Worker Protection Standard Inspection Checklist

Title Page

Site/Premise
Owner/Operator
Inspection Type
Inspector Credentials Presented
Notice of Inspection Provided
Routine inspection
For Cause inspection
Conducted on
Prepared by
Location

A. AGRICULTURAL ESTABLISHMENT INFORMATION

Immediate Family Exemption Criteria for Workers and Handlers
Are ALL the workers and handlers the owner (or majority owner) or immediate family? Exemption applies to: spouses, children, step children, foster children, sons-in-law, daughters-in-law, grandchildren, parents, step parents, foster parents, grandparents, fathers-in-law, mothers-in-law, aunts, uncles, brothers, sisters, brothers-in-law, sisters-in-law, nieces, nephews, first cousins

OWNERS OF AGRICULTURAL ESTABLISHMENTS AND IMMEDIATE FAMILY

B. APPLICATION RESTRICTIONS

For enclosed space production applications, were workers and other persons kept out of restricted areas during the application other than appropriately trained and equipped handlers involved in the application? For outdoor production applications, were workers and other persons (other than appropriately trained and equipped handlers involved with the application) kept out of the treated area and application exclusion zone?
Did the handler suspend application because someone was in the AEZ? (for enclosed space, and was the application continued properly?
Was each pesticide applied so that it did not contact either directly or through drift, anyone except appropriately trained and equipped handlers?

C. ENTRY RESTRICTIONS AFTER APPLICATIONS

After application of any pesticide to an outdoor production area, did the owner keep workers out of the treated area before the REI has expired and all warning signs have been removed or covered? (except for permitted early entry activities)
After application of any pesticide to an area of enclosed space production, did the owner keep workers out of the area before the REI has expired and all warning signs have been removed or covered? (except for permitted early entry activities)

D. INFORMATION EXCHANGE

If agricultural employer is employing a commercial handler to make applications
Does the owner give to a commercial pesticide handler employer the location and description of treated areas or REIs and restrictions in those areas where applications are or will be made on their establishment?
Does the commercial pesticide handling establishment inform the owner of: location and description of areas to be treated, date and time of application, product name, registration number, active ingredient, REI, requirement for oral and/or written notification, and any other restrictions?

E. ENTRY RESTRICTIONS

Are any workers considered Early Entry Workers?
Prior to early entry, did the employer ensure each early entry worker is provided with the required PPE, that it is used as intended and is properly maintained?

•Limited Contact Exception

If using the exception for limited contact or irrigation activities, are all the required conditions met? Including: Entry must not occur during first 4 hours or before inhalation or ventilation criteria met. No hand labor activity was performed. Time did not exceed 8 hours in 24-hour period. A dual notice pesticide was not used. Situation could not have been foreseen (except irrigation tasks). Not doing the activity would result in substantialeconomic loss.

•Short Term Activity Exception

If using the short-term activity exception,\ were all the required conditions met? Including: Entry did not occur during first 4 hours or before inhalation or ventilation criteria met. No hand labor activity was performed. Time did not exceed 1 hour in 24 hours.

•Agricultural Emergency Exception

If agriculture emergency exception, were all required conditions met? Including: Situation meets criteria for agricultural emergency. Entry did not occur during first 4 hours or before inhalation or ventilation criteria met. If dual use pesticide was used, time did not exceed 4 hours in 24 hours.

F. PERSONAL PROTECTIVE EQUIPMENT (PPE)

Did the handler employer/owner provide clean, operational PPE to the handler to meet label requirements? Did the handler use the clothing and PPE specified on the pesticide product labeling?
If respirators are required and handlers are present, did handlers receive medical clearance, fit testing and training?
If respirators are required, are medical clearance, fit testing and training records maintained on the establishment for 2 years?

