Paper Number: 01-1055 An ASAE Meeting Presentation Engineering Controls for Safer Spraying - The Results of a Survey into Awareness and Acceptability Mr. Michael J. Helms Research Support Specialist, Department of Agricultural and Biological Engineering, Cornell University, 330 Riley-Robb Hall, Ithaca, NY 14853-5701, mjh14@cornell.edu Dr. Andrew J. Landers Pesticide Application Technology Specialist, Department of Agricultural and Biological Engineering, Cornell University, 316 Riley-Robb Hall, Ithaca, NY 14853-5701, ajl31@cornell.edu Written for presentation at the 2001 ASAE Annual International Meeting Sponsored by ASAE Sacramento Convention Center Sacramento, California, USA July 30-August 1, 2001 Abstract. Farmers and custom applicators are under great pressure when applying pesticides. An increasing awareness of environmental pollution, along with worker pesticide exposure concerns, has resulted in increased pesticide use legislation. Worker protection is extremely important and engineering solutions to reduce worker exposure are coming to the market place. Exposure to hazardous substances, such as pesticides, should either be prevented or adequately controlled. Control must, so far as is reasonably practicable, be by engineering control methods. In 2000, on behalf of the United States Environmental Protection Agency, Cornell University researchers conducted a survey to consider the level of adoption and awareness of 14 different engineering controls in the US. Mail surveys of 46 equipment manufacturers, 44 state pesticide regulators, 42 state pesticide application training coordinators, and 83 state pesticide enforcement agents were used to determine engineering control availability and use. Keywords. engineering controls, occupational health, pesticide application, safety, safety devices, spraying The authors are solely responsible for the content of this technical presentation. 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Introduction Mortality resulting from pesticide exposure during application to agricultural crops is quite rare in the Western Hemisphere, however numerous medical reports have documented pesticide related illnesses. Proudfoot and Dougall (1988) commented that work related accidents were cause for concern and are generally a reflection of a breakdown in communication, inadequate training or generally poor supervision and working practices. Pesticide applicators recognize the risk associated with handling pesticides. Perry et al (2000) in a survey of operators' attitude to risk found a disturbing number of applicators believed that most pesticides would not be put into the marketplace if they were dangerous to health. Familiarity breeds contempt! They also noted that for those respondents correctly answering 9 to 14 of 18 pesticide safety knowledge items, 98.0% disagree that direct exposure to pesticides is not harmful to human health. Similarly, of those respondents answering 15 to 18 of the knowledge items correctly, 98.6% of the respondents disagreed. Attitudes toward personal protective equipment use were shown not to reflect this concern. The sprayer operator is at risk from splashes of dilute pesticide during the washing out of the sprayer, when folding booms and from spray drift, according to Turnbull et al (1985) and Landers (1989). The time taken to measure and decant pesticides and for adequate washing out of the pesticide containers and the sprayer tank after use is expensive and may well encroach upon the time available for spraying. If the operator hurries these tasks then the chance of contamination increases. Landers and Hill (1996) outlined several engineering solutions for reducing the risk of sprayer operator contamination that could be adopted by farmers. Closed transfer systems, carbon cab filters and tank rinsing systems are cited as good engineering controls to reduce the contamination hazard. As an example of engineering control effectiveness, Brazelton and Akesson (1987) showed that the number of pesticide related illnesses among mixer/loader workers in California decreased by 50% after the introduction of closed transfer systems. Governmental agencies both in the US and abroad have developed regulations on the use of engineering controls to decrease applicators pesticide exposure. In the United Kingdom, the Control of Substances Hazardous to Health Act (COSHH), Regulation 7 (2) requires that prevention or control be secured by measures other than the provision of personal protective equipment (Landers, 1990). Control, as much as reasonably practical, must be by engineering control methods. Protective clothing is used as a last resort. Landers (1989), in his reports to the British Government, noted that California had become the model for many Federal and State laws governing pesticide use. In 1973 the California Department of Food and Agriculture introduced regulations requiring that closed transfer systems be used when