Safety culture in the tree care industry has come a long way over the past several decades. Recognition of safety within tree care is paramount due to the inherently dangerous nature of the work. While adherence to safety policies in traditional tree work has grown, another facet of our industry also has been growing – plant health care (PHC) operations.
For the purpose of this article, PHC operations are defined as the handling and application of pesticides, fertilizers and bio-stimulants, in addition to using tools such as high-pressure air-excavation equipment to amend soils or perform root-collar excavations. While most companies have a strong safety program built around traditional tree care operations such as pruning and removals, awareness of safe work practices for their PHC technicians often is missing. All too often, well-intentioned companies and technicians can be found performing PHC operations without proper personal protective equipment (PPE), as well as misusing this equipment or misunderstanding what PPE needs to be worn in the operation they are performing.
In a review of popular industry publications, including Tree Care Industry Magazine, Tree Services and Arborist News, from August 2016 to August 2020, only two articles, “What to Know When Gearing Up for Spray Season,” TCI, May 2018; and “Arborist Skills: Avoiding and Cleaning Up Chemical Spills,” by Zack Shier, TCI, June 2020, discussed topics like spill prevention and operator safety measures. Even more worrisome than this void of awareness is how often PPE in PHC operations is misrepresented.
Countless advertisements, distributor websites, social-media posts and industry publications will show technicians operating with insufficient PPE. Examples of this include not wearing or wearing inadequate chemical-resistant gloves when applying pesticides, and not wearing long sleeves or a hard hat with an attached face shield when operating high-pressure, air-excavation equipment. The aforementioned May 2018 TCI article contains a picture of a technician not wearing chemical-resistant gloves while operating a piece of equipment designed to inject insecticides into the soil. Surely this is a staged photo and the equipment was clean, with no product actually being applied, but perception is everything.
Before going further, let’s set the tone for this article. This piece is meant as encouragement to build upon the safety culture already created in our industry and to show how PHC operations can be brought into the fold. As an industry, we should be proud of the ground taken in bringing safety consciousness to the forefront and excited to spread the topic to a growing segment of our business.
What does the “Z” say about safety and PHC?
The first question we need to address is, “Where can we find references to inform our PHC safety protocols?” Those of us in the United States need look no further than the ANSI Z133, American National Standard for Arboriculture Operations Safety Requirements. It may come as a surprise to some, but the Z133 has a lot of information pertaining to PHC operations. It begins in Section 1, which states:
This standard contains arboriculture safety requirements for pruning, repairing, maintaining, and removing trees; cutting brush; and for using equipment in such operations.
The Scope states that maintaining trees, as we do in PHC operations, falls within the purview of the Z133.
Moving on, Section 3, General Safety Requirement, states:
3.1.2: Employers shall instruct their employees in the proper use, inspection, and maintenance of personal protective equipment (PPE), tools (hand and powered), and other equipment including ropes and lines.
In this line, we have a “shall statement” – strong language – around an employer’s responsibility to train technicians on proper PPE and its use. An example would include reading and understanding PPE requirements dictated by a product’s label. We will examine product labels in a later section.
The Z133 begins to directly address PHC operations in Section 5.4, Sprayers and Related Equipment, where a set of shall statements highlight PPE usage:
188.8.131.52: The equipment shall have splashguards, and the applicator shall wear eye protection when injecting liquid fertilizer or pesticides into the ground.
184.108.40.206: The applicator shall wear eye protection and follow label instructions when injecting liquids into trees.
The need to wear eye protection when performing systemic applications may not seem intuitive. After all, one of the advantages of performing applications to the soil or directly into the tree is to reduce applicator exposure, but accidents do happen. A few years ago, I spoke with a technician who was temporarily blinded in one eye by equipment failure while trunk-injecting an insecticide.
Reading on, we come to Section 8.9, Pesticide Application. This is an obvious must-read for anyone who performs pesticide applications for a tree care company. Section 8.9.1-3 contains several shall statements that include instruction about licensing/certifications, local/state regulations and following the label. There are several items around PPE and safe-work procedures in Section 8.9 that stand out:
8.9.4; Personal protective equipment shall be properly fitted, cleaned, maintained, and stored. Proper use of personal protective equipment as specified on the product label will reduce the risk of pesticide exposure to the applicator.
8.9.5: Personal protective equipment shall not be stored with pesticides.
These are important, yet often overlooked, items to consider for reducing applicator exposure. Reusable gloves should be washed daily with soap and water, along with any protective head gear and footwear. Another important note – disposable gloves are intended for one-time use only. In other words, once you have put on a pair of one-time-use gloves and taken them off, they are considered contaminated and should be disposed of responsibly.
