Illinois Pesticide Review
March / April 2018
In This Issue
- Securing Pesticides for Transportation
- WPS Pesticide Safety Training Requirements: Illinois
- Aerial Applications: Fixed-wing or Helicopter
- Pesticide Misuse Cases for 2017
- End-of-the-Season Licensing Opportunities
- EPA Announces Draft Pesticide Label Revisions on Respirators to Ensure Consistency between EPA and NIOSH
Securing Pesticides for Transportation
We are approaching the time of the year when we will start to see more farmers and commercial applicators on the roadways getting fields ready for planting with spray rigs, anhydrous tanks, fertilizer wagons, and such. It is no doubt one of my most favorite seasons as we have left the dull, grey, brown, gloomy months of winter for trees leafing out, grass greening up, flowers blooming, and all these barren fields once again filled with new crops!
As a driver I am reminded of the caution I must use by slowing down and giving applicators the space they need on the road. However, those hauling also need to be mindful of the hazards of moving pesticides. As with the application of pesticides, it is also the end user's responsibility to make sure that the pesticide load is properly and safely secured, even if that end user did not load the pesticides themselves.
There are state and federal protocols in place that allow for the transportation of these materials to be done so that there is minimal risk to all. I have created a list of things that applicators/operators should consider when hauling pesticides.
Top 10 Things to Do When Hauling Pesticides
1. Make sure all vehicles and trailers are in good working order. This includes clean and clear lights, windows, and mirrors. Hitches, chains, straps, and pins should be in working order.
2. Never put pesticides inside a cab or vehicle. Make sure they are transported in the bed of a truck, trailer or trunk, but never in a passenger area. Chemicals spilled or fumes inhaled can lead to illness or death.
3. Keep pesticides in original containers. These containers already meet the US DOT regulations and therefore will keep you within compliance when hauling them to your field. Make sure that containers are not leaking or torn. If applicable, make sure that dry pesticides are transported above wet products. That way there is not a risk of cross-contamination should there be a leak.
4. A tie-down is required for loads 5 ft or shorter or less than 1,100 lbs. According to the Federal Motor Carrier Safety Administration you must have a minimum of one tie-down for this load size. Larger loads require more tie-downs. Be sure to check the working load limit (WLL) determined by the manufacturer. This is the maximum load in pounds in which new and used tie-downs in good condition should be applied. Tie-down straps should not have tears greater than 3/8 inch if the strap is less than 2 inches. Chains also need to be checked for any change of shape or cuts, as those render the chain ineffective and it needs to be replaced.
5. Drivers transporting pesticides for commercial use or across state lines are required to follow the Illinois Department of Transportation regulations regarding driver's licenses, placarding, shipping papers, inspections, and fees. Please refer to http://www.idot.illinois.gov or the Illinois Farm Bureau publication on motor vehicle rules for farmers http://www.ilfb.org/media/2800883/-otr-booklet-2017-01.pdf
6. Drive carefully and defensively. Do not let more than three cars pile up behind your rig. Pull over and let them pass. Be sure that a "Slow Moving" sign is displayed on the back of the vehicle/trailer/equipment. Travel during the day and not near dusk or dawn.
7. Stay off heavily traveled roads if at all possible or drive when roads are least traveled.
8. Carry copies of product labels and safety data sheets for each product. These provide information about active ingredients; how to use the product, including personal protective equipment; human, environmental and other hazards; first aid; storage and disposal; information for emergency personnel in case of a spill; and emergency numbers.
9. Haul pesticides in moderate temperatures. If hauling in extreme high or low temperatures there is a risk of the chemical formulations being altered and becoming less stable.
10. Pack an emergency spill kit. Include an absorbent spill pad, litter, broom or brush, dustpan or shovel, plastic bag, and personal protective equipment.
Rules and regulations do change and are complex. It is best to call and ask questions when changing how you transport or secure your load. Be sure to check out resources available at IDOT and the Federal Carrier Motor Safety Administration website. It is important that you stay informed.