mixing or loading Category 1 pesticides. (Category 1 pesticides are those having the signal word "Danger.") Specific criteria were developed later and due to a dearth of equipment, the regulations were not implemented until 1977. Presently, there are no federal regulations that require engineering control use in agricultural pesticide application. The EPA Worker Protection Standard for Agricultural Pesticides does not require engineering control use, but allows an agricultural pesticide handler to omit some of the label required personal protective equipment when using closed transfer systems or enclosed cabs that have built-in respiratory protection (40 CFR 170.240 (2000); EPA, 1993). In a public registration notice to manufacturers, producers, formulators and pesticide product registrants, the EPA (2000) has indicated that in the future, engineering control use may be required as a way to mitigate the risks associated with handling and applying certain pesticides. The type of controls required will depend on the magnitude of the risk and the potential effects from exposure to the pesticide. In 1999 the EPA issued a call for research on the current status of engineering controls in the US. In response to this request, an interdisciplinary team at Cornell University surveyed a network of application equipment manufacturers and distributors, state level pesticide regulatory officials, pesticide applicator training coordinators, and state pesticide inspectors or agents. These professionals were selected to help determine the current level of use and understanding of 2 engineering control methods and the application of engineering controls available in the US. The study took place from January 1 to December 31, 2000. Five areas of potential pesticide exposure and their related engineering solutions were addressed in the survey. A total of fourteen different engineering controls were identified. The risk areas and their engineering solutions are: Loading the sprayer - closed transfer systems, chemical induction systems, direct injection sprayers, container rinse systems Operator contamination at the boom - multiple nozzle bodies, hydraulic boom folding/extending systems, diaphragm check valves, hand wash water supplies Spray drift or contaminated clothing in the cab - cabs with carbon filtration, protective clothing lockers on the sprayer Spray drift - low-drift nozzles, air-assisted booms, twin-fluid (air and water) nozzles Cleaning spray equipment - tank rinse systems. Procedures We developed our mailing lists using several sources. Manufacturers and distributors (from this point on referred to as manufacturers) were identified through professional organization membership rosters, farm publications and the Internet. State pesticide regulatory agency and pesticide applicator training (PAT) coordinator contacts were determined from the membership rosters for their appropriate professional organizations, the American Association of Pesticide Control Officials (AAPCO) and the American Association of Pesticide Safety Educators (AAPSE), respectively. State pesticide inspectors and field agents (referred henceforth as state pesticide inspectors) were identified by randomly selecting ten states and requesting agricultural pesticide inspector or field agent names and mailing addresses from the appropriate state enforcement agency. The states selected were California, Montana, Idaho, Oklahoma, Kansas, Indiana, Ohio, Pennsylvania, New York, and South Carolina. The total number of surveys sent and response rates are provided in Table 1. Table 1. Survey Response Rates Surveys Surveys Sent Returned Manufacturers/Distributors 104 46 State Pesticide Regulatory Officials 50 44 Pesticide Applicator Training Coordinators 50 42 State Pesticide Inspectors/Agents 108 83 Percent Response 44.2 88.0 84.0 76.9 Each survey mailing contained a cover letter explaining the purpose of the study, a copy of the survey form, and a postage-paid return envelope. Postcard reminders were sent out two weeks after the original mailing to those individuals who had not responded. Approximately six weeks after the first mailing, a replacement survey form along with another postage-paid return envelope was mailed to non-respondents. The surveys were tailored specifically to each survey group. The manufacturer survey contained a total of 37 questions. The questions asked about the commodities the sprayers are manufactured for, the areas of the US where the sprayers are distributed, current and future engineering control demands and current engineering control innovations. The bulk of the survey asked manufacturers to identify which sprayer types they manufacture (mounted (three-point hitch) boom, trailed boom, self- 3 propelled boom (including heavy-duty truck mounted), skid mounted, mounted airblast, and/or trailed airblast sprayers) and if engineering controls are standard, optional or not available. The manufacturers