CropLife America (CLA) calls for the Environmental Protection Agency (EPA) to increase farmworker safety through improved pesticide application training, and withdraw its proposed sweeping revisions to the Worker Protection Standard (WPS). First implemented in 1992, the existing WPS has proven successful in protecting farmworker health and safety. EPA published proposed vast revisions to the rule in March 2014. CLA today submitted comments in response to the proposed revisions.
In the comments submitted by CLA, the association stresses five primary points:
- The current version of the WPS has successfully improved farmworker health and safety over the last 20 years, and CLA supports retention of the current version of the WPS. The proposed revisions provide no practical additional worker protection.
- CLA supports improved farmworker training to reflect the many advancements in pesticide products and application technology that have evolved since 1992.
- Data demonstrates a steep and ongoing reduction in incidents of acute poisoning and a lack of evidence in support of purported elevated levels of chronic exposure concern.
- The cost burden of revising the rule is significantly underestimated by EPA, and is not justified relative to the assumed benefits.
“The original 1992 WPS plays a critical role in supporting the safety of America’s farmworkers, and CLA supports EPA’s efforts to advance farmworker safety,” said Jay Vroom, president and CEO of CLA. “As the crop protection industry continuously improves the formulation and application technology for our products, and invents entirely new and unique products with greater safety factors, the industry supports a practical WPS that enables the safe use of crop protection products according to label directions. Continuous improvements are gained through increased commitment and targeted updates to training, in conjunction with better products and application technology, rather than a complete revision of the WPS program.”
Data demonstrates that the existing WPS is effective in protecting farmworkers. The most recent statistics from multiple sources all demonstrate that the 1992 WPS has been successful in significantly reducing the incidences of worker exposure. The significant advances in science, regulatory requirements and technology used to apply pesticides over the past 20 years are not referenced in the recently proposed WPS revision. All of these advancements must be considered if relevant incremental rule changes are to reflect the contemporary situation in agriculture.
CLA also submitted a commissioned report highlighting the cost benefit analysis of the proposed WPS revision. The report, prepared by Summit Consulting, LLC, finds that the cost burden comparison with the existing WPS is misrepresented by EPA and the added costs for record keeping and training in the proposed revisions are significantly underestimated. The Agency estimates that the cost for the proposed rule will be $196 million, while the report commissioned by CLA found an estimated cost of over $340 million, representing a 75 percent increase over the Agency’s estimation.
Given the points stated above, CLA strongly urges EPA to not proceed in advancing the February 2014 proposed rule, and instead withdraw the rule and focus on improving the necessary training mandated in the current WPS.
“We look forward to working with EPA to find ways to further enhance worker safety, but a revision to the WPS is not the best step forward,” added Vroom. “Farmer organizations, EPA and the crop protection industry all work together to support farmworker health through stewardship programs to improve their wellbeing – let’s do more of that continuous improvement.”
To learn more about CLA’s position on the WPS and access the submitted comments and report, visit www.croplifeamerica.org/pesticide-issues/worker-protection.