OSHA Training, Pesticide Storage

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Pesticide Inspectors’ Forum
Oregon OSHA
Pesticide Storage
Garnet R Cooke
Unfortunately, all pesticide
storage areas don’t look like this:
Some look like this:
Pesticide Storage Violations
• 2009 – 38 out of 394 pesticide related
violations
• 2008 - 58 out of 479 pesticide related
violations
• 2007 - 23 out of 352 pesticide related
violations
• 2006 - 22 out of 275 pesticide related
violations
• 2005 – 23 out of 272 pesticide related
violations
Understanding Pesticide Storage
Requirements – Why is it so hard?
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Multiple Agency Jurisdiction
A universal seal of approval is not available
Resources not readily accessible
The belief that a good storage facility will cost
lots of money
• Difficulties finding solutions
– Fear of calling attention to their facility
– Don’t know who to ask
Multiple Agency Jurisdiction
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Oregon State Fire Marshal
Oregon Department of Environmental Quality
Oregon Department of Agriculture
Oregon OSHA
Local Building Codes
US Environmental Protection Agency
US Department of Homeland Security
Multiple Agency Jurisdiction
• Fire Marshal- Fire – exposures to responders,
neighbors
• DEQ- Spills on land, into water, up in smoke
– ODFW & US Fish & Wildlife
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•
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•
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ODA- Use not consistent with the label
Oregon OSHA- employee exposures
Building codes- tied to fire codes
US EPA – following label
US Homeland Security – not abetting terrorists
Financial Costs &
Pesticide Storage
• Crop loss from inadvertent contamination in
storage
• Loss of pesticides due to fire
• Environmental cleanup costs > $1000/hour
• Loss of pesticides due to theft
• Liability to neighbors
• Equipment & structure loss
• Insurance costs
Pesticide Storage : First Steps
• Growers need to conduct an inventory of the
pesticides they have.
• OR-OSHA has different regulations for general
use pesticides and restricted use pesticides.
– General Use: OAR 437-004-1680 (1-5)
– Restricted Use: OAR 437-004-1680 (1-9)
• If restricted use products are present the rule
applies to all pesticides in storage (437-0041680(1-9).
• Oregon OSHA looks for HAZARDS.
OR-OSHA Pesticide Requirements
General Use
-Hazardous chemicals must be stored separately if
they could cause hazardous reactions. Label by
category
Store Pesticides in Accordance
with:
Label, packaging, or MSDS
Signage required for aluminum phosphide
Follow the Label
DO
NOT
STORE
WITH
FOOD
Follow the Label
Do NOT store within 100 feet of a
well
Following the Label
Is hard to do when there
Isn’t one.
Control the Conditions



Excessive freezing or heat
may cause containers to
break, melt, explode, and
some pesticides to
volatilize, drift, degrade
Use exhaust fans to
reduce temperature,
remove dust and vapor to
the outside
Keep storage area cool
well-ventilated, and dry
Provide Adequate Lighting
Lighting equal to 20 foot candles
 For reading labeling, spotting leaks, and
cleaning up spills
 Use spark-proof fixtures and switches!

