B

Cost Estimation, Final Regulations

Table of Contents

B.1. Pesticide Safety Training..................................................................................................... 2

a. Baseline................................................................................................................................ 2

b. Final Rule........................................................................................................................... 11

B.2. Hazard Communication .................................................................................................... 15

a. Baseline.............................................................................................................................. 15

b. Final Rule........................................................................................................................... 19

B.3. Notification.......................................................................................................................... 20

a. Baseline.............................................................................................................................. 20

b. Final Rule........................................................................................................................... 28

B.4. Age..................................................................................................................................... 35

a. Baseline.............................................................................................................................. 35

b. Final Rule........................................................................................................................... 36

B.5. Entry.................................................................................................................................. 37

B.6. Personal Protective Equipment (PPE)........................................................................... 37

a. Baseline.............................................................................................................................. 37

b. Final Rule........................................................................................................................... 44

B.7. Decontamination Supplies............................................................................................... 47

a. Baseline.............................................................................................................................. 47

b. Final Rule........................................................................................................................... 48
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1 B.1. Pesticide Safety Training

2

3 a. Baseline

4

5 Worker

6

7 Table B.1.a-1. Baseline Cost, per worker, Worker Safety Training

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Full training session 14.64 0.5 0.490 3.59

Abbreviated training session 14.64 0.05 0.052 0.04

Trainer, abbreviated session 33.44 0.05 0.052 0.09

Expected per-worker Cost (costr,i,workr

B

) 3.71

8

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

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

11 EPA experience.

12  Workers trained each year account for 49.0% of the total workforce (16% + 33.6%)*(1 – 1.2%).

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

14 o Includes 33.6% of total workforce representing returning workers who are retrained; 

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

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

17 o Excludes workers employed less than five days, which EPA calculates to be 1.2% of total 

18 workforce, assuming 5% of part-time employees are employed less than five days; part19 time employees are estimated to be 24% of total workforce (NASS, 2014b)

20  EPA assumes an abbreviated training takes 3 minutes.

21  Workers taking an abbreviated training account for 5.2% of total workforce (1.2% + 4.0%).

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

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

24 to full training; assuming 25% of new hires employed (16% of total workforce, as above)

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

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

27

28 Table B.1.a-2. Baseline Costs, per worker, Training Verification Program 

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

WPS worker

Verification card 0.06 1 0.490 0.03

Distribute card (handler trainer) 47.18 0.033 0.069 0.11

Distribute card (train-the-trainer) 47.18 0.033 0.049 0.08

Distribute card (certified applicator) 33.44 0.033 0.368 0.41

Distribute Certificates (handler) 20.04 0.033 0.005 0.00

Expected per-worker Cost (costr,i,a

B

) 0.63

29

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

31 400,000 cards or about $0.06 per card.

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

33 verification card (as above).
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34  Trainers must fill out and distribute the cards. Four categories of trainers eligible to conduct 

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

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

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

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

39 o handlers ($20.04/hr).

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

41 and other pertinent information.

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

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

44 a trainer in that category.

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

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

47 workers;

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

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

50

51

52 Handler

53

54 Table B.1.a-3. Baseline Cost, per WPS handler, Handler Safety Training

Action/Material wage/price

unit 

time/quantity

annual 

probability

cost

(costr,i,a

B

)

WPS farm handler 20.04 0.75 0.328 4.93

CPHE handler 23.26 0.75 0.328 5.72

55

56  WPS and CHPE handler wages, including benefits, are $20.04/hr and $23.26/hr, respectively 

57 (BLS, 2014b).

58  EPA assumes training typically last 45 minutes.

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

60 o Includes 16% of handlers, those who are new hires – based on a 16% new hire rate for all 

61 farm employees(DOL, 2005)

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

63 5 years (20% of remaining 84% of handlers).

64

65 Table B.1.a-4. Baseline Costs, per handler, Training Verification Program 

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

WPS farm handler

Verification card 0.06 1 0.328 0.03

Distribute card (handler trainer) 47.18 0.033 0.046 0.07

Distribute card (train-the-trainer) 47.18 0.033 0.033 0.05

Distribute card (certified applicator) 33.44 0.033 0.249 0.28

Expected per-handler Cost (costr,i,a

B

) 0.42
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Action/Material wage/price

unit 

time/quantity

annual 

probability cost

CPHE handler

Verification card 0.06 1 0.328 0.03

Distribute card (handler trainer) 47.18 0.033 0.046 0.07

Distribute card (train-the-trainer) 47.18 0.033 0.033 0.05

Distribute card (certified applicator) 32.65 0.033 0.249 0.27

Expected per-handler Cost (costr,i,a

B

) 0.41

66

67  Verification cards cost about $0.06 per card. See above.

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

69 verification card (as above).

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

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

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

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

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

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

76 and other pertinent information.

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

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

79 a trainer in that category.

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

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

82 handlers;

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

84

85

86 Establishment

87

88 Table B.1.a-5. Baseline Cost, per WPS farm, by size, Worker Training

Action/Material wage/price

unit 

time/quantity

annual 

frequency cost

Large WPS farm

Training by Handler Trainer 47.18 0.5 0.272 6.42

Training by Train-the-Trainer 47.18 0.5 0.195 4.59

Training by Certified Applicator 33.44 0.5 1.459 24.39

Training by WPS Handler 20.04 0.5 0.019 0.19

Expected per-farm Cost (costr,i,a

B

) 35.60

Small WPS farm

Training by Handler Trainer 47.18 0.5 0.113 2.66

Training by Train-the-Trainer 47.18 0.5 0.081 1.90

Training by Certified Applicator 33.44 0.5 0.604 10.10

Training by WPS Handler 20.04 0.5 0.008 0.08

Expected per-farm Cost (costr,i,a

B

) 14.75

89

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

91 2014b): 
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92 o trainers of handlers and certified applicators ($47.18/hr); 

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

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

95 o handlers ($20.04/hr).

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

97 EPA experience.

98  The probability a trainer from a given category conducting a training session

99 o Trainer probabilities, based on conversations with state officials:

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

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

102  certified applicators (75% of sessions); and

103  handlers (1% of sessions)

104 o Vector of probabilities [ 0.14 0.10 0.75 0.01 ]

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

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

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

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

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

110  Large farms with more than 10 employees hold an average of 4.5 training 

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

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

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

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

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

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

117 sessions per year. These farms primarily cultivate field crops such as grains,

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

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

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

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

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

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

124 year. These farms include fruit, nut, and vegetable farms, nurseries, and 

125 greenhouses with an average of 12.6 workers/farm, many of whom are temporary 

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

127 there are 17,598 such farms out of 255,892 small farms hiring workers.

128  Large-small farms with fewer than 10 employees are assumed to hold an average 

129 of 0.73 training sessions per year. These farms primarily cultivate field crops 

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

131 EPA estimates that there are 84,687 such farms.

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

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

134 year. These farms average 3.3 workers per farm.

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

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

137 workers/farm.

138 o Vector of number of sessions = [ 1.95 0.81 ]

139  Matrix of annual frequency of sessions lead by various trainers

140 ┌ ┐ ┌ ┐

141 │0.14│ ┌ ┐ │0.272 0.113│
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142 │0.10│∙ │1.95 0.81│ = │0.195 0.081│

143 │0.75│ └ ┘ │1.459 0.604│

144 │0.01│ │0.019 0.008│

145 └ ┘ └ ┘

146

147

148 Table B.1.a-6. Baseline Cost, per WPS farm or CPHE, Handler Training

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Training by Handler Trainer 47.18 0.75 0.073 2.60

Training by Train-the-Trainer 47.18 0.75 0.052 1.86

Training by Certified Applicator 33.44 0.75 0.399 10.00

Expected per-farm Cost (costr,i,a

B

) 14.46

Large-Small WPS farm

Training by Handler Trainer 47.18 0.75 0.034 1.22

Training by Train-the-Trainer 47.18 0.75 0.025 0.87

Training by Certified Applicator 33.44 0.75 0.187 4.69

Expected per-farm Cost (costr,i,a

B

) 6.78

CPHE

Training by Handler Trainer 47.18 0.75 0.140 4.95

Training by Train-the-Trainer 47.18 0.75 0.100 3.54

Training by Certified Applicator 32.65 0.75 0.760 18.61

Expected per-firm Cost (costr,i,a

B

) 27.11

149

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

151 additional cost for benefits (BLS, 2014b): 

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

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

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

155 CPHE).

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

157 experience.

158  The probability a trainer from a given category conducting a training session

159 o Trainer probabilities, based on conversations with state officials:

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

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

162 and

163  certified applicators (76% of sessions)

164 o Vector of probabilities [ 0.14 0.10 0.75 ]

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

166 o Large WPS farms, employing two handlers on average, average 0.525 handler 

167 trainings/year (0.656 ∙ 0.8)

168  65.6% chance of employing a handler who needs trained, given that 32.8% of 

169 handlers will be trained each year (see above)

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

171 trained, as some farms are able to share resources.

172 o Large-small WPS farms, employing one handler on average, average 0.246 handler 

173 trainings/year (0.328 ∙ 0.75)
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174  32.8% chance of employing a handler who needs trained (see above)

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

176 trained, as some farms are able to share resources and large-small WPS farms are 

177 more common than large WPS farms.

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

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

180 o Vector of number of sections [ 0.525 0.328 1.0 ]

181  Matrix of annual frequency of sessions lead by various trainers

182 ┌ ┐ ┌ ┐

183 │0.14│ ┌ ┐ │0.073 0.034 0.140│

184 │0.10│∙ │0.525 0.328 1.0│ = │0.052 0.025 0.100│

185 │0.76│ └ ┘ │0.399 0.187 0.760│

186 └ ┘ └ ┘

187

188

189 California

190

191 Table B.1.a-7. California Baseline Cost, per worker, Worker Safety Training

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Full training session 14.64 0.75 0.490 5.38

Abbreviated training session 14.64 0.05 0.052 0.04

Trainer, abbreviated session 33.44 0.05 0.052 0.09

Expected per-worker Cost (costr,i,workr

B

) 5.51

192

193  Worker safety training takes approximately 45 minutes, given expanded content.

194  Cost per worker for verification cards is the same as for the national baseline (Table B.1.a-2.

195

196 Table B.1.a-8. California Baseline Costs, per handler, Handler Safety Training 

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

WPS farm handler

Full training 20.04 1 1.000 20.04

Acknowledge training 20.04 0.008 1.000 0.17

Collect acknowledgement (handler 

trainer) 47.18 0.013 0.140 0.08

Collect acknowledgement (trainthe-trainer) 47.18 0.013 0.100 0.06

Collect acknowledgement (certified 

applicator) 33.44 0.013 0.760 0.32

Expected per-handler Cost (costr,i,a

B

) 20.67
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Action/Material wage/price

unit 

time/quantity

annual 

probability cost

CPHE handler

Full training 23.26 1 1.000 23.26

Acknowledge training 23.26 0.008 1.000 0.19

Collect acknowledgement (handler 

trainer) 47.18 0.013 0.140 0.08

Collect acknowledgement (trainthe-trainer) 47.18 0.013 0.100 0.06

Collect acknowledgement (certified 

applicator) 32.65 0.013 0.760 0.31

Expected per-handler Cost (costr,i,a

B

) 23.91

197

198  Handler safety training typically last 60 minutes, given expanded content.

199  Handler safety training must be taken annually.

200  California requires employer to keep a record of training

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

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

203 handler

204

205 Table B.1.a-9. California Baseline Costs, per handler, Training Verification Program 

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

WPS farm handler

Verification card 0.06 1 1.000 0.06

Distribute card (handler trainer) 47.18 0.033 0.140 0.22

Distribute card (train-the-trainer) 47.18 0.033 0.100 0.16

Distribute card (certified applicator) 33.44 0.033 0.760 0.85

Expected per-handler Cost (costr,i,a

B

) 1.28

CPHE handler

Verification card 0.06 1 1.000 0.06

Distribute card (handler trainer) 47.18 0.033 0.140 0.22

Distribute card (train-the-trainer) 47.18 0.033 0.100 0.16

Distribute card (certified applicator) 32.65 0.033 0.760 0.83

Expected per-handler Cost (costr,i,a

B

) 1.26

206

207  Verification cards issued annually.

208

209 Table B.1.a-10. California Baseline Cost, per WPS farm, by size, Worker Training

Action/Material wage/price

unit 

time/quantity

annual 

frequency cost

Large WPS farm

Training by Handler Trainer 47.18 0.75 0.272 9.64

Training by Train-the-Trainer 47.18 0.75 0.195 6.88

Training by Certified Applicator 33.44 0.75 1.459 36.59

Training by WPS Handler 20.04 0.75 0.019 0.29

Expected per-farm Cost (costr,i,a

B

) 53.40
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Action/Material wage/price

unit 

time/quantity

annual 

frequency cost

Small WPS farm

Training by Handler Trainer 47.18 0.75 0.113 3.99

Training by Train-the-Trainer 47.18 0.75 0.081 2.85

Training by Certified Applicator 33.44 0.75 0.604 15.16

Training by WPS Handler 20.04 0.75 0.008 0.12

Expected per-farm Cost (costr,i,a

B

) 22.12

210

211  Worker safety training takes approximately 45 minutes, given expanded content.

212

213 Table B.1.a-11. California Baseline Cost, per WPS farm or CPHE, Handler Training

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Training by Handler Trainer 47.18 1.0 0.112 5.28

