Greenhouse and Nursery Regulatory Compliance Workshop 2018 – Notes and Resources

Posted on Format AsideCategories General, Growers, Integrated Pest Management, Notes, Programs

If speakers provided permission to provide PDFs of their presentations, they are found at the end of the notes associated with that section.


Safety is a “Hot” topic: Heat illness prevention for outdoor workers.
Dr. Shaadi Khademi, UT Health Science Center at Tyler

  1. identify symptoms of heat related illness
  2. understand heat stress factors
  3. describe the components of a heat illness prevention plan

Understanding heat & heat illness

  • A serious medical condition resulting from the body’s inability to cope with a particular heat load
  • Can even happen when temperatures are moderate!
    • Not only at 100+ temperatures

How does it happen?

  • Sun -> on a worker -> body heat rises -> heart pumps faster -> blood vessel dilate to try and keep body cool -> heat escape: conduction, convection and radiation -> Sweat, heat escape by evaporation.
    • That sweat needs to be able to evaporate to cool the body

Ideal body core temperature is about 98.6ºC

  • Safe body core temp = up to 100.4ºF
  • Short excursion safe body temp = 101.3ºF
    • Humans operate at a very narrow range of operational temperature
  • As body heat increases
    • heat cramps
    • Heat syncope
    • Heat exhaustion
    • Heat stroke! (104ºF); concerning and potentially fatal

Continuum of Heat Illness:

  • heat edema -> pricky heat -> dehydration -> heat cramps -> heat exhaustion -> heat stroke

Symptoms of Heat Exhaustion:

  • Fatigue, weakness
  • Dizziness, faintness
  • Nausea
  • Headache
  • Moist, clammy skin
  • Pale or flushed
  • Rapid Pulse
  • Can be related to Normal or slightly elevated temperature

Symptoms of heat stroke:

  • much more serious, how people die of heat-related illness
  • hot, dry skin; can be red, mottled or blush
    • Body is very short on water!
  • Confusion
  • Loss of consciousness
  • Convulsions
  • Rapid pulse
  • Body core temperature > 40ºC (104ºF)

Serious outcomes:

  • Death; considered an undesirable and suboptimal outcome
  • coma
  • organ failure
  • prolonged hyperthermia; when the body temperature goes up to that, it can be very difficult to bring it back down
  • shock
  • coagulation difficulties; blood clots
  • mechanical ventilation required

Principles of Treatment

  • rest in cool environment
  • drink plenty of water
  • rapid cool down
    • Apply cold compresses (i.e. cold wet towel), especially on the neck and under arms
  • Seek medical care

Heat stress factors:

  • hydration: very important one. Not about responding to thirst. Thirst is indicating that it’s already too late, your body is water deprived.
  • Acclimatization
  • Wind (or lack thereof)
  • Environmental temperature (heat index = temperature & humidity)
  • Metabolic rate
  • Environmental humidity
  • Clothing
  • Fitness (more fit = less susceptible to heat stress)

Populations at risk and risk factors:

  • Outdoor occupants, particularly afternoon work
  • New outdoor workers
  • industrial plant workers
  • vigorous outdoor sports
  • military recruits
  • women
  • pregnancy (1st trimester)
  • poor
  • aged

Heat-related deaths in United States from 1992 – 2006

  • Fatality rate for crop production workers = 68 people
  • Over 20-fold higher than general public

When you’re in an open field with no shade, you need to provide shade, otherwise the worker is consistently exposed to the sun.

Case 1:
17 year-old female tying grape vines at a California Farm in May of 2008

  • Temperature was above 95ºF
  • Nearest worker 10-minute walk away
  • Workers reported that breaks were too short to get a drink and there wasn’t adequate shade
  • The female farmworker collapsed after working for many hours
  • Medical attention was delayed
  • When she arrived at a hospital, she was in a coma and her body temperature topped 108ºF
  • She died two days later
  • They discovered at the hospital that she was two months pregnant

Case 2:
38 year-old male began a new job during the summer performing land excavation/digging.