AGRICULTURAL ESTABLISHMENT

B. RECORDS REVIEW:

Pesticide Application Information and SDSs
Are pesticide application information and SDSs retained on the establishment for 2 years? (Safety Data Sheets, Product name, Registration number, active ingredient, crop or site treated, location and description, date, start and end time of application, duration of REI)
Identify WPS pesticide(s) applied or REI in effect in the past 30 days (minimum of 3 products if possible)
through a record review, interview and/or visual inspection of products in storage and record as appropriate to facilitate the inspection: product name/#; date applied; method of application; special requirements;weather conditions during application; PPE required; REI
Specify product name
Date applied
Method of application
Special requirements
Weather conditions during application
PPE required

•Safety Training Records

Worker Training Records
Current workers trained in past 12 months?
Records retained for 2 years on establishment? (Worker name, signature, name of ag employer)
Handler Training Records
Current workers trained in past 12 months?
Records retained for 2 years on establishment? Handler name, signature, date of training, EPA approved materials, trainer’s name, trainer’s qualifications, name of ag employer)
Respirator Safety Records
Are respirator safety records retained on the establishment for 2 years?
Have handlers received medical clearance, fit testing and training for required respirator?
Access and Availability of Records
Has a worker, handler, or designated representative requested application information and/or SDS?
was it provided within 15 days of receipt?
Have treating medical personnel requested application information and/or SDS?
was it provided promptly?

C. MINIMUM AGE FOR HANDLERS AND EARLY ENTRY WORKERS

Are all handlers and early entry workers at least 18 years of age?

D. INFORMATION DISPLAY

•Location of the “Central Display”

Has an appropriate central display been established in an area where workers and handlers are likely to congregate or pass by and is it accessible during work hours?

•WPS Safety Information Display

Is all required WPS safety information being provided at the central display? Is the EPA WPS Safety Poster (or equivalent) displayed in central location, easily accessible, and legible? Are the name, address and phone number of an emergency medical facility displayed? Are the name, address and phone number of the state/tribal pesticide agency displayed? Are any changes to required information made within 24 hours of receiving notice of changes?
Is the pesticide safety information displayed where decontamination supplies are located at permanent sites and provided at locations where a toilet is provided for 11 or more workers (as required by OSHA)?

•Pesticide Application and Hazard Information (SDS) Display

Is all required pesticide application information provided at central location? Including: Crop or site treated and location and description of treated area, date(s) of application, start and end times, pesticide product name, active ingredient(s), EPA reg. no., re-entry interval (if any)
Is the Safety Data Sheet (SDS) for each pesticide made available?
Is the application information and SDS displayed no later than 24 hours after the end of the applications (but before workers enter the treated area) and kept posted for 30 days after the last REI expiration if workers/handlers are present?
Are the application information and SDSs easily accessible and legible?

E. KNOWLEDGE OF LABELING, APPLICATION- AND ESTABLISHMENT-SPECIFIC INFORMATION

Inspection type
Before a handler performed any handler activity, did the handler employer ensure the handler read applicable portions of the label on safe use or was informed in a manner the handler can understand?
Did the handler have access to the labeling at all times, and was the handler aware of any entry restrictions, AEZ and REIs?
Before any worker performs any activity in a treated area or any handler performs any handler activity where within the last 30 days a pesticide product has been used or an REI has been in effect, has the employer informed workers and handlers in a manner workers and handlers can understand, of the location of pesticide safety information, pesticide application and SDSs, and decontamination supplies?

F. WORKER DECONTAMINATION

Inspection type
Are decontamination supplies located within 1/4 mile of the work site or nearest site of vehicular access and outside a pesticide treated area under an REI and reasonably accessible?
Are the appropriate decontamination supplies provided? Including:1 gallon of water provided for each worker at the beginning of work period and replenished to maintain adequate supply, soap,single-use towels
If REI is 4 hours or less, are the decontamination supplies provided for 7 days? Or 30 days if REI is more than 4 hours?

G. HANDLER DECONTAMINATION AND EYEWASH SUPPLIES

Inspection type
Are decontamination supplies located at mixin sites?
For all other handler tasks, are decontamination supplies located within 1/4 mile from handler or nearest place of vehicular access? Are supplies located outside a treated area or area under REI or in a closed container protected from pesticide contamination?
Are the appropriate decontamination supplies provided? Including 3 gallons of water provided for each handler (at the beginning of work period and replenished to maintain adequate supply), soap, single use towels, and a change of clothes?
At each mixing/loading site for products requiring eye protection or using a closed system under pressure is there an appropriate eyewash system immediately available to a handler? (Either a system to deliver gently running water (at a rate of 0.4 gal/min) for 15 minutes or at least 6 gallons in containers suitable for providing a gentle eye-flush for about 15 minutes)
Does each applicator have at least one pint of water immediately available in a portable container when pesticide label requires eye protection?

