Greenhouse & Nursery Regulatory Compliance Workshop 2017 – Notes and Resources

Posted on Categories General, Growers, Notes, Programs

Another year and another successful greenhouse and nursery workshop here in Overton. We had many great speakers and are very grateful for our sponsors. I have included some summaries and resources from some of our speakers down below. I have created links below that will direct you to information pertinent to each speaker below. In the case where the speaker has given consent to share their presentation, I have also included that too.

Dr. Shaadi Khademi, MD & Dr. Vanessa Casanova, PhD – Pesticides: Exposure, Health Effects, and Safety Education
UT Health Northeast

Mrs. Kathy (Katherine) Newton – How to Comply with WPS Revisions
Texas Department of Agriculture

TDA Compliance Resources

Dr. Steven Arthurs – Integrated Pest Management for Greenhouse and Nursery
Department of Entomology, Texas A&M University

Mr. Daniel Cunningham – Water U Doing for Texas Horticulture?
Department of Horticulture, Texas A&M University

Pesticides: Exposure, Health Effects, and Safety Education

Dr. Shaadi Khademi, MD & Dr. Vanessa Casanova, PhD
UT Health Northeast

UT Health Northeast does research and education for Ag workers.

  • Role is to keep workers safe through research and education.

Located in Tyler.

Serve the entire state of Texas.

Resources found out in the lobby

Pesticides are in most of our bodies.

Routes of exposure:

    • Inhalation
    • Ingestion
  • Dermal absorption

Different parts of body can differ in amount of pesticide absorption

  • For example, can get 100% absorption in scrotum

Can use biomarkers to measure absorption of pesticides.

Herbicides much lower in acute toxicity than insecticides.


    • Applied to about 92% of all soybean acres and 31% acres of corn
    • No consistent evidence of carcinogenicity
  • Ground water contamination has been reported in the mid-west


    • Widely used in the US but banned in European union
    • Acute human toxicity of atrazine is very low:
        • Possible adverse reproductive effects
      • Possible endocrine disruption
  • No convincing evidence of carcinogenicity

2,4 Dichlorophenoxyacetic acid (2,4-D)

    • One of two ingrents in agent Orange
  • Sufficient dermal and respiratory exposure can result in systemic toxicity


    • Insecticide containing phosphorous
    • Nerve gases (Sarin, Soman, Tabun)
    • Most toxic to vertebrates
    • Does not bioaccumulate
  • Use has declined by over 60% since the early 90s.


    • Work similarly to organophosphates
    • More reversible than organophosphates
  • Not as dangerous in the acute setting

Toxic Mechanism:

    • OPs and Carbamates inhibit ChE which leads to accumulation of acetylcholine at the synapse
        • OPs inhibit ACHE irreversibly
      • Carbamates inhibit reversibly
  • Why it’s important to treat for OP poisoning asap.



    • Rapid growing since 1990’s
  • Toxicology
      • Relatively low toxicity to humans/mammals
    • Nerve stimulant to sympathetic nervous system

Pesticides make up 5 – 10% occur from pesticide use, and about half are accidental.

  • 2,700 cases
      • 28% occupational related
      • 55% accidental exposures
    • 17% suicides


  • Increased fluid secretions in the body
      • Diarrhea
      • Tearing
      • Salivation
      • Slow down heart rate
    • Pupil constriction


    • Cramping
    • Reflexes
  • Increase in health rate


  • Central nervous system
    • Restlessness, …

Do repeated low-dose exposures cause neurotoxicity in humans?


Animal studies typically use doses 100 to 1000 times that of human exposure.

Epidemiological studies have limited ability to measure long-term impact of continued low-dosage exposure.

Hierarchy of controls:

    • Elimination of the hazard (do not use)
    • Substitution (use less toxic pesticides, formulation)
    • Engineering controls (nozzle placement, equipment calibration, mixing tables, etc.)
    • Administrative controls (policies, hygiene, re-entry interval, training, worker monitoring)
  • PPE (appropriate for population)

Reducing risk:

  • FIFRA: Federal insecticide, fungicide, and rodenticide act

Hygiene at work and home!

  • Such things as bringing pesticide exposure home.

When screening for organophosphates:

  • Cholinesterase screening
    • Objectives:
        • Monitor for exposure
      • Establish baseline for diagnosis of poisoning

Additional resources:

Pesticides in Your Path Poster

Bites, Stings and Venomous Things from The Southwest Center for Agricultural Health, Injury Prevention, and Education.

How to Comply with WPS Revisions

Mrs. Kathy (Katherine) Newton, Texas Department of Agriculture

Disclaimer: The notes below are provided as is and are not considered the law. Be sure to check EPA, WPS, and TDA regulations for compliance.

TDA and Mrs. Kathy Newton were kind enough to share the PDF of their presentation with us. Please view disclaimer above and keep in mind while viewing the presentation.