  • Ambient temperature by noon approached 95ºF
  • He weas not feeling well during the day, complaining of disorientation and demonstrating confusion
  • By late afternoon, he was sent to wait in his parked vehicle alone
  • He was later found unconscious and taken to the ER
  • Rectal temperature was 107.2F
  • He died 10 days later of multi-system organ failure

Education & Training

  • at the beginning of spring + frequent reminders during hot season (>85ºF)
  • Topics to cover:
    • Hydration
    • Acclimatization
    • Rest & Shade
    • Clothing
    • Environmental & personal risk factors
    • Symptoms of heat illness
    • Responding to smyptoms of heat illness
    • procedures for contacting emergence medical services
    • how to monitor weather reports & weather advisories


  • cool and desirable
  • adequate & frequent
    • 1 quart (4 cups) per person per hour
  • accessible
  • electrolyte replacement if necessary (not “salt tablets”)


  • lesser increase in body temperature
  • lesser increase in heart rate
  • sweating starts sooner; start to cool sooner
  • sweat more dilute and increased in volume
  • less perceived discomfort
  • improved knowledge of drink and dress requirements
  • Recommended first day spending about 50% doing their normal hot work they may be doing, and 50% in a cooler environment to start to acclimatize. 
    • Each day add about 10% more work load/hot environment, so that by one week, they can get to 100% work
    • 46% of workers, heat related illness on the first day of work! over 80% within the first 4 days; prevent by gradual exposure to the hot environment.
  • acclimatization can be lost in absence of heat over 3 weeks
  • Not as effective during heat waive

Rest and Shade

  • Shaded rest areas should be accessible
  • allow for recovery from exertion-derived heat
  • provide reprieve from direct sunlight

Medical risk factors:

  • stomach flu
  • Fever for any reason
  • skin infections
  • malaria
  • respiratory infection
  • hang over
  • diabetes
  • Heart disease

Personal risk factors:

  • overweight
  • out of shape
  • lack of sleep
  • high caffeine (i.e. Red Bull)
  • High sugar drinks (>6%)
  • Low salt diet
  • Drugs
    • Alcohol
    • Ecstasy
    • Cocaine
    • Meth

There’s an App for that!

NOAA’s National Weather Service – Heat index chart

  • Can get email alerts, text bulletins, etc. to receive notifications
    • heat advisories

Great resources via OSHA, CDC, Pacific Northwest agricultural safety and health center
Stay cool!

  • Different garments that can help keep cool
    • Hats, scarves, cooling vest

WPS Compliance and Training Resources
Kathy Newton, Pesticide Inspector, Texas Department of Agriculture
Inspector for Smith County area:Sandy Alexander
Kathy and Sandy always open to questions about anything. Just send them an email.

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.

  • an area often with non-compliance
  • perhaps not known how to access the information
  • Some grey areas
  • But very important

What is WPS?

  • Worker Protection Standard
    • EPA rue that provides protections for agricultural workers and pesticide handlers
    • original rule – 1992
    • revised in 2015; intent to bring it up to some of OSHAs standards
    • revisions intended to provide more protections for workers and handlers and include expanded training content and requirements

What is WPS?

  • pesticide safety training
  • access to labeling
  • access to pesticide information
  • notification of applications


  • Keep workers out of treated areas
  • PPE
  • Monitoring
  • REIs
  • AEZ
  • Protections for early-entry workers


  • Decontamination supplies
  • Emergence Assistance


  • pesticide safety training for workers and handlers
  • access to specific information regarding pesticide applications at a central location
    • where people have meals, take breaks/rest, etc.
  • access to pesticide label information; access to SDS sheets, and other information such as name of pesticide applied, active ingredient, etc.
  • notify workers about pesticide applications to those areas can be avoided
    • Don’t have to use the poster; it’s just easier because it has all of the required information
    • Can buy them or just download and print from the PERC website


  • Keep workers out of areas treated with pesticides
  • Keep workers away from application equipment (AEZ); for outdoor applications, zone surrounding the application area. If applicator sees someone approaching, application must be stopped.
    • After application is done, no more AEZ, but that’s when the REI kicks in.
  • Keep workers out of areas under an REI; found on the pesticide label.
    • Many growers doing applications near the end of the day, so that you don’t have to worry about notifications if workers won’t be there after application is done until REI is over.
  • Monitor handlers when using highly toxic products
  • Provide and maintain PPE
  • Provide respirator medical evaluation, fit testing and training
    • Employer must provide medical evaluation just to ensure that the employee is sufficiently fit to use a respirator
      • One evaluation is fine, unless the medical provider wants a follow-up. Form provided from physician will dictate when they may need to come back for another medical evaluation after one, two, three years or unspecified (in which case, renewal of medical evaluation test is not required). If your applicators health changes, good idea to do another medical fit test to ensure they are still fit to use a respirator.
      • Fit testing & training needs to be done annually. Fit test can be acquired from Gemplers. Training; how to take apart, wear, clean, etc. the respirator.
      • About 50 – 60% of inspections Kathy does, growers are not aware of the respirator training, fit test, and medical evaluation
  • If the signal word on the label is “Caution” but restricted use, monitoring is not required.
    • Not a bad idea to monitor anyway, but not required.
  • Restricted use pesticide just means that a person needs a license to purchase and apply it.


