Comments
Prepared
for
the
EPA
Pesticide
Program
Dialogue
Subcommittee
on
Worker
Safety
March
21,
2006
The
California
Minor
Crops
Council
(
CMCC)
is
a
coalition
of
18
commodity
groups
and
includes
tree
fruit,
vines,
vegetables,
berries,
and
root
crops.
Our
commodities
have
taken
a
proactive
approach
to
pest
management
in
the
last
decade
by
establishing
aggressive
research
and
extension
programs
to
increase
adoption
of
reduced
risk
pest
management
practices
that
provide
consistent,
economical
pest
control,
while
being
protective
of
consumers,
workers,
and
the
environment.

We
have
reviewed
the
materials
presented
on
February
27
at
the
one
day
meeting
and
are
providing
the
following
comments.
We
look
forward
to
working
with
the
PPDC
as
it
works
through
these
issues
over
the
next
year
and
a
half
prior
to
rulemaking.

I
ssues
of
concern
that
we
believe
warrant
further
discussion
include
the
following:

 
Training
every
2
years
instead
of
5
 
We
need
to
assess
the
practicality
of
this
proposal
along
with
costs
associated
with
increased
training
intervals.
This
issue
needs
further
input,
clarification
and
justification.

 
Hazard
communication
on
all
pesticides
 
According
to
the
information
discussed
on
February
27,
it
appears
that
the
new
rules
would
be
expanded
to
include
all
pesticides,
not
just
Restricted
Use
Pesticides.
This
issue
needs
further
clarification,
input
and
justification.

 
Exemptions
to
Regulations
 
Activity
Based
REIs.
 
It
is
important
that
growers
maintain
the
flexibility
to
enter
fields
as
horticultural
and
pest
management
issues
arise;
these
issues
are
especially
critical
for
high
value,
specialty
type
crops
which
are
much
more
labor
intensive
as
compared
to
field
crops.
This
is
a
critical
issue
for
our
farmers
and
workers.
This
issue
needs
further
clarification,
input
and
justification.

 
Protecting
Children
from
Treated
Areas
­

 
Cost
analysis
for
training,
including
staffing
in
times
of
state
cutbacks
 
how
do
we
resolve
this?
Implementation
plans
for
improved
worker
and
applicator
training,
especially
as
new
technologies
are
developed,
is
critically
important
yet
budgets
for
these
programs
are
being
cut
back
in
most
states.
This
issue
needs
to
be
addressed
in
this
process
and
the
costs
to
agencies,
educational
institutions,
cooperative
extension,
and
growers
need
to
be
identified.

 
Stakeholder
involvement
to
this
point:
We
are
concerned
that
very
few
ag
groups
have
participated
in
the
development
of
this
document;
we
request
that
sources
of
input
to
be
expanded
throughout
this
process.
Currently,
the
following
stakeholders
are
mentioned:
CTAG,
Administrative
Law
Judge,
NAAA,
National
Assessment
Group,
OMB,
Advocacy
Groups,
States.
Input
from
Crop
Advisor
Associations
and
Agricultural
Employers
do
not
appear
to
be
consistently
engaged
in
these
discussions.
We
wish
for
the
level
of
input
by
these
and
individual
commodity
groups
We
support
the
Agency
as
it
seeks
to
improve
delivery
of
worker
safety
and
programs
to
communicate
hazards
effectively
to
user
groups.
We
fully
support
the
use
of
stainable
practices,
integrated
pest
management
(
IPM),
and
establishment
of
safety
standards
for
workers.

Thank
you
for
giving
stakeholders
the
opportunity
to
provide
input
at
this
point
in
the
process
and
we
look
forward
to
further
discussions
and
exchange
at
future
workgroup
and
public
outreach
meetings.
It
is
our
sincere
desire
to
support
the
safe
and
effective
management
programs
in
both
the
agricultural
and
urban
landscapes.
If
our
organization
and/
or
specific
commodities
can
be
of
service
in
this
process,
please
do
not
hesitate
to
contact
me.

Respectfully
submitted,

Lori
Berger,
Ph.
D.
Director
of
Technical
Affairs
California
Minor
Crops
Council
4500
S.
Lapina
Street
Suite
214
Tulare,
CA
93274
(
559)
688­
5700
lori@
minorcrops.
org