Training by Train-the-Trainer 47.18 1.0 0.080 3.77

Training by Certified Applicator 33.44 1.0 0.608 20.33

Training acknowledgement 0.02 1 1.16 0.02

Collect/store acknowledgement 33.44 0.067 1.16 2.59

Folder 0.20 1 1 0.20

Expected per-farm Cost (costr,i,a

B

) 32.20

Large-Small WPS farm

Training by Handler Trainer 47.18 1.0 0.070 3.30

Training by Train-the-Trainer 47.18 1.0 0.050 2.36

Training by Certified Applicator 33.44 1.0 0.380 12.71

Training acknowledgement 0.02 1 1.16 0.02

Collect/store acknowledgement 33.44 0.067 1.16 2.59

Folder 0.20 1 1 0.20

Expected per-farm Cost (costr,i,a

B

) 21.18

CPHE

Training by Handler Trainer 47.18 1.0 0.182 8.59

Training by Train-the-Trainer 47.18 1.0 0.130 6.13

Training by Certified Applicator 32.65 1.0 0.988 32.26

Training acknowledgement 0.02 1 1.3 0.03

Collect/store acknowledgement 33.44 0.067 1.3 2.83

Folder 0.20 1 1 0.20

Expected per-firm Cost (costr,i,a

B

) 50.04

214

215  Handler safety training typically last 60 minutes, given expanded content.

216  Handler safety training must be taken annually.

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

218 some farms are able to share resources)

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

220 some farms are able to share resources)

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

222 scheduling.

223  California requires employer to keep a record of training
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

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

225 1.16 per farm to account for new hires, 1.3 times for CPHEs with every session.

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

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

228

229

230 Subtropics, Northeast, and Northwest regions

231

232 Table B.1.a-12. Subtropic, Northeast, and Northwest Baseline Costs, Training Verification 

233 Program 

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

WPS worker

Verification card 0.06 1 0.245 0.01

Distribute card (handler trainer) 47.18 0.033 0.034 0.05

Distribute card (train-the-trainer) 47.18 0.033 0.025 0.04

Distribute card (certified applicator) 33.44 0.033 0.184 0.20

Distribute Certificates (handler) 20.04 0.033 0.002 0.00

Expected per-handler Cost (costr,i,a

B

) 0.31

WPS farm handler

Verification card 0.06 1 0.164 0.01

Distribute card (handler trainer) 47.18 0.033 0.023 0.04

Distribute card (train-the-trainer) 47.18 0.033 0.016 0.03

Distribute card (certified applicator) 33.44 0.033 0.125 0.14

Expected per-handler Cost (costr,i,a

B

) 0.21

CPHE handler

Verification card 0.06 1 0.164 0.01

Distribute card (handler trainer) 47.18 0.033 0.023 0.04

Distribute card (train-the-trainer) 47.18 0.033 0.016 0.03

Distribute card (certified applicator) 32.65 0.033 0.125 0.14

Expected per-handler Cost (costr,i,a

B

) 0.21

234

235  Only about half the states in these regions participate in the program; probability of 

236 worker obtaining a card is reduced by half.

237

238

239 Midwest, Ohio Valley, and Texas/Mountain West regions

240

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

242 baseline costs per worker are essentially zero.

243

244
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11

245 Summary, Pesticide Safety Training

246

247 Table B.1.a-13. Pesticide Safety Training Cost, by Employee

Action Worker Farm Handler CPHE Handler

South, Southwest Regions

Pesticide Safety Training $ 3.71 $ 4.93 $ 5.72

Verification Card $ 0.63 $ 0.41 $ 0.41

Expected Cost (costTRAIN,i,aB) $ 4.34 $ 5.35 $ 6.14

California

Pesticide Safety Training $ 5.51 $20.02 $23.26

Record Keeping $ 0.00 $ 0.63 $ 0.65

Verification Card $ 0.63 $ 1.28 $ 1.23

Expected Cost (costTRAIN,i,aB) $ 6.13 $21.95 $25.17

Subtropics, Northeast, Northwest

Pesticide Safety Training $ 3.71 $ 4.93 $ 5.72

Verification Card $ 0.31 $ 0.21 $ 0.21

Expected Cost (costTRAIN,i,aB) $ 4.03 $ 5.14 $ 5.93

Midwest, Ohio Valley, Texas/Mountain West

Pesticide Safety Training $ 3.71 $ 4.93 $ 5.72

Verification Card $ 0.00 $ 0.00 $ 0.00

Expected Cost (costTRAIN,i,aB) $ 3.71 $ 4.93 $ 5.72

248

249 Table B.1.a-14. Pesticide Safety Training Cost, by Employer

Action

Large WPS 

Farm

Large-Small 

WPS Farm

Other Small 

WPS Farm CPHE

All Regions, except California

Worker Safety Training $35.60 $14.75 $14.75 $ 0.00

Handler Safety Training $14.46 $ 6.78 $ 0.00 $27.11

Expected Cost (costTRAIN,i,aB) $50.06 $21.53 $14.75 $27.11

California

Worker Safety Training $53.40 $22.12 $22.12 $ 0.00

Handler Safety Training $29.39 $18.37 $ 0.00 $46.98

Record Keeping $ 2.81 $ 2.81 $ 0.00 $ 3.06

Expected Cost (costTRAIN,i,aB) $85.61 $43.30 $22.12 $50.04

250

251 b. Final Rule

252

253 Worker

254

255 Table B.1.b-1. Cost under Final Rule, per worker, Worker Safety Training

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Full training session 14.64 0.75 0.905 9.94

Acknowledge training 14.64 0.008 0.905 0.11

Copy of training record 0.02 1 0.302 0.01

Distribute copy 33.44 0.033 0.302 0.34

Expected per-worker Cost (costr,i,workr

B

) 10.39

256

257  Worker wages, including for benefits, are $14.64/hr (BLS, 2014b).
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258  Worker safety training will take an additional 15 minutes, based on EPA draft materials and pilot 

259 projects, i.e., approximately 45 minutes.

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

261 who comprise the remaining 9.5%.

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

263 seconds.

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

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

266 o About one-third of trained workers will request a copy to present to subsequent 

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

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

269

270 Handler

271

272 Table B.1.b-2. Costs under Final Rule, per handler, Handler Safety Training 

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

WPS farm handler

Full training 20.04 1 1.000 20.04

Acknowledge training 20.04 0.008 1.000 0.17

Copy of training record 0.02 1 0.160 0.00

Distribute copy 33.44 0.033 0.160 0.18

Expected per-handler Cost (costr,i,a

B

) 20.39

CPHE handler

Full training 23.26 1 1.000 23.26

Acknowledge training 23.26 0.008 1.000 0.19

Copy of training record 0.02 1 0.160 0.00

Distribute copy 32.65 0.033 0.160 0.17

Expected per-handler Cost (costr,i,a

B

) 23.63

273

274  Handler wages, including for benefits, are $20.04/hr for on-farm handlers and $23.26/hr for 

275 CPHE handlers (BLS, 2014b).

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

277 projects, i.e., approximately 60 minutes.

278  All handlers will be trained annually.

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

280 seconds.

281  A copy of the training record must be provided to a handler upon request.

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

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

284 the new hire rate (DoL, 2005)

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

286

287 Establishment

288
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289 Table B.1.b-3. Cost under Final Rule, per WPS farm, by size, Worker Training

Action/Material wage/price

unit 

time/quantity

annual 

frequency cost

Large WPS farm

Training by Handler Trainer 47.18 0.75 0.404 14.30

Training by Train-the-Trainer 47.18 0.75 0.289 10.22

Training by Certified Applicator 33.44 0.75 2.194 55.04

Collect/store training record 33.44 0.117 2.89 11.26

Training record 0.02 1 2.89 0.06

Folder 0.20 1 1 0.20

Expected per-farm Cost (costr,i,a

B

) 91.08

Small WPS farm

Training by Handler Trainer 47.18 0.75 0.194 6.87

Training by Train-the-Trainer 47.18 0.75 0.139 4.91

Training by Certified Applicator 33.44 0.75 1.054 26.44

Collect/store training record 33.44 0.117 1.39 5.41

Training record 0.02 1 1.39 0.03

Folder 0.20 1 1 0.20

Expected per-farm Cost (costr,i,a

B

) 43.85

290

291  Three categories of trainers eligible to conduct worker safety training with differing wage, 

292 excluding handlers (BLS, 2014b): 

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

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

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

296 o handlers ($20.04/hr).

297  Worker safety training takes approximately 45 minutes, given additional content.

298  The probability a trainer from a given category conducting a training session

299 o Trainer probabilities, based on conversations with state officials:

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

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

302 and

303  certified applicators (76% of sessions)

304 o Vector of probabilities [ 0.14 0.10 0.76 ]

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

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

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

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

309  Large farms with more than 10 employees hold an average of 6.4 training 

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

311  Large WPS farms with fewer than 10 employees hold an average of 1.45 training 

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

313 o Small WPS farms (less than $750,000 in revenue/year) average 1.39 training sessions per 

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

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

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

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

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

319 workers/farm, many of whom are temporary workers; sessions will be conducted 
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320 throughout the year. EPA estimates that there are 17,598 such farms out of 

321 255,892 small farms hiring workers.

322  Large-small farms with fewer than 10 employees are assumed to hold an average 

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

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

325 primary production are assumed to hold an average of 1.27 training sessions per 

326 year, an increase of 75% over the baseline.

