---------------- ----- -

--- ---- - ----- --

------- ---------- ------- ----- --------- --------

------- ----- ---

STA TE OF CALIFORNIA - DEPARTMENT OF FINANCE

ECONOMIC ANO FISCAL IMPACT STATEMENT (REGULATIONS AND ORDERS) STO 399 (REV 122013)

ECONOMICIMPACT STATEMENT EMAIL ADDRE 55 TELEPHONE NUMBERARTMENT NAME

Pesticide Regulation 1

CONTACT PER50N

Joshua Ogawa joshuaogawacdprcago 916-445-6234

DE5CRIPTIVE TITLE FROM NOTICE REG15TER OR FORM 400

Worker Protection Standard - Training NOTICE FILE NUMBER

z

A ESTIMATED PRIVATE SECTOR COST IMPACTS lnclude cacuations and assumptions in the rulemaking record

1 Check the appropriate box(es) below to indicate whether this regu lation

(8) a lmpacts business andor employees O e lmposes reporting requirements

(8) b lmpacts small businesses (8) f lmposes prescriptive instead of performance

O c lmpacts jobs or occupations (8) g lmpacts individuals

O d lmpacts California competit iveness O h None of the above (Explain below)

lfany box in Items 1 a through g is checked complete this Economic Impact Statement If box in iacutetem 1h is cltecked complete tite Fiscal lmpact Statement as appropriate

Department of Pesticide Regulation 2 The -----~-~~---~ ---- estimates that the economic impact of this regulation (which includes the fiscal impact) is

(AgencyDepartment)

(8) Below S1OmiIlion

O Between S1 O and $25 mi Ilion

O Between $25 and $50 million

O Over $50 million [lf the economic impact is over $50 milion agencies are required to submit a Standardized Regulatory lmoact Assessment as specified in Government Code Section l l 3463(c)]

3 Enter the total number of businesses impacted 321 41

Describe the types of businesses (lnclude nonprofits) (see attachment)-=----------=------ ---------------- - ---- ----

Enter the number or percentage of total businesses impacted that are smal l businesses 20

4 Enter the number of businesses that will be created O eliminated O -

Explain NA - - - -

5 lndicate the geographic extent of impacts (8) Statewide

O Local or regional (List areas)

6 Enter the number of jobs created O and eliminated O

Describe the types of jobs or occupations impacted _N__A______ _________________ _________ _ _

7 Will the regulat ion affect the abi lity of Ca lifornia businesses to compete with other states by making it more costly to produce goods or services here O YES (8) NO

lf YES explain briefly

PAGE 1

---------- -----

----- ----- -----

----------

_______ ________

STATE OF CALIFORNIA - DEPARTMENT OF FINANCE

ECONOMIC ANO FISCAL IMPACT STATEMENT (REGULATIONS ANO ORDERS) STO 399 (REV 1212013)

=== = ECON =M=IC== P=A=C=T=S=TA =M= = CONTI== ==== ==============O IM = =T=E E=NT=(= ==== NUED)==== ( B ESTIMATED COSTS lncfude calculations and assumptions in the rulemaking record

1 What are the total statewide dallar costs that businesses and individuals may incur to comply with this regulation over its lifet ime $ 95 mi l-103 mil

a lnitial costs far a small business $1039-1475 Annual ongoing costs $ 1039-1475 Years 5

b lnitial costs far a typical business $2612-5006 Annual ongoing costs $ 2612-5006 Years 5

c lnit ial costs far an individual $ Annual ongoing costs $ _ _______ Years_____

d Describe other economic costs that may occur

2 lf multiple industries are impacted enter the share of total costs far each industry _____ _ _ ______________ _ _ ___

3 lf the regulation imposes reporting requirements enter the annual costs a typical business may incur to comply with these req uirements ncude rhe dolar casts to do programming record keeping reporting and other paperwork whether or not the paperwork must be submitred $_____ _ _

4 Will this regulation directly impact housing costs O YES [gj NO

lf YES enter the annual dallar cost per housing unit $____________

Number of units

S Are there comparable Federa l regulations OYES

Explain the need far State regulation given the existence or absence of Federal regulations (see attachment)---------------------------