  • Provide decontamination supplies including water, soap and single use towels
    • Not bath towels, need to be single-use (one-time then wash or paper towels)
  • HIVEc suites. Having a washing/drying machine on site can be a good idea to prevent workers from having to wash pesticide-exposed clothes with their family clothes at home.
  • provide emergence eyewash when required
  • provide transportation to an emergency medical facility in the event of a pesticide exposure
  • Eye-wash; can be a large Igloo container, if it’s elevated so that they can get their eye under it.

Who must comply with WPS?

  • owners/employers/operators of agricultural establishments
    • Farms
    • Forests
    • Nurseries
    • Greenhouses
  • does the label have the “Agricultural Use Requirements” statement on it?
    • Must comply with WPS
  • if not, then do not need to comply with WPS
  • Agricultural establishments that employ pesticide handlers (Handlers) and employees that perform worker tasks in treated areas (Workers)
  • Workers and Handlers are compensated with a wage or salary. Volunteer activities not covered by WPS
  • Members of the owners immediate family are exempt from many, but not all, WPS requirements

WPS Training

  • Agricultural employers are required to provide training to workers and handlers
  • EPA approved training courses
  • No grace period!

Who can train workers and handlers?

  • Licensed pesticide applicators
  • Trained trainers
  • others designated as trainers by state agency


Worker and Handler Training

  • must be delivered in a manner that can be understood and in an area reasonably free from distractions
  • Trainer must be present at all times during the training to answer questions
  • Worker Training – 23 items
  • Handler Training – 36 items

Training records

  • 2015 revisions require training records be kept by the agricultural employer
  • Records must be kept for two years and made available

Little green/blue card that you used to give to employees for completed WPS training no longer required

  • inspector will not ask for them
  • Record-keeping is the important bit! The worker/handler needs to have access to it though, in case the worker/handler changes jobs, they need to be able to take that with them to their new employer.

WPS Common Areas of Noncompliance

  • Record keeping – training records, respirator training records, pesticide application records
  • Training – training not conducted on an annual basis, no training provided at all!
  • Notification – not properly notifying employees of pesticide applications at the establishment. Some labels require double-notification
  • Central posting area – pesticide app info not kept for 30 days, no SDS sheets, old posters in use. After the 30-days, must keep filed for 2 years.
  • Respirator use – no medical evaluations, fit testing or training provided to pesticide handlers.
  • Pesticide label violations – REI not observed, no double notification provided to workers, no PPE provided to early entry workers

SDS sheets can be kept online or digitally – but needs to be accessible and available to all workers/handlers

WPS Resources:
WPS Training Materials for Workers & Handlers:
WPS “How-To-Comply” Manual:
WPS Updated Posters:

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.

START clean, STAY clean: Strategies for practical preventative measures against pathogenic problems
Dr. Kevin Ong
Professor & Extension Plant Pathologist Director – TX Plant Disease Diagnostic Lab Department of Plant Pathology & Microbiology Texas A&M University, College Station

If you’re a larger grower, you have a lot of plants

  • If you have a disease pop up, that’s a headache
  • If you don’t take care of it quickly, it can get out of hand!
  • You may get lucky; certain conditions can change that make those problems just go away. Most people are not that lucky…

Risk Management for plant heath;
Things to consider:

  • Type of plants and disease issues on it
    • NOT likely to occur
    • Could occur
    • Likely to occur
    • Bonafide problem

Intel on the disease issue

  1. know the enemy
  2. what can STOP or SLOW the enemy (and is it feasible)

Hard to ‘eradicate’ the plant pathogens; they are constantly around

  • we want to be able to live with those pathogens without it causing economic damage/symptoms that make the plant unmarketable

Understanding WHY & HOW disease happens

  • HOST (plant); one way to get rid of plant disease… have NO plants! ?
    • The HOST needs to be present to produce plant pathogens. Since having ’no plants’ is not an option if its your business, then you will inevitably have some plant pathogens at some point
  • PATHOGEN; interaction between microbe and plant. 
    • When your plant has disease, that relationship between pathogen and plant has gone bad.
  • When/if plant is small, it is most susceptible to disease
    • New plant tissue/growth is also most susceptible to plant disease.
  • Environment; can also contribute to plant-pathogen relationship
    • What is the environment?