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

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

329 o Vector of number of sessions = [ 2.89 1.39 ]

330  Matrix of annual frequency of sessions lead by various trainers

331 ┌ ┐ ┌ ┐

332 │0.14│ ┌ ┐ │0.404 0.194│

333 │0.10│∙ │2.89 1.39│ = │0.289 0.139│

334 │0.76│ └ ┘ │2.194 1.054│

335 └ ┘ └ ┘

336

337 Table B.1.b-4. Cost under Final Rule, per WPS farm or CPHE, Handler Training

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Training by Handler Trainer 47.18 1.0 0.112 5.28

Training by Train-the-Trainer 47.18 1.0 0.080 3.77

Training by Certified Applicator 33.44 1.0 0.608 20.33

Training acknowledgement 0.02 1 1.16 0.02

Collect/store acknowledgement 33.44 0.067 1.16 2.59

Folder 0.20 1 1 0.20

Expected per-farm Cost (costr,i,a

B

) 32.20

Large-Small WPS farm

Training by Handler Trainer 47.18 1.0 0.070 3.30

Training by Train-the-Trainer 47.18 1.0 0.050 2.36

Training by Certified Applicator 33.44 1.0 0.380 12.71

Training acknowledgement 0.02 1 1.16 0.02

Collect/store acknowledgement 33.44 0.067 1.16 2.59

Folder 0.20 1 1 0.20

Expected per-farm Cost (costr,i,a

B

) 21.18

CPHE

Training by Handler Trainer 47.18 1.0 0.182 8.59

Training by Train-the-Trainer 47.18 1.0 0.130 6.13

Training by Certified Applicator 32.65 1.0 0.988 32.26

Training acknowledgement 0.02 1 1.3 0.03

Collect/store acknowledgement 33.44 0.067 1.3 2.83

Folder 0.20 1 1 0.20

Expected per-firm Cost (costr,i,a

B

) 50.04

338

339  Handler safety training will take 60 minutes, given expanded content.

340  Handler safety training must be taken annually.

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

342 some farms are able to share resources)
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343 o Large-small farms will average 0.5 training sessions/year (1 training for every 2 farms, as 

344 some farms are able to share resources)

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

346 scheduling.

347  Employers must keep a record of training

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

349 1.16 per farm to account for new hires, 1.3 times for CPHEs with every session.

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

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

352

353

354 B.2. Hazard Communication

355

356 a. Baseline

357

358 Table A.2.a-1. Baseline Cost, per WPS farm with field workers, Information on Pesticide 

359 Applications

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Post Application Information 33.44 0.017 18.4 10.23

Expected per-large farm Cost (costr,i,a

B

) 61.76

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Post Application Information 33.44 0.017 15.7 8.73

Expected per-small farm Cost (costr,i,a

B

) 52.67

360

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

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

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

364 the REI.

365  EPA assumes a single sheet of paper, at $0.02/sheet (Staples, 2014), is sufficient to record the 

366 information about each application.

367  Posting the information is assumed to take one minute.

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

369 18.4 pesticide applications per year and small WPS farms employing workers and/or handlers 

370 make an average of 15.7 pesticides applications per year.

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

372 o EPA estimates that 91.8% of large WPS farms and 78.3% of small WPS farms with 

373 workers will make pesticide applications in any given year (Appendix A).

374
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375 California

376

377 Table B.2.a-2. California Baseline Cost, per WPS farm, Information on Pesticide Applications

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Obtain SDS 33.44 0.067 9.2 20.46

SDS 0.02 3.3 9.2 0.62

Post Information and SDS 33.44 0.017 18.4 10.23

Store Records 33.44 0.017 18.4 10.23

Copy of Information Sheet 0.02 1 18.4 0.37

Copy of SDS 0.02 3.3 9.2 0.62

Folder 0.20 1 0.918 0.18

Retrieve/Copy Record 33.44 0.1 0.918 3.07

Record copy 0.02 4.3 0.918 0.08

Expected per-large farm Cost (costr,CA,a

B

) 97.38

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Obtain SDS 33.44 0.067 7.8 17.45

SDS 0.02 3.3 7.8 0.52

Post Information and SDS 33.44 0.017 15.7 8.73

Store Records 33.44 0.017 15.7 8.73

Copy of Information Sheet 0.02 1 15.7 0.31

Copy of SDS 0.02 3.3 7.8 0.52

Folder 0.20 1 0.783 0.16

Retrieve/Copy Record 33.44 0.10 0.783 2.62

Record copy 0.02 4.3 0.783 0.07

Expected per-small farm Cost (costr,CA,a

B

) 83.05

378

379  See Table B.2.a-1 for explanation of wage/price, time/quantity, and annual probability.

380  State requires employers to post the product’s Safety Data Sheet (SDS).

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

382 internet search times. Most SDS are available with the product from the pesticide dealer.

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

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

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

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

387 6.7 pages.

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

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

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

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

392 2014).

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

394 only to current employees. EPA assumes that a copy of the record is the most convenient way to 

395 make the information available.
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17

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

397 application information sheet and SDS.

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

399 about one request per establishment using pesticides.

400

401 Subtropics, and Midwest

402

403 Table B.2.a-3. Subtropics and Midwest Baseline Cost, per WPS farm, Information on Pesticide 

404 Applications

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Obtain SDS 33.44 0.067 9.2 20.46

SDS 0.02 3.3 9.2 0.62

Post Information and SDS 33.44 0.017 18.4 10.23

Expected per-farm Cost (costr,(Subtrpc, Midwest),a

B

) 82.84

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Obtain SDS 33.44 0.067 7.8 17.45

SDS 0.02 3.3 7.8 0.52

Post Information and SDS 33.44 0.017 15.7 8.73

Expected per-farm Cost (costr,(Subtrpc, Midwest),a

B

) 70.65

405

406  See Table B.2.a-1 for explanation of wage/price, time/quantity, and annual probability.

407  States require employers to post the product’s Safety Data Sheet (SDS).

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

409 internet search times. Most SDS are available with the product from the pesticide dealer.

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

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

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

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

414 6.7 pages.

415
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416 Texas/Mountain West region

417

418 Table B.2.a-4. Texas/Mountain West Baseline Cost, per WPS farm, Information on Pesticide 

419 Applications

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Obtain SDS 33.44 0.067 9.2 20.46

SDS 0.02 3.3 9.2 0.62

Post Information and SDS 33.44 0.017 18.4 10.23

Store Records 33.44 0.017 18.4 10.23

Copy of Information Sheet 0.02 1 18.4 0.37

Copy of SDS 0.02 3.3 9.2 0.62

Folder 0.20 1 0.918 0.18

Retrieve/Copy Record 33.44 0.10 0.918 3.07

Record copy 0.02 4.3 0.918 0.08

Expected per-farm Cost (costr,(TX/Mt W),a

B

) 97.38

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Post Application Information 33.44 0.017 15.7 8.73

Expected per-farm Cost (costr,(TX/Mt W),a

B

) 52.67

420

421  State requires employers to post the product’s Safety Data Sheet (SDS), maintain records of 

422 application information and SDS, and make records available on request. EPA interprets the 

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

424 with payroll of $15,000 per year or more). See Table B.2.a-2 for explanation of large farm costs. 

425 See Table B.2.1-1 for explanation of small farm costs.

426

427 Table B.2.a-5. Texas/Mountain West Baseline Cost, per WPS worker/handler, Information on 

428 Pesticide Applications

Action/Material wage/price unit time/quantity

annual 

probability cost

Employer verifies request 

information 33.44 0.10 0.005 0.02

Retrieve/Copy Record 33.44 0.10 0.005 0.02

E-mail records 33.44 0.10 0.003 0.01

Mail Records 33.44 0.20 0.003 0.02

Record copy 0.02 4.3 0.003 0.00

Envelope & Postage 3.88 1 0.003 0.01

Expected per-employee Cost (costr,(TX/Mt W),a

B

) 0.07

429

430  State requires employers to make records available to former employees or to their designated 

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

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

433 West Region out of 163,682 total workers and handlers in the region, i.e., about 53% of workers 
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434 and handlers are employed on large farms. The probability of a request is thus about 0.53 out of 

435 100 total workers and handlers in the region.

436 o EPA assumes the employer spends 6 minutes, on average, verifying the validity of the 

437 request.

438 o EPA assume the employer spends 6 minutes, on average, retrieving and copying the 

439 record.

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

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

442  A copy of the record is made at $0.02 per page (Staples, 2014).

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

444 $3.68 (USPS, 2015) for total mailing costs of $3.88.

445

446

447 b. Final Rule

448

449 Table B.2.b-1. Cost under Final Rule, per WPS farm, Information on Pesticide Applications

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm

Record Application Information 33.44 0.083 18.4 51.16

Information Sheet 0.02 1 18.4 0.37

Obtain SDS 33.44 0.067 9.2 20.46

SDS 0.02 3.3 9.2 0.62

Post Information and SDS 33.44 0.017 18.4 10.23

Store Records 33.44 0.017 18.4 10.23

Copy of Information Sheet 0.02 1 18.4 0.37

Copy of SDS 0.02 3.3 9.2 0.62

Folder 0.20 1 0.918 0.18

Retrieve/Copy Record 33.44 0.1 0.918 3.07

Record copy 0.02 4.3 0.918 0.08

Expected per-large farm Cost (costr,CA,a

B

) 97.38

Small WPS farm

Record Application Information 33.44 0.083 15.7 43.63

Information Sheet 0.02 1 15.7 0.31

Obtain SDS 33.44 0.067 7.8 17.45

SDS 0.02 3.3 7.8 0.52

Post Information and SDS 33.44 0.017 15.7 8.73

Store Records 33.44 0.017 15.7 8.73

Copy of Information Sheet 0.02 1 15.7 0.31

Copy of SDS 0.02 3.3 7.8 0.52

Folder 0.20 1 0.783 0.16

Retrieve/Copy Record 33.44 0.10 0.783 2.62

Record copy 0.02 4.3 0.783 0.07

Expected per-small farm Cost (costr,CA,a

B

) 83.05

450

451  See Table B.2.a-2 for explanation.

452
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453

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

455 Applications

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Employer verifies request information 33.44 0.10 0.010 0.03

Retrieve/Copy Record 33.44 0.10 0.010 0.03

E-mail records 33.44 0.10 0.005 0.02

Mail Records 33.44 0.20 0.005 0.03

Record copy 0.02 4.3 0.005 0.00

Envelope & Postage 3.88 1 0.005 0.02

Expected per-employee Cost (costr,(TX/Mt W),a

B

) 0.14

456

457  See Table B.2.a-5 for explanation. EPA assumes that 1 in 100 workers and handlers will request 

458 information each year with half of the responses made via e-mail and half of responses via regular 

459 mail.

460

461

462 B.3. Notification

463

464 a. Baseline

465

466 Agricultural Establishments, Notification of REIs

467

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

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

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

471 notification for double notification products.

472  EPA assumes WPS farms typically provide oral notification when given the choice, which is 

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

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

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

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

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

478  EPA assumes that 2 signs are usually posted at a time and these signs can be reused. WPS farms 

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

480 2 or 3 signs due to few simultaneous postings. EPA assumes that it takes 10 minutes to post a 

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

482 minutes; posting three signs takes 30 minutes.

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

484 are very short and workers may not be present on-farm while it is in effect.

485

486 Table B.3.a-1. Baseline Cost, Large WPS Farm excluding greenhouses, REI Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Large WPS farm 1

Oral Notification 33.44 0.05 14.6 24.36

Warning Signs 7.35 4 0.339 9.96
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Post 2 Signs 33.44 0.333 5.42 60.42

Warning Signs 7.35 6 0.134 5.92

Post 3 Signs 33.44 0.50 2.15 35.91

Expected per-Large farm Cost (costr,i,a

B

) 136.58

1

487 Excluding greenhouses.

488

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

490  Warning signs cost $7.35 each (Gemplers)

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

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

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

494 notifications per application.

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

496 assuming 10% of applications require double notification. 

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

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

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

500 28.4% of all large WPS farms.

501 o Four REI signs are purchased with an annual frequency of 0.339, i.e., 71.6% of large 

502 farms without worker housing near fields.

503 o Six signs are purchased with annual frequency of 0.134, that is, 28.4% of large farms 

504 with worker housing near fields.

