Effective May 1, 2009 under NC Pesticide
Regulations, Section .1800 WORKER PRO-TECTION
STANDARDS FOR AGRICULTURAL
PESTICIDES, new regulation .1807 requires:
02 NCAC 09L .1807 SPECIFIC INFORMATION
ABOUT APPLICATIONS
( a) Concerning application information require-ments
contained in Sections 170.122 and 170.222
the following is also required to be completed by
the agricultural employer:
( 1) In addition to the requirements of Sections
170.122( c)( 3), and 170.222( c)( 3), the specific
time of day when each pesticide application was
completed must be recorded immediately upon
completion of the application. Each day of the ap-plication
shall be recorded as a separate record.
( 2) After the application information referenced in
1807( a)( 1) and the other information in Sections
170.122( c) and 170.222( c) has been displayed for
the required period of time in Section 170.122( b)
and 170.222( b), the agricultural employer shall
maintain the information for a period of two
years from the specific time of day when each pes-ticide
application was completed. Such informa-tion
shall be available for inspection and copying
by the Board or its agents upon their request.
( b) In addition to information contained in Sec-tion
170.224( b), the handler employer must make
the agricultural owner aware of the specific time
of day when each pesticide application was com-pleted.
The agricultural employer shall display
the information immediately and shall make it
part of the record required to be maintained in
paragraph ( a)( 1) and ( 2) of this part.
The changes will now require growers
making applications that fall under the
scope of the Worker Protection Standard
to add the actual “ end time” of applica-tion
to the records, as shown below in the
example. This is in addition to the “ time
of the application” that is required to be
posted before the application takes place
under the current WPS Regulations. Also
each day of applications shall be recorded
as a separate application record.
The application information must also
now be maintained for a period of two
years, this coincides with the USDA Re-quirements
for Restricted- Use Pesticides.
So to comply with the regulations growers
must keep the information posted at a
central location for 30 days after the re-entry
period expires ( if workers are present
on their establishment) and then maintain
the records for a period of two years to al-low
for inspection by Pesticide Inspectors
with NCDA& CS.
Revised record keeping forms may be
downloaded from the Structural Pest
Control and Pesticides Division’s web page
http:// www. ncagr. gov/ SPCAP/ pesticides/
Cmfo. htm# RecordKeeping or from the N. C.
Cooperative Extension Service.
North Carolina Dept. of Agriculture & Consumer Services • Steve Troxler, Commissioner
Structural Pest Control and Pesticides Division, www. ncagr. com/ pesticide/
Pesticide Update
Vol. XXV - No. 3 Summer 2009
New Record Keeping Requirements: Worker Protection
Standards For Agricultural Pesticide Applications
N. C. Pesticide Board Adopts New Pesticide Regulations
New EPA Bulk
Pesticide Containment
Regulations, page 2
New Record Keeping
Requirements For
Aerial Applicators,
page 4
New Bulk Storage
Regulations, adopted
by reference by NC
Pesticide Board, page 5
New Record Keeping
Requirements
For Commercial
Applicators And Public
Operators Applying
Restricted Use
Pesticides, page 6
INSIDE
• College team works to
ensure farmworkers stay
healthy when dealing
with pesticides, page 7
• The Label Is The Law!
( part 2), page 8
• North Carolina Pesticide
Board Actions, page 9
For an example showing how to comply
with the new regulations. and a sample
record keeping form, see page 4.
Pesticide Update • Page 2
By Mike Mitchell,
Pesticide Environmental
Investigative Specialist,
and NCDA& CS
The United States Envi-ronmental
Protection
Agency adopted a new
Pesticide Container and
Containment Rule. On
January 13, 2009, the
North Carolina Pesti-cide
Board adopted, by
reference, the contain-ment
portion of the Rule,
thereby making it also
a state regulation. These regulations will
become effective on August 17, 2009.
Who Must Comply?
Refilling establishments, custom blenders,
and commercial applicators ( applies pes-ticides
for compensation) must comply if
they handle agricultural pesticides. Farm-ers
will not be affected unless they fall into
one of the above categories. Furthermore,
this regulation only applies if you have
agricultural pesticides stored in stationary
tanks designed to hold undivided quanti-ties
equal to or greater than 500 gallons
of liquid pesticides or equal to or greater
than 4,000 pounds of dry pesticides. Or, if
you own or operate an agriculture pesti-cide
establishment that repackages such
pesticides and whose main business is
retail sales ( i. e. greater than 50 % of total
annual revenue generated from retail
sales).
Why New Regulations
The new regulations were developed to
protect the environment from agricultural
pesticide releases at bulk storage sites and
also from agricultural pesticide spills and
leaks resulting from pesticide refilling and
dispensing operations. This protection is
achieved by the construction and main-tenance
of secondary containment units
and/ or pads.