  • Temperature: plays a big role in how cells develop
    • Certain temperature range in which cells will grow really well
    • Optimal growth temperature range; for some pathogens we know what that range is and another we don’t.
    • Even a 2º change in irrigation water can result in a major difference in pathogen incidence.
  • Moisture
  • Fertility; sometimes as simple as adjusting materials used with fertilizers to decrease pathogens
  • Sunlight; different plants needs different amounts of sunlight. Same thing applies to pathogens. A lot of fungi rely on some level of ultraviolet light to create spores
  • Population Composition; modifying the community of pathogens in a way that creates competition or less ideal conditions for bad pathogens.
  • Population Dynamics; external pressure (such as resources) changing the makeup of the population of different pathogen species. Providing resources that will make good or neutral bacteria have an advantage over the bad pathogens.

START Clean.. Prevention is better than CURE

  • What practices can be implemented and is it reasonable?
    • Why do it?
    • What does it do?
    • How is it beneficial?
    • What might be some “fallout”?
      • For example, if you apply SubDue MAXX, what will it do?
        • It was slow down the reproductive rate of the Phytopthora
        • If we knock out the phytopthora, are we encouraging something else to come in and become problematic?
          • Yes and no, something to consider


  • potted plants spaced pot-tight with overhead irrigation
    • Restricted air flow, high humidity, and low light penetrating canopy. More likely to promote plant pathogens.
    • Always always make sure to have good drainage (where possible)
  • cuttings of roses in propagation house
    • several flats and areas that have uneven growth
    • try to rule out reasoning. Isolate them and try to determine the cause. Isolate; because if it’s a pathogen, you want to prevent it from infecting the others. If it’s not a pathogen, perhaps due to issue with watering, drainage, etc.
  • Plant blanching/whitening;
    • Fertility problem. But why? Is it a root problem? May need to pick up the plant to look at the root.

Recap: Strategies

  • Planning & Execution prior to crop
    • sanitation practices
    • irrigation plans
    • pre-treatments
    • fertility program
    • monitoring programs
    • action plans

Looking ahead…

  • always learning
    • diagnostics
    • records
    • experiences  of self & others
    • what works?
      • What can make it NOT work…

Check them out on Facebook

Pesticide Handling, Storage, and Disposal
Dr. Matocha

What is the shelf life of pesticides?

  • it depends…
    • What is opened?
    • Where is it stored?

Are you storing DF (dry) or WDF (wet)?

  • Dry typically store better than wet, as a general rule

Are you storing liquids?

  • If the chemical has ’settled’ out, does it mean it’s not good any more?
    • No. Not necessarily. You just need to shake it (don’t do it above your head!)

If a container becomes a lot more compromised (i.e. starts to break down)

  • doesn’t necessarily mean that the product is no good anymore

Two types of changes occur

  • active ingredient changes chemically
  • formulation can break down and precipitate
    • sludges, flakes, crystals
    • some increase in acidity affecting the container

Separate volatile chemicals

  • highly volatile pesticides can contaminate other products when stored in close proximity! 
    • Such as volatile herbicides near insecticides.
    • Not super common, but possible.

Environmental Conditions

  • Temperature
  • Moisture 
  • Sunlight

Signs of trouble

  • sedimentation
  • gelling
  • discoloration

How long?

  • Typically 2 years from date of manufacture; unless otherwise stated
    • Check the package when first purchased; may be past the date.
    • Just because it’s past those two years, doesn’t necessarily mean that efficacy does not work
  • outdated stocks can be used if they haven’t broken down.

Dry Ounce vs Fluid Ounce

  • For example, Lorsban can come with a container for measuring certain number of ounces of Lorsban dry product.
    • Cannot use that for any other product! Because other pesticides will be different weights.
    • Not only should you use the container only with the specific product it came with (i.e. Lorsban 15G), you may want to only use the container that came with the pesticide. Because the same product (i.e. Lorsban 15G) may be slightly different weight year after year.

Fluid Ounce

  • measure of volume
  • Not interchangeable with dry oz.
  • If the container is measuring liquid volume (i.e. mL or fl. oz.), we can use that to measure volume of different products.