provided their responses based on three sprayer sizes: less than 250 gallons, 251 to 500 gallons and 501 gallons and larger. A total of 18 different sprayer categories were created for the survey. Manufacturers were also asked to provide an estimated cost for available engineering controls. State pesticide regulatory officials were asked 8 questions to explore engineering control use requirements in their state. Questions were asked concerning current and future engineering control requirements, number of farm operations using engineering controls, engineering control training and educational materials provided to their field inspection staff. Questions regarding proposed legislation affecting pesticide application systems or handler/applicator safety were also asked. The PAT coordinator survey contained 11 questions. Questions were asked about years of experience in pesticide training, engineering control familiarity, availability of educational materials and educational methods used. Are engineering control training sessions provided to extension personnel and applicators? Are applicators interested in learning about engineering controls and what is their perception of how many farms in their state use engineering controls? The selected state pesticide inspectors were asked to answer 14 questions, most of which were based on their observations of farm operators. The questions related to their familiarity with engineering controls, observations of engineering control use and their recommendations, farm operator engineering control familiarity and attitude toward their use, numbers of farm operations adopting engineering controls, and factors used to select engineering controls. Findings Due to the large number of engineering controls included in the study, this paper will summarize the results for only four of them - closed transfer systems, chemical induction systems, tractor/sprayer cabs with carbon filtration and spray tank rinsing systems. The results for these four engineering controls are fairly consistent with the others in the study. Closed Transfer Systems We found that most manufacturers and distributors see a slight demand for closed transfer systems. As shown in Table 2, these systems are most often offered as optional equipment in 10 of the 18 possible sprayer categories. It should be noted that the survey responses most likely include plumbing systems that allow sprayers to be connected to chemical pumps or bulk containers as well as true closed transfer systems. Closed transfer systems were found to be unavailable on any 250gallon and less self-propelled sprayers or on most of the other sizes of self-propelled sprayers. For companies reporting closed transfer system prices, the average cost is $395.00 per system. The average costs for all sprayer types are provided in Table 3. 4 Table 2. Closed Transfer System Availability (Majority Responses) Percent of Availability Sprayer Type and Size Respondents Standard ----Optional Trailed Airblast - 250 gallons and less 75.0% Mounted Airblast - 251 to 500 gallons 66.7% Mounted Airblast - 501 gallons and above 66.7% Mounted Boom - 501 gallons and above 58.3% Skid Mounted - 501 gallons and above 57.1% Trailed Boom - 250 gallons and less 54.5% Trailed Boom - 251 to 500 gallons 53.3% Trailed Boom - 501 gallons and above 50.0% Trailed Airblast - 501 gallons and above 50.0% Mounted Boom 251 - to 500 gallons 42.9% Self Propelled Boom - 250 gallons and less 100.0% Not Available Self Propelled Boom - 501 gallons and above 58.3% Self Propelled Boom - 251 to 500 gallons 57.1% Mounted Boom - 250 gallons and less 52.9% Table 3. Closed Transfer System Average Cost Sprayer Type Average Cost Mounted Boom $171.33 Trailed Boom $266.00 Self-Propelled Boom $1125.00 Skid Mounted $125.00 Mounted Airblast Not Reported Trailed Airblast Not Reported Only California requires the use of closed transfer systems for the most toxic pesticides (EPA Category 1). No other states are expecting to adopt closed transfer system requirements in the foreseeable future. Most PAT coordinators (90.5%) have at least some familiarity with closed transfer systems. However, in this group, 40.5% of the coordinators responded they are slightly familiar with them. "Very familiar" was reported by only 11.9% of the respondents. Nearly two-thirds of the coordinators (64.3%) replied that closed transfer systems are generally discussed1 in their educational literature. Training that includes closed transfer systems is not provided to most pesticide applicators or extension agents/educators, as reported by 42.9% and 61.9% of the coordinators, respectively. According to the state pesticide inspectors surveyed, they felt that 84.5% of the farm operators have some familiarity with closed transfer systems, 40.3% selecting the "familiar" response. They also noted they see closed transfer systems used most often on up to 25% of the farms they visit. When asked, inspectors felt farm operations of 1001-acres and larger would most likely adopt closed transfer systems. 