in general or to children who work in agriculture. Regional EPA offices have been
inconsistent in setting goals for the number of work inspections that states should
conduct, in defining what constitutes a worker protection inspection, and in oversee-
ing and monitoring the states’ implementation and enforcement of the standards.Establishing Reentry IntervalsThere are currently two approaches for setting reentry intervals. One might be
considered the past approach and the other the future approach. In the first (or past)
approach, the EPA’s WPS established interim reentry intervals based only on acute
toxicity, without any consideration of the crop, the work activity, or the degree of ex-
posure. So if you think in terms of the simple equation that risk is equal to hazard
times exposure (Risk¼HazardExposure), this approach takes into account only
one-half of the equation. However, this approach is the basis for almost all reentry
intervals currently in place in the United States.
In the second (or future) approach, the EPA’s reregistration process requires the de-
velopment of product, crop, and activity-specific reentry intervals based on the risk
associated with any given use scenario. This approach takes into account all aspects
of the equation that risk is equal to hazard times exposure (Risk¼HazardExpo-
sure). This is how reentry intervals are currently being set and will eventually be the
basis for all reentry intervals.
The reentry intervals that are customarily seen on U.S. pesticide labels are set
based on the requirements of the WPS. If a product has acute toxicity by the dermal
route or due to eye or skin irritation, that places it in Toxicity Category I, which is a
forty-eight-hour reentry interval. Toxicity Category II products receive a twenty-four-
hour interval and Toxicity Categories III and IV receive twelve-hour reentry intervals.
The fallacy of this approach is that you may have a high exposure reentry activity
involving a Toxicity Category III product that presents a greater risk than a low expo-
sure reentry activity involving a Toxicity Category I product. Using the WPS
approach, the activity with the higher risk in this case ends up with a shorter reentry
interval.^14Safety Training DeficienciesThe daily dangers posed by pesticides are too often exacerbated by inadequate
communication; agriculture is an industry in which management often does not
speak the language of its workforce. Informing farmworkers by delivering uncompli-
cated safety information in clear, everyday language is often overlooked.
Few occupational groups are more in need of such training than farmworkers. In-
house safety training on farms, when it does happen, is not always offered in a man-
ner workers understand as spelled out in federal regulation. And because trainees are
automatically considered to be in legal compliance at the end of the class, there is
usually no test of actual comprehension. Federal and state regulations require32 | Pesticides