pesticide inspectors’ forum oregon osha pesticide storage garnet r cooke

Pesticide Inspectors’ ForumOregon OSHA

Pesticide Storage

Garnet R Cooke

Unfortunately, all pesticide storage areas don’t look like this:

Some look like this:

Pesticide Storage Violations

• 2009 – 38 out of 394 pesticide related violations

• 2008 - 58 out of 479 pesticide related violations

• 2007 - 23 out of 352 pesticide related violations

• 2006 - 22 out of 275 pesticide related violations

• 2005 – 23 out of 272 pesticide related violations

Understanding Pesticide Storage Requirements – Why is it so hard?

• Multiple Agency Jurisdiction• A universal seal of approval is not available • Resources not readily accessible• The belief that a good storage facility will cost

lots of money• Difficulties finding solutions

– Fear of calling attention to their facility– Don’t know who to ask

Multiple Agency Jurisdiction

• Oregon State Fire Marshal• Oregon Department of Environmental Quality• Oregon Department of Agriculture• Oregon OSHA• Local Building Codes• US Environmental Protection Agency• US Department of Homeland Security

Multiple Agency Jurisdiction• Fire Marshal- Fire – exposures to responders,

neighbors• DEQ- Spills on land, into water, up in smoke

– ODFW & US Fish & Wildlife

• ODA- Use not consistent with the label• Oregon OSHA- employee exposures• Building codes- tied to fire codes• US EPA – following label• US Homeland Security – not abetting terrorists

Financial Costs & Pesticide Storage

• Crop loss from inadvertent contamination in storage

• Loss of pesticides due to fire• Environmental cleanup costs > $1000/hour• Loss of pesticides due to theft• Liability to neighbors• Equipment & structure loss• Insurance costs

Pesticide Storage : First Steps• Growers need to conduct an inventory of the

pesticides they have.• OR-OSHA has different regulations for general

use pesticides and restricted use pesticides.– General Use: OAR 437-004-1680 (1-5)– Restricted Use: OAR 437-004-1680 (1-9)

• If restricted use products are present the rule applies to all pesticides in storage (437-004-1680(1-9).

• Oregon OSHA looks for HAZARDS.

OR-OSHA Pesticide RequirementsGeneral Use

-Hazardous chemicals must be stored separately if they could cause hazardous reactions. Label by category

Store Pesticides in Accordance with:

Label, packaging, or MSDS

Signage required for aluminum phosphide

Follow the Label

DONOTSTOREWITHFOOD

Follow the LabelDo NOT store within 100 feet of

a well

Following the Label

Is hard to do when thereIsn’t one.

Control the Conditions

Excessive freezing or heat may cause containers to break, melt, explode, and some pesticides to volatilize, drift, degrade

Use exhaust fans to reduce temperature, remove dust and vapor to the outside

Keep storage area cool well-ventilated, and dry

Provide Adequate Lighting Lighting equal to 20 foot candles For reading labeling, spotting leaks, and

cleaning up spills Use spark-proof fixtures and switches!

OR-OSHA Pesticide RequirementsGeneral Use, cont.

• Storage and removal of hazardous chemicals must not cause hazards to workers.

Personal Protective Equipment• Do NOT store with pesticides • Store PPE away from

Pesticides

Decontamination

• If pesticides are mixed adjacent to the pesticide storage area:– Soap– Water– Paper towels– Change of coveralls– 15 minute emergency eyewash when mixing

Danger or Danger Poison pesticides.

Emergency Eyewash AT MIX SITEACCEPTABLE

NOT ACCEPTABLEAT THE MIX SITE

ACCEPTABLE / PORTABLE

WHEN?? LABEL SAYS:DANGERDANGER POISON

OR-OSHA Pesticide RequirementsGeneral Use - Notes

• Electrical wiring must comply with Division 4/S• When dispensing a flammable or combustible

liquid must comply with Division 4/H• Chemical storage must comply with

appropriate state and local fire codes, NFPA 34 & Division 4/H

OR-OSHA Pesticide Requirements

Restricted Use Pesticides

Lock the storage area to prevent access by unauthorized employees.

RESTRICTED USE PESTICIDE REQUIREMENTS

Store by category, not by the alphabet!

RESTRICTED USE REQUIREMENTSSeal floors and shelves to prevent the absorbtion of

hazardous chemicals

Pesticide Storage RegulationsRestricted Use

When the storage area contains enough chemicals that a leak or spill could cause material to leave the confines of the building, theremust be methods or means to containthe material.

SPILLS: Prepare in Advance – Spills in Storage are

Concentrates!PREPARETRAINPRACTICE

LIMITS ECONOMICIMPACT

•Cleanup of some chemical spills may fall under Division 4/H (Haz Waste Op & Emergency Response)

Spills

• Containers can be damaged in transit and can leak, dissolve or be ripped.

• Receivers should be aware of these problems.

• Is there a plan for addressing these issues?

Pesticide Spills PPE requirements vary

depending on the type of spill.

Growers need to know their limit: when is the spill too big to clean up safely.

Do they have an outside contractor for cleanup?

CControlontrol - C - Containontain - C - Cleanlean upup

The 3 C’s

WA Ecology

Good Stewardship?

Encourage this:Confine Empty Containers

When your travels reveal……

Find an Event Near Them

Find an Event

• Pesticides with the following ingredients will be accepted at no charge*• Chlorpyrifos (Dursban, Lorsban) 2, 4, 5-Trichlorphenol (Silvex, Fenoprop)

Dicofol (Kelthane) Dinoseb (Dinitro, Premerge) Dyfonate (Fonofos) Bendiocarb (Ficam, Dycarb, Seedox) Azinphos methyl (Guthion) Chlorfenvinphos Carbofuran (Furadan) DDT Aldrin (Aldrex) Dieldrin (Dieldrite) Endosulfan (Thiodan, Thionex) Endrin (Endrix) Heptachlor (Chlorodane) Hexachlorobenzene Lead Arsenate (Gypsine, Security) Lindane (hexachlorocyclohexane, gamma-BHC) (Agrocide, Benexane) Mercury-based pesticides (e.g. mercurous chloride, mercuric chloride) Methoxychlor (Marlate, Chemform, Double-M) Mirex Phosphamdion (Dimecron) Toxaphene *The first 200 pounds of other pesticides will also be accepted at no charge. Additional quantities of other pesticides are accepted at $1.10 per pound.

• Clackamas event: 18,351 pounds from 51 individuals

Site Security• Is important if the location of the pesticide

storage area is vulnerable to theft.• Encourage inventory awareness to report theft

immediately of DANGER/POISON products.• Encourage pesticide storage areas to be in a

secure location, report suspicious activity.• Keep the storage area locked.• Inform growers that they don’t want a product

from their farm to be implicated in someone’s death.

WA Ecology

Plan ahead:

After a Fire

Contact the PesticideManufacturerFor Assistance!

Not all Haz MatContractors are familiar with pesticides!

RESOURCES*

• Designing Pesticide Storage buildings: see the order form in your handout.

• Fire Codes: State Fire Marshal• Protecting groundwater: DEQ, Soil & Water

Conservation Districts• Employee safety & Health: Oregon OSHA –call

for a FREE consultation!• Old chemicals:

– ODA, DEQ, Soil & Water Conservation Districts

Photo Credits

• Garnet Cooke, Pesticide Coordinator, OR-OSHA

• National Pesticide Applicator Core Manual, Washington State University Extension: Chapter 8.

• Virginia Tech Pesticide Program– http://www.pesticidepics.org/main.php