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a. Chemical Shed:
The off-label misuse of a chemical is one of the things that can cause an automatic failure on a GAP audit. It can also be a violation of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) of 1947. Therefore, it is important to get your chemical shed cleaned up. Chemical storage cabinet/shed must be:
- Self-contained and used only for chemicals
- Labeled (we’ll give you the sign!)
- Organized: dry chemicals above liquids, and all chemicals arranged by type (insecticide, herbicide, fungicide, etc.)
Do not ever leave containers in the field, whether full, partially full, or empty. Dispose of chemicals and containers as per label instructions. Have Logs set up and keep Standard Operating Procedures (SOPs) handy for workers. It is also important that your workers have Worker Protection Standard training for an audit.
b. Pesticide Use:
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, soil, water, harvested crops, structures, clothing, furniture, or animals to kill, attract, repel, 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 Hawai‘i by the Hawai‘i Department of Agriculture (HDOA) and Hawai‘i Department of Health (DOH). These agencies are empowered to operate under the FIFRA. There are civil (fines) and criminal penalties (fines and prison time) for using pesticides in volition of the FIFRA.
c. Worker Protection Standards:
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 educators 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
Log sheets: (click to view & download the listed logs)
- 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 Hawai‘i 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.
Proper compliance of practices is crucial for the safety and success of your farm. For more information and educational materials, visit Cornell University’s GAPs and Cornell University’s Produce Safety Alliance. Once you’ve familiarized yourself with this topic, you can move on to others!