Q: Does the Worker Protection Standard (WPS) regulation apply to sports field managers and their facilities?
[Authors Note: The WPS is a federal regulation (law) that requires employers to provide specific pesticide training for agriculture workers and pesticide handlers, as well as access to specific safety information and equipment. The Environmental Protection Agency (EPA) and state agencies enforce the WPS.]A: When this question came up in a recent meeting, I was reluctant to answer before referring to EPA’s Pesticide Worker Safety website. A quick reference check found that the standard excludes most turfgrass management operations except those establishments that produce turfgrass for commercial sale, transplanting to another area of the same facility, or research purposes.
Although most turfgrass operations are exempt from WPS, OSHA and state regulations still apply to facilities that use equipment or pesticides. Many of the rules, requirements and laws by the various federal and state pesticide regulatory groups are cross-referenced across agencies. So, for practical purposes, the content in the WPS still generally applies to turfgrass managers and their facilities, although not specifically as part of the WPS.
Best management practices at all sports field facilities should follow precautions to protect employees from pesticide exposure. While not an exhaustive list, under WPS, all employers are required to do the following:
- Provide annual pesticide safety training.
- Provide Safety Data Sheets for all pesticides applied on the site.
- Provide access to labeling information for all pesticides applied on the site.
- Provide decontamination supplies.
- Provide Personal Protection Equipment (PPE) in clean and good operating condition.
- Ensure PPE is worn.
- Dispose of contaminated PPE.
- Conduct fit tests and respirator training when required.
- Display certain pesticide safety and hazard information in a centralized location.
- Keep pesticide records for at least two years.
Every state has pesticide-related laws and regulations that they expect facilities and applicators to follow. In North Carolina, the NC Department of Agriculture & Consumer Services is tasked with protecting public health, safety and welfare, and to promote continued environmental quality by minimizing and managing risks associated with the legal use of pesticides. I often get asked if a license is required to spray glyphosate weed killer on school grounds (i.e., public property). In North Carolina, and perhaps also in your state, a pesticide license is required for anyone who applies pesticide in their course of work. It is important to know your state’s pesticide laws. If in doubt, check with your state department of agriculture for clarification on specific rules that apply to your situation. They may also offer training opportunities that you or your employees could attend.
The WPS provides rules that make sense and allow monitoring for compliance. The requirements seem reasonable. It is important to spend time reviewing the labels for all the chemicals that are purchased to make sure you have the required PPE on hand for your employees. Keep supplies on hand to deal with pesticide spills and leaks. Lastly, make sure all your pesticide safety equipment is available and in good working condition. Nothing is worse than an employee needing to use a portable eye wash and the eye-flush bottle is empty. Do everything you can to protect your team and your fields.
Grady Miller, Ph.D.
Professor and Extension Turf Specialist
North Carolina State University
Questions?
Send them to Grady Miller at North Carolina State University, Box 7620, Raleigh, NC 27695-7620, or e-mail grady_miller@ncsu.edu