The following references can help:
Maria Turner (mailto:email@example.com)
WPS Pesticide Safety Training Requirements: Illinois
The Worker Protection Standard (WPS) is a regulation intended to reduce the risks of illness or injury resulting from occupational exposures to pesticides used in the production of agricultural plants.
WPS requires agricultural employers and commercial pesticide handler employers to provide specific information and protections to workers, handlers, and other persons when WPS-labeled pesticide products are used on agricultural establishments in the production of agricultural plants.
In 2015, the USEPA announced a major revision to the WPS. As of January 2, 2018, almost all new requirements within the 2015 Revised Worker Protection Standard are in full enforcement. The only exception is the expansion of worker training topics to 23 items, and handler training expanded to 36 items. The expanded training topics requirement will not become effective until 6 months after a Federal Register Notice announcing the availability of training materials.
Do you need to provide pesticide safety training to your employees?
Not all pesticide operations fall under the WPS. If you are unsure, use The Worker Protection Standard: Does It Apply To You? tool produced by the Pesticide Educational Resources Collaborative (PERC): http://pesticideresources.org/wps/doesitapply.html, or review the How to Comply With the 2015 Revised Worker Protection Standard For Agricultural Pesticides Manual: http://pesticideresources.org/wps/htc/htcmanual.pdf
WPS pesticide safety training frequency and exemptions
If WPS applies to your operation, you must provide training prior to a worker entering a treated area on an agricultural establishment, or prior to a handler conducting any handling task. The revised regulation no longer allows a grace period for this training. The regulation also requires pesticide safety training for all workers and handlers on an annual basis.
Certain employees may be exempt from the annual training requirements. Certified pesticide applicators, certified crop advisors, agricultural workers who never enter treated areas within 30 days of pesticide application or within 30 days of the end of a restricted entry interval (REI), and certain members of the establishment owner's immediate family are not required to complete safety training. Consult the previously referenced "How to Comply" manual for details on each exemption.
WPS training resources for owners and employers in Illinois
Trainers can use any WPS training materials as long as they are EPA-approved. Approved trainings will have an EPA-approval number similar to the following: EPA approval W/H PST 00001. Be sure to select training materials that meet the training requirements for the employee; i.e. worker training, handler training, or training for trainers. In the past, Illinois Pesticide Safety Education Program (PSEP) training clinics qualified for WPS trainings. Unfortunately, we are not able to cover all of the expanded training topics within the short timeframe of our PSEP training clinics. Illinois PSEP currently recommends that trainers utilize training materials published on the Pesticide Educational Resources Collaborative (PERC) website: http://pesticideresources.org.
Who can conduct the safety training?
The person who conducts the training must be a certified applicator or have completed an EPA-approved train-the-trainer program. The Illinois Department of Agriculture also has the authority to designate approved trainers, such as University of Illinois Extension. The trainer must be present at all times during the training to respond to trainees' questions. A translator may be necessary to ensure that the information is presented in a manner that the trainees can understand.
Training records for each worker and handler must be kept on the establishment for 2 years from the date of training. Training records must include the following information:
• The worker's or handler's printed name and signature,
• The date of training,
• Trainer's name,
• Evidence of the trainer's qualification to train,
• Employer's name, and
• Information to identify which EPA-approved training materials were used for the training (i.e., the EPA document number or EPA approval number for the materials)
If requested, the employer must provide a copy of the training record to the employee. These records will also be necessary in the event of a WPS compliance inspection.
Pesticide Educational Resources Collaborative (PERC) http://pesticideresources.org
How to Comply with the 2015 Revised Worker Protection
Standard for Agricultural Pesticides: What Owners and Employers Need to Know.
Travis Cleveland (mailto:firstname.lastname@example.org)
Aerial Applications: Fixed-wing or Helicopter
The benefits of aerial application are well known to many growers. One item that sometimes gets confusing when selecting an aerial applicator, however, is which platform does a better job in terms of application efficacy: helicopter or fixed-wing. The truth is that when properly set up, there is no difference in application efficacy between these two platforms.
A common misconception is that the downwash of air generated by a helicopter results in more canopy penetration and deposition of spray droplets than a fixed-wing aircraft. In actuality, this effect only happens when the helicopter is at a stationary hover or very slow forward airspeed.
