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9. Chemical Hygiene Plan

USDA-ARS NCGR 33447 Peoria Road

Corvallis, OR 97333-2521 Phone: 541.738.4200 FAX: 541.738.4205

Kim Hummer, Research Leader Kim.Hummer@usda.gov

We have reviewed the attached plan. Kim E. Hummer, Research Leader/Curator Date Jeanine DeNoma Plant Physiologist, Unit Chemical Hygiene Officer Date

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A. General Plan Introduction

The following Chemical Hygiene Plan (CHP) was developed to fulfill the safety standards set forth by the Occupational Safety and Health Administration (OSHA) (40 CFR 1910.1450). The purpose of the report is to create and maintain a safe working environment and limit the exposure of personnel to hazardous chemicals/situations in the laboratory. This CHP was expressly written for use at the USDA-ARS National Clonal Germplasm Repository, Corvallis, OR.

Sources The sources used to compile this CHP include: Chemical Hygiene Plan; University of Minnesota, January, 1991&1992 Hazardous Chemical Waste Management; University of Minnesota, 1990 Chemical Hygiene Plan; USDA-ARS, SWMRU, February, 1991 National Research Council Recommendations Concerning Chemical Hygiene in

Laboratories; Federal Register, Vol. 55, No. 21, 40 CFR 1910.1450 Prudent Practices for Handling Hazardous Chemicals in Laboratories; National

Research Council, 1981 Employee Right to Know Standards, Minnesota Department of Labor and Industry,

Chapter 5206, 1983, 1988, 1989 Legislature Session

Scope and Limitations This CHP is limited in content and context to procedures, chemicals and equipment currently in use at the National Clonal Germplasm Repository, Corvallis, OR. It is the intent of the authors to provide as complete guidelines as possible and to adopt and modify the guidelines as equipment and procedures change in this laboratory.

Training

"Technically Qualified Individual" (TQI) or a "Non-Technically Qualified Individual". The requirement for being a TQI involves the individual having a B.S. degree and/or 2 years of laboratory experience with hazardous materials. If an employee does not meet these requirements, they will need to participate in a safety training session prior to the beginning of work in the laboratory. The initial training sequence required is as follows: 1. Mandatory review of the safety notebook with emphasis on chemicals and safety in a laboratory environment. For headhouse and field employees, appropriate sections of the safety notebook will be reviewed. 2. Discussions with the supervisor where the employee can ask questions and also relate previous laboratory experiences to the supervisor. Also, at this point, the supervisor should tour the lab with the person to show them particular hazards (ovens, appliances, chemical storage, and chemical waste). 3. The supervisor will show the employee where the safety showers and emergency eye wash stations, first aid kits, Automated Emergency Defibrillators (AEDs), fire extinguishers, fire alarm and pull stations, Personal Protective Equipment (PPE), and lab safety equipment

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(i.e., fume hood, spill kit) are located and instruct the employee how to use these items. Location of fire exits and procedures during fire alarms are also discussed. 4. The supervisor will show the employee the laboratory binder of Safety Data Sheets (SDS) that relate to those chemicals used and stored in the laboratory. Employees will be shown this CHP and advised to read and sign that they have read it. The employee should become familiar with the handling methods, PPE needed, how the body is affected by the chemical and other important information outlined on the SDS of each chemical used in the laboratory analyses they will be working with. As the individual progresses on to new analyses, they should re-consult the SDS for any new chemicals that will be used. 5. The supervisor will show the employee Job Hazard Analyses (JHAs), Hazard Communication Plan, Occupant Emergency Plan, Chemical Inventory, Lab floor Plans, Lab Door Signs 6. Once all these steps have been taken, the safety form is signed by the employee and supervisor and filed in the facility office. A separate form should be signed and given to the ARS Location Administrative Officer. Future training need not take on as formal a sequence as the initial training schedule discussed above. The Corvallis ARS Location has scheduled safety meetings and presentations annually and employees are urged/required to attend these. Personnel should have additional safety training as new chemicals, equipment or procedures become part of the laboratory environment. Laboratory Safety Guidelines Specific Standard Operating Procedures (SOP's) used for each laboratory analysis performed in this lab are located in the "Lab Procedures" binder in the Safety Manual in each lab. Following are some general safety issues: Personal/Personnel Items: ++Wear eye protection and gloves at all times when working with chemicals. Additionally, a lab coat is strongly recommended. ++For safety considerations, loose clothing (sleeves, neckties etc..) long hair and dangling

jewelry should be restrained. ++Footwear should cover feet completely; no open-toe shoes should be worn in the lab. ++Wear a laboratory coat or apron to protect skin and clothing from chemicals. ++All buildings at the Repository are no smoking areas. ++Food and drinks should not be kept in the refrigerator and freezers located in the labs.

