Take Action to
Keep Farm Workers Safe on the Job
Send a
Comment Letter to the NC Pesticide Board no later than
December 15th
Thanks to the work of farmworker allies like you, North Carolina has a new pesticide safety law that requires growers who use pesticides to keep more precise records of what pesticides they apply, and when. That new law directs the NC Pesticide Board to make a set of record-keeping rules for growers to follow. The NC Pesticide Board has just released a proposal for pesticide record-keeping rules, and though it's a good start, the proposal is missing some pieces that threaten to make the changes ineffective for improving health and safety on NC farms. More information about the proposed rules. Please join Toxic Free NC and our allies in the Farmworker Advocacy Network in asking the NC Pesticide Board to make their pesticide rules clear and enforceable – because our worker safety laws won’t mean much if they can’t be enforced! >>Take action today to ensure that NC's new pesticide rules will really work to protect farm workers >>More background information and links Want to do more? Come to the public hearing on the proposed rules on Nov 12 at 1 PM in the Gov. Martin Building at the State Fair Grounds in Raleigh. Contact Toxic Free NC for more details. |
Workers deserve
safety laws that can actually be enforced. Growers
deserve clear rules that they can comply with. >>Send a comment letter to the NC Pesticide Board. >>Join the Real Food Now Month of Action and ask for Fair Food at your cafeteria. >>Support our work. Donate today!
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Take Action Today for Farm Worker Safety
Please submit a letter to the NC Pesticide Board expressing your support for clear and enforceable pesticide record-keeping rules that really work to protect farm workers. Please submit your letter as soon as possible, and no later than the December 15th deadline for public comments. You can use our sample letter, below, and submit your letter by mail or email to:
NC Pesticide Board
c/o Mr. Jim Burnette
1090 Mail Service Center
Raleigh, NC 27699-1090
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Please contact us at , or 919-833-1123 to let us know you're taking action, or if you have any questions. Thank you! |
Sample Comment Letter to the NC Pesticide Board
* Note, please be sure to replace the text [IN CAPS AND BRACKETS] with your own information. Thank you!
[DATE]
NC Pesticide Board
c/o Mr. Jim Burnette
1090 Mail Service Center
Raleigh, NC 27699-1090
Re: Proposed Pesticide Record-keeping Rules 2 NCAC 9L .1002, .1402 and .1807
To the Members of the NC Pesticide Board,
As a resident of North Carolina who is concerned about the safety of agricultural workers, and the integrity of our food supply, I thank you for this opportunity to submit comments to you on the proposed record-keeping rules. [DO YOU HAVE A PARTICULAR CONNECTION TO THIS ISSUE YOU'D LIKE TO SHARE? IF SO, YOU CAN DO SO HERE.]
The proposed rules are an important step to better protect workers and growers when pesticides are used in agriculture. However, there are two main problems in the rules that I urge you to fix before the rules are adopted:
- The rules should apply consistently to all pesticides, not just to restricted-use pesticides, no matter what type of pesticide application is being made.
- The rules should track both the specific time of the pesticide application, and the specific time when workers are allowed back into the fields.
The new rule should apply consistently to all pesticides, whether restricted-use or general-use pesticides, whether or not workers are present. Growers should not have to comply with a patchwork of different record-keeping requirements for different types of pesticide applications. And if the worker re-entry time is not recorded, the rule will remain ineffective for enforcing the critical re-entry intervals that are designed to protect workers' health and safety.
It is not worth the public expense of adopting rules that will not be effective. Please correct these oversights before the final rule is adopted.
Sincerely,
[YOUR NAME AND ADDRESS]
Background information about the proposed pesticide recod-keeping rules:
Pesticide use records
should include worker protection.
North Carolina is required to
improve pesticide record-keeping under a new state law. The
new rules should require growers to show that they have
complied with our laws that are designed to protect worker
safety and health.
Recording worker field entry
time protects workers and growers.
Federal regulations require a waiting period after pesticides
are applied, before workers can be safely sent back into
the same field. Because growers do not have to document
when workers enter the fields after pesticides are applied,
it is difficult to prove whether the required waiting period
was observed. Growers and workers are put in a he-said-she-said
situation with no documentation to prove (or disprove)
compliance. In the now-infamous case
against AgMart,
the company has argued that its records of worker field
entry times cannot be used against them, because those
records were not required in the first place.
A minor adjustment to record-keeping logs can
fix the problem.
Worker field entry times could be recorded in a single
column to be added to the record-keeping logs that growers
already use.
Recording worker field entry times would keep
workers safer.
Knowing that they need to document field entry times would
remind growers of the obligatory waiting period before
workers can be safely sent into sprayed fields.
Records should apply to all pesticides.
The current proposal applies inconsistently to “general-use” pesticides
and “restricted-use” pesticides. It should
apply consistently to all pesticide applications. >>Take
Action Now
Links for more information:
>>Download the full text of the proposed rule on pesticide record-keeping.
>>Read more about farm workers and pesticides in North Carolina.
>>More information about the Ag-Mart case.
>>More about new state legislation, adopted earlier this year, Prevent Agricultural Pesticide Exposure, from Toxic Free NC and from the NC General Assembly.
PS: Don't forget to vote! Early voting and one-stop voter registration starts on October 16th in North Carolina, so you can avoid long lines on election day, and you can even vote on the weekend. Get all your questions answered about where, why and how at the NC State Board of Elections Website.