What to Expect During a WPS Inspection – Presentation PDF

Routine inspections

  • Call before

Sometimes may do a visit beforehand

Before the inspection:

    • Make records, licenses, CEUs, insurance documents available
    • Inform employees
  • Allow access to facility, storage area and equipment

First thing they do when they get there:

  • Get an idea of the size, scope of operations, what is being grown/done there, number of employees, number of people making pesticide applications, how many people work in the areas where pesticides are applied

Have any WPS applications been made?

    • “Agricultural Use Requirements”
      • Use this product in accordance with its labeling and with the Worker Protection Standard, 40 CFR part 170.
    • If the pesticide label does not have this label and box in it, then it is not a WPS regulated product and doesn’t need to follow WPS requirements
    • Most homeowner products won’t have the WPS statements on it
  • If the above is seen on a pesticide label, then TDA inspector will go through check to ensure WPS is being followed


    • Training records for all workers & pesticide handlers
    • Application records for WPS applications made in the last 30 days at a central location with SDS sheets
  • Medical evaluations, fit test record & respirator use training record

Application records:

    • Are they kept in a central location for 30 days after the application AND do they contain all of the required information?
  • Are they retained for 2 years?

Form in the lobby that contains all information required to meet TDA and WPS requirements:

    • Name of pesticide applied, ex. Roundup Powermax, Rodeo, Ranger Pro
    • Active Ingredient, ex. Glyphosate
    • EPA Registration number, ex. 524-549
  • REI, ex. Four hours

Are there workers or handlers employed at the facility?

    • Has training been conducted in the last year?
    • Training records:
        • Worker or handles printed name & signature
        • Date of training
        • Trainer’s name & qualification to train
        • Employer’s name
      • EPA document number, ex. EPA 735-B-06-003, or EPA approval number, ex. EPA PST 00022.
  • New WPS regulations requires handlers to be trained annually now (as opposed to every 5 years).

Do handlers use pesticides that require respirator use?

    • Medical evaluation completed by physician at NO COST TO THE EMPLOYEE
    • Record of medical release
        • Whether the employee is able to use a respirator
        • Any restrictions on use
        • Need for follow up evaluations
        • Verification that the physician has given the employee a copy of the written determination
      • 2 years
    • Medical evaluation must be done by a physician
  • Fit test can be done by the employer; there are kits (~$100) to conduct this test for employees. Would only need to do this if there are products being used that require respirators.
  • This testing can be done UT Health Northeast
      • And lots of occupational health providers in the area
    • The law even allows for online medical evaluations; just need to make sure the physician is certified for occupational health evaluation

Has the handler been given a respirator fit test?

  • Record
      • Name of the handler tested
      • Type of fit test performed
      • Make, model & size of the respirator tested
      • Date of fit test
      • Results of fit test, ex. Pass/Fail
    • Keep that record for 2 years

Has the handler been trained on respirator use?

    • Training to be conducted annually
  • Record
      • Name and signature of handler
      • Date of training
      • Trainer’s name
      • Training topics
    • Keep that record for 2 years as well!

Do you provide decontamination supplies?

    • Workers: 1 gallon of water per worker
    • Soap & Single use towels
    • Located together, reasonably accessible, outside of treated area under an REI
  • Within 1/4 mile

Do you provide decontamination supplies?

    • Handlers: 3 gallons of water per handler
    • Protective eyewear required on pesticide label? Must provide emergency eye wash
    • 6 gallons of water in container that can provide gentle flow for 15 minutes
    • Soap & single use towels
    • Clean change of clothes
  • Accessible & outside of treated area

Are you notifying employees of pesticide applications?

  • How do you notify of pesticide applications?
      • Oral notification
      • Check pesticide labels for double notification requirements!
    • Post warning signs at treated area

Signs must be posted at the treated area if:

    • Outdoor applications – REI>48 hours
    • Indoor applications: REI>4 hrs
    • Signs must be posted prior to the application, no earlier than 24 hours
  • Signs must be removed or covered within 3 days of the end of the REI

Worker and handler interviews

  • A worker and/or handler will be interviewed during the inspection about training provided, PPE & decontamination supplies, notification, central posting areas, etc.

At the end of an inspection:

    • A findings page will be presented at the end of the inspection listing any noncompliance found during the inspector
    • Any noncompliance found during an inspection results in a report sent to TDA and EPA
  • EPA may issue civil or criminal enforcement action for violations found

Types of enforcement action:

    • A warning letter
    • An administrative order
    • An administrative order with penalty
    • An civil lawsuit
  • Criminal prosecution

Penalties will depend:

    • Number, length, severity of violations
  • Economic benefit obtained from violation

New training material is out and is on EPA and PERC’s website

How to comply manual from the EPA website;

  • An easy-to-read guide for all the requirements. Not in the federal CFR language.