There is a food refrigerator located in the head house and one in the library/conference room.

++Keep all drinks in closed containers and confined to the desk area by the telephone. The more prudent thing to do is not bring any drinks into the lab. ++Prudent practice has it that no one should work in the lab alone. The supervisor must approve any independent work in the lab. Also, there should be as minimal as possible unattended operations of lab equipment (including dishwasher and autoclave) ++Do not use eye wash station for a drinking fountain. ++Do not use lab glassware outside of the lab. ++Wash hands thoroughly whenever you leave the lab.

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Safety Equipment: --Fume Hoods --Autoclaves --Eye Wash Stations --Shower Stations --Fire Extinguishers --Fire Alarm Pull Stations --Automated Emergency Defibrillators If there are any problems with any of these items contact your supervisor or a member of the safety committee. ++The exits will be kept clear and easily accessible. ++Do not block access to the shower/eye wash station. ++Do not block any of the above safety equipment. ++There will be an evacuation plan posted at the exits. ++The lab will maintain a laboratory first aid kit to handle minor injuries. This first aid kit

will be easily accessible to all personnel. ++There are a number of lab coats and safety glasses/goggles available in the lab for personnel use. There is also a selection of disposable gloves in various sizes and filtering facepiece respirators (e.g. N95 mask) for voluntary use. These items will be kept on hand at all times so that any employee has a selection of comfortable safety gear available for use. ++Choose appropriate gloves for the chemical being handled. ++There is a chemical spill clean-up kit that can handle Acid, Base, and Solvent spills up to

several liters located in the drawer next to the fume hood in the small lab. A smaller kit, which is located above the sink by the dishwasher in the small lab, can handle minor mercury spills. Detailed instructions on their use are included in each kit.

Fume Hood: The Fume Hood should be used when working with an organic solvent or any chemical that poses an inhalation threat. ++Keep the face opening of the hood at the marked level. ++Never lean into the hood. ++Work 6 inches or more into the hood to keep fumes from coming out of the hood. ++If there is a mechanical problem with the hood do not use and call your supervisor. Chemicals: There are several aspects that must be taken into consideration when dealing with chemicals in the laboratory. These are: 1. Inventory/SDSs 2. Storage 3. Use 4. Disposal

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A. Chemical inventory and SDSs The laboratory and headhouse will maintain a computerized chemical inventory that will show: 1. Chemical name (as stated on the container) and commonly used lab term if

different. 2. CAS number (if available) 3. Date the chemical was received 4. Amount (in terms of L or Kg) 5. Date the container was emptied 6. Disposal method 7. Liquid or Solid indicator 8. Location of storage (refrigerator, freezer, desiccator) 9. Brand Name In addition, each container will be labeled with the date it was received. ++Of special consideration is 95% ethanol. This chemical should be kept in the locked

flammable storage cabinet except for containers, which will be labeled, for regular use.

++Material Safety Data Sheets (SDSs) will be maintained in each lab for each chemical in use or storage. Every effort should be made to keep the SDSs up to date. Orders from chemical companies typically are followed by SDSs. The SDSs will be alphabetized and the chemical name used in the lab will be highlighted for easier identification.

B. Chemical storage Chemicals will be stored according to the recommendations of the chemical manufacturer or supplier. Typically, the catalogs from which the chemical was ordered would state how/where the chemical should be stored. Storage conditions that are available are: Flammable storage in the breezeway Corrosive storage in the breezeway Refrigerated Desiccated Dry (Shelf) ++Incompatible chemicals will be stored in separate locations. Other reactive chemicals will be stored according to their specific requirements. ++Large quantities of flammables (i.e., acetone, ethanol) will be stored in the breezeway (Flammable Storage Cabinet). ++Do not keep ethers, such as diethyl ether, dioxin, or other peroxidizable materials past their expiration date because they can form explosive and shock sensitive peroxides. Outdated chemicals of this sort will be disposed of through the Hazardous Chemical Waste program.