Enter any addit ional costs to businesses andor individuals that may be dueto State - Federal differences $ ___________

C ESTIMATED BENEFITS Estimation of the dolar value ofbenefits is not specifically required by rulemaking law but encouraged

1 Briefly summarize the benefits of the regulation which may include among others the health and welfare of California residents worker safety and the States environment Expa ndi ng the required t rain ing content for pest icide

handlers and fie ldworkers will improve worker safety by providing a more comprehensive descri ption of rights and

protections and how to red uce risks and behaviors associated with accidenta l exposure to pesticides

2 Are the benefits the result of O specific statutory requirements o r (g] goals developed by the agency based on bread statutory authority

Explain DPR has broad authority t o adopt regu lations to protect handlers and wo rkers in pesticide treated a reas

3 What are the total statewide benefits from this reg ulation over its lifetime $ not quantifi ed

4 Briefly describe any expansion of businesses currently doing business within the State of California that would result from this regulation non e expected

D AL TERNATIVES TO THE REGULATION Jnclude caculations ond assumptions in the rulemaking record Estimation of the dolar vaue of benefits is n ot

specificaly required by rulemaking aw but encouraged

1 List alternatives considered and describe them below lf no alternat ives were considered explain why not (see attachment) _____

PAGE 2

---------- -----

----- ----- -----

----------

_______ ________

STATE OF CALIFORNIA - DEPARTMENT OF FINANCE

ECONOMIC ANO FISCAL IMPACT STATEMENT (REGULATIONS ANO ORDERS) STO 399 (REV 1212013)

=== = ECON =M=IC== P=A=C=T=S=TA =M= = CONTI== ==== ==============O IM = =T=E E=NT=(= ==== NUED)==== ( B ESTIMATED COSTS lncfude calculations and assumptions in the rulemaking record

1 What are the total statewide dallar costs that businesses and individuals may incur to comply with this regulation over its lifet ime $ 95 mi l-103 mil

a lnitial costs far a small business $1039-1475 Annual ongoing costs $ 1039-1475 Years 5

b lnitial costs far a typical business $2612-5006 Annual ongoing costs $ 2612-5006 Years 5

c lnit ial costs far an individual $ Annual ongoing costs $ _ _______ Years_____

d Describe other economic costs that may occur

2 lf multiple industries are impacted enter the share of total costs far each industry _____ _ _ ______________ _ _ ___

3 lf the regulation imposes reporting requirements enter the annual costs a typical business may incur to comply with these req uirements ncude rhe dolar casts to do programming record keeping reporting and other paperwork whether or not the paperwork must be submitred $_____ _ _

4 Will this regulation directly impact housing costs O YES [gj NO

lf YES enter the annual dallar cost per housing unit $____________

Number of units

S Are there comparable Federa l regulations OYES

Explain the need far State regulation given the existence or absence of Federal regulations (see attachment)---------------------------

Enter any addit ional costs to businesses andor individuals that may be dueto State - Federal differences $ ___________

C ESTIMATED BENEFITS Estimation of the dolar value ofbenefits is not specifically required by rulemaking law but encouraged

1 Briefly summarize the benefits of the regulation which may include among others the health and welfare of California residents worker safety and the States environment Expa ndi ng the required t rain ing content for pest icide

handlers and fie ldworkers will improve worker safety by providing a more comprehensive descri ption of rights and

protections and how to red uce risks and behaviors associated with accidenta l exposure to pesticides

2 Are the benefits the result of O specific statutory requirements o r (g] goals developed by the agency based on bread statutory authority

Explain DPR has broad authority t o adopt regu lations to protect handlers and wo rkers in pesticide treated a reas

3 What are the total statewide benefits from this reg ulation over its lifetime $ not quantifi ed

4 Briefly describe any expansion of businesses currently doing business within the State of California that would result from this regulation non e expected

D AL TERNATIVES TO THE REGULATION Jnclude caculations ond assumptions in the rulemaking record Estimation of the dolar vaue of benefits is n ot

specificaly required by rulemaking aw but encouraged

1 List alternatives considered and describe them below lf no alternat ives were considered explain why not (see attachment) _____

