Worker notification and warning signs
Choose posting or an oral warning from the rule
Check the notification statement on the pesticide label first. If it calls for both posting and oral notification, provide both. For outdoor production, an REI longer than 48 hours requires posting. At 48 hours or less, the federal rule allows posting or an oral warning unless labeling requires otherwise. For enclosed production, the corresponding dividing line is four hours: longer intervals require signs; an interval of four hours or less allows either method under the rule. A greenhouse aisle and an outdoor orchard therefore need separate decisions even when their applications finish together.
The notification exceptions are specific. One concerns workers who will stay out of the entire enclosed structure through the application and REI. Another concerns outdoor workers who will stay out of the treated area and any area within a quarter mile on the establishment throughout that period. A third concerns a handler involved in the application who already knows the required warning information.
Design of the federal WPS sign
The federal WPS sign has a white background and a red circle containing the raised hand and stern face. Its warning uses DANGER and PELIGRO, PESTICIDES and PESTICIDAS, and KEEP OUT and NO ENTRE. The hand, face, lettering and circle have prescribed proportions or minimum sizes. Dimensions are set in §170.409(b)(2)–(3).
The employer may replace the Spanish portion with equivalent wording in the language read by the largest group of workers who do not read English. That alternative must keep the required format and other design features. Additional information, such as a pesticide name or application date, may appear only if it does not detract from the required appearance or change the meaning. Before adding a sticker, check that it leaves the principal warning unobstructed.
A standard sign measures at least 14 by 16 inches and uses letters at least one inch high. Smaller signs have different lettering and circle measurements and require closer spacing. The intermediate option requires signs no more than 50 feet apart around the perimeter; the smallest permitted option requires no more than 25 feet. Those perimeter intervals supplement the required entrance locations. A box of smaller signs may therefore require substantially more installation points than standard boards.
Walk every reasonably expected entrance
For outdoor areas using standard signs, identify access roads, footpaths, other walking routes and borders with worker housing within 100 feet of the treatment. Place signs where they are visible from the reasonably expected entry points. Where there are no such points, post signs at corners or other positions providing maximum visibility. This is a visibility requirement tied to worker access, so a sign facing the highway may leave an internal footpath unmarked.
For an enclosed structure treated in its entirety, check the entrances to the structure or space. If only a subsection is treated, inspect the aisles and walking routes into that subsection. If several contiguous areas are posted together for rotating treatments, worker entry is prohibited throughout the posted area except under the applicable early-entry provision.
Coordinate installation, weather changes and removal
Post before application, but no earlier than 24 hours before its scheduled start. Leave the signs in place during the application and throughout the REI. If weather postpones the treatment, review the posting time against the revised schedule and tell the crew which area is actually restricted. A sign installed for a cancelled job should not be mistaken for evidence that a pesticide was applied.
Remove or cover signs within three days after application or REI ends, whichever is later, unless the extended-posting conditions below are met. Longer posting is allowed only when the employer gives the specified instructions to workers who may come within a quarter mile and ensures that workers stay out while signs remain, apart from permitted early entry. Removing a board early does not shorten an unexpired REI. Leaving one after the interval is over still affects ordinary worker access.
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Deliver an understandable oral warning
When an oral warning is required, use a manner workers understand. Workers present when application begins need the warning beforehand. Workers arriving during the application or an unexpired REI need it at the beginning of their work period. The warning must identify the restricted areas, restriction dates and times, and the instructions to avoid the treated area and application exclusion zone during application. Ordinary entry also waits for REI expiration and removal or covering of treated-area signs, subject to the regulatory early-entry exception.
Handle an unexpected entry request without moving the boundary
If irrigation fails while warning signs are posted, identify the proposed activity before anyone crosses the boundary. Meet that exception’s conditions and the protections in §170.605. Wearing gloves or calling a task urgent does not by itself satisfy an exception. The no-contact exception expressly excludes activities involving contact with treated surfaces even when PPE is worn.
For short-term activities, the regulation prohibits hand labor, limits a worker's time to one hour in 24 hours, excludes entry during the first four hours after application, and requires the applicable inhalation or ventilation criteria to be met. Limited-contact and irrigation exceptions have different time limits and economic-loss criteria.
The provision also requires the applicable state or tribal determination or previously determined circumstances. Mismanagement losses do not count toward its definition of substantial loss.
Build the calculation from the completed application
Record the application’s start and finish dates and times, treated crop or site and location, product identity and label REI. Those facts provide the application-specific foundation for a restricted-entry calculation. They should identify the treatment unambiguously before arithmetic begins.
Separate application exclusion from restricted entry
The application exclusion zone, or AEZ, moves around outdoor application equipment during application. Its size depends on method and spray quality. It can extend beyond the establishment, and handlers must suspend application when people are within the applicable zone. Post-application restrictions continue to concern the treated area after that moving zone ceases to exist.
Verify the narrow family exception before relying on it
For the immediate-family AEZ exception, the establishment owner must provide the required advance information and instructions. Employees and other nonfamily occupants require a different assessment.
Check separate public-notification programs
Washington’s Pesticide Sensitivity Registry has a defined application scope. The registry covers notice for certain landscape and right-of-way applications near listed residences. Agricultural applications do not require notification under that registry.
Recognize the limits of a public notification system
California's SprayDays provides advance information about intended restricted-material pesticide applications in production agriculture. Its coverage is limited to the intended applications included in the restricted-material reporting system. The system obtains information through the restricted-material permitting and notice-of-intent process.
Scheduled applications can be canceled or postponed.
Next step
Read the label's notification statement, calculate the REI from the completed application, and use the WPS notification rule to place signs and deliver warnings.