On August 15 NAAA filed comments on the EPA’s proposed revisions to the Agricultural Worker Protection Standard (WPS). In the comments, NAAA outlined concerns we had 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 U.S. Small Business Administration’s (SBA) Office of Advocacy (Advocacy) also submitted comments on the WPS. NAAA worked with SBA Advocacy and issued its concerns with the EPA WPS proposal to help them develop their comments to the EPA.  SBA Advocacy has done a lot of good work on NAAA’s behalf to protect our small businesses from proposed regulations that don’t adequately take into account the unique operating environment of small businesses. SBA Advocacy’s comments included recommending farms be exempt from the 100-foot buffer requirement, removing the requirement that operators share information with non-specified “authorized representatives” and expanding the definition of “immediate family” to include additional relatives that may work on a family-run facility. SBA Advocacy also helped to file down a number of the serrated edges of EPA’s initial proposed National Pollution Discharge Elimination System – Pesticide General Permit (NPDES-PGP) that would have required even more burdensome regulations than those currently imposed on operators.