Ensuring the safety and compliance of pesticide application is essential for protecting not only your workers but also the community, the environment and your business.

Pesticide applicators, technicians and businesses must adhere to strict guidelines, regulations and best practices to ensure safe use and minimize risk. Compliance with the Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA) and state and local laws is not just a regulatory necessity, but also a crucial component of a responsible, sustainable business operation.

Personal protective equipment is a critical line of defense against pesticide exposure. Photo is of a PHC technician with Stanley Tree Service Inc. TCIA staff photo.

In this article, we will walk through key areas of safety and compliance, focusing on personal protective equipment (PPE) requirements, notification procedures, hypersensitivity considerations, apiary notifications, application requirements and documentation responsibilities.

Personal protective equipment
Personal protective equipment is a critical line of defense against pesticide exposure. Ensuring that your applicators and technicians are equipped with the appropriate PPE is not just a matter of compliance, it is a matter of health and safety. And, as the business owner, you are required by OSHA to ensure your staff has appropriate PPE.

The type of PPE required will depend on the pesticide being applied, the method of application and the risks involved. Minimal PPE requirements are listed on every pesticide label, and the law is the law! Minimal requirements usually include long sleeves and long pants, safety glasses, chemical-resistant gloves and shoes and socks. No mesh shoes.

You also should ensure there is an eyewash station or materials, spill kits and any other items as required by OSHA or a pesticide label. Regulations are changing, and it is best practice to refer to the OSHA link for updates.

Here’s a URL for the OSHA and Worker Protection Standards: epa.gov/pesticide-worker-safety/agricultural-worker-protection-standard-wps.

Another great resource for pesticide safety and stewardship is pesticidestewardship.org/personal-protective-equipment.

Key PPE components:

• Gloves: Always use pesticide-resistant gloves to prevent skin exposure.
• Respirators: Depending on the toxicity of the pesticide and application method, respirators may be necessary. Ensure that respirators are NIOSH approved and fit tested for the wearer. When not in use, they must be stored in a way that prevents contamination.
• Eye protection: Safety goggles or face shields should be used to protect against splashes or drift.
• Coveralls or long-sleeved clothing: These should cover as much skin as possible and be made of pesticide-resistant materials.
• Footwear: Boots with chemical-resistant soles to prevent pesticide penetration.

Ensure all PPE is regularly inspected, maintained and replaced according to the manufacturer’s instructions. Provide your employees with training on proper usage, cleaning and storage of their PPE. Train all personnel involved with pesticides on proper procedures for PPE and inspection of PPE to ensure you always have appropriate items when needed.

It’s important to keep PHC supplies well organized and secure. Photo courtesy of Barrett Tree Service East.

Failure to wear proper PPE
In a worst-case scenario, improper PPE leads to severe health effects for the worker, significant environmental damage and substantial legal and financial repercussions for the business. This is typically the result of prolonged exposure to a highly toxic pesticide, combined with a failure to recognize the severity of the situation until it’s too late.

For example, say an applicator applies a highly toxic pesticide to a large nursery without wearing the required gloves, respirator or protective clothing. They are exposed to pesticide fumes for an extended period and fail to notice early symptoms of poisoning. The applicator continues working despite experiencing mild headaches and dizziness, ultimately suffering from a more severe toxic reaction later that day. Meanwhile, the pesticide drifts into a nearby water source, impacting local wildlife and possibly contaminating drinking water.

Outcome:

• Severe health impact: The worker experiences acute pesticide poisoning, which requires hospitalization. Symptoms might include nausea, vomiting, respiratory distress, seizures or even permanent organ damage, depending on the pesticide’s toxicity. The worker may be unable to return to work for an extended period, leading to significant medical costs and potential long-term health problems.
• Environmental contamination: The pesticide’s drift and runoff contaminate nearby water sources, killing fish, polluting soil and potentially affecting the broader ecosystem. Such contamination may result in expensive cleanup efforts, environmental fines and long-term damage to the local wildlife and plant life.
• Legal consequences: The business faces lawsuits from the worker for negligence and from environmental groups for violating environmental protection laws. Regulatory bodies may impose significant fines for noncompliance with PPE requirements and for failing to follow safe pesticide-application protocols. The company also might face public backlash and damage to its reputation.
• Regulatory fines and penalties: The EPA or state environmental agencies could impose substantial fines for improper application, failure to comply with pesticide-application requirements and endangerment of human health and the environment.
• Business shutdown or suspension: In some cases, the severity of the breach could lead to the suspension of the business’s pesticide applicator license or other operational permits, disrupting business operations for an extended period.

Key takeaway
This worst-case scenario illustrates the far-reaching consequences of improper PPE, not just for the worker but also for the environment, the community and the business as a whole. The failure to use proper PPE increases the likelihood of severe health consequences, environmental damage and regulatory scrutiny. The financial costs alone can be catastrophic, and the reputation of the business could be permanently damaged.

Hendrick Wenning, with Barrett Tree Service East Inc., an accredited, 18-year TCIA member company based in Medford, Massachusetts, climbs onto a spray tank truck safely, using three points of contact. Photo courtesy of Phil Perron, Barrett Tree Service East.

Notification requirements
Some states require comprehensive information to be included in your estimates. Some states have restricted use of certain chemistries. Be sure to understand your local regulations, and remember, federal requirements are the basis, but state and/or municipalities can implement stricter guidelines, and as certified applicators, we are required to abide by all regulations, but never less than federal standards.