1 In the survey, a general discussion was defined as a paragraph or less. A detailed discussion was defined as a chapter or entire bulletin or fact sheet. 5 Chemical Induction System Most manufacturers (46.5%) currently see moderate demand for chemical induction systems. As shown in Table 4, induction systems are most often available as optional equipment. Induction systems tend to be unavailable on most smaller sizes (250 gallons and less) of mounted boom, skid mounted, trailed boom and mounted airblast as well as 251-to 500-gallon skid mounted and trailed airblast sprayers. Manufacturers noted an average chemical induction system cost of $720.00. Table 5 summarizes the average costs for chemical induction systems. Table 4. Chemical Induction System Availability (Majority Responses) Percent of Availability Sprayer Type and Size Respondents Standard ----Optional Mounted Airblast - 501 gallons and above 100.0% Self-propelled Boom - 501 gallons and above 75.0% Trailed Airblast - 250 gallons and less 75.0% Trailed Airblast - 501 gallons and above 75.0% Self-propelled Boom - 251 to 500 gallon 71.4% Trailed Boom - 501 gallons and above 68.2% Mounted Airblast - 251 to 500 gallons 66.7% Trailed Boom - 251 to 500 gallons 60.0% Skid Mounted - 501 gallons and above 57.1% Mounted Boom - 251 to 500 gallon 52.4% Mounted Boom - 501 gallons and above 50.0% Mounted Boom - 250 gallon and less 76.5% Not Available Skid Mounted - 250 gallons and less 75.0% Trailed Boom - 250 gallon and less 63.6% Mounted Airblast - 250 gallons and less 62.5% Skid Mounted - 251 to 500 gallons 60.0% Trailed Airblast - 251 to 500 gallons 57.1% Table 5. Chemical Induction System Average Cost Sprayer Type Average Cost Mounted Boom $566.22 Trailed Boom $462.33 Self-Propelled Boom $1150.00 Skid Mounted $573.33 Mounted Airblast $1237.50 Trailed Airblast $1012.50 Currently, no state requires the use of induction systems. Three-quarters of the states surveyed do not expect to require them in the future. The majority of the PAT coordinators are unfamiliar with chemical induction systems with 61.9% indicating so. Most coordinators (66.7%) indicated they do not discuss induction systems in their educational materials. Training that includes information on induction systems is also limited. A high percentage of coordinators (81.0%) noted they have not provided training to extension agents/educators and 73.8% indicated they have not provided training to pesticide applicators. 6 State pesticide inspectors indicated that 59.8% of the farm operators have at least a slight familiarity with induction systems, 36.4% of them selecting the "slightly familiar" response. Chemical induction systems are used most often on up to 25% of the farm operations, as reported by 40.3% of the inspectors. Much like closed transfer systems, most inspectors feel farm operations of 1001-acres and larger would most likely adopt chemical induction systems. Cabs with Carbon Filtration Just under a third of the equipment manufacturers (32.6%) indicated they see a high demand for operator cabs with carbon filters. Only those companies manufacturing self-propelled sprayers were asked to provide cab availability information. Most self-propelled sprayer manufacturers offer cabs with carbon filtration as standard equipment. One company who manufactures 501-gallon and larger self-propelled sprayers offers optional cabs. Another company who builds 250-gallon or less selfpropelled sprayers does not offer cabs at all. Manufacturers were asked if their cabs meet the ASAE S-525 standard for cab environment. Nearly two-thirds of the manufacturers (60.0%) indicate that all their cab systems can meet this standard. Not enough data was provided to accurately assess cab costs. No state currently requires cabs with carbon filtration. California has taken the lead, in cooperation with the EPA, to allow agricultural applicators to use ASAE certified cabs in place of label required respirators. The California Department of Pesticide Regulation has developed a list of cabs meeting this requirement. As for future requirements, nearly three-quarters of the remaining states (72.7%) are not planning any. Minnesota noted that at the time of survey completion, they were working on a policy related to cabs and might have it completed within 6 months. Nearly all of the PAT coordinators (90.5%) indicated they have a slight familiarity with cabs with carbon filtration. In this group, 47.6% said they are slightly familiar and only 11.9% noted they are very familiar with them. The coordinators are divided in the level of information about cabs with carbon filters they provide in their educational materials - 47.6% say they do not provide any discussion while 45.2% say they provide only a general discussion. Only 28.6% of the coordinators have offered one or more training sessions to extension