PAGE 2

--------

- --------------------- -------- ------------------- --

---------------------------------------------------

------------ --- ------- - -

------------ ------------

----------------------------------- ---

STA TE OF CALIFORNIA - DEPARTMENT OF FINANCE

ECONOMIC AND FISCAL IMPACT STATEMENT (REGULATIONS AND ORDERS) STO 399 (REV 122013)

ECONOMIC IMPACT STATEMENT (CONTINUED)

5ummarize the tota l statewide costs and benefits from this regulation and each alternative considered

Regulation Benefit S not quantified Cost S 95-103 mil

Alternative 1 Benefit S not quantified Cost S

Alternative 2 Benefit S Cost S _____ ___

3 Briefly discuss any quantification issues that are relevant to a comparison of estimated costs and benefits fo r this regulatio n or alternatives _n_o_n_e_______ _____________________

4 Rulemaking law requires agencies to consider performance standards asan alternative if a regulation mandates the use of specific technologies or equipment or prescribes specific actions or procedures Were performance standards considered to lower compliance costs D YES ~NO

Explain Performance standards are not appropriate for this rulemaking Specific requirements are necessary for

compl iance and enforcement

E MAJOR REGULATIONS lncude calculations and assumptions in the rulemoking record

California E11viro11mental Protection Agency (CalEPA) boards ofices and departme11ts are required to mbmit thefollowi11g (per Health and Safety Code section 57005) Otherwise skip to E4

1 Will the estimated costs of this regulation to California business enterprises exceed $1 O million D YES ~NO

lf YES complete E2 and E3 lf NO skip to E4

Briefly describe each alternative or combination of alternatives for which a cost-effectiveness analysis was performed

Alternative 1

A I terna tive 2

(Attach additional pages for other alternatives)

3 For the regulation and each alternative just described enter the estimated total cost and overall cost-effectiveness ratio

Regulation Total Cost $_ ________ ___ Cost-effectiveness ratio S____________

Alternative 1 Total Cost S Cost-effectiveness ratio $

A I terna tive 2 Total Cost $ Cost -e ffe c ti ven ess ratio S

4 Will the regu lation subject to OAL review have an estimated economic impact to business enterprises and ind ividuals located in or d oing business in California exceeding $50 miIlion in any 12-month period between the date the major regu lation is estimated to be filed with the Secretary of State through 12 months after the major regulation is estimated to be fully implemented

D YES ~NO

lf YES agencies are required to submit a Standardized Regulatory lmpact Assessment CSRIAJ as specified in Government Code Section 11346J(c) and to include the SRA in the lnitial Statement ofReasons

S Briefly describe the following

The increase or decrease of investment in the State

The incentive for innovation in products materials or processes ------ ---------- ---------------- -

The benefits of t he regulations including but not limited to benefits to the health safety and welfare of California residents worker safety and the states environment and quality of life among any other benefits identified by the agency ____________

PAGE 3

----------------------

STATE OF CALIFORNIA- DEPARTMENT OF FINANCE

ECONOMIC AND FISCAL IMPACT STATEMENT (REGULATIONS AND ORDERS) STD 399 REV 122013)

FISCAL IMPACT STATEMENT

A FISCAL EFFECT ON LOCAL GOVERNMENT Indica te appropriate boxes 1 through 6 and attach caculations and assumptioacutens of fiscal impact for the current year and two subsequent Fiscal Years

D 1 Additional expenditures in the current State Fiscal Year which are reimbursable by the State (Approximate) Pursuant to Section 6 of Article XIII B of the Callfornia Constitution and Sections 17500 et seq of the Government Code)

$

D a Funding provided in

BudgetActof_________ or Chapter______ Statutes of________

D b Funding will be requested in the Govemors Budget Act of

Fiscal Year________

O 2 Additional expenditures in the cunent State Fiscal Year which are NOT reimbursable by the Sta te (Approximate) (Pursuant to Section 6 of Article XIII B of the California Constltution and Sections 17500 et seq of the Government Code)