Many states and municipalities have strict requirements for notifying the public and other workers about pesticide applications. Notifications help reduce risks to nonlicensed individuals, such as residents in adjacent properties or workers in nearby fields.

• Written or verbal notice: In some jurisdictions, especially in agricultural settings, a written notice of pesticide application must be provided to nearby workers, neighbors or residents typically 24 to 48 hours before application. Commercial properties, HOAs, parks and schools will most likely require a longer notification period. Check with your local extension if you are unsure!
• Electronic or paper notification: Ensure the method of communication complies with local regulations, whether it be physical notice, email, phone call or fax (who faxes anymore?).

Complying with notification requirements not only adheres to legal obligations but builds trust within the community.

Hypersensitivity and apiary notifications
Certain individuals may be hypersensitive to pesticides, especially if they have allergies or other health conditions. Furthermore, the presence of apiaries (bee colonies) in the vicinity of pesticide-application sites requires extra care to avoid harming pollinators.

Hypersensitivity:

• Worker sensitization: Be mindful of workers who may have a sensitivity to particular chemicals. If workers have known hypersensitivity to certain pesticides, have them avoid exposure or assign them to different tasks.
• Monitoring for symptoms: Regularly monitor for symptoms of pesticide exposure, such as dizziness, headaches, nausea or skin irritation. Maintain an up-to-date record of workers’ medical conditions and any potential allergies to pesticides.

Hypersensitivity also applies to individuals within a specific distance from the property with a planned application of any pesticide. You, the certified applicator, are required to check your area’s hypersensitivity lists and abide by notification requirements. Also, if any individual asks for a pesticide label or SDS while on a job site, they must be provided that document. If they inquire or mention they have a sensitivity to pesticides, there is a form that must be completed by a doctor and submitted to the state so they can be added to these lists.

Apiary notifications:

• Bee protection: Some pesticides can be particularly harmful to pollinators. Before applying pesticides, especially those that are toxic to bees (like neonicotinoids), check local apiary registration databases or contact nearby beekeepers.
• Notification to beekeepers: Inform beekeepers in the area of upcoming pesticide applications and provide them with application dates and the types of pesticides being used. The notification should ideally happen at least 48 hours prior to application.
• Application timing: Avoid applying pesticides during bloom times and during the times of day when bees are most active. If possible, schedule applications when wind conditions are low to reduce pesticide drift that could affect nearby colonies – especially if using misters!

Notification procedures
(post application):

1. Posting signs: When applying pesticides in public or commercial spaces, ensure that clearly visible signs are posted to alert others to the potential danger. These signs should include information such as the name of the pesticide, the date of application and the safety re-entry interval. Some states require posting signs, while in other states, posting is considered a courtesy. Some states have requirements for what is on the posting sign, the color of the sign and even size and font. Blackburn Flag, for example, is a long-time vendor of posting flags and can help with your state requirements. (blackburnflag.com)

A PHC technician with Stanley Tree Service Inc., a dual accredited, 35-year TCIA member company based Smithfield, Rhode Island, at the controls of a spray truck. TCIA staff photo.

Application requirements
Proper application methods are crucial to ensuring pesticide effectiveness while minimizing harm to the environment, workers and surrounding communities. Each pesticide has a specific label with application instructions, and these instructions must be followed precisely.

Application best practices

• Adherence to label instructions: Always follow the pesticide label, which is a legal document outlining the correct application methods, rates and safety precautions.
  Calibration of equipment: Regularly calibrate application equipment to ensure accurate dosing of pesticides and prevent over-application, which can lead to both environmental harm and legal consequences.
• Weather conditions: Avoid applying pesticides during windy or rainy conditions, as these can cause drift or run-off/wash-off. Ideal weather conditions include mild temperatures and minimal wind.
• Targeting the right area: Only apply pesticides to the intended target area. Avoid drift by using shields or low-drift nozzles when necessary. Do not spray during windy conditions. I was told once that if the flag is flying perfectly, it’s not a good day to apply foliar sprays.

Leave behind documentation
In some states, following pesticide applications, leaving behind documentation may be required by law. This documentation serves as both a record of the application and a notification to others about potential hazards.

Bethany “Toddie” Todd, PHC technician with Barrett Tree Service East Inc., performs soil injection. Photo courtesy of Phil Perron, Barrett Tree Service East.

Key documentation

• Application logs: These should detail the date, time, location, pesticide product, amount used, applicator and any specific conditions such as wind speed or temperature. Keep records for the legally required retention period (often two to three years).
• Safety Data Sheets (SDS): Always have updated SDS for all pesticides on hand. These documents provide essential information about the chemical, including hazards, first-aid measures and safe handling practices.
• Pesticide labels: Keep copies of pesticide labels that are specific to the products used. These labels contain vital safety and application information.

This documentation is not only important for compliance purposes, but it also protects your business in the event of an audit, lawsuit or environmental investigation.

Conclusion
Planning for safety and compliance in pesticide application requires a comprehensive, proactive approach. By addressing PPE requirements, notification obligations, hypersensitivity concerns, apiary protections and application protocols, and providing thorough documentation, you can create a safer environment for your workers, the public and the environment.

Maintaining ongoing training – at minimum on an annual basis – plus staying up to date with regulations and fostering a culture of safety within your organization, will ultimately contribute to long-term success and compliance, while minimizing risk and ensuring sustainable pesticide use.

Next up …
In part 4 of this series, we’ll look at FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) updates for 2025; state and local updates and compliance with updates.

Kathy Glassey is a senior consultant with Inspire Green Inc., a Pennsylvania-based company committed to helping tree companies around the country.