505  Therefore, 2 signs will be posted (20 minutes) 5.4 times/year, i.e., 71.6% of the 7.6 postings, and 

506 3 signs will be posted (30 minutes) 2.2 times/year.

507

508 Table B.3.a-2. Baseline Cost, Large-Small WPS Farm excluding greenhouses, REI Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Large-Small WPS farm 1

Oral Notification 33.44 0.05 20.8 34.70

Warning Signs 7.35 2 0.383 5.63

Post 2 Signs 33.44 0.333 1.53 17.06

Warning Signs 7.35 3 0.089 1.96

Post 3 Signs 33.44 0.50 0.36 5.95

Expected per-Lrg-Sml farm Cost (costr,i,a

B

) 65.31

509

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

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

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

513 application.

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

515 assuming 10% of applications require double notification.

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

517 year, i.e., half of the 94.3% of large-small WPS farms that reported using pesticides in 2012. 

518 EPA assumes that 20% of large-small WPS farms applying pesticides have worker housing near a 

519 field, or 18.9% of all large-small WPS farms.

520 o Two REI signs are purchased with an annual frequency of 0.383, i.e., 81.1% of large521 small farms without worker housing near fields.
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522 o Three signs are purchased with annual frequency of 0.089, that is, 18.9% of large-small 

523 farms with worker housing near fields.

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

525 3 signs will be posted (30 minutes) 0.4 times/year.

526

527 Table B.3.a-3. Baseline Cost, Medium-Small WPS Farm excluding greenhouses, Notification of 

528 REIs

Action/Material wage/price unit time/quantity

annual 

frequency cost

Medium-Small WPS farm 1

Oral Notification 33.44 0.05 17.5 29.24

Warning Signs 7.35 2 0.366 5.38

Post 2 Signs 33.44 0.333 1.46 16.31

Warning Signs 7.35 3 0.032 0.70

Post 3 Signs 33.44 0.50 0.13 2.11

Expected per-Med-Small farm Cost (costr,i,a

B

) 53.75

1

529 Excluding greenhouses.

530

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

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

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

534 application.

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

536 assuming 10% of applications require double notification.

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

538 year, i.e., half of the 79.5% of medium-small WPS farms that reported using pesticides in 2012. 

539 EPA assumes that 10% of medium-small WPS farms applying pesticides have worker housing 

540 near a field, or 7.9% of all medium-small WPS farms.

541 o Two REI signs are purchased with an annual frequency of 0.366, i.e., 92.1% of medium542 small farms without worker housing near fields.

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

544 farms with worker housing near fields.

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

546 3 signs will be posted (30 minutes) 0.1 times/year.

547

548 Table B.3.a-4. Baseline Cost, Small-Small WPS Farm excluding greenhouses, REI Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Small-Small WPS farm 1

Oral Notification 33.44 0.05 11.6 19.38

Warning Signs 7.35 2 0.256 3.77

Post 2 Signs 33.44 0.333 1.03 11.43

Warning Signs 7.35 3 0.007 0.15

Post 3 Signs 33.44 0.50 0.03 0.46

Expected per-Small-Small farm Cost (costr,i,a

B

) 35.20

1

549 Excluding greenhouses.

550

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

552 report using pesticides in 2012. They will make oral notifications to their workers for all 
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

23

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

554 application.

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

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

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

558 year, i.e., half of the 52.7% of small-small WPS farms that reported using pesticides in 2012. 

559 EPA assumes that 5% of small-small WPS farms applying pesticides have worker housing near a 

560 field, or 2.6% of all small-small WPS farms.

561 o Two REI signs are purchased with an annual frequency of 0.256, i.e., 97.4% of small562 small farms without worker housing near fields.

563 o Three signs are purchased with annual frequency of 0.007, that is, 2.6% of small-small 

564 farms with worker housing near fields.

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

566 3 signs will be posted (30 minutes) 0.03 times/year.

567

568 Table B.3.a-5. Baseline Cost, Large WPS Greenhouse, per actor, REI Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Large WPS Greenhouse

Oral Notification 33.44 0.05 1.64 2.74

Signs 7.35 4 0.372 10.95

Posting Signs 33.44 0.333 14.9 166.07

Expected per-Greenhouse Cost (costr,i,a

B

) 179.76

569

570  Large WPS greenhouses will make 14.9 applications per year given that 74.5% of large WPS 

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

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

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

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

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

576 Large WPS greenhouses will need 4 signs.

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

578 posted 14.9 times/year.

579

580 Table B.3.a-6. Baseline Cost, Small WPS Greenhouse, per actor, REI Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Small WPS Greenhouse

Oral Notification 33.44 0.05 1.20 2.01

Signs 7.35 4 0.273 8.02

Posting Signs 33.44 0.333 10.9 121.62

Expected per-Greenhouse Cost (costr,i,a

B

) 131.64

581

582  Small WPS greenhouses will make 10.9 applications per year given that 59.2% of small WPS 

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

584 workers for 10% of applications, i.e., double notification products, implying 1.2 oral notifications 

585 per year, on average, assuming 1.1 notifications per application.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

24

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

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

588 2012. Small WPS greenhouses will need 4 signs.

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

590 posted 10.9 times/year.

591

592 Workers, Notification of REIs

593

594 Table B.3.a-7. Baseline Cost, WPS Workers, Notification of REI

Actor, Receives Notification wage/price unit time/quantity

annual 

frequency

cost

(costr,i,a

B

)

Large Farm worker 1 14.64 0.05 10.6 7.74

Lrg-Sml Farm worker 1 14.64 0.05 15.1 11.04

Med/Sml Farm worker 1 14.64 0.05 13.1 9.63

Large Greenhouse worker 14.64 0.05 1.3 0.92

Small Greenhouse worker 14.64 0.05 0.8 0.59

1

595 Excluding greenhouses.

596

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

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

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

600 farm size.

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

602 notifications for 14 of 20 applications (Table B.3.a-1), there is an 80% chance a worker 

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

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

605 o Workers on large-small farms receive 15.1 notifications per year. Large-small farms 

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

607 on-farm during the REI, and 94.2% of workers are employed on large-small WPS farms 

608 making a pesticide application (NASS, 2008b) (20 ∙ 0.8 ∙ 0.942).

609 o Workers on medium and small-small farms receive 13.1 notifications per year. Small 

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

611 will be on-farm during the REI, and 82.2% of workers are employed on WPS farms 

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

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

614 oral notifications for 2 of 20 applications, there is an 80% chance a worker will be on615 farm during the REI, and 78.5% of workers are employed on large WPS greenhouses 

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

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

618 make oral notifications for 2 of 20 applications, there is an 80% chance a worker will be 

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

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

621

622

623 Agricultural Establishments, Early Entry Notification

624

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

626 field under a REI. The employer is required to inform the worker of the labeling requirements 

627 related to hazard or safety.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

25

628

629 Table B.3.a-8. Baseline Cost, per WPS farm, Early Entry Notification

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm 1

Gather Information 33.44 0.017 0.378 0.21

Provide Information 33.44 0.05 0.378 0.63

Expected per-farm Cost (costr,i,a

B

) 0.84

Large-Small WPS farm 1

Gather Information 33.44 0.017 0.377 0.21

Provide Information 33.44 0.05 0.377 0.63

Expected per-farm Cost (costr,i,a

B

) 0.84

Medium-Small WPS farm 1

Gather Information 33.44 0.017 0.318 0.18

Provide Information 33.44 0.05 0.318 0.53

Expected per-farm Cost (costr,i,a

B

) 0.71

Small-Small WPS farm 1

Gather Information 33.44 0.017 0.211 0.12

Provide Information 33.44 0.05 0.211 0.35

Expected per-farm Cost (costr,i,a

B

) 0.47

Large WPS Greenhouse

Gather Information 33.44 0.017 0.298 0.17

Provide Information 33.44 0.05 0.298 0.50

Expected per-farm Cost (costr,i,a

B

) 0.66

Small WPS Greenhouse

Gather Information 33.44 0.017 0.218 0.12

Provide Information 33.44 0.05 0.218 0.36

Expected per-farm Cost (costr,i,a

B

) 0.49

1

630 Excluding greenhouses.

631

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

633 from the pesticide label.

634  EPA assumes that providing the information takes 3 minutes.

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

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

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

638 applications.

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

640 implying an annual frequency of 0.378 across all such farms.

641 o EPA estimates that 94.3% of large-small WPS farms, excluding greenhouses, apply 

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

643 o EPA estimates that 79.5% of medium-small WPS farms, excluding greenhouses, apply 

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

645 o EPA estimates that 52.7% of small-small WPS farms, excluding greenhouses, apply 

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

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

648 annual frequency of 0.298 across all such farms.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

26

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

650 annual frequency of 0.218 across all such farms.

651

652 Workers, Early Entry Notification

653

654 Table B.3.a-9. Baseline Cost, WPS Workers, Early Entry Notification

Actor, Receive Notification wage/price unit time/quantity

annual 

frequency

cost

(costr,i,a

B

)

Large Farm worker 1 14.64 0.05 0.189 0.14

Lrg-Sml Farm worker 1 14.64 0.05 0.188 0.14

Med/Sml Farm worker 1 14.64 0.05 0.164 0.12

Large Greenhouse worker 14.64 0.05 0.157 0.12

Small Greenhouse worker 14.64 0.05 0.102 0.07

1

655 Excluding greenhouses.

656

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

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

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

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

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

662 establishment using pesticides.

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

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

665 (Appendix A) (0.2 ∙ 0.944).

666 o EPA estimates that 18.8% of workers on large-small farms participate in an early entry 

667 task since 94.2% of workers are employed on large-small WPS farms making a pesticide 

668 application (Appendix A) (0.2 ∙ 0.942).

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

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

671 application (Appendix A) (0.2 ∙ 0.822).

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

673 task since 78.5% of workers are employed on large WPS greenhouses making a pesticide 

674 application (Appendix A) (0.2 ∙ 0.785).

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

676 since 50.8% of workers are employed on large WPS farms making a pesticide application 

677 (Appendix A) (0.2 ∙ 0.508).

678

679 Agricultural Establishments, Safety Displays

680

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

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

683

684 Table B.3.a-10. Baseline Cost, per WPS farm, Safety posters

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm 1

Central Poster 6.25 1 0.315 1.97

Post Sign 33.44 0.033 0.946 1.05

Expected per-farm Cost (costr,i,a

B

) 3.03
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

27

Large-Small WPS farm 1

Central Poster 6.25 1 0.314 1.97

Post Sign 33.44 0.033 0.943 1.05

Expected per-farm Cost (costr,i,a

B

) 3.02

Medium-Small WPS farm 1

Central Poster 6.25 1 0.265 1.66

Post Sign 33.44 0.033 0.795 0.89

Expected per-farm Cost (costr,i,a

B

) 2.54

Small-Small WPS farm 1

Central Poster 6.25 1 0.176 1.10

Post Sign 33.44 0.033 0.527 0.59

Expected per-farm Cost (costr,i,a

B

) 1.68

Large WPS Greenhouse

Central Poster 6.25 1 0.248 1.55

Post Sign 33.44 0.033 0.745 0.83

Expected per-farm Cost (costr,i,a

B

) 2.38

Small WPS Greenhouse

Central Poster 6.25 1 0.182 1.14

Post Sign 33.44 0.033 0.545 0.61

Expected per-farm Cost (costr,i,a

B

) 1.74

Large Handler-Only Farm

Central Poster 6.25 1 0.283 1.77

Post Sign 33.44 0.033 0.849 0.95

Expected per-farm Cost (costr,i,a

B

) 2.72

Small Handler-Only Farm

Central Poster 6.25 1 0.269 1.68

Post Sign 33.44 0.033 0.807 0.90

Expected per-farm Cost (costr,i,a

B

) 2.58

1

685 Excluding greenhouses.

686

687  According to an on-line source of WPS materials, a safety poster costs $6.25 (Gempler’s, 2014).

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

689  EPA assumes poster lasts about 3 years, so one-third of WPS farms will need to purchase a sign 

690 each year.