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C. Use of chemicals Every effort shall be made to insure that all containers (both primary and secondary) are labeled following the Global Harmonization System (GHS). Immediate use containers are not covered under this requirement; however, it is good practice to label all containers. Immediate use refers to one work shift by one person. Primary containers are the original containers as shipped from the manufacturer. A secondary container refers to subsequent repackaging by the lab for storage use. Additional information should include date and the name of the person who performed the analysis. ++Toxic and flammable labels can be applied to bottles containing methanol or acetone. ++Laboratory personnel should be aware of incompatible chemicals. ++Do not add water to concentrated acid, rather add acid to water to keep that mixture as dilute as possible. ++Use two hands when carrying a chemical bottle. If the chemical must be transported (i.e., from flammable storage) use a safety carrier or the original box the material was shipped in. ++Never pipette chemicals by mouth. ++Analyze new procedures to pinpoint hazardous areas. Advise workers of plans to carry out hazardous work. D. Disposal of chemicals Each waste material will be packaged alone or only with compatible waste. Consult the location safety committee for additional information. ++Old chemicals no longer needed or past their expiration date should be discarded or recycled to other programs. ++The facility will maintain a written record of the wastes that are disposed of. This record will include: 1. Waste type 2. How much waste was disposed of 3. When the manifest was sent. In addition, a photocopy of the manifest will be kept in the lab. ++If there are questions as to whether a chemical may be disposed of within the lab, consult the safety committee. ++Never throw toxic chemicals in the trash can or dump them down the drain. ++Do not use the fume hood to evaporate off any quantities of solvents.

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Gas Cylinders: ++Cylinders shall have the name of the gas labeled on the cylinder. ++Cylinders shall be stored/used in an upright position. There will be tie down points at all times. Unused or empty cylinders will be stored with the cap installed. Empty cylinders should be called in for pickup as soon as possible. ++Cylinders will be moved only in suitable handcarts. Cylinders will not be moved with regulators attached. Caps must be on. Glassware: ++Glassware should be handled carefully to avoid damage. Damaged glassware should be discarded or repaired. ++Glassware that is broken should be swept up immediately and placed in the glass disposal box, not the garbage can. Once the collection box is full, lab personnel will remove it to the dumpster. ++Every effort will be made to keep glassware clean inside and out. Labels should be removed prior to washing. 95% Ethanol can be used to remove ink and labels. ++Glassware subjected to heat and/or vacuum will be made of Pyrex or of a similar glass type. These containers should be thick walled and should be inspected for flaws prior to use. ++Do not store alkaline (i.e., NaOH) solutions in glass stoppered containers. Experience has

shown that the stopper can become permanently lodged in the neck of the container. Specialized Equipment: Autoclaves: The lab uses the autoclave regularly. Wear insulated gloves when opening the autoclaves. Centrifuge: There is one table-top centrifuge located in Lab B. The operation of this centrifuge is limited to persons who have been trained in its use. Prior Approval for Laboratory Operations The National Clonal Germplasm Repository does not, at this time, use any chemicals which are deemed sufficiently hazardous (by OSHA listings of Hazardous Chemical, Appendix C) to require prior approval. A change in the use of what may be deemed a sufficiently hazardous chemical will require additional training on the use and hazardous of the new chemical.

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Emergency Procedures Chemical spills or hazardous materials emergency situations should be handled on the same level as a fire emergency. RESCUE: ++Evacuate personnel from the spill area. ++Do not enter an area where a chemical spill has occurred. ++Use nearest fire exit, pull fire alarm to activate emergency system (nearest pull alarm is in the hall immediately to the left of the nearest building exit door). ++Attend to victims. First Aid ++Remove victim from spill area to fresh air (do not endanger yourself by entering areas of toxic gases) ++Immediately remove contaminated clothing ++Wash skin with soap and water ++Flush skin and/or eyes with water for at least 15 minutes. ++Get medical attention for victims ++Make sure medical personnel understand exactly what chemicals are involved. CONFINE: ++Isolate area by closing off room. REPORT: ++Call .911 for: --spills that involve injury requiring medical treatment. --spills that involve fire or explosion. --spills which are potentially life threatening. If a chemical spill occurs after work hours (430PM-730AM) contact your supervisor. Consult the safety committee for information on: --spills you do not have proper training or proper protective equipment to do the cleanup. --spills for which you have any question or doubts about your ability to clean up. SECURE: ++Lock all doors leading to the spill site and post warning notices. ++If chemical fumes are being spread through the building's air handling system have the ventilation turned off.