Back-flow Prevention

  • If you stick the hose end below the surface of the liquid in the container with the pesticide, you could have some backflow of the pesticide back up the hose.
  • Make sure to keep an “air gap” or use a backflow prevention device to prevent pesticide from backflowing into the water source

Every pesticide label has a section on Storage and Disposal

  • They will typically just provide some general temperature guidelines for storage
  • Just leaving containers laying around is not a good way to store pesticides

Keep containers up off the floors

  • ideally, temperature/climate controlled room
  • If possible, have a secondary containment (i.e. keep the pesticides on a piece of Tupperware)
  • Keep it out of general public access

Triple rinse containers

  • What then?
  • Most labels don’t give you much guidance on that! The TDA has nothing to really say about this either. TCEQ, on the other hand, does. They BAN burning or burying triple-rinsed containers.

USAg Recycling, in Waller, TX

  • Free Service Specailizing in Recycling Plastic Agricultural Containers
  • 1-800-654-3145
  • Mostly recycled into plastic coverts
  • Don’t have to recycle, but if you want to keep the containers out of the landfill, this is a good option.
  • May consider contacting your distributor to see whether they coordinate collection and pickup by USAg.
  • Typically won’t take the large 30 gallon containers, but do take the 30 gallon drums
  • Primary are the 2.5 gallons
  • Container needs to be clean! Can be stained, that’s ok. But can’t have visible product all over it.

What if you have old pesticide that you don’t want or know what to do with anymore?

  • it depends!
  • Old but still registered? Or products that are no longer legal (i.e. DDT)?

7.30. Classification of Pesticides Prhibited Pesticides

  • Aldrin
  • Chlordane
  • DDT
  • DDD
  • Dieldrin
  • Hexachlorobenzen
  • All mercury-based
  • Mirex
  • Toxaphene
  • Heptachlor
  • 2,3,5-T
  • 2,4,5-TP (silvex)
  • No person shall USE any prohibited pesticide for any purpose
  • A person in possession shall by proper storage, care, handling, and transport prevent the release of the prohibited pesticide into the environment and prevent exposure…

If you pesticides that are not prohibited;

  • best way to get rid of them; just spray them!
  • When those pesticides were manufactured by the manufacturer, what was their intent for them to go away?
    • To degrade/break down in the environment!
    • Spraying it in the environment (formulated as per the label) will break down; good way to dispose
  • Most of our more modern insecticides don’t last very long in the environment
  • Factors such as Photochemical decomposition, microbial decomposition (most pesticides), chemical breakdown, runoff/erosion, leaching, adsorption by soil organic matter and clay, plant uptake, and volatilization all contribute to decreasing concentration (i.e. dilution) and degrading the pesticides.

“Houston company accused of dumping chemicals down storm drain”

  • Company called Wright Containers
  • Dumping 1,000s of gallons of harsh chemicals straight into the storm drains.
  • They weren’t even legally permitted to handle the chemicals in the first place, nor were those chemicals intended to be dumped directly into a storage drain!
    • Pesticide have the potential to negatively impact the environment if not properly disposed
  • Was discovered by disgruntled employee

In Texas, we have a commission on environmental quality

  • TCEQ (Texas Commission on Environmental Quality)
  • State 303(d) list;
    • List of all impaired bodies of water in Texas.
    • Bodies of water that cannot be used for some purpose (wildlife, recreation, drinking, etc.)
    • Only one body of water in Texas on that list that is due to pesticide contamination!
  • Pesticides not currently considered a major issue, but can if we aren’t careful!

Texas HB 572 would have re-started a pesticide collection program for Texas

  • what do you do about pesticides that you need to dispose and don’t know what to do with?
  • Last legislative session it passed! Had support of a lot of traditional ag-like groups and folks that are not traditional ag-like groups
    • Safe, legal, free way to dispose of chemicals that folks don’t want to keep
  • Used to exist until it was disbanded in 2010.
  • This bill will be out there again for Texas legislature to consider; possible for it to pass this legislative session

We have had some regional pesticide collection projects

  • Some town, municipalities that will dispose of hazardous waste. Usually limited to homeowners; but some may allow ag workers.
  • Even though the legislation of Texas HB 572 was defeated last session, TDA has already initiated some programs in local regions.
  • Within 4 hours, collected over 120,000 lbs!
  • This was in Wharton
  • May be doing another further North in Texas, but currently undetermined
    • Pushed out by radio, county extension agents, etc.

There are also private facilities out there that charge a fee; can use that option as well TCEQ has a list available (for different regions)

Paul Toler: Some big-box stores; requiring growers to uphold new European pesticide standards

  • Some of it includes not being able to spray old pesticides
  • The HB 572 would help solve this problem.

Recent Advances in Integrated Pest Management
Erfan Vafaie, Texas A&M AgriLife Extension

No notes were taken during this presentation, since the note-taker (Erfan) was presenting.

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