Comments are due Aug. 18 to the EPA on revisions proposed to its Worker Protection Standards (WPS).  NAAA has drafted comments on the proposal outlining concerns it has with the many  unnecessary and burdensome provisions EPA has proposed. Additionally, NAAA believes EPA's proposal does not take into account the current WPS ability to protect workers and commonplace aerial application industry technology, techniques and practices utilized to protect farm workers and handlers.

The biggest concern to NAAA proposed by EPA’s WPS revisions would require a 100-foot aerial entry restriction area around fields at the time of application regardless of wind direction.  Other concerns include stringent requirements for closed system loading equipment and federal requirements for exchanged communication by an applicator to the farmer within two hours of any programmatic changes to the application.  NAAA’s comments addressing its concerns with the proposal may be found by clicking here.

The Federal Register publication of the proposed rule can be found here.  A summary comparing the WPS proposals with existing standards may be found by clicking here.

NAAA urges aerial applicators to submit individual comments to the EPA expressing concern with the WPS proposal, particularly the 100-foot aerial entry restriction area (see pages 7-11 of NAAA’s draft comments).  To submit comments be sure it is on your company letterhead and identified by docket identification (ID) number EPA-HQ-OPP-2011-0184 (see page one of NAAA’s comments). To send comments electronically visit the link: http://www.regulations.gov/#!submitComment;D=EPA-HQ-OPP-2011-0184-0180

If submitting comments by mail use the following address:

OPP Docket

Environmental Protection Agency Docket Center (EPA/DC)

Mail code: 28221T

1200 Pennsylvania Ave. NW.

Washington, DC 20460