The downwash effect on a given ground area is rapidly reduced as forward airspeed increases. At 50-60 MPH, the downwash resembles that of a similar size (power and weight) fixed-wing aircraft. Further, wake vortices generated at the rotor blade tips will impact the spray pattern in the same way wingtip vortices affect fixed-wing spray patterns, and spray systems should be configured to introduce a minimum amount of spray particles into these vortices.
In terms of downwash, then, there is no effective advantage of using a helicopter or fixed-wing aircraft over the other.
A study conducted in part by the University of Illinois Department of Agricultural and Biological Engineering in 2012 had the opportunity to compare fixed-wing and helicopter performance making fungicide applications to corn.
While the primary purpose of the study was to compare different adjuvants for their performance on corn fungicide applications from a fixed-wing aircraft, we were able to add a helicopter treatment to the study. This was done to address the claim that helicopters provide better coverage.
The fixed-wing aircraft was an Air Tractor AT-402; the helicopter was a Bell 206. Both aircraft were set up to apply 2 gallons of spray per acre. The spray solutions used for the comparison were identical: water, fungicide at a rate of 10 fluid ounces per acre, a drift reduction adjuvant at 4 fluid ounces per acre, and a pink dye to measure coverage mixed at 2 quarts per 100 gallons of spray.
The sampling occurred in a production cornfield. The field was divided up into sections for each treatment. Every treatment received four swaths of application. The center section of each treatment was sampled at two locations within the treatment area. The sampling section was 100 feet wide, and samples were collected from every other row across the 100-foot sampling line. The samples consisted of white kromekote cards attached to leaves in the upper, middle, and lower parts of the plant. In addition, a card was attached to a sampling platform at the ear. The pink dye used in the spray solution stained the cards pink where it deposited. The cards were collected, scanned in a flatbed scanner, and analyzed with a software program that measured the percent area covered. The higher the percent coverage, the more spray deposited on the card.
The figure above shows the average percent coverage for the two treatments in the four canopy locations and overall.
The fixed-wing aircraft had slightly more coverage at three out of the four canopy positions and overall. There was, however, no statistical difference in spray coverage between the two aircraft types at any canopy location or overall.
Proper aircraft setup and operation, including things such as nozzle choice, deflection angle, and application height, have a major impact on the coverage obtained during an aerial application of any pesticide. If properly set up and operated, there should not be a difference in coverage and application efficacy between fixed-wing aircraft and helicopters, as demonstrated by this study.Matt Gill (mailto:email@example.com)
Pesticide Misuse Cases for 2017
In 2017, 430 pesticide misuse complaints were filed with the Illinois Department of Agriculture. This was 309 more than in 2016. There were 246 complaints related to dicamba misuse.
Of the 430 complaints, 212 resulted in issuing warning letters. Fourteen of the complaints (7 were applicators without a license) received a monetary penalty between $500-$1,000. A total of 135 cases were closed or withdrawn.
Maria Turner, based on information from an Illinois Department of Agriculture Report.
Maria Turner (mailto:firstname.lastname@example.org)
End-of-the-Season Licensing Opportunities
We are entering the final stretch of the 2017-2018 pesticide operator and applicator training clinic season. If you have new employees or just haven't had time to attend one of the early training clinics, there are still opportunities to register for a training clinic or attend testing sessions.
Six training and testing clinics remain for the season. Registration for the training clinics is available through the University of Illinois Pesticide Safety Education Program (PSEP) website: http://web.extension.illinois.edu/psep/training/commercial/clinics.php.