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CLEANUP: If the spill can be handled by the lab personnel with the correct training and proper safety and handling materials: ++Locate spill kit (drawer by fume hood in labs). ++Wear protective gloves and goggles/face shield. ++If need be, wear apron and coveralls. ++If there are inhalation hazards, wear respirator. ++Remove ignition sources; turn off stir plates, hot plates, shut down equipment. ++Confine or contain the spill, cover with absorbent mixture. ++Clean up minor spills with paper towels or sponge if they will not react. ++Sweep solid material into a dustpan, place in sealed container. ++For acids and bases, first add neutralizer, sodium bicarbonate (baking soda) for acids, sodium bisulfate for bases. ++Small amounts of other chemicals use a non-reactive material (sand, vermiculite, cat litter). ++Mercury spills (Do not use mercury thermometers) --Use aspirator bulb or suction device to pick up small quantities. --Do not use a vacuum cleaner. --If necessary mop area with saturated solution of HgX (located by above sink in t.c.

lab) in water. ++Remove absorbent material with broom and dust pan. --Place in plastic bag or other appropriate container. --If the spill is a non-volatile, hazardous chemical, dispose as a hazardous chemical waste. --Wet mop spill areas. Treat all clean-up equipment as hazardous waste --If the spill is a non-volatile, non-hazardous chemical, call the safety committee for advice. Reporting Injury Accidents: Because NCGR includes both state and federal workers there are two different systems for reporting accidents: In General: --Seek medical aid immediately if necessary. --Report any accident to immediate supervisor as soon as possible. For federal employees: --All necessary forms and instructions are located with the secretary and “What a Federal Employee Should do When Injured at Work" is on the safety bulletin board. For state employees: Contact the department of Horticulture at Oregon State University. Medical Consultation and Examination In accordance with the Occupational Medical Surveillance Program (OMSP) established for the Corvallis Location of the USDA-ARS, any employee who is exposed to hazardous chemicals or has a concern regarding his/her health because of laboratory working conditions may see a physician once a year at no cost to the employee. There are appropriate forms for authorization located at the USDA-ARS Administrative Office that must be completed prior to making an appointment to the specified clinic. ++Currently NCGR does not use any of the select carcinogen or reproductive toxins for which OSHA requires chemical monitoring. Any other toxic or hazardous chemical

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will be handled as a solvent would; requiring use of the fume hood and appropriate eye and skin safety equipment.

Reviewing Chemical Hygiene Plan This CHP will be reviewed annually by the Principal Investigator and all personnel. At that time, written revisions will be made and new copies will be placed in the labs and the library. Recommended Reading General Lab Safety-- Prudent Practices for Handling Hazardous Chemical in Laboratories "Occupational Safety and Health Standards", Federal Register, Vol.55, No.22, Rules

and Regulations, Part 1910.1450. Catalogs-- EM Science--excellent reference on storage and cleanup of certain chemicals Lab Safety Supply- excellent source on glove materials and other safety equipment

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THE CHEMICAL HYGIENE PLAN FOR THE NATIONAL CLONAL GERMPLASM REPOSITORY

Dr. Kim Hummer, Supervisory Horticulturist is the Research Leader for the unit. Jeanine DeNoma, Biological Science Research Technician, Unit Safety Officer A. Specifics DEFINITION OF A CHEMICAL HYGIENE PLAN A chemical hygiene plan encompasses procedures, equipment, personal protective equipment and work practices that are capable of protecting employees from health hazards presented by hazardous chemicals used in the work place and meet the requirements of the general occupational safety and health rules of OSHA and EPA. GENERAL CONCEPTS: 1. Protection of employees from health hazards in the lab and keeping exposures below

the limits specified. 2. Hygiene plan is available to employees through the safety manual at the facility. 3. Chemical hygiene plan includes: 1. Standard operating procedures for hazardous chemicals 2. Criteria to determine control of employee exposure. 3. Proper maintenance schedules of safety equipment such as fume hoods. 4. Employee training and information on hazards in the work place. 5. Special approvals required for hazardous procedures. 6. Provisions for medical consultations and exams. 7. Protection for employees working with selected carcinogens, reproductive

toxins and acutely toxic substances. Containment devices, decontamination procedures and waste removal procedures documented.