What Is Covered?
The new regulations address both second-ary
containment for stationary contain-ers,
and containment pads for pesticide
dispensing areas.
Stationary containers in affected facilities
( see Who Must Comply) must have sec-ondary
containment. Multiple stationary
containers may be protected within one
containment unit. A stationary container
is defined as a container that is fixed at a
facility, or a non- stationary container that
remains at a facility for at least 30 consecu-tive
days and contains pesticide during
that time. The new regulation exempts
some stationary containers. Stationary
containers exempted in the new regula-tion
include: empty containers, containers
holding only rinsate or wash water ( and
so labeled); containers holding pesticides
which are gaseous at atmospheric tem-perature
and pressure; and containers
dedicated to non- pesticide use ( and so
labeled).
Dispensing areas in affected facilities must
have containment pads. Containment
pads are required if refillable containers
are being emptied, cleaned or rinsed; if
agricultural pesticides are dispensed from
a transport vehicle for purposes of refill-ing
a refillable container; if agricultural
pesticides are dispensed from any other
container for the purpose of refilling a
refillable container for sale or distribution;
or if agricultural pesticides are dispensed
from a stationary container designed to
hold undivided quantities equal to or
greater than 500 gallons liquid or 4,000
pounds dry for any purpose.
There are also sections of the rule that
mandate operational procedures. The
owner or operator of the facility must
manage all structures in a manner that
prevents pesticides and mixtures from
escaping. All spills and leaks must be
collected and recovered in a manner that
ensures protection of human health and
the environment. All cleanup must oc-cur
no later than the end of the day and
all pesticides and materials containing
pesticide residues that are collected must
be managed according to label instruc-tions
and applicable Federal, State and
local laws and regulations.
Additionally, all transfers
of pesticides between
containers and/ or vehicles
must be attended at all
times and all lockable
valves must be locked
when unattended. Lock-ing
an entire facility will
satisfy this requirement.
The new rule also ad-dresses
requirements for
inspection, maintenance,
and recordkeeping. All
structures and containers
must be inspected at least
monthly whenever pesticides are present.
If upon inspection it is determined that
repairs are needed, they must be initi-ated
no later than the end of the day and
completed repairs must be affected within
a time frame that is reasonable taking into
account the availability of materials, staff
and equipment. No additional pesticides
may be stored in or on the structure until
suitable repairs have been made. In addi-tion
to applicable Pesticide Producer Es-tablishment
record keeping requirements,
facilities must also keep records of inspec-tions
and maintenance for three years.
These records must include the name of
the person conducting the inspection and
the maintenance, date of inspections and
maintenance, conditions noted and main-tenance
performed. Also, records of the
construction date of structures must be
kept for as long as the structure is in use,
and for three years afterwards.
The Complete Story
This article is only a brief overview of the
new containment rule. For additional
information, or for specific details regard-ing
the new rule, contact Mike Mitchell,
NCDA& CS at 919- 733- 3556 ext. 275 or visit
the EPA’s websites shown below for ad-ditional
information.
http:// www. epa. gov/ pesticides/
regulating/ regulations_ at_ a_ glance. htm
( Note: the website shown above outlines
the entire rule. See Table 7 for information
regarding Containment Structures)
http:// www. epa. gov/ pesticides/
regulating/ containers. htm
http:// ecfr. gpoaccess. gov/ cgi/ t/ text/ text- id
x? c= ecfr& sid= 93dee353f2abe7469a3a51f5
b2fb7a7c& rgn= div6& view= text& node= 40:
23.0.1.1.15.5& idno= 40
New Bulk Pesticide Containment Regulations
Pesticide Update • Page 3
Recordkeeping Form for the USDA Restricted- Use Pesticides Regulation and the Worker Protection Standard
Maintain records of all pesticide applications for a minimum of 2 years.
Field ID/ location of Treated Area ( 1)
( 2) ( 3) ( 4) ( 5) ( 6) ( 7) ( 8) ( 9) ( 10) ( 11)
Time
Date Planned
( mo/ day/ yr)
Time
Completed
Restricted
Entry
Interval
( REI)
Crop or
Commodity
Treated
Brand Name( s)
EPA
Registration
Number( s)
Active
Ingredient( s)
Size of
Area
Treated
Total
Amount
Applied**
Applicator's Name
&
Certification
Number
AM
PM
AM
PM
AM
PM
AM
PM
AM
PM
AM
PM
AM
PM
AM
PM
AM
PM
AM
PM
Worker Protection Standard ( WPS) information must be posted before pesticide application and remain posted for 30 days after the end of the Restricted Entry Interval ( REI). After this
time the records are required to be maintained for 2 years. All other information must be recorded within 14 days of application. If you apply a tank mix of pesticides with different
REIs, write down the longest REI.