Upcoming training and testing clinics:
April 3-4 in Matteson
General Standards, Turfgrass, Ornamental, Rights-of-Way, Mosquito
April 10-11 in Collinsville
General Standards, Rights-of-Way, Mosquito
April 23-24 in Alsip
General Standards, Turfgrass, Ornamental, Rights-of-Way, Mosquito
April 25-26 in Skokie
General Standards, Turfgrass, Ornamental, Aquatics
May 2-3 in Des Plaines
General Standards, Turfgrass, Rights-of-Way, Mosquito
May 9-10 in Springfield
General Standards, Mosquito
During each of these two-day clinics, the morning on the first day will be dedicated to General Standards training. Applicator training sessions are offered in the afternoon on the first day and in the morning on the second day of training. our $50 registration fee includes both days of training so please feel free to register for topics in addition to General Standards and join us for applicator training! Testing sessions on both days run from 12:30 PM - 4:00 PM. On the first day of the clinic, only General Standards tests will be available. On the second day, any test can be taken, including all applicator tests and General Standards.
General Standards Training 8:00 AM – 11:30 AM
Testing for General Standards 12:30 PM – 4:00 PM
2:30 PM – 5:00 PM
8:00 AM* – 11:30 AM
Testing for any topic
12:30 PM – 4:00 PM
* 8:00 AM for Turfgrass; 8:30 AM for Rights-of-Way, Mosquito
Online training modules are available for Demonstration & Research, Grain Facility, Vegetable Crop, Plant Management and Private Applicators. Registration for online training is $15 and can be found at http://web.extension.illinois.edu/psep/index.php.
In addition to the combined training and testing clinics, three test-only sessions are available. To register for test-only sessions visit the University of Illinois PSEP website: http://web.extension.illinois.edu/psep/training/commercial/clinics.php. While registration is required for these sessions, there are no registration fees.
April 12 in Carterville
April 17 in Springfield
May 17 in Streamwood
The Illinois Department of Agriculture (IDA) also offers testing by appointment at their Springfield and Dekalb offices. To register by phone, call the Springfield office at (800) 641-3934 or the Dekalb office at (815) 787-5476
What to bring for the test
When it is time to take your test(s), you will be asked to provide a photo ID, your social security number (card not needed) and, if you have been licensed in the past, a retest or renewal letter sent to you by IDA. For everyone who wishes to use a calculator during the test, please bring a basic function, scientific calculator. Smartphones and graphing calculators cannot be used during the test.
After you have completed and passed your test(s), IDA will bill you for your operator or applicator license(s) by mail. Most people receive their license(s) in the mail in 3 – 4 weeks. If you have any questions about training, testing or licensure, please visit the University of Illinois PSEP website: http://web.extension.illinois.edu/psep/index.php.
Good luck on your tests!
Sarah Hughson (mailto:email@example.com)
EPA Announces Draft Pesticide Label Revisions on Respirators to Ensure Consistency between EPA and NIOSH
EPA is requesting public comment on revised respirator descriptions for pesticide labels.
EPA is making these revisions, with the encouragement of state regulatory agencies, as part of our efforts to:
• Bring the respirator descriptions on pesticide labels into conformance with the current National Institute for Occupational Safety and Health (NIOSH) respirator language (https://www.cdc.gov/niosh/index.htm);
• Ensure that pesticide handlers and their employers have the information they need to identify and buy the respirator required to provide needed protection;
• Delete outdated statements referring to respirators that no longer exist; and
• Clarify and update language to ensure easy compliance with the guidance.
After considering comments, EPA will update Chapter 10, "Worker Protection Labeling," of the Label Review Manual (LRM). After releasing the revised chapter, EPA will ask registrants submitting labels for other reasons to revise their personal protective equipment (PPE) statements to include the updated descriptions at the same time. Those registrants who wish to revise only the PPE statements to incorporate the new respirator descriptions will be advised to submit a fast-track amendment with the changes. For existing products not otherwise updated, EPA will require the submission of labels with the revised descriptions of respirators during the registration review process.
Please submit comments on the revised respirator section by May 22, 2018, to firstname.lastname@example.org. We are requesting comment from regulators, registrants, pesticide users, safety educators and other stakeholders on the revised respirator descriptions for the LRM.
Read the proposed revisions: Label Review Manual Chapter 10; Revised Respirator Descriptions for Public Comment (https://www.epa.gov/sites/production/files/2018-03/documents/lrm-chapter-10-respirator-language-6-mar-2018_0.pdf)
EPA press release, submitted by Michelle Wiesbrook
Michelle Wiesbrook (mailto:email@example.com)