Comment on Worker Protection Standard Rulemaking
By Arwen McGilvra –
To Garnet Cooke at OR-OSHA,
I am very concerned about the OR-OSHA WPS PROPOSAL. I am the fourth generation to live on my families Willamette Valley farm. The farm my great-grandfather bought after leaving the dust bowl in North Dakota. The farm my grandfather and grandmother struggled to keep going during some rough years when the economy of our country was changing and the way we farm was changing too. They were able to turn things around and now my uncle farms this same land. If we had not cared for our land it would not be possible to pass it down from one generation to the next.
The care of our land includes the responsible use of pesticides. Without these important crop protection tools, we risk losing our crop to slugs, glassy cutworms, mites, beetles, sawflies and more. We have always worked hard to responsibly use these tools and have worked closely with our extension agents to find new and better ways to manage them, utilizing current science and up-to-date information from Oregon State University crop sciences and on-site information from our farm.
The current proposal for worker protection standards for application seems to be driven not by current science, but by lobbying from environmental activists, and therefore my concern.
These rules would impact not only my families farm, but our ability to enjoy peace and quiet and the use of our own home, which is just steps away from the nearest field.
While I agree that allowing a “shelter in place” alternative is safer for workers than having them leave their homes or workplaces during an application. I wonder at some of the other language in the proposal. The storage of personal household items is particularly vague, and I am left wondering how much of our stuff would have to be put in storage. My family has lived here a long time and has never had to pack up personal items, secure door and windows, and turn off air intakes during pesticide applications before.
My grandmother is still living on the farm with us at the age of 92, and is in good health. My grandfather lived to be 95 and was in good health until the last couple of months of his life. Both have been on the farm for 50 + years. In all that time they have not felt ill effects from crop protection applications, and my grandfather was the one doing most of the applying. Neither has the rest of the family. Of course, when applying these crop protection products, we have always used personal protection equipment (PPE) we used what was available to us at the time (PPE in 1952 being much different than it is today,) and appropriate to current standards.
There is a lot more that could be said, but I will end with one last thought, Oregon-specific rules make Oregon growers less competitive. We want to see the farm passed down to a fifth generation this will not happen if Oregon farmers are at a disadvantage by burdensome and arbitrary regulations, that do not have a scientific basis.
Pesticide applications are already tightly regulated by the Oregon Department of Agriculture and off-target drift is subject to civil penalties. The current rules for application are working to protect our family, our home, our neighbors and employees. Any change should be based on new science, on understanding of our land and on corporation with farmers and extension agents.
I urge you to reject the current proposed rulemaking.
OWA Positions State:
Environmental Protection Agency (EPA) & Oregon Department of Environmental Quality (DEQ)
· OWA supports requirements for chemicals that are reasonable and realistic, at a set fraction of an unsafe exposure. For example, medicine is allowed a 10% safety margin but 1% is common for pesticide application.
and Food Safety
· Responsible use of crop protection chemicals (pesticides) is one of the important tools that have made this abundance and quality possible. OWA supports continued use of crop protection chemicals. OWA supports verifiable, scientific evidence to determine the benefits versus the risks before the Environmental Protection Agency (EPA) (or any other regulatory agency) takes any precipitous action against their registration or use.
If you would like to submit a comment of your own use the Oregon Farm Bureau Advocacy Portal.