Check reason(s) this regulation is not refmbursable and provide the appropriate information

O a lmplements the Federal mandate contalned ln

D b lmplements the court manda te set forth by the ________________________court

Case of___________________ vs ---------------------1(

D c lmplements a manda te of the people of this State expressed in thelr approval of Proposition No

Date of Election___________________

D d lssued only in response to a specific request-from affected local entity(s)

Local entity(s) affected _______________________________________

D e Will be fully financed from the fees revenue etc from

Authorized by Sectlon middot____________ of the _______________ Code

O f Provides far savings to each affected unit of local government which will ata minimum offset any addltlonal costs to each

O g (reates eliminates or char1ges the penalty for a new crlme ar infraction contained In

D 3 Annual Savings (approximate)

$

D 4 No additional costs or savings This regulation makes only technical non-substantive or clarifying changes to current law regulations

[8J S No fiscal impact exists This regulatlon does not affect any local entity or program

O 6 Other Explain

PAGE4

---------

STA TE OF CALIFORNIA - DEPARTMENT OF FINANCE

ECONOMIC ANO FISCAL IMPACT STATEMENT middot (REGULATIONS AND ORDERS) STO 399 (REV 122013)

FISCAL IMPACT STA TEMENT (CONTINUED) FISCAL EFFECT ON STATE GOVERNMENT Indicate appropriate boxes 1 through 4 and attach calculations and assumptions offiscal impact for the current

year and two subsequent Fiscal Years

D 1 Additional expenditures in the current State Fiscal Year (Approximate)

$ ____ __________

lt is anticipated that Sta te agencies wi1

D a Absorb these additional costs within their existing budgets and resources

D b lncrease the currently authorized budget level for the Fiscal Year

ordm 2 Savings in the current State Fiscal Year (Approximate)

s

~ 3 No fiscal impact exists This regulation does not affect any State agency or program

D 4 Other Explain

C FISCAL EFFECT ON FEDERAL FUNDING OF STATE PROGRAMS Indica te appropriate boxes 1 through 4 and attach calculations and assumptions of fiscal impact for the currentyear and two subsequent Fiscal Years

[=1 1 Additional expenditures in the current State Fiscal Year (Approximate)

$ ______________

D 2 Savings in the current State Fiscal Year (Approximate)

s

~ 3 No fiscal impact exists This regulation does not affect any federally funded State agency or program

D 4 Other Explain

DATE

6-U-J7 The sign e attests agency has completed the STD 399 according to the instruclions in SAM sections 6601-6616 and underslands the im acts ofthe proposed rulemaking State boards ofjices or deparlments not under an Agency Secretay mus have the form signed by the hi hest rankin o 1cial in the or anization

AGENCY SECRETARY v-----Finance approval and signature is required when SAM sections 6601-6616 require completion ofFiscal lmpact Stalement in the STD 399

)EPARTMENT OF FINANCE PROGRAM BUDGET MANAGER DATE

PAGE 5

( Proposed Regulation for Worker Protection Standard

Attachment to Economic and Fiscal Impact Statement - STD 399

A3 Describe the types ofbusiness (Include nonprofits) Farms and agricultura businesses

employing workers that either handle pesticides or work in treated fields and nonagricultural businesses employing pesticide handlers

B5 Explain the need for State regulations given the existence or absence ofFederal regulations US EPA has granted California the authority to implement state regulations that are equivalent to the federal worker protection standard In order to maintain equivalency with federal regulations California regulations must be at least as protective as the federal standards In 2015

the federal worker protection regulations were updated to include additional training topics

covered during required pesticide handler and fieldworker trainings Federally the new training requirements are to go into effect no earlier than January 1 2018 and no later than 180 days after

the US EPA notices in the Federal Register the availability oftraining materials Given the uncertainty ofwhether the federal regulations are effective January 1 2018 or at sorne later unknown time the proposed State regulations would ensure that California regulations are equivalent to federal regulations and ensure that ali handlers (both agricultura and nonshyagricultural) are trained under the same higher standard middot