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

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

693 o EPA estimates that 94.3% of large-small WPS farms, excluding greenhouses, apply 

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

695 o EPA estimates that 79.5% of medium-small WPS farms, excluding greenhouses, apply 

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

697 o EPA estimates that 52.7% of small-small WPS farms, excluding greenhouses, apply 

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

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

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

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

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

703 o EPA estimates that 84.9% of large handler-only farms apply pesticides and will post a 

704 sign; this implies 28.3% will purchase a sign each year.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

28

705 o EPA estimates that 80.7% of small handler-only farms apply pesticides and will post a 

706 sign; this implies 26.9% will purchase a sign each year.

707

708

709 b. Final Rule

710

711 Agricultural Establishments, Notification of REIs

712

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

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

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

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

717

718 Table B.3.b-1. Cost under Final Rule, Large WPS Farm excluding greenhouses, REI 

719 Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Large WPS farm 1

Oral Notification 33.44 0.05 14.6 24.36

Warning Signs 7.35 4 0.339 9.96

Post 2 Signs 33.44 0.333 5.42 60.42

Warning Signs 7.35 6 0.134 5.92

Post 3 Signs 33.44 0.50 2.15 35.91

Expected per-Large farm Cost (costr,i,a

B

) 136.58

1

720 Excluding greenhouses.

721

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

723 posting is probably already preferred in many situations.

724

725 Table B.3.b-2. Cost under Final Rule, Large-Small WPS Farm excluding greenhouses, REI 

726 Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Large-Small WPS farm 1

Oral Notification 33.44 0.05 14.5 24.29

Warning Signs 7.35 4 0.383 11.25

Post 2 Signs 33.44 0.333 6.12 68.26

Warning Signs 7.35 6 0.089 3.92

Post 3 Signs 33.44 0.50 1.42 23.81

Expected per-Lrg-Sml farm Cost (costr,i,a

B

) 131.53

727

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

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

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

731 application.

732  Large-small WPS farms will post REI warning signs in 40% of applications, or 7.5 times/year, 

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

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

29

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

736 year, i.e., half of the 94.3% of large-small WPS farms that reported using pesticides in 2012. 

737 EPA assumes that 20% of large-small WPS farms applying pesticides have worker housing near a 

738 field, or 18.9% of all large-small WPS farms.

739 o Four REI signs are purchased with an annual frequency of 0.383, i.e., 81.1% of large740 small farms without worker housing near fields.

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

742 farms with worker housing near fields.

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

744 3 signs will be posted (30 minutes) 1.4 times/year.

745

746 Table B.3.b-3. Cost under Final Rule, Medium-Small WPS Farm excluding greenhouses, REI 

747 Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Medium-Small WPS farm 1

Oral Notification 33.44 0.05 12.2 20.47

Warning Signs 7.35 4 0.366 10.76

Post 2 Signs 33.44 0.333 5.85 65.26

Warning Signs 7.35 6 0.032 1.39

Post 3 Signs 33.44 0.50 0.51 8.45

Expected per-Med-Small farm Cost (costr,i,a

B

) 106.33

1

748 Excluding greenhouses.

749

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

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

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

753 per application.

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

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

756 year, i.e., half of the 79.5% of medium-small WPS farms that reported using pesticides in 2012. 

757 EPA assumes that 10% of medium-small WPS farms applying pesticides have worker housing 

758 near a field, or 7.9% of all medium-small WPS farms.

759 o Four REI signs are purchased with an annual frequency of 0.366, i.e., 92.1% of medium760 small farms without worker housing near fields.

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

762 farms with worker housing near fields.

763  Therefore, 2 signs will be posted (20 minutes) 5.9 times/year, i.e., 92.1% of the 6.4 postings, and 

764 3 signs will be posted (30 minutes) 0.5 times/year.

765

766 Table B.3.b-4. Cost under Final Rule, Small-Small WPS Farm excluding greenhouses, REI 

767 Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Small-Small WPS farm 1

Oral Notification 33.44 0.05 8.1 13.56

Warning Signs 7.35 2 0.256 3.77

Post 2 Signs 33.44 0.333 4.10 45.73

Warning Signs 7.35 3 0.007 0.15
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

30

Post 3 Signs 33.44 0.50 0.11 1.86

Expected per-Small-Small farm Cost (costr,i,a

B

) 65.07

1

768 Excluding greenhouses.

769

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

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

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

773 application.

774  Small-small WPS farms will post REI warning signs in 40% of applications, or 4.2 times/year.

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

776 year, i.e., half of the 52.7% of small-small WPS farms that reported using pesticides in 2012. 

777 EPA assumes that 5% of small-small WPS farms applying pesticides have worker housing near a 

778 field, or 2.6% of all small-small WPS farms.

779 o Two REI signs are purchased with an annual frequency of 0.256, i.e., 97.4% of small780 small farms without worker housing near fields.

781 o Three signs are purchased with annual frequency of 0.007, that is, 2.6% of small-small 

782 farms with worker housing near fields.

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

784 3 signs will be posted (30 minutes) 0.1 times/year.

785

786 Table B.3.b-5. Cost under Final Rule, Large WPS Greenhouse, per actor, REI Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Large WPS Greenhouse

Oral Notification 33.44 0.05 1.64 2.74

Signs 7.35 4 0.372 10.95

Posting Signs 33.44 0.333 14.9 166.07

Expected per-Greenhouse Cost (costr,i,a

B

) 179.76

787

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

789 probably preferred in many situations.

790

791 Table B.3.b-6. Cost under Final Rule, Small WPS Greenhouse, per actor, REI Notification

Action/Material wage/price unit time/quantity

annual 

frequency cost

Small WPS Greenhouse

Oral Notification 33.44 0.05 3.60 6.02

Signs 7.35 4 0.273 8.02

Posting Signs 33.44 0.333 8.73 97.29

Expected per-Greenhouse Cost (costr,i,a

B

) 111.33

792

793  Small WPS greenhouses will make 10.9 applications per year given that 59.2% of small WPS 

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

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

796 assuming 1.1 notifications per application.

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

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

799 2012. Small WPS greenhouses will need 4 signs.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

31

800  REI warning signs will be posted 80% of applications. Therefore, 2 signs (20 minutes) will be 

801 posted 8.7 times/year.

802

803 Workers, Notification of REIs

804

805 Table B.3.b-7. Cost under Final Rule, WPS Workers, Notification of REIs

Actor, Receives Notification wage/price unit time/quantity

annual 

frequency

cost

(costr,i,a

B

)

Large Farm worker 1 14.64 0.05 10.6 7.74

Lrg-Sml Farm worker 1 14.64 0.05 10.6 7.73

Med/Sml Farm worker 1 14.64 0.05 9.2 6.74

Large Greenhouse worker 14.64 0.05 1.3 0.92

Small Greenhouse worker 14.64 0.05 2.4 1.78

1

806 Excluding greenhouses.

807

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

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

810 farm size.

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

812 o Workers on large-small farms receive 10.6 notifications/year. Large-small farms make 

813 oral notifications for 70% of 20 applications, there is an 80% chance a worker will be on814 farm during the REI, and 94.2% of workers are employed on large-small WPS farms 

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

816 o Workers on medium and small-small farms receive 9.2 notifications per year. Small 

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

818 worker will be on-farm during the REI, and 82.2% of workers are employed on WPS 

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

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

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

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

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

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

825

826 Agricultural Establishments, Early Entry Notification

827

828 For early entry situations, the employer will be required to provide additional information to the 

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

830 the field.

831

832 Table B.3.b-8. Cost under Final Rule, per WPS farm, Early Entry Notification

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm 1

Gather Information 33.44 0.10 0.378 1.27

Provide Information 33.44 0.10 0.378 1.27

Expected per-farm Cost (costr,i,a

B

) 2.53

Large-Small WPS farm 1

Gather Information 33.44 0.10 0.377 1.26
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32

Provide Information 33.44 0.10 0.377 1.26

Expected per-farm Cost (costr,i,a

B

) 2.52

Medium-Small WPS farm 1

Gather Information 33.44 0.10 0.318 1.06

Provide Information 33.44 0.10 0.318 1.06

Expected per-farm Cost (costr,i,a

B

) 2.13

Small-Small WPS farm 1

Gather Information 33.44 0.10 0.211 0.70

Provide Information 33.44 0.10 0.211 0.70

Expected per-farm Cost (costr,i,a

B

) 1.41

Large WPS Greenhouse

Gather Information 33.44 0.10 0.298 1.00

Provide Information 33.44 0.10 0.298 1.00

Expected per-farm Cost (costr,i,a

B

) 1.99

Small WPS Greenhouse

Gather Information 33.44 0.10 0.218 0.73

Provide Information 33.44 0.10 0.218 0.73

Expected per-farm Cost (costr,i,a

B

) 1.46

1

833 Excluding greenhouses.

834

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

836 the information takes 6 minutes.

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

838

839 Workers, Early Entry Notification

840

841 Table B.3.b-9. Cost under Final Rule, WPS Workers, Notification

Actor, Receive Notification wage/price unit time/quantity

annual 

frequency

cost

(costr,i,a

B

)

Large Farm worker 1 14.64 0.10 0.189 0.28

Lrg-Sml Farm worker 1 14.64 0.10 0.188 0.28

Med/Sml Farm worker 1 14.64 0.10 0.164 0.24

Large Greenhouse worker 14.64 0.10 0.157 0.23

Small Greenhouse worker 14.64 0.10 0.102 0.15

1

842 Excluding greenhouses.

843

844  EPA assumes that information at early entry takes 6 minutes.

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

846 baseline.

847

848

849 Agricultural Establishments, Safety Display

850

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

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

853 decontamination supplies are provided for a crew of 11 or more people. Under the final rule, the 
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33

854 employer will be required to provide contact information for a near-by medical facility and for 

855 the state agency responsible for the WPS on all displays.

856

857 Table B.3.b-10. Cost under Final Rule, per WPS farm, Safety posters

Action/Material wage/price unit time/quantity

annual 

probability cost

Large WPS farm 1

Central Poster 6.25 1 0.315 1.97

Add Contact Information 33.44 0.05 0.315 0.53

Post Display 33.44 0.033 0.946 1.05

Decontamination Display 6.25 1.5 0.048 0.45

Add Contact Information 33.44 0.05 0.048 0.12

Post Display 33.44 0.033 1.43 1.60

Expected per-farm Cost (costr,i,a

B

) 5.72

Large-Small WPS farm 1

Central Poster 6.25 1 0.314 1.97

Add Contact Information 33.44 0.05 0.314 0.53

Post Display 33.44 0.033 0.943 1.05

Decontamination Display 6.25 1 0.044 0.28

Add Contact Information 33.44 0.05 0.044 0.07

Post Display 33.44 0.033 0.529 0.59

Expected per-farm Cost (costr,i,a

B

) 4.48
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34

Action/Material wage/price unit time/quantity

annual 

probability cost

Medium-Small WPS farm 1

Central Poster 6.25 1 0.265 1.66

Add Contact Information 33.44 0.05 0.265 0.44

Post Display 33.44 0.033 0.795 0.89

Expected per-farm Cost (costr,i,a

B

) 2.99

Small-Small WPS farm 1

Central Poster 6.25 1 0.176 1.10

Add Contact Information 33.44 0.05 0.176 0.29

Post Display 33.44 0.033 0.527 0.59

Expected per-farm Cost (costr,i,a

B

) 1.98

Large WPS Greenhouse

Central Poster 6.25 1 0.248 1.55

Add Contact Information 33.44 0.05 0.248 0.42

Post Display 33.44 0.033 0.745 0.83

Decontamination Display 6.25 1.5 0.248 2.33

Add Contact Information 33.44 0.08 0.248 0.62

Post Display 33.44 0.033 7.45 8.30

Expected per-farm Cost (costr,i,a

B

) 14.05

Small WPS Greenhouse

Central Poster 6.25 1 0.182 1.14

Add Contact Information 33.44 0.05 0.182 0.30

Post Sign 33.44 0.033 0.545 0.61

Expected per-farm Cost (costr,i,a

B

) 2.05

Large Handler-Only Farm

Central Poster 6.25 1 0.283 1.77

Add Contact Information 33.44 0.05 0.283 0.47

Post Sign 33.44 0.033 0.849 0.95

Expected per-farm Cost (costr,i,a

B

) 3.19

Small Handler-Only Farm

Central Poster 6.25 1 0.269 1.68

Add Contact Information 33.44 0.05 0.269 0.45

Post Sign 33.44 0.033 0.807 0.90

Expected per-farm Cost (costr,i,a

B

) 3.03

1

858 Excluding greenhouses.

859

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

861 when it is purchased.

