The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) is a foundational law in agriculture that governs the registration, labeling, and safe use of pesticides, with a strong emphasis on protecting applicators, workers, and the environment.
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so next we get into fifra you should
know this one
because it is
phenomenally important in agriculture
the federal
insecticide fungicide and rodenticide
act fifra
that's right up there with fisma food
safety modernization act in terms of
if you're an ag student and you took one
of treyano's classes you should know
those two acronyms uh
uh they're
they're
central to
the laws and regulations of agriculture
agriculture
so fifra 1947 has certainly been amended
numerous times since then
and some of the specifics of
chemicals uh controlled under fifra have
been modified over and over and over and
over again as new scientific data
is learned
but fifra
initially was focused on
pesticide safety and pesticide is an
umbrella term
meaning that it covers a lot of
other types of
biological toxins
manipulators
of a life cycle so there can be things that
that
don't directly kill an organism but
prevent them from reaching sexual
insecticides
that would fall into that category they
don't kill they
they
prevent proper complete
development of their life cycle and the
life cycle is broken anyway
anyway pesticide
pesticide
doesn't matter what the pest is
if it is something that kills or
interferes with
the life cycle of any type of organism
and even some non-organisms
it is
a pesticide so there's fungicides
there's insecticides
rodenticides for rodents
virus sides for viruses that's not
considered a living organism but you
still want to kill viruses
how do you kill something that's not
really living it's
not something i'm going to talk about
in this lecture
but virus sites nematicides for nematodes
nematodes and
and
uh on and on miticides there are so many different
different
specific names things that kill mites
kill nematodes kill insects kill fungi
bacteriocytes kill bacteria and on and
on and on all of them fall under this
umbrella of pesticides
pesticides
and so even though fifra only handles
three of them
technically all of the categories that i
mentioned and i'm sure a few i missed
fall under this umbrella of fifra
bacteriocytes are covered in fifra
at least used in agriculture
that's a different story anyway
anyway
requirements on the labeling one of the
most important things people were using
all of these poisons starting in the 1800s
1800s and
and
there was very little information you
got this bucket of something and it's
killing people
because they didn't know how to use it
they didn't know
how to be safe they didn't know how to
properly mix it so now it has to be labeled
labeled
what's in there and how do you use it safely
safely
who manufactured it who distributed
all of that has to be part of
the labeling of pesticides and that's
just the tip of the iceberg
on fifa but it's one of the crucial
so what about
pesticide applicator safety
here's another acronym ppe
ppe
you want to be in agriculture you better
know that i should i could walk up to
you on the street hey
what's ppe
and you say
personal protective equipment
because of course you know that you're
an ag student personal protective
equipment and that is
all the stuff and maybe more
that this person is wearing and there's
ppe for medical safety
safety
for bio hazards for pesticide safety
for cleanroom safety and manufacturing
computer chips you name it ppe is not
specific to agriculture
anybody who needs to wear
something that is specific to their work environment
environment
must know what the ppe is and in
agriculture it gets a little more
complicated because ppe changes
depending on what chemicals you're using
sometimes you do need a full hazmat type suit
suit
not too often
but sometimes you do
other times you can get by with what you
see here this is clearly not hazmat you
can see the person's hair
their neck i'm sure is slightly exposed so
this is plenty
plenty
for many chemical application uses
however you've got safety goggles or
face shield of some sort you have some
kind of respirator or
breathing lung protection
uh you have some sort of cover chemical
resistant coveralls
somehow
joined to the gloves where they're
tucked into
longer gloves with proper chemical
resistant gloves
chemical resistant rubber boots and i
hope those are chemical resistant rubber
boots i think they are um
um
you don't want to wear leather boots
your leather work boots uh-uh
you want chemical resistant boots
and so this is a person who set up for
agricultural safety now depending on the
chemical you're using the respirator
might change the eye protection might change
change how
how
strong of an eye protection do you need
how what type of respirator filter do
you need well it depends on what i'm
filtering out
some chemicals need one level of
filtration other chemicals need another
do you need a tyvek suit
oftentimes you do but not for every
chemical some chemicals
you just need to cover yourself you
don't necessarily need a chemical
resistant suit uh
uh
what about the gloves
it's not only the material the gloves
are made of
but the fact that gloves should never be lined
lined
for comfort never ever ever use lined
gloves in agriculture
with pesticide use
their problems with lined gloves meaning
they have some fuzzy
cushiony feel good on the fingers type
of material on the inside
but the thickness as well so you might need
need
nitrile gloves of a certain thickness or
you might need
a specific type of rubber chemical
resistant rubber
so when you're working with pesticides
you need to be sure you're using the proper
proper
ppe is this guy working with the proper ppe
ppe
oh hell no no eye protection
wearing a dust mask which
isn't good enough for anything except
dust and maybe
slowing the spread of covid but
it is not for prevention of inhaling
chemicals period
no gloves no
no
tyvek just a hoodie