** Multiply the rate of application that you used by Size of Area Treated ( item 9) to get Total Amount Applied ( item 10). The Total Amount Applied is not the quantity after water or a carrier is
added.
Note: For applications made to less than 1/ l0- acre, indicate " spot treatment" within Crop or Commodity Treated ( item 5) and record the Location of Treated Area ( item 1). Record the Date, Brand
Name, EPA Reg. No., and Total Amount Applied ( items 2, 6, 7, and l0).
Developed by Wayne G. Buhler, Ph. D., NC State University, in collaboration with the Structural Pest Control and Pesticides Division, NCDA& CS. AG- 689W
E08- 50268
New Record Keeping Requirements:
Below is an example showing how to comply with the new regulations.
FIELD ID/ LOCATION: 52- 48 Old creek Field ( 1)
Applicator Name and Certification Number
Mo/ Day/
Year & Time
EPA Reg.
Number
Active
Ingredients
Brand Name
Crop, Commodity, Stored
Product, or Site
Bob B. Smith 200028265
5/ 3/ 09 ( 3)( a) 10am
( 3)( b) end time: 2: 00pm
241- 337 Pendimethalin Prow/ 3.3EC cotton
5/ 3/ 09 ( 3)( a) 10am
( 3)( b) end time: 2: 00pm
100- 642 Fluometuron Cotoran 4L cotton
( 2) ( 3) ( 4) ( 5) ( 6) ( 7)
( 1) Identify the location of the application ( not the farm or business). A field may be identified on a farm map, by a USDA map and number, by a
common field name ( for example, 52- 48 Old Creek Field), or by a legal description. If the location treated is a greenhouse or storage facility, give it a
unique name or number. If treating a section of a greenhouse, record the section or bed as part of the greenhouse location.
( 2) If the name and certification number are the same as the name and certification number of the person on the applicator information form on
page 4, then you may record the letter listed for the applicator. If anyone else is applying the pesticide, record the applicator’s name and certifica-tion
number.
( 3) Fill in the month, day, and year of application.
( a) WPS requires you to post the time the application is to be made prior to the application, so record time here.
( b) You must now add the actual end time of the application to the application information.
For more information please contact the NCDA & CS – Pesticide Section, Compliance Monitoring & Field Operations at ( 919) 733- 3556.
Pesticide Update • Page 4
Effective May 1, 2009 the record
keeping requirements for aerial
applicators have been updated to
include the time each application
was completed and each day of
application recorded as a separate
record. Regulation changes are
notated in red in below:
SECTION .1000 - AERIAL
APPLICATION OF PESTICIDES
02 NCAC 09L .1002 GENERAL RE-QUIREMENTS
( a) All agricultural aircraft opera-tions
in North Carolina shall comply
with the Federal Occupational
Safety and Health Act of 1971
( OSHA), the North Carolina Occu-pational
Safety and Health Law, all
regulations promulgated thereunder and
the Federal Aviation Regulations part 137.
In any case of conflict, a provision of the
aforenamed authorities takes precedence
over any of these Rules.
( b) Each aerial application business shall
have a licensed contractor. The contractor
shall be responsible for the compliance
of the business with the North Carolina
Pesticide Law of 1971 and all regulations
promulgated thereunder except where
the responsibility is specifically designated
to another person( s) by these Rules.
( c) All agricultural aircraft operations ( pilot
or contractor) shall keep a written record
to be completed within 72 hours after
each application. This requirement must
be fulfilled as soon as requested by an
employee of the Pesticide Section for the
purposes of a pesticide incident investiga-tion.
The record shall show the following:
( 1) name of contractor;
( 2) name and address of the person for
whom the pesticide was applied;
( 3) identification of farm or land sites
treated with pesticide( s);
( 4) name of crop which was treated;
( 5) total number of acres treated;
( 6) the year, month, date, and the spe-cific
time of day when each pesticide
application was
completed;
( 7) the brand name of the pesticide( s)
and EPA registration number;
( 8) amount of formulated product or
active material applied per acre ( must
specify);
( 9) total gallons or pounds per acre of
the final tank mix applied per acre;
( 10) name of pilot;
( 11) signature of person completing this
record.
( d) Each day of application shall be re-corded
as a separate record.
( e) The pilot shall, prior to application,
learn and confirm:
( 1) the boundaries and exact location of
the target area( s),
( 2) the identity of nontarget areas and
safety hazards located on or adjacent to
the target areas.
( f ) Spray and spreading equipment shall
be rinsed after each agricultural aircraft
operation except when the next agri-cultural
aircraft operation will be made
using the same pesticide, or if another
pesticide, one which by its manufacturer’s
recommendations is compatible with
that previously in the equipment, and will
not result in any adverse effects or illegal
residues. Rinsing shall be conducted in an
area where an environmental hazard will
not be created by the drainage or disposal
of waste materials and conducted with
methods which will not create an environ-mental
or human hazard.