personnel. Pesticide applicators have received slightly more training with 31.0% of the coordinators providing one or more sessions to them. Nearly half of the state pesticide inspectors (49.4%) noted that up to 25% of the farms they visit use operator cabs with carbon filters. The inspectors felt that 84.5% of the farm operators are at least slightly familiar with this engineering control, 48.1% selecting the "familiar" response. Like many of the other controls in the study, most inspectors feel that farms of 1001-acres and larger would be most likely to use cabs with carbon filtration. Spray Tank Rinse Systems Most sprayer manufacturers (39.5%) see a moderate demand for spray tank rinsing systems. Table 6 summarizes tank rinse system availability. Tank rinse systems are only found as standard equipment on 42.9% of the 251- to 500-gallon self-propelled sprayers. The remaining sprayer types show that most companies offer tank rinse systems as an option. Tank rinse systems were found to have an average cost of $718.60 per system. Table 7 shows the average cost for all sprayer types. 7 Table 6. Spray Tank Rinse System Availability (Majority Responses) Percent of Availability Sprayer Type and Size Respondents Standard Self-Propelled Boom - 251 to 500 gallon 42.9% Optional Trailed Airblast - 250 gallons and less 100.0% Trailed Boom - 251 to 500 gallons 81.8% Trailed Boom - 501 gallons and above 81.8% Skid Mounted - 251 to 500 gallons 80.0% Mounted Boom - 251 to 500 gallons 76.2% Mounted Boom - 501 gallons and above 75.0% Skid Mounted - 250 gallons and less 75.0% Skid Mounted - 501 gallons and above 71.4% Mounted Airblast - 251 to 500 gallons 66.7% Mounted Airblast - 501 gallons and above 66.7% Mounted Airblast - 250 gallons and less 62.5% Mounted Boom - 250 gallons and less 58.8% Trailed Airblast - 251 to 500 gallons 57.1% Trailed Boom - 250 gallons and less 54.5% Trailed Airblast - 501 gallons and above 50.0% Not Available ----- Table 7. Spray Tank Rinse System Average Cost Sprayer Type Average Cost Mounted Boom $513.11 Trailed Boom $701.85 Self-Propelled Boom $1100.00 Skid Mounted $939.33 Mounted Airblast $662.50 Trailed Airblast $662.50 None of the states responding to the survey currently require tank rinse system use. Most states (70.5%) noted they do not plan to require these systems in the near future. A total of 81.0% of the PAT coordinators indicated they have some degree of familiarity with tank rinse systems, 40.5% stating they are familiar with them. Just over half of the coordinators (54.8%) noted they provide a general discussion on tank rinse systems in their educational materials. Only 14.3% said they provide detailed information. Nearly half of the coordinators (47.6%) pointed out they have offered one or more training sessions to extension agents/educators that included tank rinse systems. Pesticide applicator training sessions are slightly more available with 54.8% of the coordinators offering one or more training sessions to them. The majority of inspectors (40.3%) noted they see tank rinse systems used on up to 25% of the farms they visit. Only 2.6% of the inspectors reported that all farms they visit use them. Inspectors felt that 87.1% of the farm operators had at least a slight familiarity with tank rinse systems, 37.1% of them selecting "slightly familiar" as their response. Most inspectors feel farms of 501-acres and larger in size would most likely use tank rinse systems. 8 Discussion The survey results indicate that with a few exceptions, most spray equipment manufacturers are not providing engineering controls as standard equipment. For the most part, manufacturers are offering several engineering controls as options. Farm operators appear to have some awareness of engineering controls, but are reluctant to use them despite their availability. Two questions arise from this observation. If the engineering controls are optionally available, what will encourage farmers to purchase an engineering control? How do we get manufacturers and farmers, to buy into safety and the related costs of engineering controls? One way is through federal or state government adoption of legislation requiring engineering control use to be prescribed on the pesticide label. The survey also points out that engineering control education is deficient. PAT coordinators have developed written materials that include engineering control discussions, but the discussions tend to be general (one paragraph or less) in nature. Very few states have detailed engineering control educational materials available to farm operators or pesticide applicators. In a similar vein, engineering control training for pesticide applicators and extension agents/educators is somewhat limited. We would suggest that many pesticide application coordinators do not know where to obtain engineering control information to include in their presentation materials and information packages or to respond to farm operator or