862  Large and large-small fruit and vegetables and large greenhouses will potentially have work 

863 crews of 11 or more people, especially at harvest.

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

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

866 need 1 to 2 displays.

867 o EPA estimates that there are about 13,500 large-small fruit and vegetable farms, implying 

868 almost 4,500 purchasing signs each year, or 4.4% of 102,024 large-small farms and 

869 nurseries. Farms are assumed to need 1 display.

870 o All large WPS greenhouses will need additional displays if pesticides are used.
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35

871  Large work crews will typically be associated with harvest tasks

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

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

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

875 and nurseries.

876 o EPA assumes that a large-small fruit/vegetable farm will have 4 occasions/year, on 

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

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

879 54,000 display or an average of 0.5 across all large-small farms and nurseries.

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

881 crew of 11 or more, on the 74.5% of greenhouses that report using pesticides.

882

883

884 B.4. Age

885

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

887

888 a. Baseline

889

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

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

892

893 Table B.4.b-1. Baseline Labor Cost, per WPS handler, Minimum Age

Action/Material wage/price unit time/quantity

annual 

probability cost

WPS Farm with workers

14-15 yr old WPS handler 12.03 50 0.004 2.33

16-17 yr old WPS handler 15.03 50 0.018 13.27

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

B

) 15.60

WPS Farm with handlers only

14-15 yr old WPS handler 12.03 50 0.003 2.04

16-17 yr old WPS handler 15.03 50 0.016 11.66

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

B

) 13.70

CPHE

16-17 yr old CPHE handler 17.45 640 0.013 145.15

Expected per-CPHE handler cost (costr,i,a

B

) 145.15

894

895  EPA assumes that 14-15 year old WPS handlers are paid $8.22/hour, 60% of adult handlers, 

896 somewhat higher than the federal minimum wage of $7.25/hour. Loaded wages are calculated to 

897 be $10.28/hour

898  EPA assumes that 16-17 year old WPS handlers are paid $10.28/hour, 75% of adult handlers. 

899 Loaded wages are calculated to be $15.03/hour.

900  EPA assumes that 16-17 year old CPHE handlers are paid $11.93/hour, 75% of adult handlers. 

901 Loaded wages are calculated to be $17.45/hour.

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

903 (DOL, 2005).

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

905 1.87% are between 16 and 18 years old (DOL, 2005). These percentages are weighted by 94.4%
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36

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

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

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

909 40 hr/wk for 16 weeks.

910  EPA assumes that 1.3% of CHPE handlers are under the age of 18. According to the Current 

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

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

913 1,000 were aged 16 to 19, or 1.3 percent of the workforce.

914

915 Table B.4.a-2. Baseline Labor Cost, per WPS worker, Minimum Age, Early Entry

Action/Material wage/price unit time/quantity

annual 

probability cost

14-15 yr old worker 7.32 4 0.006 0.18

16-17 yr old worker 8.79 4 0.008 0.29

Expected per-worker Cost (costr,i,a

B

) 0.47

916

917  EPA assumes that 14-15 year old WPS workers are paid $5.01/hour, 50% of adult worker, 

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

919 days of employment with a given employer. Loaded wage rate is $7.32/hour.

920  EPA assumes that 16-17 year old WPS workers are paid $6.01/hour, 60% of adult workers. 

921 Loaded wage rate is $8.79/hour.

922  EPA assumes that early entry tasks take no more than 4 hours.

923  EPA calculates the likelihood of a youth worker to participate in early entry activities to be 0.006

924 for 14-15 year olds and 0.008 for 16-17 year olds, given that about 27% of farm laborers are 

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

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

927 Assuming a near uniform distribution of ages EPA assumes that 14-15 year old workers 

928 make up 3.4% of the workforce and 16-17 year old workers make up 4.5% of the 

929 workforce.

930 o EPA assumes there is a 40% chance that a WPS farm will have an early entry event each 

931 year, or one event for every 50 applications.

932 o EPA assumes that half the workforce will participate in an early entry event.

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

934 given year (Appendix A).

935

936 b. Final Rule

937

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

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

940

941 Table B.4.b-1. Labor Cost under Final Rule, per handler, Minimum Age (18)

Action/Material wage/price unit time/quantity

annual 

probability

cost

(costr,i,a

P

)

Adult WPS handler, farm with 

workers 20.04 50 0.022 21.57

Adult WPS handler, farm with 

handlers only 20.04 50 0.019 18.95

Adult CPHE handler 23.26 640 0.013 193.54

942
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37

943  Loaded wages for on-farm handlers are $20.04/hour and are $23.26/hour for CPHE handlers 

944 (BLS, 2014b).

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

946 work more efficiently at handling tasks.

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

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

949

950 Table B.4.b-2. Labor Cost under Final Rule, per WPS worker, Minimum Age (18), Early Entry

Action/Material wage/price unit time/quantity

annual 

probability cost

Adult worker 14.64 4 0.014 0.84

951

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

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

954 work more efficiently at handling tasks.

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

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

957

958

959 B.5. Entry

960

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

962

963

964 B.6. Personal Protective Equipment (PPE)

965

966 a. Baseline

967

968 Respirator Fit Test

969

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

971 him/herself or employees: On-site testing or Off-site testing. In the former, the operator 

972 purchases an OSHA-approved fit testing kit and administers the test and training on the farm or 

973 within the firm. In the latter, the handler travels to a central location to obtain an OSHA974 approved test; this appears to be a common method for those required under fumigant labels to 

975 obtain a fit test. EPA assumes that more on-farm handlers will opt for off-site testing and that 

976 most CPHEs will opt for on-site testing. 

977
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

38

978 Table B.6.a-1. Cost, per WPS farm handler, Off-farm Respirator Fit

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Medical evaluation, on-line 27.00 1 1.0 27.00

Medical evaluation, time 20.04 0.5 1.0 10.02

Follow-up examination 72.12 1 0.25 18.03

Follow-up examination, time 20.04 2.0 0.25 10.02

Fit test and training, fee 50.00 1 1.0 50.00

Fit test and training, time 20.04 1.5 1.0 30.06

Employer oversight 33.44 1 1.0 33.44

Expected per-handler Cost (costr,i,a

B

) 178.57

979

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

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

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

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

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

985  EPA assumes that a follow-up examination is needed in 25% of the cases.

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

987 information from state lead agencies.

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

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

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

991

992 Table B.6.a-2. Cost, per CPHE handler, On-site Respirator Fit

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Medical evaluation, on-line 27.00 1 1.0 27.00

Medical evaluation, time 23.26 0.5 1.0 11.63

Follow-up examination 72.12 1 0.25 18.03

Follow-up examination, time 23.26 2.0 0.25 11.63

Fit test compliance kit 130.93 1 0.25 32.73

Fit test and training, time 23.26 0.5 1.0 11.63

Employer administration 32.65 0.5 1.0 16.33

Expected per-handler Cost (costr,i,a

B

) 128.98

993

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

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

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

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

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

999  EPA assumes that a follow-up examination is needed in 25% of the cases.

1000  Fit test compliance kits cost $130.93, including shipping (Allegro Safety, 2014). They contain 

1001 sufficient solution to test 4 handlers.

1002  The fit test and training takes about 30 minutes and is administered by the employer, whose time 

1003 is valued at $32.65/hour (BLS, 2014b).

1004
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

39

1005 Agricultural Establishments, Respirator Fit

1006

1007 Table B.6.a-3. Baseline Cost, per WPS Farm, Respirator Fit

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

WPS Farm with Handler

Employer assures proper fit 33.44 0.1 0.390 1.31

Handler assures proper fit 20.04 0.1 0.390 0.78

Respirator fit test, off-farm 178.57 1 0.004 0.80

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

B

) 2.88

1008

1009  The employer’s time is valued at $33.44/hour, including wages and benefits and handler wages 

1010 are $20.04/hour, including benefits (BLS, 2014b).

1011  EPA assumes that agricultural employers and handlers spend about 6 minutes checking the fit of 

1012 a respirator together, assuming one handler per farm is trained to work with a respirator.

1013  EPA calculates that 39.0% of WPS farms will have one handler fit tested.

1014 o Assumes that WPS farms using a pesticide that requires a respirator are concentrated in 

1015 crop-production, not livestock operations, accounting for 71.4% of farms.

1016 o Assumes that 60% of farms would use such a product.

1017 o Assumes fit adjustment occurs when product is used (91.2% of farms with handlers use 

1018 pesticides in any given year).

1019  A respirator fit test, taken at a central location, is estimated to cost $178.57, as detailed in Table 

1020 B.6.a-1.

1021  EPA estimates that 0.4% of WPS farms currently obtain an OSHA-type respirator fit test for a 

1022 handler because they handle fumigants. EPA’s estimate is based on proprietary market survey 

1023 data on the projected number of farms reporting fumigant applications, averaged over 2011 to 

1024 2013, multiplied by the proportion of farms that use pesticides that also hire labor.

1025 o Data are reported for farmer-applied fumigants in field crops.

1026 o Data are reported on type of fumigant applied for tree, fruit, and vegetable crops.

1027  EPA assumes all chemigations are farmer-applied.

1028  EPA assumes that all applications of 1,3-D (including chloropicrin mixes), 

1029 metam sodium, and metam potassium are farmer applied while all applications of 

1030 chloropicrin and chloropicrin mixed with methyl bromide and methyl iodide are 

1031 applied by commercial applicators.

1032

1033 Agricultural Establishments, Respirator Fit, California and Northwest

1034

1035 Table B.6.b-4. Cost under Final Rule, per farm, Respirator Fit, California and Northwest

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Respirator fit test, off-farm 178.57 1 0.535 95.57

Large-small WPS farm

Respirator fit test, off-farm 178.57 1 0.135 24.05

1036

1037  California and Washington, the representative state for the Northwest region, currently require 

1038 OSHA-style respirator fit testing for products requiring a respirator.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

40

1039  A respirator fit test, taken at a central location, is estimated to cost $178.57, as detailed in Table 

1040 B.6.a-1.

1041  EPA estimates that 53.5% of large WPS farms will have a handler obtain a fit test, assuming 75% 

1042 of large WPS farms that primarily produce crops or 40,190 large WPS farms out of 79,434 (Table 

1043 3.2-3, Economic Analysis). This proportion is based on national-level data and is not adjusted for 

1044 the numbers of farms in each NAICS within California and the Northwest.

1045  EPA estimates that 13.5% of large-small WPS farms will have a handler obtain a fit test, 

1046 assuming 75% of large-small WPS farms that primarily produce nuts, fruits, and vegetable crops, 

1047 and cotton, as well as nurseries and greenhouses, or 17,673 large-small WPS farms out of 

1048 141,753 (Table 3.2-3, Economic Analysis). This proportion is based on national-level data and is 

1049 not adjusted for the numbers of farms in each NAICS within California and the Northwest.