( g) During application, the flow and mix-ture
of the pesticide( s) shall be uniform.
Pilots and contractors shall utilize equip-ment
which will maintain a uniform mix-ture
and flow during application.
( h) Pilots and contractors shall use and op-erate,
in any agricultural aircraft operation,
aircraft equipped with spray or spread-ing
equipment suited, according to its
manufacturer’s recommendations for the
pesticide( s) to be applied. All aerial spray
or spreading equipment shall
be free of leaks and shall have a
positive shutoff system to prevent
leaking and dissemination of pesti-cides
on any nontarget areas over
which the flight is made. Such
equipment shall not allow spillage,
dripping and backflow or create a
hazard from vapors or drift.
( i) The loading area shall be kept
reasonably free of pesticide con-tamination.
( j) No pesticide( s) shall be applied
by an aerial applicator while any
persons other than those assisting
in the application are in the target
area.
( k) The shape of the tank or hopper
of the spray or spreading equipment shall
be such as to allow complete drainage
during flight and on ground.
( l) The contractor or pilot shall immedi-ately
notify the Secretary of the Board, or
designated alternate, of any emergency or
accidental release of pesticide( s) from the
application or auxiliary equipment. They
shall provide the following information:
( 1) the name of the pilot,
( 2) the contractor involved,
( 3) the name of the property owner or
operator,
( 4) the location of the incident,
( 5) the name of the pesticide,
( 6) the estimated amount of pesticide
involved,
( 7) the estimated size of the area that
received the spill,
( 8) the description of what is located
within 300 feet from the edge of the spill
in all directions,
( 9) the number of humans or animals
known to have been contaminated,
( 10) the weather conditions at the site of
the emergency or accidental release of
pesticide( s).
History Note: Authority G. S. 143- 458; 143-
463; 143- 466;
Eff. July 2, 1976;
Amended Eff. May 1, 2009; February 1, 1989;
January 1, 1985; August 1, 1982; March 1,
1981.
Also effective May 1, 2009 under NC
Pesticide Regulations, Section .1800
New Record Keeping Requirements For Aerial Applicators
Please see Aerial Applicators,
page 6
Pesticide Update • Page 5
On January 13, 2009, the North Carolina
Pesticide Board adopted, by reference the
containment portion of the United States
Environmental Protection Agency’s new
Pesticide Container and Containment Rule,
thereby making it also a state regulation.
This regulation will become effective on
August 17, 2009. Regulation changes are
notated in red in below:
02 NCAC 09L .0810 ADOPTION BY
REFERENCE
The North Carolina Pesticide Board hereby
adopts by reference, including subsequent
amendments, Part 165 of Title 40: Protec-tion
of Environment of the Code of Federal
Regulations, entitled “ Pesticide Manage-ment
and Disposal Subpart E – Standards
for Pesticide Containment Structures.”
Copies of this material may be obtained at
no cost from the U. S. Government Printing
Office website, www. gpoaccess. gov/ cfr/
index. html.
History Note: Authority G. S. 143- 441; 143-
461; Eff. April 1, 2009.
02 NCAC 09L .1901 DEFINITIONS
All specific words or terms used in this Sec-tion
other than those defined in this Rule
shall have the same definitions as shown in
the North Carolina Pesticide Law of 1971,
G. S. 143- 460. The rules contained in this Section shall be deemed
to be minimum for storage.
( 7) Bulk Storage. Commercial Storage of any pesticide held
in stationary pesticide containers designed to hold undivided
quantities equal to or greater than 500 gallons ( 1,890 liters)
of liquid pesticide or equal to or greater than 4,000 pounds
( 1,818 kilograms) of dry pesticide are subject to the regula-tions
in this Rule unless any of the following conditions ex-ists:
( a) The container is empty, that is, all pesticide that can be
removed by the methods such as draining, pumping, or aspi-rating
has been removed ( whether or not the container has
been rinsed or washed).
( b) The container holds only pesticide rinsates or wash wa-ters,
and is labeled accordingly.
( c) The container holds only pesticides which would be
gaseous when released at atmospheric temperature and
pressure.
( d) The container is dedicated to non- pesticide use, and is
labeled accordingly.
History Note: Authority G. S. 143- 437; 143- 441; 143- 461; 143- 466;
Eff. January 1, 1984;
Amended Eff. April 1, 2009; November 1, 1989;
November 1, 1988.
NEW STATE BULK STORAGE REGULATIONS - are now found in
the Sub- Section .1914
02 NCAC 09L .1914 BULK STORAGE REQUIREMENTS
( a) Outlets, filler and access ports shall be locked at all times when
not in use. Keys to the outlet, filler and access ports shall be in
the possession of the purchaser and authorized employees only.
