Early-entry workers, REIs: How do you make sense of it all?
The pesticide label and Worker Protection Standards are the law. Sometimes interpreting them is the greatest challenge.
Over the past 10 plus years, I have had the privilege of visiting greenhouses unannounced and was able to see operations in full swing. Visits have been during “normal” work hours and sometimes on a weekend or evening. In both situations, I came across a common practice that occurs in every greenhouse that I am associated with – application of some sort of pesticide; an insecticide, fungicide or growth regulator.
There are two particular laws that apply when a pesticide is used in a production facility. The first law is that the pesticide label is the law and you are to follow what that document says. The second source is the federal Worker Protection Standard (WPS). Now this is where it gets a bit confusing; you need to understand both the label and the WPS rules to determine entry into a treated area. What actually is the treated area? Can I be an early entry worker? Does there need to be “special air exchange requirements?”
Since I got completely confused as I sorted through these laws, I figured some other owners, applicators, and workers may also need a little clarification. In response, I developed this document for the 2011 growing season: Worker Protection Standards: Who and When Can Someone Enter a Treated and Untreated Area in Your Greenhouse?
Things change, so this document is intended to help clarify the laws associated with the label and WPS on some of the commonly used pesticides in the greenhouses. Always refer to the pesticide label and the EPA’s “How to Comply” documents.
I hope this helps and, however, my quote of the day related to who should be in the greenhouse is, “When in doubt, keep them all out….”