pesticide applicator inquiries. Development of web-based engineering control resources and training modules can help to fill this void, educating farm operators, pesticide applicators, and extension agents/educators on the benefits of engineering controls. Another question arising from our research is what is the best combination of personal protective equipment (PPE) and engineering controls that should be used to maximize safety? Concern about this balance may well be seen in preliminary results from a Cornell analysis of pesticide residues in tractor and sprayer cabs. The results have indicated that pesticide residues on the tractor or sprayer seat are 80 times greater than any other part of the cab. It is believed that operators are not removing their chemical resistant suits before entering the cab, therefore transferring pesticide residues from the suit to the seat. This should cause concern since tractors are used for other farm tasks and could result in contamination of unknowing tractor operators. Contamination can be prevented if protective clothing lockers mounted to the sprayer or tractor were used to place contaminated clothing in before operators enter the cab. Conclusion As the results of this study show, spray equipment manufacturers need to be encouraged to provide engineering controls as standard equipment. Manufacturers should also be encouraged to supply a wide array of basic engineering controls for their spray equipment and to promote them on economic and safety grounds. Most states do not require the use of engineering controls stricter than demanded by the federal government. Labeling that requires the use of engineering controls should be considered. Written materials and training programs for applicators and extension agents/educators is somewhat limited. Work needs to be done to develop web-based information resources and training materials to provide adequate engineering control information and training to pesticide applicators and educators. Engineering control use in the field is relatively low. Most engineering controls are used on 25% or less of the farms. The development of nationwide extension educational resources will improve awareness of engineering controls among educators and growers alike, helping to create a demand to satisfy market developments offered by manufacturers. A reduction in operator exposure should result from these efforts. 9 Acknowledgements We wish to acknowledge the EPA Office of Pesticide Programs, Certification and Worker Protection Branch for funding this project and the various participants who responded to our surveys. References Brazelton, R.W and N.B. Akesson. 1987. Principles of closed systems for handling of agricultural pesticides. In Pesticide Formulations and Application Systems: Seventh Volume, ASTM STP 968, ed. G.B. Beestman and D.I.B. Vander Hooven, 15-27. Philadelphia: American Society for Testing and Materials. EPA. 1993. Exceptions to PPE requirements. In The Worker Protection Standard for Agricultural Pesticides - How to Comply, EPA 735-B-93-001, ch. 5, 85-87. Washington DC: US Government Printing Office. EPA. 2000. Worker risk mitigation for organophosphate pesticides, Pesticide Registration (PR) Notice 2000-9. [online]. Washington, DC: Environmental Protection Agency, Office of Pesticide Programs, 2000 [cited 27 April 2001]. Available from World Wide Web at: (http://www.epa.gov/opppmsd1/PR_Notices/pr2000-9.pdf) Landers, A.J. 1989. The effect of legislation on the application of pesticides in the state of California. A report to Her Majesty's Agricultural Inspectorate, Health and Safety Executive and the Douglas Bomford Trust. October 1989. Cirencester: Royal Agricultural College. (In confidence) Landers, A.J. 1990. Engineering control methods - the development of direct injection sprayers. In: COSHH - Engineering Controls in Agriculture. Stoneleigh, September 1990. Bootle: Health and Safety Executive. Landers, A.J and P. Hill. 1996. Solutions for safety. In Tank Mixes and Spraying '96 Supplement, p.S6. Farmers Weekly. February 23, 1996. Vol 124 No.8. Landers, A.J., M.J. Helms, G.L. Good, and R. Gardner. 2000. Survey of engineering control technology for pesticide application, Report to EPA. Ithaca, NY: Cornell University. Perry, M. J., A. Marbella, P.M. Layde. 2000. Association of Pesticide Safety Knowledge with Beliefs and Intentions among Farm Pesticide Applicators. Journal of Occupational and Environmental Medicine. February 1, 2000 42 (2) 187 Proudfoot, A.T. and H. Dougall. 1988. Poisoning treatment centre admissions following acute incidents involving pesticides. Human Toxicology 7, 255-258. Turnbull, G.J., Sanderson, D.M. and Crome, S.J. 1985. Exposure to pesticides during application. In Occupational Hazards of Pesticide Use. ed. G.J. Turnbull, D.M. Sanderson, and J.M. Bonsall, 35-50. London: Taylor and Francis. Worker Protection Standard, 40 Code of Federal Regulations, part 170 (2000 ed.) 10