4. Annual review and evaluation of plan and updating as necessary.

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USDA/ARS, NCGR CHEMICAL HYGIENE PLAN: 1. Laboratory: Standard laboratory chemicals that do not fall under the above categories

may also carry risks. SDS files are maintained in each laboratory and employees should review them for chemicals with which they are unfamiliar. Safe handling of all chemicals should be standard procedure.

2. Field, Screenhouse, and Greenhouse: Pesticide and herbicides are used as indicated

on the label, SDS sheets are maintained for each chemical stored. Protective clothing is worn in all instances and only those with state pesticide applicators or consultants licenses will work with these chemicals.

3. Any employee working with hazardous chemicals can enroll in the Occupational

Medical Surveillance Program (OMSP). This program includes establishment of baseline values, annual checkup with OMSP Doctors, and tests to monitor exposure.

4. Fume hoods and safety equipment such as PPE and showers are inspected for proper

functioning yearly, before use, and weekly, respectively. 5. If specific hazardous chemicals are brought into the work place, the immediate

supervisor of the employee using the chemical and the chemical hygiene officer are responsible for developing a protocol for safe use of the chemical before it is used.

6. Approval from the Research Leader is required for use of specific hazardous chemical

as listed in #1 above. 7. Employee training takes place on a per need basis with general safety training

available on a regular basis. 8. Hazardous waste disposal takes place in a timely, safe manner as designated by the

location safety committee. 9. Shop/mechanical equipment rooms: Refrigerants are used in these areas. Only

federally certified technicians holding refrigerant certification may handle refrigerant in any form.

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B. Pesticide Policy

PESTICIDE POLICY Introduction This is a set of guidelines for pesticide use at the USDA-ARS National Clonal Germplasm Repository (henceforth known as the Repository) in addition to the policy for compliance to the EPA Worker Protection Standard for Agriculture Pesticides. The adoption of these guidelines will improve worker safety and bring the Repository into compliance with 1992 Federal Worker Protection Standard, Code of Federal Regulations, Title 40, Part 170 and the Environmental Protection Agency EPA 735-B-93-001 The Worker Protection Standard for Agricultural Pesticides, 2015 (WPS). Information Availability Pesticide application information is readily available at all times in two external glass encased bulletin boards which are centrally located on the side of the head house wall by the entrance to pesticide mixing room and on the east wall of the storage building on the North Farm. These locations make the information readily available to all workers. The information will also be available for after-hours workers when the office and storage building are not open. The information will include: * EPA WPS safety poster * Name, address, and telephone number of the nearest emergency medical facility * Pesticide application information for 30 days after the restricted entry interval (REI) Including: * Product name, EPA registration number, and active ingredients * Location and description of the treated area * Time and date of application, and REI. Employees of the Repository and cooperators who may be working on Repository grounds are told and shown where the pesticide information is posted during new-worker safety-orientation and at annual-spray safety meetings License Requirements Consultant Pesticides will be applied under the supervision of the Plant Collection Manager, Agricultural Science Research Technician. This individual will hold a valid Oregon Department of Agriculture Pesticide Consultant License. The license will be maintained through state accredited courses given for continuing recertification. Applicators

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Only employees having a valid Oregon Department of Agriculture Public Pesticide Applicator License will apply pesticides at the Repository. Their licenses will be maintained through the state-accredited courses for continuing education and recertification.