Once a piece of PPE has been used in mixing or application, it should be considered contaminated and stored away from uncontaminated areas such as in the cab of a truck. Boxes on trucks should be designated for pesticides and PPE. Large, sealable plastic bins also can be used to keep PPE from contaminated and non-contaminated areas.
Continuing on with Section 8.9:
8.9.8: The applicator shall follow pesticide label instructions in regard to laundering his/her clothing.
We will look at how labels inform safe-work protocols in the following section, but with regard to 8.9.8, most labels will have the following statement:
“Follow manufacturer’s instructions for cleaning/maintaining PPE. If no such instructions (are available) for washables, use detergent and hot water. Keep and wash PPE separately from other laundry.”
In the context of some labels, long-sleeve shirts and long pants are considered PPE. This would imply a technician should not be washing contaminated clothing with the rest of his/her personal laundry. Here is where an employer can step in to aid with compliance by covering the cost of a uniform service that picks up, launders and delivers clean work clothes directly to its office. Another option would be to have a washer and dryer on site. This way, technicians avoid bringing contaminated PPE home to their families.
After stating that the applicator should shower or bathe at the end of the workday, the “Z” goes on with Section 8.9.10:
8.9.10: The employer shall provide a clean-water source at the work site, which may be used for emergency personal decontamination. Precautions shall be taken to prevent contamination of the clean-water source. Drinking water and decontamination water shall be kept in separate containers and each labeled.
This shall statement presents a conundrum. Most PHC activities occur over several sites throughout the day. There is an easy fix for this situation; simply affixing a clean-water service tank to the PHC truck and labeling it accordingly gives the technician a mobile clean-water source at all work sites. Care needs to be taken with this tank. The tank should be cleaned regularly to avoid bacteria and algae from causing other health concerns.
The next PHC operations the standard covers are 8.10, Mixing Pesticides, and 8.11, High-Pressure Air-Excavation Equipment. Section 8.11 begins with a strong shall statement:
8.11.1: Personal protective equipment shall include hard hat with attached face shield, hearing protection, eye protection, and gloves. Additionally, long pants, a long-sleeved shirt, and/or coveralls shall be worn.
This is very specific and detailed on exactly what PPE is required for operating this type of equipment. This is followed by the next statement in 8.11:
8.11.2: Respiratory protection should be worn when conditions warrant. When used, respiratory protection shall be in accordance with the OSHA 1910.134 Respiratory standard.
The first part of this clause leaves when to wear a respirator up to the technician and the employer. There are health concerns associated with inhaling fine soil/dust particles associated with this type of work. While the Centers for Disease Control and Prevention (CDC) and the National Institute for Occupational Safety and Health (NIOSH) have set exposure limits for many types of particulate matter, there is not a lot of guidance when it comes to soil in our industry. Certain soil types contain high concentrations of crystalline silica, which can cause a range of acute and chronic respiratory illnesses. OHSA does have an advisory document for General Industry discussing crystalline silica (Occupational Exposure to Respirable Crystalline Silica, 29 C.F.R. § 1910.1053). There also are some soil-borne illnesses to be aware of, such as valley fever (Coccidioides spp.), a soil-borne fungal disease that occurs in different areas of the Western U.S. Suffice it to say that wearing an approved respirator is highly encouraged, especially when soil conditions are dry.
The OSHA 1910.134 Respiratory Protection document describes developing a “respiratory protection program” and provides guidance on using and maintaining respirators. Note, OSHA and CDC references discuss using engineering control measures to control breathing contaminates. An example in the case of high-pressure, air-excavation equipment may be to have the client irrigate the soil around the area prior to the work occurring.
How can the product label inform safe work practices?
Pesticide applications are a large part of PHC operations. All pesticides, including insecticides, fungicides, herbicides and plant-growth regulators, must be registered with the U.S. Environmental Protection Agency, which reviews and approves product labels. Most applicators are familiar with the front panel of a pesticide label. But pull back the front panel, and you will find more detailed information about the product.
With regard to applicator safety, technicians and employers will want to turn their attention to the “Precautionary Statements.” Precautionary Statements are designed to provide pesticide users with information regarding the toxicity, irritation and sensitization hazards associated with the use of a pesticide, as well as application instructions and information to reduce exposure potential. Under this section of the label is located the “Hazards to Human and Domestic Animals” statement, which discusses routes of exposure; First Aid; and the “Personal Protective Equipment” statement, which discusses specific PPE requirements.
The Personal Protective Equipment section specifically addresses what an applicator is required to wear for mixing, application, etc. Most label PPE statements will read at a minimum:
Applicators and other handlers must wear:
• Long-sleeved shirt and long pants
• Chemical-resistant gloves such as barrier laminate, butyl rubber, nitrile rubber or Viton.