Locks on ports are not required if bulk tanks are stored inside a
facility utilizing security precautions that prevent unauthorized
access to the bulk pesticide storage area.
( b) All bulk pesticide storage tanks must display the appropriate
signal word as shown on the label on all sides exposed to view.
The words shall be either stenciled directly on the containers or
storage tanks or placed on a sign of durable construction which is
firmly attached to the containers and storage tanks. All
letters of said words shall be a minimum of four inches in height
and one inch in width, and shall be printed in contrasting colors
to the containers and storage tanks which are readily visible.
( c) All bulk storage areas shall be posted with a durable sign stat-ing
“ PESTICIDE STORAGE,” “ AUTHORIZED PERSONNEL ONLY,” “ IN
CASE OF EMERGENCY CALL______”
( d) Pesticide applicators utilizing bulk storage containers shall be
subject to the same requirements as set forth in this Rule.
History Note: Authority G. S. 143- 441; 143- 461; Eff. April 1, 2009.
For more information please contact the NCDA & CS – Pesticide
Section, Compliance Monitoring & Field Operations at ( 919) 733-
3556.
New Bulk Storage Regulations
Pesticide Update • Page 6
Effective April 1, 2009 the record
keeping requirements for commer-cial
applicators and public opera-tors,
has been updated to include
the time each application was
completed and each day of applica-tion
recorded as a separate record.
Regulation changes are notated in
red in below:
02 NCAC 09L .1402 RECORD
KEEPING REQUIREMENTS
All licensed pesticide applicators,
as defined in G. S. 143- 460 which
includes public operators, utilizing
ground equipment shall keep for
three years and make available to
the commissioner for like period
records of all applications of re-stricted
use pesticides showing the
following:
( 1) name of licensed pesticide ap-plicator
or licensed public operator;
( 2) name and address of the person
for whom the pesticide was ap-plied;
( 3) identification of farm or site( s)
treated with pesticide( s);
( 4) name of crop, commodity, or
object( s) which was treated with
pesticide( s);
( 5) approximate number of acres
or size or number of other object( s)
treated;
( 6) the year, month, date and the
specific time of day when each
pesticide application was
completed and each day of applica-tion
shall be recorded as a separate
record;
( 7) the brand name of the
pesticide( s) and EPA registration
number( s);
( 8) amount ( volume or weight) of
pesticide formulation( s) or active
ingredient( s) applied per
unit of measure; and
( 9) name( s) of person( s) applying
pesticide( s).
History Note: Authority G. S. 143-
458; 143- 463; 143- 466( a);
Eff. October 21, 1977;
Amended Eff. April 1, 2009.
For more information please con-tact
the NCDA & CS – Pesticide
Section, Compliance Monitoring &
Field Operations at ( 919) 733- 3556.
WORKER PROTECTION STANDARDS FOR AGRICULTURAL PES-TICIDES,
new regulation .1807 requires specific record keep-ing
and display information for agricultural applications:
02 NCAC 09L .1807 SPECIFIC INFORMATION ABOUT APPLICA-TIONS
( a) Concerning application information requirements contained
in Sections 170.122 and 170.222 the following is also required to
be completed by the agricultural employer:
( 1) In addition to the requirements of Sections 170.122( c)( 3),
and 170.222( c)( 3), the specific time of day when each pesticide
application was completed must be recorded immediately
upon completion of the application. Each day of the applica-tion
shall be recorded as a separate record.
( 2) After the application information referenced in 1807( a)( 1)
and the other information in Sections 170.122( c) and 170.222( c)
has been displayed for the required period of time in Section
170.122( b) and 170.222( b), the agricultural employer shall
maintain the information for a period of two years from the
specific time of day when each pesticide application was com-pleted.
Such information shall be available for inspection and
copying by the Board or its agents upon their request.
( b) In addition to information contained in Section 170.224( b),
the handler employer must make the agricultural owner aware
of the specific time of day when each pesticide application was
completed. The agricultural employer shall display the informa-tion
immediately and shall make it part of the record required to
be maintained in paragraph ( a)( 1) and ( 2) of this part.
For more information please contact the NCDA & CS – Pesticide
Section, Compliance Monitoring & Field Operations at ( 919) 733-
3556.
Aerial Aplicators, from page 4
New Record Keeping Requirements For Commercial Applicators
And Public Operators Applying Restricted Use Pesticides
Photo: Tom Bowman
Pesticide Update • Page 7
Art Latham
NCSU College of Agriculture & Life Sciences Perspective Online
Reprinted with Permission
A College of Agriculture and Life Sciences team is working to make
crop fields safer for Spanish- speaking laborers through bilingual
pesticide safety training.
