While much on-farm food safety deals with living pathogens (germs), audits can have “automatic failures” for farms using a pesticide in a manner inconsistent with the product label or not following the Worker Protection Standard (WPS) for workers and pesticide handlers. “Workers” are those who are not “immediate family” (only spouse, children, stepchildren, foster children, parents, stepparents, foster parents, brothers, and sisters are immediate family and they are “self responsible” for knowing how to protect themselves from pesticides). A pesticide — natural, organic or conventional — is defined as:
Any material that is applied to plants, the soil, water, harvested crops, structures, clothing, furniture, or animals to kill, attract, repel, or regulate or interrupt the growth and mating of pests, or to regulate plant growth.
Pesticide use (purchase, application, safety, storage/disposal and residues) is enforced nationally by the US Environmental Protection Agency (US EPA) and the US Food and Drug Administration (US FDA) and in Hawaii by the Hawaii Department of Agriculture (HDOA) and Hawaii Department of Health (DOH). These agencies are empowered to operate under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). There are civil (fines) and criminal penalties (fines and prison time) for using pesticides in volition of the FIFRA.
The WPS provides training about exposure to pesticides and it ensures that workers and handlers are protected against possible harm from pesticide exposure. WPS also provides for decontamination sites and emergency assistance. The 2005 WPS Quick Reference is a good summary of what is required by farm owners and employees. More information on WPS can be found here.
The following fact sheets can help you learn more about pesticides and their safe application:
- On-Farm Food Safety: A basic checklist for understanding timing and responsibilities for using pesticides on conventional and organic food farms in Hawaii
- Handler & Applicator Safety (poster – coming soon)
- Emergency On-Site First Aid for Pesticide Exposure (poster – coming soon)
CTAHR coaches will tune-up the pesticide handling safety of your crew, help you comply with WPS, and work with your pesticide manager to get your pesticide inventory, application records, and chemical storage shed in order. For all applications of pesticides you need to alert farm personnel either verbally, by posting a sign, or both. You are also required to have an application log in an easily accessible location that tells employees about the following. By law, this information is to remain posted for 30 days after the end of the Restricted Entry Interval (REI).
- location and description of the area treated
- product name
- EPA registration number
- active ingredient
- time and date of scheduled application
- restricted-entry interval (and re-entry time would be good)
The following educational materials will help you with these requirements.
- Whole Farm Ag. Pesticide and Fertilizer Surveys [PDF]
- On Farm Food Safety: Your Farm’s Pesticide Key
- Worker Protection Standard Training Record
- Ag Chemical Inventory (for Pesticides)
- Crop Protection Application Log
CTAHR has an intensive Pesticide Risk Reduction Program for farmers who are preparing for the Hawaii Department of Agriculture’s’ Pesticide Applicator Certification Exam and those who want to be informed pesticide handlers (see their information site here). CTAHR’s Local Immigrant Farmer Education (LIFE) program has pesticide safety information available to farmers in Cambodian, Chinese, Ilocano, Korean, Lao, Tagalog, Thai and Tongan. LIFE also does some group workshops on WPS for immigrant farmers.
A critical aspect of using pesticides, for conventional or organic agriculture, is taking care not to get contaminated. Here are hot spots you should protect with extra care as REQUIRED by the instructions on the pesticide label.
Keep all pesticides and harmful cleaners in a locked cabinet.
Always keep products in their original containers with the lids on tight. Never use emptied beverage or food containers, which could be mistaken by children and others to still contain a food or beverage.
Avoid overloading shelving or compressing containers at the bottom of a stack. Place dry powder or granular pesticide containers above liquid containers.