1050

1051

1052 CPHEs, Respirator Fit

1053

1054 Table B.6.a-5. Baseline Cost, per CPHE, Respirator Fit

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Fit test compliance kit 130.93 1 0.5 65.47

Replacement solution 21.69 1 1 21.69

Employer administration 32.65 3.5 1.0 114.29

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

B

) 201.44

1055

1056  Most CPHEs will conduct respirator fit test under OSHA requirements.

1057  A fit test compliance kit costs $130.93, including shipping, and additional or replacement solution 

1058 costs $21.69 (Allegro Safety, 2014). 

1059  EPA assumes that the kit will last two years, thus half the CPHEs are likely to purchase a kit each 

1060 year.

1061  EPA assumes the CPHE employer will spend about 3.5 hours per year administering the test and 

1062 training, assuming about half the firms handlers work with products requiring a respirator.

1063

1064 CPHE Handlers, Respirator Fit

1065

1066 Table B.6.a-6. Baseline Cost, per CPHE handler, Respirator Fit

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Medical evaluation, on-line 27.00 1 0.5 13.50

Medical evaluation, time 23.26 0.5 0.5 5.82

Follow-up examination 72.12 1 0.13 9.02

Follow-up examination, time 23.26 2.0 0.13 5.82

Fit test and training, time 23.26 0.5 0.5 5.82

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

B

) 39.97

1067

1068  Handler wages are $23.26/hour, including benefits (BLS, 2014b).

1069  On-line medical evaluations are available for $27.00 (Affordable Safety Training, 2015).

1070  EPA assumes the handler will spend about 30 minutes filling out the medical evaluation.

1071  A follow-up examination may be needed to ensure that a respirator can be worn safely. A 

1072 medical examination costs $72.12 (citation) and takes about two hours, including travel.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

41

1073  EPA assumes that a half of CPHE handlers will receive fit tests and training to work with 

1074 pesticides requiring a respirator. Follow-up examination is needed in 25% of these cases or 

1075 12.5% of CPHE handlers.

1076  The fit test and training takes about 30 minutes and is administered by the employer, whose time 

1077 captured under establishment costs.

1078

1079

1080 Agricultural Establishments, Closed Systems

1081

1082 Table B.6.a-7. Baseline Cost, per farm, Closed System

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Fully closed system 49.72 1 0.133 6.59

Partially closed system 22.32 1 0.199 4.44

PPE upkeep 6.93 1 0.331 2.29

Employer provides instruction 33.44 0.25 0.331 2.77

Employee receives instruction 20.04 0.25 0.331 1.66

Expected per-farm Cost (costr,i,a

B

) 17.75

Large-small WPS farm

Fully closed system 49.72 1 0.029 1.43

Partially closed system 22.32 1 0.043 0.96

PPE upkeep 6.93 1 0.072 0.50

Employer provides instruction 33.44 0.25 0.072 0.60

Employee receives instruction 20.04 0.25 0.072 0.36

Expected per-farm Cost (costr,i,a

B

) 3.85

Large family farm

Fully closed system 49.72 1 0.075 3.75

Partially closed system 22.32 1 0.113 2.52

PPE upkeep 6.93 1 0.188 1.30

Operator provides instruction 33.44 0.25 0.188 1.58

2

nd Operator receives instruction 33.44 0.25 0.188 1.58

Expected per-farm Cost (costr,i,a

B

) 10.72

1083

1084  A fully closed system costs $49.72/year, based on the depreciation over 10 years at 8% interest, 

1085 of equipment costs of $333.62 (Giles and Billing, 2013).

1086  A partially closed system, i.e., lacking an adaptor for the pesticide container, costs $22.32/year, 

1087 based on the depreciation over 10 years at 8% interest, of equipment costs of $149.75 (Giles and 

1088 Billing, 2013).

1089  PPE upkeep costs $6.93/year, based on depreciation over 5 years, of costs of $27.65 for coveralls, 

1090 overshoes, and gloves (Gempler’s, 2014).

1091  The time of farm employers and operators is valued at $33.44/hour and handlers at $20.04/hour, 

1092 including wages and benefits (BLS, 2014b).

1093  EPA assumes that instruction in operations take about 15 minutes and includes the employer and 

one handler or, in the case of family farms, the operator and the 2nd 1094 operator.

1095  EPA assumes that 33.1% of large WPS farms (half the large WPS farms producing oilseeds and 

1096 grains, cotton and tobacco, fruits, nuts, and vegetables, as well as nurseries and greenhouses), 

1097 have a system; 40% of the systems, on 13.3% of farms, are fully closed and 60%, on 19.9% of 

1098 farms, are partially closed.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

42

1099  EPA assumes that 7.2% of large-small WPS farms (40% the large-small WPS farms producing 

1100 cotton and tobacco, fruits, nuts, and vegetables, as well as nurseries and greenhouses), have a 

1101 system; 40% of the systems, on 2.9% of farms, are fully closed and 60%, on 4.3% of farms, are 

1102 partially closed.

1103  EPA assumes that 18.8% of large family farms (one-third of the large family farms producing 

1104 oilseeds and grains, cotton and tobacco, fruits, nuts, and vegetables, as well as nurseries and 

1105 greenhouses), have a system; 40% of the systems, on 7.5% of farms, are fully closed and 60%, on 

1106 11.3% of farms, are partially closed.

1107

1108 CPHEs, Closed Systems

1109

1110 Table B.6.a-8. Baseline Cost, per firm, Closed System

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

CPHE

Fully closed system 49.72 2 0.70 69.61

Partially closed system 22.32 2 0.30 13.39

PPE upkeep 6.93 2 1.0 13.85

Employer provides instruction 32.65 0.25 1.0 8.16

Employee receives instruction 23.26 0.25 4.0 23.26

Expected per-firm Cost (costr,i,a

B

) 128.27

CPHE, 1-2 person

Fully closed system 49.72 1 0.70 34.80

Partially closed system 22.32 1 0.30 6.70

PPE upkeep 6.93 1 1.0 6.93

Expected per-firm Cost (costr,i,a

B

) 48.42

1111

1112  A fully closed system costs $49.72/year, based on the depreciation over 10 years at 8% interest, 

1113 of equipment costs of $333.62 (Giles and Billing, 2013).

1114  A partially closed system, i.e., lacking an adaptor for the pesticide container, costs $22.32/year, 

1115 based on the depreciation over 10 years at 8% interest, of equipment costs of $149.75 (Giles and 

1116 Billing, 2013).

1117  PPE upkeep costs $6.93/year, based on depreciation over 5 years, of costs of $27.65 for coveralls, 

1118 overshoes, and gloves (Gempler’s, 2014).

1119  The time of CPHE employers and operators is valued at $32.65/hour and handlers at $23.26/hour, 

1120 including wages and benefits (BLS, 2014b).

1121  EPA assumes that instruction in operations take about 15 minutes and includes the employer and 

1122 four handlers. No instruction is needed for 1-2 person operations.

1123  EPA assumes that CPHEs have two systems; 70% of the systems are fully closed and 30% are 

1124 partially closed.

1125  EPA assumes that all 1-2 person CPHEs have a system; 70% of the systems are fully closed and 

1126 30% are partially closed.

1127
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

43

1128 California, Closed Systems

1129

1130 Table B.6.a-7. Baseline Cost, per farm, Closed System, California

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Fully closed system 49.72 1 0.331 16.47

PPE upkeep 6.93 1 0.331 2.29

Employer provides instruction 33.44 0.25 0.331 2.77

Employee receives instruction 20.04 0.25 0.331 1.66

Expected per-farm Cost (costr,i,a

B

) 23.19

Large-small WPS farm

Fully closed system 49.72 1 0.072 3.57

PPE upkeep 6.93 1 0.072 0.50

Employer provides instruction 33.44 0.25 0.072 0.60

Employee receives instruction 20.04 0.25 0.072 0.36

Expected per-farm Cost (costr,i,a

B

) 5.03

Large family farm

Fully closed system 49.72 1 0.188 9.37

PPE upkeep 6.93 1 0.188 1.30

Operator provides instruction 33.44 0.25 0.188 1.58

2

nd Operator receives instruction 33.44 0.25 0.188 1.58

Expected per-farm Cost (costr,i,a

B

) 13.19

CPHE

Fully closed system 49.72 2 1.0 99.44

PPE upkeep 6.93 2 1.0 13.85

Employer provides instruction 32.65 0.25 1.0 8.16

Employee receives instruction 23.26 0.25 4.0 23.26

Expected per-firm Cost (costr,i,a

B

) 144.71

CPHE, 1-2 person

Fully closed system 49.72 1 1.0 49.72

PPE upkeep 6.93 1 1.0 6.93

Expected per-firm Cost (costr,i,a

B

) 56.64

1131

1132  California requires closed systems to meet certain performance standards. Other parameters are 

1133 as provided above.

1134
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

44

1135 b. Final Rule

1136

1137 Agricultural Establishments, Respirator Fit

1138

1139 Table B.6.b-1. Cost under Final Rule, per farm, Respirator Fit

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Respirator fit test, off-farm 178.57 1 0.535 95.57

Collect/Store documentation 33.44 0.067 0.535 1.19

Expected per-farm Cost (costr,i,a

B

) 96.76

Large-small WPS farm

Respirator fit test, off-farm 178.57 1 0.135 24.05

Collect/Store documentation 33.44 0.067 0.135 0.30

Expected per-farm Cost (costr,i,a

B

) 24.35

Large family farm

Medical evaluation, on-line 27.00 1 0.226 6.10

Medical evaluation, time 33.44 0.5 0.226 3.78

Follow-up examination 72.12 1 0.057 4.08

Follow-up examination, time 33.44 2.0 0.057 3.78

Fit test and training, fee 50.00 1 0.226 11.30

Fit test and training, time 33.44 1.5 0.226 11.34

Collect/Store documentation 33.44 0.067 0.226 0.50

Expected per-farm Cost (costr,i,a

B

) 40.89

Large-small family farm

Medical evaluation, on-line 27.00 1 0.023 0.62

Medical evaluation, time 33.44 0.5 0.023 0.39

Follow-up examination 72.12 1 0.006 0.42

Follow-up examination, time 33.44 2.0 0.006 0.39

Fit test and training, fee 50.00 1 0.023 1.16

Fit test and training, time 33.44 1.5 0.023 1.16

Collect/Store documentation 33.44 0.067 0.023 0.50

Expected per-farm Cost (costr,i,a

B

) 4.18

1140

1141  The employer’s or operator’s time is valued at $33.44/hour, including wages and benefits and 

1142 handler wages are $20.04/hour, including benefits (BLS, 2014b).

1143  A respirator fit test, taken at a central location, is estimated to cost $178.57, as detailed in Table 

1144 B.6.a-1.

1145  Activities and time for respirator fit are the same for a family farm except for the oversight.

1146  Collecting and storing the documentation of the fit test is assumed to take 4 minutes.

1147  EPA estimates that 53.5% of large WPS farms will have a handler obtain a fit test, assuming 75% 

1148 of large WPS farms that primarily produce crops or 40,190 large WPS farms out of 79,434 

1149 (Appendix A).

1150  EPA estimates that 13.5% of large-small WPS farms will have a handler obtain a fit test, 

1151 assuming 75% of large-small WPS farms that primarily produce nuts, fruits, and vegetable crops, 

1152 and cotton, as well as nurseries and greenhouses, or 17,673 large-small WPS farms out of 

1153 141,753 (Appendix A).
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

45

1154  EPA estimates that 22.6% of large family farms will have an operator obtain a fit test, assuming

1155 40% of large family farms that primarily produce oilseeds and grains, nuts, fruits, and vegetable 

1156 crops, and cotton, as well as nurseries and greenhouses or 4,284 large family farms out of 18,949 

1157 (Appendix A).