Pesticide Safety Training Pesticide Handlers An employee who applies pesticides or comes into direct contact with pesticides is called a "Pesticide Handler." This includes consultants, applicators, and equipment maintenance-personnel. Agricultural Workers Any employee or cooperator who works at the Repository who does not directly contact pesticides is called an "Agricultural Worker." Training for Pesticide Handlers and Agricultural Workers will be provided once a year at the Repository. New employees will be trained at new-worker safety-orientation within five days of beginning work. The person with the Pesticide Consultant License will conduct the training as follows: * Written or audiovisual training materials will be used. * Training will not be done just orally. * The information will be presented in a manner easily understood. * Training will be done in non-technical terms. * Training material will include EPA developed WPS training materials. * The trainer will respond to trainees' questions. Decontamination Sites Decontamination sites will be provided within 1/4 mile of all workers and handlers. For the greenhouses, screenhouses, and the southern fields, the decontamination site is at the end of the headhouse and in the chemical mixing room. A portable decontamination station will be transported to the pear field and the north farm fields. The decontamination sites will have the following: * Water for routine and emergency whole-body washing. * Water for eye flushing. * Soap and single use towels. * A clean coverall for changing clothes. The water at the decontamination site will meet the following criteria: * Safe and cool enough for washing, for eye flushing, and for drinking. * Separate from any water source used for pesticide mixing.

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Decontamination stations will be used at all mixing and loading sites. Whether or not the applicator is within 1/4 mile of the headhouse. The decontamination station will not be in the treated area or in an area that is in a REI. Supplies for these sites or station will be kept in enclosed plastic containers. Applicators will be responsible for filling and emptying the tank on the portable decontamination station with each use. Personal Protective Equipment Applicators will use all Personal Protective Equipment (PPE) as specified on the label of the pesticide being applied. On old pesticide labels the proper PPE may not be listed. In such cases the PPE will be rubber boots, cotton coveralls, eye protection, (face shields, protective goggles, or side shielded safety glasses) and an approved respirator. When using pesticides with a "Danger" label, a rubber or disposable Tyvek type spray suit will be used with the other PPE. Cotton coveralls are not acceptable for an application of a "Danger" label pesticide application. Each year at the beginning of the spray season each pesticide applicator will have a fit test for their respirator. A written record will be kept of the test. Instruction will be given for proper repair, cleaning, and adjustment of PPE. Applicators will be responsible for the care of their PPE issued to them. This includes: * That the PPE is clean and in good operating condition * Inspection checks before each day of use * Repair or replace PPE as needed * Used PPE will not be worn or taken home * The PPE will be worn and used correctly * Replacement of dust/vapor removing cartridges at the end of each work shift that it used. PPE will be stored in an area that is pesticide-free. Two metal cabinets are provided for this purpose in the headhouse at the main office complex. One will be for the storage of respirators, repair parts, and replacement filters. An area will be labeled in the cabinet for each applicator to keep their respirator. This area will also hold new unused Tyvek spray suits. The second cabinet will be for clean cotton coveralls to be stored in one section and one section for used, but not contaminated coveralls, to be hung in. The North Farm has a metal cabinet in the storage barn. This is used for general PPE Storage and short-term storage of applicators' respirators. Users of Tyvek suits can put their names in on them for reuse later. Tyvek suits used for "Danger" restricted use pesticides will neither be reused nor restored in the PPE cabinet.

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Cotton coveralls will be provided for PPE. These can be used for most applications. A washer and dryer are available. Applicators are expected to launder their own soiled suits soon after use. Care should be used in handling contaminated suits to avoid the harmful effects of exposure. Rubber gloves will be used when loading the washing machine. The washing machine will run at the highest water level and at the hottest temperature setting. A second cycle without any clothing will be run to rinse the machine. Tyvek suits or rubber rain type apparel will be supplied and required for some applications. Any application of a "Danger" labeled pesticide will require a suit of this type. Certain other applications will also require these suits. Vapor producing pesticides like Casoron require this type of protection to prevent contamination of clothing. Soiled rubber suits can be washed and the Tyvek suits thrown away. Emergency Assistance Transportation and a driver are always available to take people in for medical attention. In extreme exposure situations contacting outside help by dialing 911 may be preferable. We are very close to the sources for the EMT responses. When a person is taken in to be treated the information about the pesticide will be made readily available to aid in treatment. This information will include the following: * Product name, EPA registration number, and active ingredients of the product or products exposed to * Any antidote, first aid, statement of practical treatment or emergency information from the

