As a crop advisor,
you may perform many tasks related to the production of agricultural
plants that will make you fall under the scope of the WPS. These tasks
include such things as assessing pest numbers/damage, pesticide
distribution, and/or evaluating the status, condition, or requirements
of agricultural plants. Often these tasks entail working in
pesticide-treated
areas that are subject to WPS requirements.
It's your responsibility to understand the requirements, follow
instructions to avoid restricted areas, wear the required protective
equipment, and take steps to avoid bringing pesticide residues
home. Children, pregnant women, and the elderly are more sensitive to
pesticide exposures than other adults.
First, are you considered a
"worker" or a
"handler" under the WPS?
The difference is whether you conduct crop-advising tasks in a
pesticide-treated area during
or after a
restricted-entry interval
(REI).
- If you perform crop-advising tasks during the REI, you are
considered a pesticide handler. Your employer must provide protections
required for handlers.
- If you perform crop-advising tasks after the REI, but within 30
days of the REI, you are considered an agricultural worker. Your
employer must provide protections required for agricultural
workers.
- If you perform crop-advising tasks more than 30 days after the end
of the REI, the WPS probably doesn't apply to your work.
- Crop advisors are not permitted to perform crop-advising tasks
during an application.
Second, are you considered a "certified" crop
advisor or a "non-certified crop advisor"? The difference is whether you
have completed other coursework that includes the same training topics
required by the WPS.
- If you are currently a certified/licensed as a pesticide
applicator, authorized to use restricted-use pesticides, you are
considered a "certified crop advisor."
- If you have completed a crop advisor program deemed appropriate in
writing by the EPA, State, or Tribal pesticide enforcement agency, you
are considered a "certified crop advisor." It must include all of the
same training topics required for
WPS handler training
- If neither of the bullets above apply to you, you are considered a
"non-certified crop advisor."
Third, who is your employer? This determines who will provide you
with information about the pesticide applications in your
workplace.
- You might be self-employed as an independent contractor.
- You might be employed by an agricultural establishment
directly. If that's the case, you might only perform crop-advising
tasks on that establishment.
- You might be employed by a company that provides crop-advising
services to more than one agricultural establishment. If that's the
case, that company is considered a "commercial pesticide handler
establishment" (CPHE) under the WPS.
Learn more about the protections required in your role as
a Worker
or Handler
Required Protections for Crop Advisors Performing Activities as Handlers
Unless you are a self-employed crop advisor, your employer must
provide you with the applicable handler protections (see below) if you
perform crop-advising tasks during an REI. These include handler
training, personal protective equipment (PPE), access to
decontamination supplies, emergency assistance, and special
instructions. There may be additional requirements if you are employed
directly by an agricultural establishment.
Pesticide Safety Training
- Certified crop advisors are exempt from WPS training requirements as long as their other licenses/credentials are current.
- Non-certified crop advisors must receive WPS handler training before performing crop advisor tasks during an REI.
Personal Protective Equipment (PPE)
- Certified crop advisors are exempt from label-required PPE for handlers. You qualify to make your own PPE determinations and substitutions as you see fit.
- Non-certified crop advisors must wear some PPE when performing crop-advising tasks during an REI. Your employer is required to provide the label-required PPE for pesticide handlers unless the exception below applies.
If all of the following conditions are met:
- The pesticide application has been complete for 4 hours, and
- You only perform crop advising tasks during the REI, and
- You do not enter treated areas until the inhalation exposure level
on the label is met OR the ventilation criteria on the label are
met. When no ventilation restrictions are listed on the label for
enclosed space production, use this
table to determine
the ventilation requirements.
...then noncertified crop advisors can wear either of the following instead of the label-required PPE for handlers:
- The PPE listed on the label for early-entry workers, or
- Cloth coveralls, shoes plus socks, and waterproof gloves. Additionally, eye protection must be worn if required by the label for handlers of that product.
Decontamination Supplies
- Certified crop advisors can determine their own needs for decontamination supplies, and their employers are not required to provide them.
- Non-certified crop advisors must be provided with the decontamination supplies required for handlers under the WPS.
Emergency Assistance
- Certified crop advisors can determine their own needs for
emergency assistance, and their employers are not required to provide
it.
- Non-certified crop advisors must be provided with the same
emergency assistance required for handlers under the WPS.
Required Protections for Crop Advisors Performing Activities as Workers
If you are a non-certified crop advisor and you conduct crop
advising activities in pesticide treated areas after the REI has
expired but within 30 days of a pesticide application or REI, then you
are considered a worker under the WPS.
Pesticide Safety Training
- Non-certified crop advisors must receive
WPS worker training before
performing crop advisor tasks in a treated area.
Personal Protective Equipment (PPE)
- Certified crop advisors are exempt from label-required PPE for
handlers.
- There are no requirements for workers to wear PPE when working in
treated areas after an REI has ended, unless the label says
otherwise.
Decontamination Supplies
- Certified crop advisors can determine their own needs for
decontamination supplies, and their employers are not required to
provide them.
- Non-certified crop advisors must be provided with the
decontamination supplies required for workers under the WPS.
Emergency Assistance
- Certified crop advisors can determine their own needs for
emergency assistance, and their employers are not required to provide
it.
- Non-certified crop advisors must be provided with the same
emergency assistance required for workers under the WPS. If you think
a pesticide exposure is making you sick, your employer must make sure
you receive emergency medical assistance.
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