STAYING IN COMPLIANCE

Posted on | by Justin Harrison

WHY COMPLIANCE MATTERS
Staying in government compliance is critical when handling and storing TELONE™. Handling a restricted-use product like TELONE™ adds a layer of complexity to compliance, especially at bulk facilities, where storage, transport, and worker safety require careful oversight. Understanding these requirements is key to minimizing risks and ensuring smooth, uninterrupted operations.

DEPARTMENT OF TRANSPORTATION (DOT)

SITE SECURITY PLANS (49 CFR PART 172 SUBPART I)

WHO NEEDS IT?

  • Businesses handling large quantities of hazardous materials (ex: 3,000L or more of division 6.1 poisons).

KEY COMPONENTS:

  • Risk Assessments: Identify potential security vulnerabilities.
  • Physical Security Measures: Install fences, locks and surveillance systems.
  • Employee Security Awareness Training: Educate staff on recognizing and reporting suspicious activities.
  • Emergency Response: Develop protocols for leaks and spills.

HAZMAT EMPLOYEE TRAINING

WHO NEEDS IT?

  • Employees involved in shipping, packaging, or handling hazardous materials, including supervisors.

TRAINING DETAILS:

  • Initial training must occur within 90 days of hiring.
  • Training should include regulatory awareness, safety procedures, and practical applications.
  • Recurrent training every 3 years ensures updated knowledge.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA)

RESPIRATORY PROTECTION STANDARDS

WHO NEEDS IT?

  • Workers using respirators to protect against airborne hazards.

REQUIREMENTS:

  • Conduct annual fit testing to ensure proper seal and effectiveness.
  • Provide thorough training on respirator use, care, and maintenance.
  • Maintain records of testing and training for verification.

HAZARD COMMUNICATION STANDARD (HAZCOM)

WHO NEEDS IT?

  • All workplaces with hazardous chemicals.

REQUIREMENTS:

  • Develop and implement a written HazCom plan tailored to your operations.
  • Ensure every hazardous chemical has an up-to-date Safety Data Sheet (SDS).
  • Train employees on chemical hazards, label interpretation, and safe handling practices.
  • Regularly review the program and update it when new hazards are introduced.

ENVIRONMENTAL PROTECTION AGENCY (EPA)

WORKER PROTECTION STANDARD (WPS)

The Worker Protection Standard (WPS) is designed to reduce the risk of pesticide exposure
to agricultural workers and pesticide handlers. Compliance ensures safety and minimizes
liability.

WHO NEEDS IT?

  • Employers involved in agriculture (e.g., farms, nurseries, greenhouses, and forests)where pesticides are used.

REQUIREMENTS:

  • WORKER TRAINING: Provide annual EPA-approved training to all agricultural workers and pesticide handlers. Include instructions on avoiding exposure and emergency procedures.
  • DECONTAMINATION SUPPLIES: Ensure workers have access to water, soap, towels, and clean clothes in case of exposure.
  • RESTRICTED-ENTRY INTERVALS: Follow label-specific guidelines for when workers can re-enter treated areas.
  • NOTIFICATION REQUIREMENTS:
    • Verbally inform workers of areas treated with pesticides.
    • Post clear warning signs in applicable languages at entry points to treated areas.
  • PERSONAL PROTECTIVE EQUIPMENT (PPE):
    • Ensure workers handling pesticides are provided with and properly trained on using required PPE.
  • EMERGENCY ASSISTANCE:
    • Have a protocol for immediate medical treatment in the event of exposure, including providing the pesticide label to medical personnel.

PRODUCTION REPORTING REQUIREMENTS

The EPA mandates annual reporting from facilities involved in the production or distribution of pesticides to track environmental impact and ensure compliance with federal regulations.

WHO NEEDS IT?

  • Facilities registered with the EPA for pesticide production or distribution. TELONE™ repackaging facilities.

KEY REQUIREMENTS:

  • Submit reports on the quantities of pesticides produced, distributed, and sold annually.
  • Include details of specific products, formulations, and production sites.
  • Maintain accurate records for at least two years for verification and audits.
  • Reports are typically due by March 1st for the preceding calendar year.

HOW TO PREPARE:

  • Establish a reliable record-keeping system.
  • Assign a compliance officer to oversee reporting.
  • Review EPA guidelines to ensure your submission meets current standards.

KEY TAKEAWAYS

1) DOCUMENT EVERYTHING: keep detailed records of all compliance-related activities.

2) PROACTIVELY TRAIN: regular updates ensure workers are prepared even if refresher training isn’t mandated.

3) MONITOR UPDATES: Regulations change frequently. Assign a compliance officer or team to stay informed about updates.

4) REGULAR AUDITS: Use slower operational periods to review compliance plans and inspect equipment to ensure compliance.

In conclusion, when handling and storing TELONE™, it is vital to comply with the various required government agencies. If you have any questions, reach out to your TELONE™ Specialist and they can assist in getting you the answers you need. We are here to help make sure you and your team are set up for success when it comes to TELONE™ compliance. Remember, there’s no coming back from a poor start!

Disclaimer:
The resources and information provided are meant purely for educational discussion, contains only general information about legal matters, and is not to be construed as advice. Please note that any information or resources provided are not legal or regulatory advice, and should not be treated as such. You must not rely on the information provided as an alternative to legal advice from your attorney or other professional services. Teleos Ag encourages readers to consult with counsel, and their local, county, and state regulators. We make no representations or warranties, express or implied, in relation to the information provided through our resources and blog posts. It is the readers responsibility to know the laws related to 1,3- D, appropriate PPE, Licensing, etc., in his or her City, County, State, and Country.

Justin Harrison
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