Dr. Greg Cope, Julia Storm and Catherine LePrevost of the College’s
Environmental and Molecular Toxicology Department are devel-oping
“ Pesticides and Farmworker Health: A Toolkit to Enhance
Pesticide Safety Training for Hispanic/ Latino Workers.” The three-year
project is funded by a $ 223,785 NC Pesticide Board Pesticide
Environmental Trust Fund grant.
Cope is associate professor, department Extension leader and N. C.
State University agromedicine coordinator; Storm is an agromedi-cine
information specialist, and LePrevost is a doctoral candidate
and project coordinator.
LePrevost and Buhler discuss warning notices.
“ The project is necessary and timely for several reasons,” says Cope.
“ Pesticide products and their use in agricultural practice have
changed since our original series was developed. The U. S. Envi-ronmental
Protection Agency is evaluating changes to the Worker
Protection Standard involving hazard communication, and relevant
stakeholders have expressed the need for effective pesticide safety
training resources for farmworkers to augment the crop sheets.”
Says Storm, “ We are developing innovative materials for crop- spe-cific
pesticide safety training for Latino farmworkers based on the
latest research in hazard recognition and hazard communication as
well as our own product development testing. The product we are
developing is more visual and comprehensive than existing crop
sheets in our state and others and addresses preferences expressed
by farmworkers.”
Based on the success of their 1998- 2003 bilingual publication
series, “ Pesticides and Human Health” -- which covered tobacco,
green peppers, cucumbers, Christmas trees, sweet potatoes,
apples, tomatoes and grapes -- the team decided to enhance farm
worker pesticide safety training by developing the toolkit.
• The toolkit includes: updated, improved, culturally appropri-ate,
illustrated, low- literacy crop sheets and posters in Spanish
and English that include information about toxicity signal words
printed on pesticide labels, such as “ caution,” warning” and “ dan-ger”;
• information on restricted entry intervals, or the time period,
based on a pesticide’s toxicity, during which workers can’t enter a
pesticide- treated area;
• symptoms of acute health effects for pesticides most commonly
used in many hand- labor- intensive crops in North Carolina;
• lesson plans for Extension and outreach educators, including
a set of interactive activities from which trainers can choose to
reinforce lesson learning objectives and assess most appropriate
learning for a low- literacy audience with lower levels of formal
education;
• a color flip chart with crop- specific images and scenarios for
each crop that provides trainers with appropriate questions for
engaging workers while displaying visual cues:
• references to more training resources.
“ Because this is a low- literacy population and a Latino audience,
traditional lecture methods such as PowerPoint presentations are
less appropriate,” says LePrevost.
“ We are developing resources and educational tools based on basic
and adult education principles and culturally appropriate design,”
she says. “ For adults, lessons should validate learners’ knowledge
and experiences by providing opportunities to contribute these
aspects to the training. So the lesson takes on a guided discus-sion
format in which the
trainer engages farm-workers
in a conversation
about pesticide safety. ”
Assisting the team are
Cintia Aguilar, Coop-erative
Extension’s Latino
Affairs facilitator; Cesar
Asuaje, bilingual farm
safety educator, Univer-sity
of Florida Coopera-tive
Extension, who also
collaborated on farmworker focus groups; and N. C. Farmworker
Health Program consultants from the state Health and Human
Services Department. The team field tested toolkit prototypes with
25 farmworkers through focused small- group discussions to assess
learning and preferences.
The team also consults with crop specialists for current use infor-mation
for commonly used pesticides for each crop in the series.
College consultants for the tobacco crop sheet in progress include
Dr. Clyde Sorenson, entomology professor; Dr. Loren Fisher, associ-ate
professor and extension crop science specialist; and Dr. Asimina
Mila, assistant professor and extension tobacco specialist.
The team will later include crops covered in their previous series
-- tobacco, Christmas trees, sweet potatoes, green peppers, apples,
cucumbers, tomatoes and grapes -- and several new ones: blueber-ries,
landscape horticulture and strawberries.
“ Some of these crops, like tomatoes, blueberries and strawberries,
have a greater proportion of female workers,” notes LePrevost.
“ To be sure the established prototype effectively communicates
information to both men and women, we’ll begin field testing the
materials with a group of women working in tomatoes in 2009.”
College team works to ensure farmworkers
stay healthy when dealing with pesticides
From left are Dr. Greg Cope, Environmental and Molecular
Toxicology Department; Catherine LePrevost, project coordinator;
and Dr. Wayne Buhler, Extension specialist, Horticultural Science
Department. Cope and Buhler are listening to LePrevost’s
presentation of the bilingual pesticide safety training project.
LePrevost and Buhler discuss warning
notices.