How do you dispose of a non-use item

    • Check with your counties and cities first; see if the county has a site where you can take things to
    • Take it or have it picked up by a disposal company. Can be a little expensive
    • TDA used to have a county pickup; that has since ended and has not been brought back yet. Hopefully they’ll try again next session to bring it back
  • Can keep it in storage until there is a safe way to dispose of it

Kathy Newton
TDA Region 2
Office: 214-631-0625

Additional related resources:

EPA “How to Comply” Manual |

Pesticide Educational Resources Collaborate (PERC): Guide to WPS – Training Videos for Workers |

PERC: WPS Compliance Suite – Training Materials for Workers |

Agricultural Worker Protection Standards (WPS) Comparison of Revised Protections to the Previous Protections | en:

WPS Quick Reference Guide (including requirements as of January 2, 2018) | en:

WPS/EPA Poster Provided by EPA |

WPS/EPA Poster by PERC |

Disclaimer: The notes above are provided as is and are not considered the law. Be sure to check EPA, WPS, and TDA regulations for compliance.

Integrated Pest Management for Greenhouse and Nursery

Dr. Steven Arthurs, Department of Entomology, Texas A&M University

Pyramid of IPM:

Prevention> Cultural/Sanitation>Scouting/monitoring>Biological>Chemical(pesticide)

Costs associated with some pesticides that aren’t apparent upfront:

    • Longer REI
    • Impact on beneficials that may prevent future outbreaks
  • Pesticide residues


    • Screens & double access doors
    • Inspections of plant stock (propagation)
  • Remove weeds/mow turf


    • Footbaths (disinfectant)
    • Hand/equipment washing stations
    • Remove/dispose of contaminated plants
    • Monitor/treat reclaimed water
  • Avoid ‘dew point’ conditions


    • Soilless media
    • Solarization
    • Mulching
  • Select resistant plants/cultivars

Bethke and Paine (1991), Green-Tek (2015), and Stansly and Naranjo (2010)

  • Describe size of holes needed to exclude different insects


    • Nursery planting media under double-layer plastic for solarization
  • In the summer, 4 weeks or less to sterilize.

Timely detection can answer questions:

    1. What kinds of pests? Something to worry about?
    1. Are they causing damage?
    1. When to control?
  1. Have control methods worked?

Good reasons to do this!

    1. Deal with pest infestation early
    1. Identify hot spots
  1. Know patterns of infestation year after year to prevent problems from happening

Useful equipment for sampling, digging, and monitoring

    • Hand lens
    • Magnifying lens
    • Containers
    • Pocket knife
    • Handbook
  • Rubbing alcohol or hand sanitizer

Tips for scouts:

    • Enter each block looking for abnormal plant symptoms
    • Remove some suspect plants out of the pot (check moisture and root decay)
  • Examine foliage for trouble

Scale insect ‘tape’ trap good for detecting scale insect crawlers

Many companies investing in bioinsecticides

  • Fungi, bacteria, or other microorganisms that provide control of the pest

May not always work well against conventional pesticides

  • For example, if you use a fungicide, and then use a biological control fungus product, you may kill the fungus you just put out!

Conventional pesticides:

    • Residue concerns (export)
    • Often toxic to beneficials
    • Often used curatively
    • 12 – 48 REI
    • Few organic registered
    • Often kills a variety of pests
    • Market 3% growth
  • Shelf life >1 year


    • Few residue concerns
  • Compatible with beneficials and pollinators

Releasing beneficial insects

    • Predators and parasitoids, such as lady beetles and various wasps
  • Hard to get good coverage with insecticides when crop is densely cultivated
    • Use predatory mites & blow them out. Mites can move around the plant and find the pests

Chemical control

    • Select appropriate material for the job
    • Spray during calm weather
    • Use economic or aesthetic threshold to make spraying decisions
    • Calibrate based on label rate for that pest
    • Spot treat where practicable
  • Rotate chemicals by class

Treat pest problem, not the symptom;

  • Sooty mold is caused by a sucking pest. No need to spray fungicide, need to control the insect.

Dr. Arthurs was kind enough to be willing to share the PDF of his presentation | Integrated Pest Management in Greenhouse and Nursery

Water U Doing for Texas Horticulture?

Mr. Daniel Cunningham, Department of Horticulture, Texas A&M University

Website |

Have several DIY Guides

Active on social media

Do private and public consulting

Follow him @TXPlantguy

Texas’ existing water supplies (that can be relied on in the event of drought)

    • Expected decline by approximately 11% and population grower!
  • Need to do more with less water

Development on land prevents water cycle

Population of Texas expected to increase 70% by 2070.

(29.5 million to 51 million by 2030)

Water supply expected to decrease (from 15.2 million acre feed to 13.6).

Potential water shortage?

    • 4.8 million acre-feet short per year in 2020
  • 8.9 million acre-feet short per year in 2070

(in drought record conditions)

Conservation & Reuse strategies:

  • Increased from 34% to 45% of total future water volume!

Indoor use

  • Percent of homes meeting efficiency criteria

88% of people are interested in rainwater harvesting

86%of people are interested in native plants/adapted plants

77% of people are interested in pervious paving

75% of people are interested in edible landscaping

73% of people are interested in rain gardens

Give your landscapes CPR:


  • Preserving and enhancing habitat and ecological functions of the watershed



Capillary matts

Substrate surface irrigation


Test your system using an aggie catch can test!

Proper design = efficiency

    • Pumps
    • Lines
    • Emitters
  • Water pressure

Mr. Cunningham was kind enough to be willing to share the PDF of his presentation |