I did not say that every time I go out I see people spraying too close to unprotected workers. What I said was that every time I go out I can find violations of pesticide-related laws. I was not specific as to the exact violations that I could find. These could relate to storage, record-keeping, labeling, licensing, posting, or spray drift, among many others.
I did not say the re-entry restrictions of the Worker Protection Standard are weak or rarely enforced. What I did say was that, given the Washington State Department of Agriculture’s limited resources and complaint-driven enforcement practice, we don’t often encounter re-entry violations.
I did not say that we are a police agency. I said that our job is to enforce the laws pertaining to pesticides and that we should be looking for problems like the police do (i.e. pre-emptive enforcement). I did not say that it “never” happens; I said that it seldom happens. Some pre-emptive enforcement is done through inspections and a small amount is done from observing violative acts while investigators are in the field.
What I said in regards to the department’s enforcement policy is that a person can have three or more violations before there is a license suspension or fine. I explained that verbal or written warnings as well as Notices of Correction could be issued prior to a license suspension or fine. I also explained that for serious violations, such as human exposures or significant crop or property damage, the department can go right to fines and/or license suspensions without first issuing a Notice of Correction.
I never said I viewed my job as being a “personal struggle.” My agenda, if it can be so called, is to promote the safe and legal use of pesticides in Washington. Everything I do revolves around that goal.
HCN’s characterization of the regulatory system does not represent what I said and believe. In the five years that I have worked with the Washington State Department of Agriculture, I think the federal and state regula-tory support of farmworkers has been improving. Regulatory change is often slow, but it is changing, and the change will improve farmworker protection.
Agricultural Chemical Specialist,
Pesticide Management Division,
Washington State Department of Agriculture