Pesticide Update • Page 8
[ This is part 2 of the article discussing
Signal Words on pesticide labels. Part 1
appered in the Summer 2008 Pesticide
update, which can be found at http:// www.
ncagr. gov/ SPCAP/ pesticides/ documents/
Pesticideupdatesummer08. pdf]
By Cam McDonald, Certification & Training
Specialist, NCDA& CS
In the first part of this article, I explained
how 5 acute toxicity studies are used for
determining the toxicity of a pesticide
product; the results of these studies
are then used to assign the appropriate
Signal word to the product. The acute
( short- term exposure) toxicity studies
include: Acute Oral ( swallowing), Acute
Dermal ( contact with skin), Acute Inhala-tion
( breathing), Primary Eye, and Primary
Skin. The acute toxicity studies are directly
related to the 4 main routes of pesticide
exposure ( oral, inhalation, ocular, and
dermal). The Signal Word is determined by
the most severe toxicity category assigned
to the five acute studies or by the pres-ence
of methanol in concentrations of 4%
or greater. The Signal Words and associ-ated
toxicity categories are as follows:
Toxicity Category I................... DANGER
Toxicity Category II................ WARNING
Toxicity Category III................ CAUTION
Toxicity Category IV..... None Required*
* If a Signal Word is used, it must be
“ CAUTION.”
If methanol is present at concentrations
of 4% or greater, regardless of the toxicity
category results, the Signal Word must be
“ DANGER.” In addition to the Signal Word
“ DANGER,” pesticide products classified as
Toxicity Category I for Acute Oral, Acute
Dermal or Acute Inhalation Studies are
also required to use the word “ POISON”
along with the skull and crossbones
symbol .
Table 2 shows how the Toxicity Categories
are used for assigning the appropriate
Signal Word to a pesticide product. Prod-uct
A ( Table 2) must bear the Signal Word,
CAUTION, due to the fact that the most
severe Toxicity Category from the 5 stud-ies
is III ( for Acute Oral, Acute Inhalation,
and Primary Eye). Product B must bear the
Signal Word, WARNING, since the most
severe Toxicity Category is II ( for Primary
Eye). Products C, D, and E must all bear
the Signal Word, DANGER. Product C must
bear the Signal Word, DANGER, due to be-ing
Category I ( for Acute Oral and Primary
eye). Product D must bear DANGER due
to being in Toxicity Category I ( for Primary
Eye). Product E must bear the Signal Word,
DANGER, due to the presence of methanol
in a concentration greater than 4% in the
product.
In addition to the Signal word, DANGER,
Products C and E must bear additional
labeling. They must also bear the Skull &
Crossbones symbol and the word, POI-SON
( which must appear in red). Product
C must bear the additional labeling as a
result of being in Toxicity Category I for
the Acute Oral Toxicity study. Product E
must bear the additional labeling because
it contains methanol at greater than 4%
concentration.
A Signal Word is required for all registered
pesticide products unless the pesticide
product meets the criteria of Toxicity
Category IV by all routes of exposure. If
the manufacturer or registrant desires to
use a Signal Word on a Toxicity Category
IV product, they must use CAUTION as the
Signal Word.
EPA requires that the Signal Word appear
on the front panel of the label. Addi-tionally,
the EPA request that the Signal
Word appear on a separate line from the
required Child Hazard Warning statement,
Keep Out of Reach of Children. The EPA
also request that the Signal Word also
appear in the Precautionary Statements
section of a label immediately below the
subheading “ Hazards to Humans and
Domestic Animals.”
EPA also prefers that the Signal Word ap-pear
in all capital letters.
Signal Words are not randomly assigned.
Many scientific studies are required to
insure that the proper Signal Word is
placed on a pesticide product. The studies
are directly related to the main routes
of pesticide exposure ( oral, inhalation,
ocular, and dermal) and provide important
information regarding the toxicity ( poten-tial
of a pesticide to cause adverse effects)
of a pesticide product. The Signal Word on
a pesticide product is there to help the ap-plicator,
and is an important indicator of
the toxicity of the product. If you have the
option of choosing between different pes-ticide
products to complete a spray task,
and the products have different Signal
Words, the Signal Word is an excellent way
to pick the least toxic product to apply.
The Label Is The Law! ( part 2)
Table 2 - Examples of Signal Word Determination
Type of Study Product
A
Product
B
Product
C*
Product
D
Product
E*
Acute Oral III IV I III III
Acute Dermal IV III III IV III
Acute III IV III III III
Primary Eye III II I I III
Primary Skin IV IV II IV III
Special
Inert, e. g.,
methanol
No No No No Yes*
CORRECT
SIGNAL WORD
CAUTION WARNING
DANGER
( Poison
with Skull &
Crossbones)
DANGER
DANGER
( Poison
with Skull &
Crossbones)
Pesticide Update • Page 9
North Carolina Pesticide Board Actions
At the January 2009 through March 2009 meetings of the North
Carolina Pesticide Board, the following settlement agreements,
including license suspensions and monetary penalties totaling
$ 8,200.00 were approved for alleged violations of the NC Pesticide
Law of 1971. Consent to the terms of the settlement agreement does
not constitute an admission of guilt to any alleged violation.