this is a disaster
this is a safety disaster now
now
hopefully this person is just spraying um
um
a soap solution for aphid control or something
something
otherwise they're in
strict violation
even that you can't spray anything even
soap solution
that you could spray directly in your eyes
eyes
and it wouldn't blind you
could sting a little bit
even that you would be cited by
monterey county
and commissioner's office what is the ppe
ppe
you read the label for everything how to
mix it how to use it
proper application and concentration and
how many ounces per acre
on and on and on read the dang label
you got to think about wind and drift
and there are a lot of factors there
it's one of the biggest problems in
pesticide safety in my experience where
people need to get the job done and
they're out there getting the job done
and where do we live
central coast where it's always windy
salinas valley really windy and
you got to get the job done and so
you want to be able to tell your boss i
and in the process
you're not doing a good job because all
the chemical is supposed to go on your
plants a bunch of it's
being moved downwind
downwind with
with that
that
that wind that's moving through and the drift
drift
can cause problems with workers that are
downwind of you
lots of lawsuits and sicknesses because
some idiot is spraying on a windy day
and is spraying part on the field and
part on the workers downwind of them
stupid dangerous and
has caused lots of problems
and we've also had
cases that i have been involved in where
somebody sprays a really bad
really bad chemical
that starts killing our lettuce because
of wind drift they spray it on their cotton
cotton
when we're growing lettuce seed and it
drifts onto our lettuce and starts
killing our lettuce plants
triple rinsing this is for containers
and you should know that how do you
properly clean a pesticide container
you triple rinse it and there are
appropriate rules for how and where you
do it but essentially you rinse it out
shake it shake it shake it and dump it out
out once
once
do it again and do it again once you
triple rinsed it then you can take it to a
a
chemical container recycling facility
i think they still have one off of
highway 101 [Music]
[Music]
oh what's that called
anyway there's a facility not too far away
away
if you go to highway 101 in castroville
head south to the very next
exit south of castroville um
um supervision
supervision
people who are
doing the sprays need to be properly supervised
supervised
what are the requirements under osha for that
that
actually pesticides safe excuse me that
this is not osha what are the
requirements for the department of
pesticide regulations for supervision
you need to know that if you are the
supervisor and you need to know it if
you're the applicator
my rule of thumb is that if anybody's spraying
spraying
there's always a person nearby always
who knows what they're doing in a
supervisory capacity
and if you schedule things right it's
usually possible
i always found it possible
so that there's
never somebody who's an applicator
that's alone and
and
you check with them on the radio
periodically whatever is necessary if
you're not you know if you're the
supervisor that's not there and you have
an on-site person who is there you still
check in on
the the crew um
um
that's not required under the law you
can leave people alone doing applicator
work as long as you check in with them
uh at intervals appropriate for that
chemical i
still never liked that i always had
somebody somebody was always there
with an applicator
nearby doing something watching the person
person
uh training
i mentioned training already a number of
times you've got to train people before
they start the work
in a level that is appropriate for their task
task
are they a true handler of pesticides
are they an applicator
are they just working around pesticides
after the fact you need to know and then
you have to document
there's the noi another beautiful acronym
acronym
noi is the notice of intent
notice of intent and for some chemicals
you have to give advanced notice
that you plan on spraying this chemical
on a particular field on a particular day
day
um with all the details and then the ag
commissioner is going to come back and
either approve
or not approve of your notice of intent
now usually they approve it because
growers know what they can and can't do
but occasionally it's like no no you
can't do that there's a school too close
which you should have known already as
if you try if you suggest that you're
going to do something or file a notice
that you're going to do something in the
a commissioner's job is to make sure
that you're doing it right
then there's postings where you put
signs up around
all corners of the field so anybody
approaching that field can see
the signs that tell you what was sprayed
when it was sprayed and when you can
re-enter that field
postings are critical and
and
it seems like it's been a long time but
in terms of
modern agriculture it's been not that long
long
i was an adult already when postings
postings
the federal environmental pesticide
control act of 1972 and
and
i guess there should be no surprise the
word environmental and that year that
you're looking at the early 1970s
the environmental protection agency or epa
epa
to ensure that the labeling and
classification of pesticides protected farmers
farmers
farm workers and other persons coming in
contact with pesticides or pesticide residues
residues
so again it's making sure that
that everybody's
everybody's safe
then comes the worker protection
standard wps oh joy
joy
the wps or worker protection standard
states that no pesticide is applied so
as to contact either directly or through drift
drift
any worker or other person other than an
appropriately and equipped handler 1992
yeah i mean to some of you that might
seem like a long time ago that's recent
in agricultural history and it blows my
mind that it took until 1992 to say that
you can't spray a toxic chemical on an
