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September 5, 1989
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THOUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS
FROM: THOMAS J. SHEPICH, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Field Sanitation
This is to inform you of a policy change regarding the scope of coverage of
the field sanitation standard. Effective immediately, the scope of coverage
shall apply to any agricultural establishment/employer that has employed,
during the past twelve months, at any one time, eleven (11) or more employees
engaged in hand-labor operations in the field. This coverage applies
regardless of the location(s) of the field(s) and regardless of the number of
employees in any particular field or the number of employees engaged in
hand-labor operations in the field on the day of inspection.
This change rescinds the interpretation found in the February 6 and 27
memorandums to Regional Administrators and in the January 31 and June 7
correspondence to Hi-Bred International, Inc. These interpretations were
based on an erroneous reading of portions of the standard's preamble.
Please contact James C. Dillard, of my staff, at 523-8041, if you have
additional questions.
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