product * A description of the application method and how the accident or exposure occurred Pesticide applicators working on the north farm or in the pear field will take a VHF radio with them. This will allow them to call for emergency help on channel 16. All employees will be trained in the radio operation either during new-worker safety-orientation or during the safety meetings. When a pesticide handler is working in one of these areas for longer than two hours they are required to check in on the radio. The Repository uses channel 82 that is an open general-use government channel. Pesticide Spills Three factors must be considered if a pesticide spill occurs. First and foremost is human safety. The person at the spill must consider their own safety as they determine a plan of action. The safety of others comes next. If their or others safety is in question then outside help needs to be called. The second factor to consider is property damage is going to occur and if it can be prevented by the person. If damage cannot be prevented outside help should be called to prevent or minimize the damage. The third factor involved is to determine the risk of environmental damage. Again if damage cannot be prevented by those on the site, outside help should be called in. Each of these factors involves value judgments. If each of these factors is determined non-critical then the clean-up can be handled on-site. There are cleanup supplies stored in the pesticide storage area. Those doing the clean-up must wear the proper PPE for the material involved. The material cleaned up will be treated as hazardous waste and disposed of in the proper manner.

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Health Monitoring All employees that are pesticide handlers can participate in the Occupational Medical Surveillance Program (OMSP). If the employees’ duties require the use of a respirator then they must participate in the program to determine if they are medically qualified to use a respirator. The intent of the program is to detect medical problems associated with exposure on the job and to find corrective solutions. Application Notification All fields, greenhouses, screenhouses, or treatment areas will be posted when pesticides are applied. When the pesticide label requires oral warnings this will also be given. The guidelines for posting are as follows: * WPS- design warning signs will be the only signs used. * Greenhouses will post the front entrance and the rear door will be locked. * Fields will be posted at all four corners. * Irregular shaped fields will be posted at the established entry routes, both driving & walking. * Posting will occur not more than 24 hours prior to the scheduled application. * Signs will remain posted during the application. * Signs will be removed within three days after the restricted-entry interval. Restricted-Entry Interval The restricted-entry interval is the time immediately after a pesticide application when entry into the treated area is limited. The REI is listed on pesticide label. When tank mixes are used the pesticide with the longest REI will be used. In general there will be no entry during the REI. The two exceptions are as follow: * Early entry with no contact with the plants if the following conditions apply: * Inhalation levels are below the level listed on the label * Worker will not touch or be touched by any pesticide residue including: * residue on agricultural plants or weeds * residue on soil or planting medium. * residue in water such as irrigation or standing water.

* residue in the air that is still suspended after the application. * No-contact early-entry workers do not have to be provided the special protection required for other early entry workers. But they must be provided the same protections as given to agricultural workers. * Early entry with contact for short term, emergency or specially excepted tasks. There will be only three situations when this will occur: * Short term tasks that last less than an hour and do not involve hand labor. * Emergency tasks that take place because of an agricultural emergency. * Specific tasks approved by the EPA through a formal exception process. Shadehouses

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Special application restrictions apply to nurseries under the WPS. The shadehouses are our equivalent of a nursery situation. When an application is sprayed upward or uses a 150 P.S.I. spray pressure the treated area plus 100 feet in all directions will be within the REI area. The same is true for applications of Fumigants, Smoke bombs, Mists, and Fogs. These types of application are rare. Applications applied downward using spray heights greater than 12 inches from the target or fine sprays or spray pressures between 40 - 150 P.S.I. will include an area 25 feet in all directions as an REI area. If the pesticide label requires an applicator to wear a respirator then the REI area will also be 25 feet in all directions. The applications most common in the shadehouses will require the 25-foot REI area. Any other applications will require the REI area be the treated area only. Greenhouses Special application restrictions apply in greenhouses. If a fumigant is used the REI area will be the entire greenhouse plus the headhouse since it cannot be sealed off from the treated area. Smoke, mist, fogs, or aerosols will require the closing of the entire greenhouse area. Other than the above-mentioned situations, applications using pesticides that require a respirator will close the entire greenhouse. Special ventilation is required in each of these applications. Before anyone is allowed to enter one of the following must occur: * 2 hours of ventilation using fans or other mechanical ventilation systems * 4 hours of passive ventilation such as vents, windows * 11 hours of no ventilation followed by one hour of mechanical ventilation. * 11 hours of no ventilation followed by two hours of passive ventilation Other special pesticide application restrictions in greenhouses that do not require special ventilation are as follows. When applications use a spray height greater than 12 inches, or fine spray, or greater than 40 P.S.I. spray pressure then the REI will be the treated area plus 25 feet in all directions. If the application is done in any other manner then the REI area is the pesticide treated area only. In keeping with our Integrated Pest Management program, monitoring will provide early detection of pest problems. Early detection will allow for better selection and the ability to choose softer pesticides. Spot applications will be done with low pressure medium sized droplets within one foot above the plants using a pesticide that does not require a respirator and only the treated plants will be in the REI area. For spot applications that do not meet these requirements the plant material will be moved to the spray booth or greenhouse 4 in the spray room. If there are too many plants to move, the application will take place in the greenhouse and higher restrictions will apply as described above. Pesticide Storage There is a pesticide storage locker at each farm with positive pressure ventilation systems. These are steel chemical lockers that have negative air pressure and are vented high to the outside. The doors are kept closed unless material is being moved in or out. One locker is for herbicides and one is for insecticides and fungicides. The North Farm pesticide storage locker is in the tractor storage building. The pesticide storage at the main office site is in the soil storage room. The intent is to have pesticide storage at both farms and to minimize transportation of concentrate between farms. Sizes of pesticide inventories are a concern at the repository and the intent is to keep inventories low and to purchase in quantities that will