D1 List alternatives considered and describe them Federally the expanded handler and fieldworker training topics are applicable to only agricultura workers and there are no handler

training requirements for nonagricultural workers applying general use pesticides In California both agricultura and nonagricultural employers must provide workers handling pesticides or

working in pesticide treated areas the same leve of training DPR considered only expanding the training content required for agricultura pesticide handlers however this alternative is

untenable The additional training topics cover worker rights and protection on how to reduce the

risk of accidental exposure to pesticides and are not industry specific Separating pesticide handler training content based on application site (agricultura use versus non-agricultura use) creates a double standard where one group of handlers is provided more comprehensive worker safety training than another In addition having two sets of training requirements would crea te confusion in industry when trying to determine when and which employees require training under the new requirements

----------------------

STATE OF CALIFORNIA- DEPARTMENT OF FINANCE

ECONOMIC AND FISCAL IMPACT STATEMENT (REGULATIONS AND ORDERS) STD 399 REV 122013)

FISCAL IMPACT STATEMENT

A FISCAL EFFECT ON LOCAL GOVERNMENT Indica te appropriate boxes 1 through 6 and attach caculations and assumptioacutens of fiscal impact for the current year and two subsequent Fiscal Years

D 1 Additional expenditures in the current State Fiscal Year which are reimbursable by the State (Approximate) Pursuant to Section 6 of Article XIII B of the Callfornia Constitution and Sections 17500 et seq of the Government Code)

$

D a Funding provided in

BudgetActof_________ or Chapter______ Statutes of________

D b Funding will be requested in the Govemors Budget Act of

Fiscal Year________

O 2 Additional expenditures in the cunent State Fiscal Year which are NOT reimbursable by the Sta te (Approximate) (Pursuant to Section 6 of Article XIII B of the California Constltution and Sections 17500 et seq of the Government Code)

Check reason(s) this regulation is not refmbursable and provide the appropriate information

O a lmplements the Federal mandate contalned ln

D b lmplements the court manda te set forth by the ________________________court

Case of___________________ vs ---------------------1(

D c lmplements a manda te of the people of this State expressed in thelr approval of Proposition No

Date of Election___________________

D d lssued only in response to a specific request-from affected local entity(s)

Local entity(s) affected _______________________________________

D e Will be fully financed from the fees revenue etc from

Authorized by Sectlon middot____________ of the _______________ Code

O f Provides far savings to each affected unit of local government which will ata minimum offset any addltlonal costs to each

O g (reates eliminates or char1ges the penalty for a new crlme ar infraction contained In

D 3 Annual Savings (approximate)

$

D 4 No additional costs or savings This regulation makes only technical non-substantive or clarifying changes to current law regulations

[8J S No fiscal impact exists This regulatlon does not affect any local entity or program

O 6 Other Explain

PAGE4

---------

STA TE OF CALIFORNIA - DEPARTMENT OF FINANCE

ECONOMIC ANO FISCAL IMPACT STATEMENT middot (REGULATIONS AND ORDERS) STO 399 (REV 122013)

FISCAL IMPACT STA TEMENT (CONTINUED) FISCAL EFFECT ON STATE GOVERNMENT Indicate appropriate boxes 1 through 4 and attach calculations and assumptions offiscal impact for the current

year and two subsequent Fiscal Years

D 1 Additional expenditures in the current State Fiscal Year (Approximate)

$ ____ __________

lt is anticipated that Sta te agencies wi1

D a Absorb these additional costs within their existing budgets and resources

D b lncrease the currently authorized budget level for the Fiscal Year

ordm 2 Savings in the current State Fiscal Year (Approximate)

s

~ 3 No fiscal impact exists This regulation does not affect any State agency or program

D 4 Other Explain

C FISCAL EFFECT ON FEDERAL FUNDING OF STATE PROGRAMS Indica te appropriate boxes 1 through 4 and attach calculations and assumptions of fiscal impact for the currentyear and two subsequent Fiscal Years

[=1 1 Additional expenditures in the current State Fiscal Year (Approximate)

