October 16, 2019

October 15, 2019

Subscribe to Latest Legal News and Analysis

October 14, 2019

Subscribe to Latest Legal News and Analysis

EPA Posts Videos and FAQs on WPS and AEZ

On February 15, 2018, the U.S. Environmental Protection Agency (EPA) added resources to its website regarding the Worker Protection Standard (WPS) and the Application Exclusion Zone (AEZ) requirements of the WPS.  As of January 2, 2018, full compliance is required with all of the AEZ-related requirements in the WPS. The new EPA website resources include:

  • A WPS Frequently Asked Questions (FAQ) document that includes answers to questions on implementation and applicability; training; notification and hazard communication; designated representative; AEZ; minimum age; personal protective equipment (PPE); decontamination; definitions; and exemptions and exceptions;

  • An AEZ Question and Answer Fact Sheet that contains further explanation of the AEZ requirement in the WPS;

  • A video that provides a visual representation of an  AEZ titled Application Exclusion Zone in Outdoor Production Pesticide Applications; and

  • A video that provides a visual representation of an AEZ on field borders titled Application Exclusion Zones on Field Borders for Pesticide Applications.

While many welcome EPA’s guidance on the many thorny issues presented by the WPS and AEZ requirements, some believe that in places, the newly issued guidance raises additional questions and leaves some significant questions unaddressed.  Given the controversy over this rule, this new guidance should be reviewed closely.

©2019 Bergeson & Campbell, P.C.

TRENDING LEGAL ANALYSIS


About this Author

Lisa Campbell, Bergeson PC, Federal Insecticide Fungicide Rodenticide Act attorney, TSCA lawyer, environmental statutes legal counsel, regulation compliance law
Partner

Lisa Campbell founded Bergeson & Campbell, P.C. (B&C®) with Lynn Bergeson. Today her practice focuses on many aspects of pesticide and chemical regulation. She counsels clients on a wide range of issues pertaining to exposure and risk assessment, risk communication, and related legal and regulatory aspects of pesticide programs under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). She also counsels B&C clients on various chemical-specific programs under the Toxic Substances Control Act (TSCA) as well as chemicals regulation and...

202-557-3802
Susan M. Kirsch, Bergeson Campbell, agriculture industry lawyer, commodity grower communities attorney
Government Affairs Advisor

Susan M. Kirsch, Government Affairs Advisor for Bergeson & Campbell, P.C. (B&C®), offers regulatory and technical policy expertise at the local, state, and federal levels to clients in the agriculture and commodity grower communities, including those engaged in pesticide and fertilizer manufacturing, crops and livestock production, biotechnology, seed production, food processing, and bioenergy crops production. Ms. Kirsch assists clients in achieving competitive advantage by developing environmental and water quality compliance approaches that are scientifically defensible and commercially implementable.

With extensive experience working with state and federal environmental regulators, Ms. Kirsch offers clients a broad perspective of agricultural and environmental policy issues, with particular focus on Clean Water Act issues. She provides monitoring and analysis of regulatory and legislative initiatives; development of political strategies for effective client actions; drafting of client comments on proposed regulations; and drafting of congressional testimony, articles, and other documents on specific policy topics.

202-557-3810