1158  EPA estimates that 2.3% of large-small family farms will have an operator obtain a fit test, 

1159 assuming 40% of large-small family farms that primarily produce nuts, fruits, and vegetable 

1160 crops, and cotton, as well as nurseries and greenhouses or 6,704 large-small family farms out of

1161 115,950 (Appendix A).

1162

1163 CPHEs, Respirator Fit

1164

1165 Table B.6.b-2. Cost under Final Rule, per CPHE, Respirator Fit

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Fit test compliance kit 130.93 1 0.5 65.47

Replacement solution 21.69 1 1 21.69

Employer administration 32.65 3.5 1.0 114.29

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

B

) 201.44

1166

1167  The per-CPHE costs are unchanged from the baseline. The recordkeeping requirement is 

1168 calculated per-handler.

1169

1170 CPHE Handlers, Respirator Fit

1171

1172 Table B.6.b-3. Cost under Final Rule, per CPHE handler, Respirator Fit

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Medical evaluation, on-line 27.00 1 0.5 13.50

Medical evaluation, time 23.26 0.5 0.5 5.82

Follow-up examination 72.12 1 0.13 9.02

Follow-up examination, time 23.26 2.0 0.13 5.82

Fit test and training, time 23.26 0.5 0.5 5.82

Collect/Store documentation 32.65 0.067 0.5 1.09

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

B

) 41.06

1173

1174  Per-handler costs are largely unchanged from the baseline.

1175  The time of CPHE employers is valued at $32.65/hour, including wages and benefits (BLS, 

1176 2014b).

1177  Collecting and storing the documentation of the fit test is assumed to take 4 minutes per handler.

1178

1179
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

46

1180 Agricultural Establishments, Closed Systems

1181

1182 Table B.6.a-7. Cost under Final Rule, per farm or firm, Closed System

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Fully closed system 49.72 1 0.331 16.47

PPE upkeep 6.93 1 0.331 2.29

Write operating instructions 33.44 2 0.066 4.43

Operating instructions 0.02 1 0.166 0.00

Employer provides instruction 33.44 0.25 0.331 2.77

Employee receives instruction 20.04 0.25 0.331 1.66

Expected per-farm Cost (costr,i,a

B

) 27.63

Large-small WPS farm

Fully closed system 49.72 1 0.072 3.57

PPE upkeep 6.93 1 0.072 0.50

Write operating instructions 33.44 2 0.014 0.96

Operating instructions 0.02 1 0.036 0.00

Employer provides instruction 33.44 0.25 0.072 0.60

Employee receives instruction 20.04 0.25 0.072 0.36

Expected per-farm Cost (costr,i,a

B

) 5.99

Large family farm

Fully closed system 49.72 1 0.188 9.37

PPE upkeep 6.93 1 0.188 1.30

Write operating instructions 33.44 2 0.038 2.52

Operating instructions 0.02 1 0.094 0.00

Operator provides instruction 33.44 0.25 0.188 1.58

2

nd Operator receives instruction 33.44 0.25 0.188 1.58

Expected per-farm Cost (costr,i,a

B

) 16.34

CPHE

Fully closed system 49.72 2 1.0 99.44

PPE upkeep 6.93 2 1.0 13.85

Write operating instructions 32.65 2 0.2 13.06

Operating instructions 0.02 2 0.5 0.02

Employer provides instruction 32.65 0.25 1.0 8.16

Employee receives instruction 23.26 0.25 4.0 23.26

Expected per-firm Cost (costr,i,a

B

) 157.80

CPHE, 1-2 person

Fully closed system 49.72 1 1.0 49.72

PPE upkeep 6.93 1 1.0 6.93

Write operating instructions 32.65 2 0.2 13.06

Operating instructions 0.02 1 0.5 0.01

Expected per-firm Cost (costr,i,a

B

) 69.72

1183

1184
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

47

1185 B.7. Decontamination Supplies

1186

1187 a. Baseline

1188

1189 Decontamination Water, Workers

1190

1191 Employers are required to provide “sufficient” water for workers entering a field during the REI. 

1192 Guidance indicates that 1 gal is considered sufficient.

1193

1194 Table B.7.a-1. Baseline Cost, per worker, Water for decontamination at early entry events

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Provide sufficient water (1 gal) 0.004 1 0.183 0.001

Expected per-worker Cost (costr,i,a

B

) 0.00

1195

1196  EPA estimates 1 gal of water costs $0.004/gal, based on the average cost of irrigation water in 

1197 Kentucky (the state with the highest cost) of $1,258/acre-foot (NASS, 2014).

1198  EPA estimates that there is an annual probability of 18.3% that a worker will be involved in an 

1199 early entry event (see B.3.a)

1200 o An early event occurs about 1 in 50 applications, implying there is a 40% probability a 

1201 WPS farm applying pesticides will have an early entry event

1202 o EPA assumes that, on average, 50% of the establishment’s workers will be involved in an 

1203 early entry event, implying 20% of the workers on WPS farm applying pesticides.

1204 o Overall, EPA estimates that 91.3% of workers are employed on WPS farms that apply 

1205 pesticides in any given year (Appendix A), resulting in a 18.3% chance a WPS worker 

1206 being involved in an early entry event.

1207

1208 Eyeflush, WPS Handlers

1209

1210 Table B.7.a-2. Baseline Cost, per WPS farm, Eyewash

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Eyewash bottle 3.65 1 0.211 0.77

Water 0.004 0.125 3.10 0.00

Expected per-farm Cost (costr,i,a

B

) 0.77

Large-Small WPS farm

Eyewash bottle 3.65 1 0.159 0.58

Water 0.004 0.125 1.15 0.00

Expected per-farm Cost (costr,i,a

B

) 0.58

1211

1212  A pint bottle, with squirt top, costs $3.65 at Gempler’s supply (2014).

1213  Water costs $0.004 per gallon, based on the average cost of irrigation water in Kentucky (the state 

1214 with the highest cost) of $1,258/acre-foot (NASS, 2014).

1215  One bottle is needed per farm, given relatively low frequency that products requiring eye 

1216 protection are used.

1217  EPA calculates that 21.1% of large WPS farms will purchase a bottle annually.
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

48

1218 o EPA estimates that 84.4% of large WPS farms will use a product requiring eye protection 

1219 at some point, based on the proportion of large WPS farms primarily producing oilseeds 

1220 and grains, fruits and vegetables, cotton and tobacco, and cattle, sheep, goats, and hogs, 

1221 as well as nurseries and greenhouses, i.e., 67,077 out of 79,434 (Appendix A).

1222 o EPA assumes that a bottle lasts about 4 years, implying one-fourth of farms replace a 

1223 bottle each year.

1224  EPA calculates that 15.9% of large-small farms will purchase a bottle annually.

1225 o EPA estimates that 63.4% of large-small WPS farms will use a product requiring eye 

1226 protection at some point, based on the proportion of large WPS farms primarily 

1227 producing oilseeds and grains, fruits and vegetables, and cotton and tobacco, as well as 

1228 nurseries and greenhouses, i.e., 89,881 out of 141,753 (Appendix A).

1229 o EPA assumes that a bottle lasts about 4 years, implying one-fourth of farms replace a 

1230 bottle each year.

1231  EPA calculates that a pint of water (0.125 gal) is needed, on average, on 3.10 occasions/year per 

1232 large WPS farm and 1.15 occasions/year per large-small WPS farm.

1233 o Large farms have 4 occasions and 91.8% of large farms use pesticides in a given year 

1234 (Appendix A).

1235 o Large-small farms have 2 occasions and 90.5% of large-small farms use pesticides in a 

1236 given year (Appendix A).

1237

1238 Eyeflush, CPHE Handlers

1239

1240 Table B.7.a-3. Baseline Cost, per CPHE handler, Eyewash

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Eyewash bottle 3.65 1 0.250 0.91

Water 0.004 0.125 36 0.02

Expected per-handler Cost (costr,i,a

B

) 0.93

1241

1242  A pint bottle, with squirt top, costs $3.65 at Gempler’s supply (2014).

1243  Water costs $0.004 per gallon, based on the average cost of irrigation water in Kentucky (the state 

1244 with the highest cost) of $1,258/acre-foot (NASS, 2014).

1245  One bottle is needed per handler and a bottle lasts about 4 years.

1246  EPA calculates that a pint of water (0.125 gal) is needed, on average, on 36 occasions/year per

1247 handler, assuming that 40% of applications made by a CPHE handler are of products requiring 

1248 protective eyewear and a CPHE handler makes 90 applications/year, on average.

1249

1250 b. Final Rule

1251

1252 Decontamination Water, Workers

1253

1254 Employers are required to provide 3 gallons of water for workers entering a field during the REI.

1255
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

49

1256 Table B.7.b-1. Cost under Final Rule, per worker, Water for decontamination at early entry 

1257 events

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Provide sufficient water (1 gal) 0.004 3 0.183 0.002

Expected per-worker Cost (costr,i,a

B

) 0.00

1258

1259  Employers must provide 3 gallons of water per worker at each early entry event.

1260  Prices and annual probability are as in baseline (see Table B.7.a-1).

1261

1262

1263 Eyeflush, WPS Handlers

1264

1265 Table B.7.b-2. Baseline Cost, per WPS farm, Eyewash

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Large WPS farm

Water container/dispenser 20.65 1 0.106 2.18

Eyewash bottle 3.65 1 0.211 0.77

Water 0.004 6 3.10 0.07

Expected per-farm Cost (costr,i,a

B

) 3.02

Large-Small WPS farm

Water container/dispenser 20.65 1 0.063 1.31

Eyewash bottle 3.65 1 0.159 0.58

Water 0.004 6 1.15 0.03

Expected per-farm Cost (costr,i,a

B

) 1.91

1266

1267  A 5-gallon container, with a valve for controlling the flow of water, costs $20.65 at Gempler’s 

1268 supply (2014).

1269  A large farm is assumed to purchase a container every eight years; given the proportion of farms 

1270 using products requiring protective eyewear, 84.4% (see Table B.7.a-2), 10.6% of large farms are 

1271 expected to purchase a container each year.

1272  A large-small farm is assumed to purchase a container every ten years; given the proportion of 

1273 farms using products requiring protective eyewear, 63.4% (see Table B.7.a-2), 6.3% of large1274 small farms are expected to purchase a container each year.

1275  Farms will need to provide 6 gallons of water for eyeflush.

1276  All other parameters are as in the baseline (see Table B.7.a-2).

1277

1278
*** EO 12866 Review Draft – Deliberative – Do Not Cite, Quote or Release During Review ***

50

1279 Eyeflush, CPHE Handlers

1280

1281 Table B.7.b-3. Baseline Cost, per CPHE handler, Eyewash

Action/Material wage/price

unit 

time/quantity

annual 

probability cost

Water container/dispenser 20.65 1 0.1 2.07

Eyewash bottle 3.65 1 0.250 0.91

Water 0.004 6 36 0.83

Expected per-handler Cost (costr,i,a

B

) 0.93

1282

1283  A 5-gallon container, with a valve for controlling the flow of water, costs $20.65 at Gempler’s 

1284 supply (2014).

1285  EPA calculates that one container is purchased annually for every 10 handlers.

1286 o EPA assumes one container can be shared between two handlers.

1287 o EPA assumes that a container lasts five years.

1288  The handler will need to be provided 6 gallons of water for each application requiring protective 

1289 eyewear.

1290  All other parameters are as in the baseline (Table B.7.a-3).

1291

1292