John F. Ireland, Dunn, NC, for the alleged violation( s) of using a
pesticide in a manner inconsistent with its labeling and applying
a pesticide( s) under such conditions that drift from pesticide( s)
particles or vapors results in adverse effect. Mr. Ireland agreed to
pay a monetary penalty of $ 500.00.
Samuel B. Church, Fleetwood, NC for the alleged violation( s) of
using a pesticide in a manner inconsistent with its labeling and
for alleged violations of the Worker Protection Standard. Mr.
Church agreed to pay a monetary penalty of $ 1,200.00.
Wade Lamb, New Bern, NC for the alleged violation( s) of pro-viding
or making available a restricted use pesticide to a non-certified
applicator. Mr. Lamb agreed to pay a monetary penalty
of $ 900.00.
James A. Sparks, Columbia, NC for alleged violation( s) of dispos-ing
of pesticides or pesticide containers in such a manner as may
cause injury to humans, vegetation, crops, livestock, wildlife, or to
pollute any water supply or waterway. Mr. Sparks agreed to pay
monetary penalties totaling $ 1,600.00.
Benjamin L. Lynch, Mill Spring, NC for alleged violation( s) of
using a pesticide in a manner inconsistent with its labeling. Mr.
Lynch agreed to pay a monetary penalty of $ 300.00.
David V. Walton, Lumber Bridge, NC for alleged violation( s) of
using a pesticide in a manner inconsistent with its labeling. Mr.
Walton agreed to pay a monetary penalty of $ 400.00.
Bobby H. Pipkin, Blounts Creek, NC for alleged violation( s) of
using a pesticide in a manner inconsistent with its labeling and
applying a restricted use pesticide without the proper license
or certification. Mr. Pipkin agreed to pay a monetary penalty of
$ 500.00.
Jonathan N. Berrier, Brevard, NC for alleged violation( s) of us-ing
a pesticide in a manner inconsistent with its labeling and
applying a pesticide( s) under such conditions that drift from
pesticide( s) particles or vapors results in adverse effect. Mr. Ber-rier
agreed to pay a monetary penalty of $ 700.00.
Edward L. Williams, Jr., Williamston, NC for alleged violation( s)
of using a pesticide in a manner inconsistent with its labeling. Mr.
Williams agreed to pay a monetary penalty of $ 500.00.
Ronnie R. Bowes, Roxboro, NC for alleged violation( s) of using
a pesticide in a manner inconsistent with its labeling and for
alleged violations of the Worker Protection Standard. Mr. Bowes
agreed to pay a monetary penalty of $ 1,200.00.
Coneal W. Hughes, Elizabeth City, NC for alleged violation( s) of
using a pesticide in a manner inconsistent with its labeling and
applying a restricted use pesticide without the proper license or
certification. Ms. Hughes agreed to pay a monetary penalty of
$ 400.00.
Pesticide schools and materials for certification and recertification:
CONTACT: Dr. Wayne Buhler, Dept. of Horticultural Science,
Box 7609, NCSU, Raleigh, NC 27695.
Phone ( 919) 515- 3113
Certification, licensing, and recertification credits or testing:
CONTACT: Pesticide Section, NCDA& CS,
1090 Mail Service Center, Raleigh, NC 27699- 1090.
Phone ( 919) 733- 3556
Private applicator recertification classes:
CONTACT: Pesticide Section Homepage www. ncagr. gov/ SPCAP/ pesticides/
Commercial applicator and dealer recertification classes:
CONTACT: Pesticide Section Homepage www. ncagr. gov/ SPCAP/ pesticides/
Pesticide container recycling:
CONTACT: Henry Wade, Pesticide Section, NCDA& CS, 1090 Mail Service Center,
Raleigh, NC 27699- 1090.
Phone ( 919) 733- 3556
Pesticide waste disposal:
CONTACT: Derrick Bell, Pesticide Section, NCDA& CS,
1090 Mail Service Center, Raleigh, NC 27699- 1090.
Phone ( 919) 733- 7366 or ( 919) 715- 9023.
Send your suggestions for topics for future Pesticide Update articles to Cam
McDonald at e- mail address: cam. mcdonald@ ncmail. net
For More Information
Please Recycle.
North Carolina Department of Agriculture
& Consumer Services
Structural Pest Contol and
Pesticides Division
James W Burnette Jr., Director
1090 Mail Service Center
Raleigh, NC 27699- 1090
( 919) 733- 3556
FAX ( 919) 733- 9796
http:// www. ncagr. gov/ SPCAP/ pesticides/
Pesticide Update is a biannual report of
the Pesticide Section.
Pesticide
Section