• Shoes plus socks
Although often not stated on labels, wearing safety glasses is highly recommended. Wearing chemical-resistant footwear also should be considered, since many products can linger on organic material such as leather.
It is important to read and understand the PPE portion of the label, as some of these bullets are subject to significant changes between similar products. One of the most commonly overlooked examples is around chemical-resistant glove material and thickness. Work gloves with nitrile-coated palms are not considered acceptable for chemical application. Additionally, some labels require specific glove material and thickness:
• Chemical-resistant gloves (Category C) such as barrier laminate; butyl rubber ≥14mils; nitrile rubber ≥14 mils; or neoprene rubber ≥14 mils.
Additional PPE requirements that may be listed include, but are not limited to:
• Chemical-resistant footwear plus socks
• Protective eyewear
• Chemical-resistant headgear for overhead exposure
• Chemical-resistant apron when cleaning equipment, mixing or loading
It is also important to review the First Aid section of the label, as some first-aid measures may be counterintuitive. For example, you may assume that if you accidentally ingest a pesticide, vomiting immediately will reduce exposure. But for some products, the label explicitly says not to induce vomiting. You also will want to cross reference what is recommended in the first-aid section with what is available on the truck, such as first-aid kits, mobile eye-wash stations, etc.
One additional note is to ensure spill-response kits are available and intact, and personnel are trained in their use. Parts of a spill kit include PPE, absorbent material, berms or dikes and absorbent pads. Technicians also should carry a spare set of clothes in the event they spill product on themselves. Remember, it is a violation of federal law to use pesticides in a manner inconsistent with their labeling.
Safety Data Sheets and safe work practices
The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)) requires that the chemical manufacturer, distributor or importer provide Safety Data Sheets (SDSs, formerly MSDSs or Material Safety Data Sheets) for chemicals to communicate information on any potential hazards. SDSs are not just for pesticides registered with the U.S. EPA. SDSs are created for everything from household cleaners to fertilizers and bio-stimulants used in arboriculture.
Safety Data Sheets contains 16 sections. For EPA-registered pesticides, the First-Aid Measures (Section 4) and Exposure Controls/Personal Protection (Section 8) are similar to what is on the label, though the SDSs may have stronger recommendations for PPE on some products. For example, many pesticides, surprisingly, do not list eye protection in the PPE statement on the label. However, it is not unusual to find a statement about eye protection on the SDS, such as this:
• Eye Protection – Use chemical splash goggles. Facilities storing or utilizing this material should be equipped with an eye-wash facility and a safety shower.
From a safety perspective, Section 8 of SDSs becomes important for products that are not required to have a PPE statement on their labels, such as fertilizers and select bio-stimulant products. Some products that most people think of as benign, such as composts, may contain human pathogens, and care needs to be taken to reduce exposure. Many of these products will have PPE recommendations on their SDSs in Section 8 that may include the use of gloves, protective eyewear and respirators.
Throughout this article, we have discussed the need for bringing safety culture into the forefront of our PHC operations and have identified some references to begin building our PHC safety programs. The next step begins with reflecting on where your PHC safety program currently stands. Perform an audit of products you are using. Identify PPE and safety precautions dictated by the product labels and SDSs. Inventory your PPE to determine if what you are providing technicians is adequate based on what the ANSI Z133, labels and SDSs are mandating. Identify what equipment you are using in your PHC operations and reach out to the manufacturers to ensure the hardware is being used safely as intended. Ensure you are following the laws and guidelines directed by government authorities.
Importantly, communicate with your technicians and build from the safety culture present within traditional tree care operations. One strategy that can be very effective is having PHC technicians present at the regularly scheduled safety tailgates, and having them actively participate. Lessons in close calls and situational awareness are universal. A great idea to bring this to the forefront is a technician “huddle” after the general safety meeting to discuss a safety topic specific to their day-to-day, such as caring for chemical-
resistant gloves, monitoring spray-hose wear, etc.
This article is intended to bring additional awareness to a PHC safety culture and introduce some resources that can be the building blocks of a PHC safety program. The examples provided are not exhaustive of all resources available, and are not meant to take precedence over the full body of material referenced, reference material not included or federal, state and local laws/ordinances.
EPA Pesticide Label Review Training: https://www.epa.gov/pesticide-labels/
Hazard Communication Standard: https://www.osha.gov/dsg/hazcom/
Patrick Anderson is an arborologist, or regional technical director, with Rainbow Treecare Scientific Advancements, a 22-year TCIA Corporate Member company based in Minnetonka, Minnesota. For TCIA members who would like to view a webinar on this topic featuring Patrick Anderson, go to tcia.org and, under the Education & Events tab, select Webinars then “Creating a Plant Health Care Safety Culture.”