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be used quickly. Pesticide purchases will be made according to the needs of each farm and materials taken to each farm. An inventory is kept of the pesticides on hand at the repository on a computer database. Every six months a physical inventory will be taken of the pesticides. When new material is acquired the person bringing it in is responsible for updating the database and obtaining the SDS for the file. When new material is purchased consideration will be given to the quantity needed. Only quantities that will be used up in one year will be purchased. This is a more costly method to purchase pesticides but it has many benefits. There is reduced storage and record keeping. Materials are fresher and containers remain intact and are safer to handle. Registration is current on the products. Smaller containers are easier and safer to handle. Empty containers will be cleaned before disposal. Plastic and metal containers will be triple rinsed or flushed until clear. These containers will have the word 'WASTE' written across them in big letters. The containers will be taken to the container storage area on Oregon State University Lewis Brown Farm for recycling. Plastic sacks will be disposed according to the label. Tools to puncture and flush the containers for plastic and steel are stored in the outdoor mixing area. All rinse water will be used in the application of the pesticide. Application Record Storage All pesticide application information is stored in several forms. The original paper copy that the applicator writes is retained in office files. The information is transferred to a computer database once each year. Pesticide safety To meet EPA Worker Protection Standards a portable emergency wash station and drinking water station was built. This station also has a first aid kit attached. Included in the safety equipment are VHF portable radios that are carried by field workers. This allows communications with our office. In the case of a pesticide accident help can be reached quickly. Transportation of pesticides All pesticide applications are mixed on each farm site. Mixed spray solutions will not be transported from one farm to the other. The application equipment that is transported on the public road will be empty. Pesticides used at the north farm will be brought in concentrate form. Pesticide mixing Pesticide mixing practices will be as follows. At the main office complex pesticide mixing occurs at the end of the head house next to the emergency shower and the pesticide storage area. On the North farm the mixing is to take place at the side of the field where the application is to take place. Water will be obtained from the irrigation system. Backpack sprayers can be mixed in the field on the back of a vehicle if all the safety requirements are met as outlined in the WPS for Agricultural. Pesticides. Mixing must occur where there is a labeled use of the pesticide.

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Pesticide Notification and records Both farms have Pesticide Information Centers. At the main office the center is on the side of the headhouse by the back parking lot. A pesticide board for central posting of spray information is attached to the north side of the headhouse in the main building complex. The fields are posted according to EPA posting requirements. Applications are recorded at the main office central posting board. Equipment cleanup After an application is finished the tank is partially filled with water. This will take place where the application was mixed. The rinsate is agitated in the tank and then the boom and nozzles are flushed until clean. The remainder of the tank is emptied. The whole procedure is done in the field where the application has occurred or in a field that has a labeled use for the pesticide. This way the material is used in an area where there is a legal use. Materials are not flushed in one spot time after time and they will not accumulate in this manner. The rinsate does not have to be collected, stored, and will not be mixed with other types of pesticides. It does not become hazardous material. The same method can be used for cleanup of the exterior of the application equipment.