H. APPLICATION AND ENTRY RESTRICTIONS AND HANDLER PROTECTIONS

Inspection type
Do all handlers observed by the inspector appear to be over 18?
Did the handler suspend application because someone was in the AEZ?
Was each pesticide applied so that it did not contact, either directly or through drift, anyone except appropriately trained and equipped handlers?
If toxic “skull & crossbones” products were used, was contact made at least every 2 hours by voice, sight or another appropriate method?
If a fumigant was applied in an enclosed space, was continuous visual or voice contact with another handler equipped with PPE maintained? Did the handler outside the enclosed space have immediate access to required PPE in case a rescue is required?

I. NOTIFICATION AND ENTRY RESTRICTIONS

•Entry Restrictions after Applications

After application of any pesticide to an outdoor production area, does the employer not allow any worker to enter or remain in the treated area before the REI has expired and all warning signs have been removed or covered? (except for permitted early entry activities)
After application of any pesticide to an area of enclosed space production, does the employer not allow any worker to enter or remain in the area before the REI has expired and all warning signs have been removed or covered? (except for permitted early entry activities)

•Posting & Notification

For any dual notice pesticide(s) (highly toxic): Was notification provided both orally and by posting?
For any outdoor production area applications with REI of 48 hours or less, was either oral notification or posted warning signs used? If oral notification: Did the notification include the location, dates and times of restrictions? Did the notification include instructions about the restriction in a manner that was understandable to workers? Was the notification provided before the application or at the time a worker begins their work period?
For any outdoor production area applications with REI greater than 48 hours were posted warning signs used? Did signs meet the size and content requirements? Were signs posted in adequate locations? Were signs posted no sooner than 24 hours but before the application? Did signs remain posted until REI expired? Were signs removed within 3 days of REI expiration (or was no entry ensured)?
For any enclosed space production area applications with REI greater than 4 hours Were posted warning signs used? Did signs meet the size and content requirements? Were signs posted in adequate locations? Were signs posted no sooner than 24 hours but before the application? Did signs remain posted until REI expired? Were signs removed within 3 days of REI expiration (or was no entry ensured)?
For any enclosed space production area applications with REI of 4 hours or less was either oral notification or posted warning signs used? If oral notification: Did notification include the location, dates and times of the restriction? Did notification include instructions about the restriction in a manner that were understandable to the workers? Was the notification provided before the application or at the time a worker begins their work period?

J. INFORMATION EXCHANGE

If agricultural employer is employing a commercial handler to make applications:
Does the agricultural employer give the location and description of treated areas or REIs and restrictions in those areas where applications are or will be made on their establishment to a commercial pesticide handler employer?
Does the commercial pesticide handling establishment inform the agricultural employer of: location and description of areas to be treated, date and time of application, product name, registration number, active ingredient, REI, requirement for oral and/or written notification, and any other restrictions?

K. PERSONAL PROTECTIVE EQUIPMENT (PPE)

Inspection type
For pesticide products reviewed
Did the handlers use the clothing and PPE specified on the product labeling?
Did the handler employer provide clean, operational PPE to the handler to meet label requirements?
Before each day of use, did the handler employer inspect all PPE and repair or discard PPE as appropriate?
Did employer assure that handler wears and uses PPE correctly, and before each day of use, is the PPE inspected, and repaired or discarded as appropriate?
Is the PPE properly cleaned and thoroughly dried before storage? Is clean PPE stored separately from personal clothing and contaminated areas? Is there a clean place for putting on and removing PPE?
Where labeling requires PPE for handler activities, did the employer take sufficient measures to prevent heat-related illness and instruct each handler in the prevention, recognition and first aid treatment of heat-related illness?
If respirators are required and handlers are present, did handlers receive medical clearance, fit testing and training?
If using particulate filtering facepiece respirators, are they replaced appropriately? (i.e., breathing resistance excessive; filter is damaged; according to respirator or product label; after 8 hours of use)
If using vapor-removing canister/cartridge respirators, are they replaced appropriately? (based on odor, taste, irritation; breathing resistance excessive; according to respirator or pesticide product label; after 8 hours of use)

