Agriculture Reference
In-Depth Information
speaking workers were not provided with appropriate training. Such scientific,
non-regulatory studies contribute knowledge that underpins regulatory advice.
Less visible but important have been the efforts of some of the separately
funded regional NIOSH Ag Centers. For example, Pacific Northwest Agricultural
Safety and Health (PNASH) Center research efforts have led to invitations to center
faculty to participate in national policymaking discourse. The Western Center for
Agricultural Health and Safety has engaged county health departments in Merced
and Fresno Counties, California, regarding current research initiatives of interest.
Several researchers presented policy briefings at the California state capitol to a
large audience of legislative staff and advocacy groups (Villarejo and Schenker,
2005). Other centers similarly have engaged local and regional agencies and private
organizations and trade groups in policy discussions.
NIOSH core staff continuously engaged federal agencies in policy discourse.
For example, NIOSH staff met with USDA Forest Service representatives concern-
ing issues ranging from the use of insect repellents by Forest Service staff to cleanup
policies regarding the use of safe cleaning agents. Also notable are the multiple re-
search contributions that inform proposed new hazardous orders for child workers
in agriculture and ergonomics standards to address repetitive-stress disorders.
Barriers to Effective Use of NIOSH Policy and Regulatory Expertise
Although NIOSH is uniquely positioned to provide independent, scientifically
founded information and advice to inform public policy and regulatory discourse,
several barriers may severely limit its contributions. First, as the NIOSH evidence
package notes, the AFF workforce is to a great degree unregulated. The various stat-
utory exemptions from the Fair Labor Standards Act and the Occupational Safety
and Health Act, noted in Appendix F, severely limit the purview of NIOSH research
activities; OSHA, for example, excludes all farms with 10 or fewer employees.
Second, and perhaps decisive in the current regulatory regime, there is a strong
preference in some agencies for allowing market forces to shape the workplace en-
vironment. That preference is reflected in the sharp decline in federal occupational
safety regulatory activity in recent years.
Third, Congress itself has been an important barrier even to the consideration
of regulatory change. As the NIOSH AFF evidence package points out, “the pro-
gram has provided information to support new OSHA standards related to logging,
field sanitation, air contaminants (remanded in 1992), and ergonomics (repealed
in 2002) (Luginbuhl, 1997). Moreover, the program sought out other opportunities
for supporting federal regulations including the Coast Guard's implementation of
the Commercial Fishing Vessel Safety Act of 1988, EPA's promulgation and enforce-
ment of the pesticide Worker Protection Standard, and Department of Labor revi-
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