$ ______________

D 2 Savings in the current State Fiscal Year (Approximate)

s

~ 3 No fiscal impact exists This regulation does not affect any federally funded State agency or program

D 4 Other Explain

DATE

6-U-J7 The sign e attests agency has completed the STD 399 according to the instruclions in SAM sections 6601-6616 and underslands the im acts ofthe proposed rulemaking State boards ofjices or deparlments not under an Agency Secretay mus have the form signed by the hi hest rankin o 1cial in the or anization

AGENCY SECRETARY v-----Finance approval and signature is required when SAM sections 6601-6616 require completion ofFiscal lmpact Stalement in the STD 399

)EPARTMENT OF FINANCE PROGRAM BUDGET MANAGER DATE

PAGE 5

( Proposed Regulation for Worker Protection Standard

Attachment to Economic and Fiscal Impact Statement - STD 399

A3 Describe the types ofbusiness (Include nonprofits) Farms and agricultura businesses

employing workers that either handle pesticides or work in treated fields and nonagricultural businesses employing pesticide handlers

B5 Explain the need for State regulations given the existence or absence ofFederal regulations US EPA has granted California the authority to implement state regulations that are equivalent to the federal worker protection standard In order to maintain equivalency with federal regulations California regulations must be at least as protective as the federal standards In 2015

the federal worker protection regulations were updated to include additional training topics

covered during required pesticide handler and fieldworker trainings Federally the new training requirements are to go into effect no earlier than January 1 2018 and no later than 180 days after

the US EPA notices in the Federal Register the availability oftraining materials Given the uncertainty ofwhether the federal regulations are effective January 1 2018 or at sorne later unknown time the proposed State regulations would ensure that California regulations are equivalent to federal regulations and ensure that ali handlers (both agricultura and nonshyagricultural) are trained under the same higher standard middot

D1 List alternatives considered and describe them Federally the expanded handler and fieldworker training topics are applicable to only agricultura workers and there are no handler

training requirements for nonagricultural workers applying general use pesticides In California both agricultura and nonagricultural employers must provide workers handling pesticides or

working in pesticide treated areas the same leve of training DPR considered only expanding the training content required for agricultura pesticide handlers however this alternative is

untenable The additional training topics cover worker rights and protection on how to reduce the

risk of accidental exposure to pesticides and are not industry specific Separating pesticide handler training content based on application site (agricultura use versus non-agricultura use) creates a double standard where one group of handlers is provided more comprehensive worker safety training than another In addition having two sets of training requirements would crea te confusion in industry when trying to determine when and which employees require training under the new requirements

---------

STA TE OF CALIFORNIA - DEPARTMENT OF FINANCE

ECONOMIC ANO FISCAL IMPACT STATEMENT middot (REGULATIONS AND ORDERS) STO 399 (REV 122013)

FISCAL IMPACT STA TEMENT (CONTINUED) FISCAL EFFECT ON STATE GOVERNMENT Indicate appropriate boxes 1 through 4 and attach calculations and assumptions offiscal impact for the current

year and two subsequent Fiscal Years

D 1 Additional expenditures in the current State Fiscal Year (Approximate)

$ ____ __________

lt is anticipated that Sta te agencies wi1

D a Absorb these additional costs within their existing budgets and resources

D b lncrease the currently authorized budget level for the Fiscal Year

ordm 2 Savings in the current State Fiscal Year (Approximate)

s

~ 3 No fiscal impact exists This regulation does not affect any State agency or program

D 4 Other Explain

C FISCAL EFFECT ON FEDERAL FUNDING OF STATE PROGRAMS Indica te appropriate boxes 1 through 4 and attach calculations and assumptions of fiscal impact for the currentyear and two subsequent Fiscal Years

[=1 1 Additional expenditures in the current State Fiscal Year (Approximate)

$ ______________

D 2 Savings in the current State Fiscal Year (Approximate)

s

~ 3 No fiscal impact exists This regulation does not affect any federally funded State agency or program