L. PESTICIDE HANDLING EQUIPMENT

Before use, did the handler employer instruct handlers in the safe operation of application and mixing/loading equipment and inspect and repair application and mixing/loading equipment before each day of use?
Has any person employed by the agricultural establishment, who cleans, repairs, or adjusts the pesticide equipment, been trained as a handler?
If any persons not employed by the agricultural establishment, clean, repair, or adjust the pesticide equipment, are they provided the following information: that the equipment may be contaminated; potential harmful effects of pesticide exposure; how to limit exposure; and how to wash to remove contamination?

M. EARLY ENTRY

•Entry Restrictions

Inspection type
Are any workers considered Early Entry Workers?
Do all early entry workers appear to be at least 18?
Prior to early entry, did the employer provide the following information in a manner understandable to the workers? Location of early entry area where work is to be performed. Pesticides applied. Dates and time the REI begins and ends. Which exception is the basis for early entry and tasks that may be performed. Whether contact with treated surfaces is allowed. Amount of time allowed in the treated area. PPE required by the label for early entry. Location of pesticide safety information and decontamination supplies.
Prior to early entry, did the employer ensure that each early entry worker has either read the product labeling or has been informed in a manner that is understandable, of all labeling requirements and statements related to human hazards or precautions, first aid or user safety?
Prior to early entry, did the employer ensure each early entry worker is provided with the required PPE, that it is used as intended and is properly maintained?
Prior to early entry, did the employer take sufficient measures to prevent heat-related illness and instruct each worker in the prevention, recognition and first aid treatment of heat-related illness?
Are decontamination supplies located outside any treated area or area under REI or where reasonably accessible to workers conducting early entry tasks?
Are decontamination supplies located where a worker removes personal protective equipment?
Are the appropriate decontamination supplies provided? 3 gallons of water for each early entry worker (at the beginning of work period and replenished to maintain adequate supply), soap and single use towels
Does each worker have at least one pint of water immediately available for eye-flushing in a portable container when pesticide label requires eye protection?

•No Contact Exception

If using the no contact exception, are all the required conditions met? Including: No contact with anything treated with the pesticide even if wearing PPE. No entry before inhalation or ventilation criteria met

•Limited Contact Exception

If using the exception for limited contact and irrigation activities, are all the required conditions met? Including: Entry must not occur during first 4 hours or before inhalation or ventilation criteria met. No hand labor activity was performed. Time did not exceed 8 hours in 24-hour period. A dual notice pesticide was not used. Situation could not have been foreseen (except irrigation tasks). Not doing the activity would result in substantial economic loss.

•Short Term Activity Exception

If using the short-term activity exception, were all the required conditions met? Including: Entry did not occur during first 4 hours or before inhalation or ventilation criteria met. No hand labor activity was performed. Time did not exceed 1 hour in 24 hours.

•Agricultural Emergency Exception

If agriculture emergency exception, were all required conditions met? Including: Situation meets criteria for agricultural emergency. Entry did not occur during first 4 hours or before inhalation or ventilation criteria met. If dual use pesticide was used, time did not exceed 4 hours in 24 hours.

N. EMERGENCY ASSISTANCE

Has a worker or handler experienced potential pesticide exposure during or within 72 hours after employment?
Was transportation to an emergency medical care facility provided and information (SDS, circumstances of application and exposure) provided to medical personnel?

O. ANTI-RETALIATION

Based on information available, no person was threatened, intimidated, coerced, discriminated against or experienced retaliation for complying with or attempting to comply with WPS requirements, or for providing information regarding violative behavior. Check Yes if this is correct.