agricultural field
and just inadvertently spray the workers too
and the person doing the spraying is in
full personal protective equipment not
the workers that are 200 feet that way
getting blasted in the face with the
wind and drift it
it
it blows my mind that it took until 1992
to establish the worker protection standard
standard
but here we are
we have it now
and we've had it for
uh at least
some time
the work protection standard applies to
all agriculture
uh there are exemptions for the
operators immediate family so if it's
your kid you can spray them with toxic
poison that's okay
so the exemption doesn't apply [Music]
[Music]
with entry during application you can't
have your kids going unprotected into an
applied area and
and
you can't have them going into a field
during the restricted entry interval rei
rei
another wonderful acronym the restricted
entry interval you need to know all
these acronyms folks i could be on a test
test
so the restricted entry interval is used
a lot in agriculture that is the moment
you spray the restricted entry interval starts
starts
and then you post the field with when the
the
workers can go back into that field
and the restricted entry interval can be um
um
one day two days
two weeks whatever it depends on the chemical
chemical
and you're not allowed to go back in
that field during the rei
unless you have to
in which case you have to put on full
personal protective equipment you know
the full hazmat suit type equipment in
order to go in to repair a pipe or do
something but generally speaking you
spray you just stay out
one last acronym that i want to
give you that
isn't on the screen here but it's p
h i
p as in pre
pre h
h harvest
harvest
i interval the pre-harvest interval
and the pre-harvest interval starts at
the exact same moment
as the restricted entry interval the
moment you spread
so you're done spraying the field you
put up your postings with your
restricted entry interval information
is the date you must wait until you can
actually harvest
that material and that's really important
important
because the
material you can't just
harvest it hold it and then sell it once
the phi has elapsed no it has to stay in
the field attached to the plant no
harvest operations at all until the phi
is expired
and that can be a
a problem it's a scheduling issue so
restricted entry interval is three days
but your phi your pre-harvest interval
is 10 days
well workers can go in and do weeding or
whatever they need to do
after three days but you can't harvest
that material for 10 days
and i've seen it happen where somebody
wasn't paying attention they sprayed
some material
10-day phi
five days later was the scheduled
now for some crops can you hold it for
five days in the field and harvested a
little bit late
yeah for some crops
for most things like lettuce five days
you might as well just disk it now it's
dead and that's what we had to do
when somebody screwed up and you don't
want 80 acres of lettuce two blocks of
lettuce two big blocks of lettuce to be
disked down because somebody whoops
the certification of pesticide
applicators standard
1992 requires the applicator of
restricted used pesticides to be
certified this doesn't mean all
pesticide this is restricted use
pesticides which are the more dangerous
ones the ones we use less and less year
after year because they get more
regulations supplied to them companies
try to avoid them but they're still in
high use
so if you're somebody who's considered
the applicator you're doing tasks that
are performed as an applicator you must
be certified for
for
uh application
now there is again
exemption for operators immediate family
you can personally train your kid and
have them doing certain things they
still should be safe but
your own family members can be
personally trained as opposed to
state certified um
and again
during the application and during the
rei period the exemption for family members
members
no pesticide is applied so as to contact
ah no pesticide is applied so as to
contact either directly or through drift
any worker or other person other than an
appropriately equipped handler [Music]
[Music]
most fifa activities have been delegated
to the states
standards adopted in arizona and
california are more restrictive than the federal
federal laws
laws and
so
in the states fifa is a law
a code
with its code of regulations at the
federal level the states must do this
but what does the
federal government do
they basically hand it over the
responsibility is handed over
to the states now your responsibility do
it here's the rules
you'd go and do it
and so in california we have the
department of pesticide regulations the dpr
dpr
the california department of pesticide regulations
regulations
they're responsible to make sure that
california is doing
everything that meets federal safety requirements
requirements
and so our california legislature has
added a few extra things
that make the workers protection safety standards
standards
higher than are required under fifra so
workers are more protected in california
than they are in
in
most other states or arizona as well
but then what does the department of
pesticide regulation do they say all
right we have to follow
federal fifa law we have to follow any
amendments to fifa that have occurred ever
ever
and we have to follow anything our state
legislature has required for
agricultural pesticide workers safety
and environmental safety
and so then the dpr
dpr
hands off the responsibility the real
boots on the ground work
is the agricultural commissioner's offices
offices and
and
each county or small group of counties
has an agricultural commissioner's office
office and
and
the ag commissioner is responsible to
really enforce
the epa the environmental protection
agency worker protection standard
has 10 standards again
we're looking at another agency involved in
in protections
protections and
and
as usual california's rules are stricter than
than federal
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