(Part of Pesticide Issues Conference)
Jeff Lutz
Pacific Northwest Agricultural Safety and Health Center
Understanding the Rule
- Tracking and record keeping
- Workforce training & education
- Identification of covered products and tolerances
- Small farm disadvantage
- Assurance of provider understanding of rule
- Rural area difficulties
- Using DOT, Occ. Med., Respirator rule providers?
- Certified-trained medical provider list not available to growers
- Can growers have on-site visits and streamline the draw process?
- Will providers do “mass draws” as is done with Respirator questionnaire?
- Growers are suspect of Medical Providers; will ChE depression become claim?
- Will state lab have timely results?
- Will testing result show problem?
- Will lab report to provider generate WISHA inspection?
- Will natural fluctuations in ChE result in false positives?
- Additional grower costs for testing
- Perceived versus actual exposure problem
- Legislature mandated dollars for testing
- Currently lab is only cost deferred
- Annual review of rule needed
- Governor’s commission needs “current” data
- Rule should sunset if results show little or no exposure
- Will shift in threshold result in more positives?
- Will natural ChE fluctuations cause false positives-negatives?
Disclaimer and Reproduction Information: Information in NASD does not represent NIOSH policy. Information included in NASD appears by permission of the author and/or copyright holder. More
Reviewed for NASD: 06/2006