DISPOSITION OF INSPECTION

Describe or list any suspected or documented violations of the WPS identified during this inspection. Attach documentation for all suspected violations.
Inspector Signature

COMMERCIAL PESTICIDE HANDLING ESTABLISHMENT

A. RECORDS REVIEW

Handler Training Records
Current handlers trained in past 12 months?
Records retained on the establishment for 2 years? (Handler name, signature, date of training, EPAapproved materials, trainer’s name, trainer’s qualifications, name of handler employer)
Respirator Safety Records
Are Respirator Safety Records retained on establishment for 2 years?
Have handlers received medical clearance, fit testing, and training for required respirator?

B. MINIMUM AGE FOR HANDLERS

Are all handlers at least 18 years of age?

C. WPS PESTICIDE APPLICATIONS

Identify recent WPS pesticide applications through a record review, interview and/or visual inspection of
products in storage and record as appropriate to facilitate the inspection: Product name/#, Date applied, Method of application, Special requirements, weather conditions during application, PPE required, REI
Specify product name
Date applied
Method of application
Special requirements
Weather conditions during application
PPE required

D. INFORMATION EXCHANGE

Where applicable, does the agricultural employer give the location and description of treated areas or REIs and restrictions in those areas where applications are or will be made on their establishment to the\ commercial pesticide handler employer?
Does the commercial pesticide handler employer provide this information about the areas with entry restrictions to the handler who worked on the agricultural establishment?
Does the commercial pesticide handler employer\ inform the agricultural employer of: location and description of areas to be treated, date and time of application, product name, registration number, active ingredient, REI, requirement for oral and/or written notification, and any other restrictions?
If there are changes to the location or description of the area to be treated, the REI, the notification requirements, restrictions or use directions, or if the start time will be earlier than scheduled, was updated information provided before the application? If there were changes to any other information, was updated information provided to the agricultural employer within 2 hours after completing the application?

E. KNOWLEDGE OF LABELING AND APPLICATION SPECIFIC INFORMATION 170.503

Before a handler performed any handler activity, did the handler employer ensure the handler read applicable portions of the label on safe use or was informed in a manner the handler can understand?
Did the handler have access to the label at all times, and was the handler aware of any entry restrictions, AEZ and REIs?

F. HANDLER DECONTAMINATION AND EYEWASH SUPPLIES

Are decontamination supplies located at mixing sites?
For all other handler tasks, are decontamination supplies located within 1/4 mile from handler or nearest place of vehicular access? Are the supplies located outside a treated area or area under a REI or in a closed container protected from pesticide contamination?
Are the appropriate decontamination supplies provided? including 3 gallons of water provided for each handler (at the beginning of work period and replenished to maintain adequate supply), soap, single use towels, and a change of clothes?
At each mixing/loading site for products requiring eye protection or using a closed system under pressure is there an appropriate eyewash system immediately available to a handler? (Either a system to deliver gently running water (at a rate of 0.4 gal/min) for 15 minutes or at least 6 gallons in containers suitable for providing a gentle eye-flush for about 15 minutes)
Does each handler have at least one pint of water immediately available in a portable container when pesticide label requires eye protection?

G. PERSONAL PROTECTIVE EQUIPMENT (PPE)

For pesticide products on site and/or recently applied
Did the handlers use the clothing and PPE specified on the product labeling?
Did the handler employer provide clean, operational PPE to the handler to meet label requirements?
Did employer assure that handler wears and uses PPE correctly, and before each day of use, is the PPE inspected, and repaired or discarded as appropriate?
Is the PPE properly cleaned and thoroughly dried before storage? Is clean PPE stored separately from personal clothing and contaminated areas? Is there a clean place for putting on and removing PPE?
If using particulate filtering facepiece respirators, are they replaced appropriately? (i.e., breathing resistance excessive; filter is damaged; according to respirator or product label; after 8 hours of use)
If using vapor-removing canister/cartridge respirators, are they replaced appropriately? (based on odor, taste, irritation; breathing resistance excessive; according to respirator or pesticide product label; after 8 hours of use)

H. PESTICIDE HANDLING EQUIPMENT

Before use, did the handler employer Instruct handlers in the safe operation of application and mixing/loading equipment and inspect and repair application and mixing/loading equipment before each day of use?
Has any person employed by the commercial pesticide handling establishment, who cleans, repairs, or adjusts the pesticide equipment, been trained as a handler?
If persons not employed by the commercial pesticide handling establishment clean, repair, or adjust the pesticide equipment, are they provided with the following information: that the equipment may be contaminated; potential harmful effects of pesticide exposure; how to limit exposure; and how to wash to remove contamination?

