toxicity to the standard labeling requirements for all chlorpyrifos-based products. Manufacturers rejected the request. In February 2013 in Dow AgroSciences vs NMFS, the Fourth Circuit Court of Appeals vacated EPA's order for these labeling requirements. In August 2014, in the settlement of a suit brought by environmental and fisheries advocacy groups against EPA in the U.S. District Court for the Western District of Washington, EPA agreed to re-instate no-spray stream buffer zones in California, Oregon and Washington, restricting aerial spraying (300 ft.) and ground-based applications (60 ft.) near salmon populations. These buffers will remain until EPA makes a permanent decision in consultation with NMFS. Reporting EPCRA designates the chemicals that facilities must report to the Toxics Release Inventory (TRI), based on EPA assessments. Chlorpyrifos is not on the reporting list. It is on the list of hazardous substances under CERCLA (aka the Superfund Act). In the event of an environmental release above its reportable quantity of 1 lb or 0.454 kg, facilities are required to immediately notify the National Response Center (NRC). In 1995, Dow paid a $732,000 EPA penalty for not forwarding reports it had received on 249 chlorpyrifos poisoning incidents. Occupational exposure In 1989, OSHA established a workplace permissible exposure limit (PEL) of 0.2 mg/m3 for chlorpyrifos, based on an 8-hour time weighted average (TWA) exposure. However, the rule was remanded by the U.S. Circuit Court of Appeals and no PELs are in place presently. EPA's Worker Protection Standard requires owners and operators of agricultural businesses to comply with safety protocols for agricultural workers and pesticide handlers (those who mix, load and apply pesticides). For example, in 2005, the EPA filed an administrative complaint against JSH Farms, Inc. (Wapato, Washington) with proposed penalties of $1,680 for using chlorpyrifos in 2004 without proper equipment. An adjacent property was contaminated with chlorpyrifos due to pesticide drift and the property owner suffered from eye and skin irritation. State laws Additional laws and guidelines may apply for individual states. For example, Florida has a drinking water guideline for chlorpyrifos of 21 ug/L. In 2003, Dow agreed to pay $2 million to New York state, in response to a lawsuit to end Dow's advertising of Dursban as "safe". Oregon's Department of Environmental Quality added chlorpyrifos to the list of targeted reductions in the Clackamas Subbasin as part of the Columbia River National Strategic Plan, which is based on EPA'S 2006–11 National Strategic Plan.