D 4 Other Explain

DATE

6-U-J7 The sign e attests agency has completed the STD 399 according to the instruclions in SAM sections 6601-6616 and underslands the im acts ofthe proposed rulemaking State boards ofjices or deparlments not under an Agency Secretay mus have the form signed by the hi hest rankin o 1cial in the or anization

AGENCY SECRETARY v-----Finance approval and signature is required when SAM sections 6601-6616 require completion ofFiscal lmpact Stalement in the STD 399

)EPARTMENT OF FINANCE PROGRAM BUDGET MANAGER DATE

PAGE 5

( Proposed Regulation for Worker Protection Standard

Attachment to Economic and Fiscal Impact Statement - STD 399

A3 Describe the types ofbusiness (Include nonprofits) Farms and agricultura businesses

employing workers that either handle pesticides or work in treated fields and nonagricultural businesses employing pesticide handlers

B5 Explain the need for State regulations given the existence or absence ofFederal regulations US EPA has granted California the authority to implement state regulations that are equivalent to the federal worker protection standard In order to maintain equivalency with federal regulations California regulations must be at least as protective as the federal standards In 2015

the federal worker protection regulations were updated to include additional training topics

covered during required pesticide handler and fieldworker trainings Federally the new training requirements are to go into effect no earlier than January 1 2018 and no later than 180 days after

the US EPA notices in the Federal Register the availability oftraining materials Given the uncertainty ofwhether the federal regulations are effective January 1 2018 or at sorne later unknown time the proposed State regulations would ensure that California regulations are equivalent to federal regulations and ensure that ali handlers (both agricultura and nonshyagricultural) are trained under the same higher standard middot

D1 List alternatives considered and describe them Federally the expanded handler and fieldworker training topics are applicable to only agricultura workers and there are no handler

training requirements for nonagricultural workers applying general use pesticides In California both agricultura and nonagricultural employers must provide workers handling pesticides or

working in pesticide treated areas the same leve of training DPR considered only expanding the training content required for agricultura pesticide handlers however this alternative is

untenable The additional training topics cover worker rights and protection on how to reduce the

risk of accidental exposure to pesticides and are not industry specific Separating pesticide handler training content based on application site (agricultura use versus non-agricultura use) creates a double standard where one group of handlers is provided more comprehensive worker safety training than another In addition having two sets of training requirements would crea te confusion in industry when trying to determine when and which employees require training under the new requirements

( Proposed Regulation for Worker Protection Standard

Attachment to Economic and Fiscal Impact Statement - STD 399

A3 Describe the types ofbusiness (Include nonprofits) Farms and agricultura businesses

employing workers that either handle pesticides or work in treated fields and nonagricultural businesses employing pesticide handlers

B5 Explain the need for State regulations given the existence or absence ofFederal regulations US EPA has granted California the authority to implement state regulations that are equivalent to the federal worker protection standard In order to maintain equivalency with federal regulations California regulations must be at least as protective as the federal standards In 2015

the federal worker protection regulations were updated to include additional training topics

covered during required pesticide handler and fieldworker trainings Federally the new training requirements are to go into effect no earlier than January 1 2018 and no later than 180 days after

the US EPA notices in the Federal Register the availability oftraining materials Given the uncertainty ofwhether the federal regulations are effective January 1 2018 or at sorne later unknown time the proposed State regulations would ensure that California regulations are equivalent to federal regulations and ensure that ali handlers (both agricultura and nonshyagricultural) are trained under the same higher standard middot

D1 List alternatives considered and describe them Federally the expanded handler and fieldworker training topics are applicable to only agricultura workers and there are no handler

training requirements for nonagricultural workers applying general use pesticides In California both agricultura and nonagricultural employers must provide workers handling pesticides or

working in pesticide treated areas the same leve of training DPR considered only expanding the training content required for agricultura pesticide handlers however this alternative is

untenable The additional training topics cover worker rights and protection on how to reduce the

risk of accidental exposure to pesticides and are not industry specific Separating pesticide handler training content based on application site (agricultura use versus non-agricultura use) creates a double standard where one group of handlers is provided more comprehensive worker safety training than another In addition having two sets of training requirements would crea te confusion in industry when trying to determine when and which employees require training under the new requirements