Worker Protection Standard for Agricultural Pesticides : Do the benefits outweigh the costs?

"The U.S. Environmental Protection Agency has proposed stricter requirements to avoid exposure to pesticides on farms, leaving farmers and officials divided about whether they go too far or provide needed protection."  (

While the author of the above piece certainly hits upon some of the more costly (and perhaps overprescriptive) elements of the Worker Protection Standard for Agricultural Pesticides revisions - such as increasing reporting requirements and reducing frequency of training - what is not captured is the interesting disconnect between the seemingly innocuous rule changes (... who doesn't want pesticide workers protected to the nth degree of the law, right?) and the overall tone of the the rule and its cost.

If you separate the preamble of the rule from the actual rule changes, you get the sense that proper label-directed use of pesticide products leads to increased longer-term burden of chronic disease and thus, the reduction of these alone justifies the cost.  One estimate in the comments received in the docket was that a $65 million dollar implementation cost was justified by the reduction of just over 50 cases of chronic disease per year.  Not only is there no causative data to support the justification of the expense, the correlative data used to make the case for pesticide workers and cancer appears selective. For example, the lung cancer connection was based on a single (government-led) study cohort, ignoring other industry- and academic-led studies that found no causal link between pesticide exposure and lung cancer.

The bottom line is that the regulations used to protect workers have not been modified since 1992 and there is room for improvement, particularly when it comes to acknowledging the considerable advances made in formulation chemistry, reduced risk active ingredients and application technology in the last 20 years.  There is considerable interest in the revisions, as evidenced by the amount of public response (as of today, there were almost 120,000 comments filed to the docket with only about 2% reviewed and posted online).  There is also likely top-down pressure from the White House, as evidenced by the fact that the President assigned the grand-daughter of Cesar Chavez himself to announce these changes to the world on behalf of the Administration.  It certainly appears that the WPS is going to be revised; however, it is unclear to what extent the current proposal will be revised.  Many more weeks are needed to process the other 98% of the public dockets.