I. APPLICATION RESTRICTIONS AND HANDLER PROTECTIONS

Do all handlers observed by the inspector appear to be over 18?
Did the handler suspend application because someone was in the AEZ? and was the application continued properly?
Was each pesticide applied so that it did not contact, either directly or through drift, anyone except appropriately trained and equipped handlers?
If toxic “skull & crossbones” products were used was contact made at least every 2 hours by voice, sight or another appropriate method?
If a fumigant was applied in an enclosed space, was continuous visual or voice contact with another handler equipped with PPE maintained? Did the handler outside the enclosed space have immediate access to required PPE in case a rescue is required?

J. EMERGENCY ASSISTANCE

Has a handler experienced potential pesticide exposure during or within 72 hours after employment?
Was transportation to an emergency medical care facility provided and information (SDS, circumstances of application and exposure) provided to medical personnel?

K. ANTI-RETALIATION

Based on information available, no person was threatened, intimidated, coerced, discriminated against or experienced retaliation for complying with or attempting to comply with WPS requirements, or for providing information regarding violative behavior. Check Yes if correct.

DISPOSITION OF INSPECTION

Describe or list any suspected or documented violations of the WPS identified during this inspection. Attach documentation for all suspected violations.
Inspector Signature

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A. AGRICULTURAL ESTABLISHMENT INFORMATION

OWNERS OF AGRICULTURAL ESTABLISHMENTS AND IMMEDIATE FAMILY

B. APPLICATION RESTRICTIONS

C. ENTRY RESTRICTIONS AFTER APPLICATIONS

D. INFORMATION EXCHANGE

E. ENTRY RESTRICTIONS

•Limited Contact Exception

•Short Term Activity Exception

•Agricultural Emergency Exception

F. PERSONAL PROTECTIVE EQUIPMENT (PPE)

AGRICULTURAL ESTABLISHMENT

B. RECORDS REVIEW:

•Safety Training Records

C. MINIMUM AGE FOR HANDLERS AND EARLY ENTRY WORKERS

D. INFORMATION DISPLAY

•Location of the “Central Display”

•WPS Safety Information Display

•Pesticide Application and Hazard Information (SDS) Display

E. KNOWLEDGE OF LABELING, APPLICATION- AND ESTABLISHMENT-SPECIFIC INFORMATION

F. WORKER DECONTAMINATION

G. HANDLER DECONTAMINATION AND EYEWASH SUPPLIES

H. APPLICATION AND ENTRY RESTRICTIONS AND HANDLER PROTECTIONS

I. NOTIFICATION AND ENTRY RESTRICTIONS

•Entry Restrictions after Applications

•Posting & Notification

J. INFORMATION EXCHANGE

K. PERSONAL PROTECTIVE EQUIPMENT (PPE)

L. PESTICIDE HANDLING EQUIPMENT

M. EARLY ENTRY

•Entry Restrictions

•No Contact Exception

•Limited Contact Exception

•Short Term Activity Exception

•Agricultural Emergency Exception

N. EMERGENCY ASSISTANCE

O. ANTI-RETALIATION

DISPOSITION OF INSPECTION

A. RECORDS REVIEW

B. MINIMUM AGE FOR HANDLERS

C. WPS PESTICIDE APPLICATIONS

D. INFORMATION EXCHANGE

E. KNOWLEDGE OF LABELING AND APPLICATION SPECIFIC INFORMATION 170.503

F. HANDLER DECONTAMINATION AND EYEWASH SUPPLIES

G. PERSONAL PROTECTIVE EQUIPMENT (PPE)

H. PESTICIDE HANDLING EQUIPMENT

I. APPLICATION RESTRICTIONS AND HANDLER PROTECTIONS

J. EMERGENCY ASSISTANCE

K. ANTI-RETALIATION

DISPOSITION OF INSPECTION

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