OR-OSHA Pesticide Requirements
General Use, cont.
• Storage and removal of
hazardous chemicals
must not cause hazards
to workers.
Personal Protective Equipment
• Do NOT store with
pesticides
• Store PPE away from
Pesticides
Decontamination
• If pesticides are mixed adjacent to the
pesticide storage area:
– Soap
– Water
– Paper towels
– Change of coveralls
– 15 minute emergency eyewash when mixing
Danger or Danger Poison pesticides.
Emergency Eyewash AT MIX SITE
ACCEPTABLE
ACCEPTABLE / PORTABLE
WHEN?? LABEL SAYS:
DANGER
DANGER POISON
NOT ACCEPTABLE
AT THE MIX SITE
OR-OSHA Pesticide Requirements
General Use - Notes
• Electrical wiring must comply with Division 4/S
• When dispensing a flammable or combustible
liquid must comply with Division 4/H
• Chemical storage must comply with
appropriate state and local fire codes, NFPA 34
& Division 4/H
OR-OSHA
Pesticide
Requirements
Restricted Use
Pesticides
Lock the storage
area to prevent
access by
unauthorized
employees.
RESTRICTED USE PESTICIDE
REQUIREMENTS
Store by category, not by the alphabet!
RESTRICTED USE REQUIREMENTS
Seal floors and shelves to prevent the
absorbtion of hazardous chemicals
Pesticide Storage Regulations
Restricted Use
When the storage area
contains enough
chemicals that a leak or
spill could cause material
to leave the confines of
the building, there
must be methods or
means to contain
the material.
SPILLS: Prepare in Advance –
Spills in Storage are
Concentrates!
PREPARE
TRAIN
PRACTICE
LIMITS
ECONOMIC
IMPACT
•Cleanup of some chemical spills may fall under
Division 4/H (Haz Waste Op & Emergency Response)
Spills
• Containers can be
damaged in transit and
can leak, dissolve or be
ripped.
• Receivers should be
aware of these
problems.
• Is there a plan for
addressing these
issues?
Pesticide Spills

PPE requirements vary
depending on the type
of spill.

Growers need to know
their limit: when is the
spill too big to clean up
safely.

Do they have an
outside contractor for
cleanup?
WA Ecology
The 3 C’s
Control - Contain - Clean up
Good Stewardship?
Encourage this:
Confine Empty Containers
When your travels reveal……
Find an Event Near Them
Find an Event
• Pesticides with the following ingredients will be accepted at no charge*
• Chlorpyrifos (Dursban, Lorsban) 2, 4, 5-Trichlorphenol (Silvex, Fenoprop)
Dicofol (Kelthane) Dinoseb (Dinitro, Premerge) Dyfonate (Fonofos)
Bendiocarb (Ficam, Dycarb, Seedox) Azinphos methyl (Guthion)
Chlorfenvinphos Carbofuran (Furadan) DDT Aldrin (Aldrex) Dieldrin
(Dieldrite) Endosulfan (Thiodan, Thionex) Endrin (Endrix) Heptachlor
(Chlorodane) Hexachlorobenzene Lead Arsenate (Gypsine, Security)
Lindane (hexachlorocyclohexane, gamma-BHC) (Agrocide, Benexane)
Mercury-based pesticides (e.g. mercurous chloride, mercuric chloride)
Methoxychlor (Marlate, Chemform, Double-M) Mirex Phosphamdion
(Dimecron) Toxaphene *The first 200 pounds of other pesticides will also be
accepted at no charge. Additional quantities of other pesticides are
accepted at $1.10 per pound.
• Clackamas event: 18,351 pounds from 51 individuals
Site Security
• Is important if the location of the pesticide
storage area is vulnerable to theft.
• Encourage inventory awareness to report theft
immediately of DANGER/POISON products.
• Encourage pesticide storage areas to be in a
secure location, report suspicious activity.
• Keep the storage area locked.
• Inform growers that they don’t want a product
from their farm to be implicated in someone’s
death.
Plan ahead:
WA Ecology
After a Fire
Contact the
Pesticide
Manufacturer
For Assistance!
Not all Haz Mat
Contractors are
familiar with
pesticides!
RESOURCES*
• Designing Pesticide Storage buildings: see the
order form in your handout.
• Fire Codes: State Fire Marshal
• Protecting groundwater: DEQ, Soil & Water
Conservation Districts
• Employee safety & Health: Oregon OSHA –call
for a FREE consultation!
• Old chemicals:
– ODA, DEQ, Soil & Water Conservation Districts
Photo Credits
• Garnet Cooke, Pesticide Coordinator, OROSHA
• National Pesticide Applicator Core Manual,
Washington State University Extension:
Chapter 8.
• Virginia Tech Pesticide Program
– http://www.pesticidepics.org/main.php
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