The lush green fields that are rich with tobacco, sweet potatoes and cucumbers are the setting for one of the most controversial federal regulatory actions in recent years, an issue hotly debated in terms of states' rights, workers' health and human dignity.

After 13 years of court decisions, hearings, and opinions that fill more than 4,000 pages, the Labor Department has yet to resolve whether to enact a federal standard requiring farmers and agribusinesses to provide portable toilets and clean water for drinking and hand-washing to an estimated 529,000 farm workers.

The debate pits groups such as the AFL-CIO and the U.S. Catholic Conference -- which demand a federal rule on health and humanitarian grounds -- against organizations like the 3 million-member American Farm Bureau Federation, which vigorously opposes the rule as a needless and costly bureaucratic intrusion into free enterprise.

On April 16, the Labor Department's Occupational Safety and Health Administration announced it would not enact a federal rule covering field sanitation. OSHA Director Robert A. Rowland, who later announced his resignation, said that 13 states employing two-thirds of the nation's farm workers already have some form of "field sanitation" standard, and OSHA officials said the danger posed by sanitary conditions are not life-threatening.

Labor Secretary William E. Brock, who took office two weeks after the decision, has pledged to reconsider enacting a rule. Brock's decision is expected shortly, and his action is being viewed by labor unions and employers as a test of his approach to health and safety issues.

"No other group of American workers have been declared second-class citizens like this," said Charles Horwitz, attorney for the federally funded Migrant Legal Action Program, which initially petitioned the government for field toilets in 1972.

But in farm country, the prospect of Uncle Sam ordering "porta-johns" for the fields provokes strong anger.

The issue has also become a symbolic challenge, a perceived attack on the rights of staunchly independent farmers and landowners, whose control over their workers dates to the days of slavery. The debate, which often pits white farmers against black, Hispanic and Haitian workers, also takes on racial overtones here.

The dispute hits closest to home for people such as Elasta Smith and Wilma Robinson, a farmer and a field hand whose lives are linked to the rich Piedmont and who differ passionately about "field sanitation."

Smith, 67, is a third-generation farmer who employs up to 50 migrant and local workers, usually at minimum wage, to pick cucumbers, potatoes and tobacco on 300 acres formerly tended by plantation slaves.

"You got a bunch of damn fools up there making laws who don't know a damn thing about farming," Smith said, shouting about the "bureaucrats" attempting to run his business, and punctuating his sentences with spits of tobacco juice.

"You don't need toilets. Let them go in the woods. Let them go behind the bushes. That's what we always did . . . . That's what my ancestors always did," Smith said.

He said toilets for his fields would cost him $2,000 to $5,000. OSHA has estimated the cost at 53 cents to 77 cents per worker per day, including the cost of cleaning the toilets.

Wilma Robinson, a 29-year-old black woman, has tied tobacco bundles in the North Carolina heat since she was 12. She supports her two children on her husband's child-support payments, supplemented by her $3.35-an-hour field work. Robinson, a high school graduate, has become active with Farmworker Legal Services, and sometimes helps distribute "Know Your Rights" booklets for migrants printed in English, Spanish and Creole.

"I enjoy working in the fields. But to me, this is just an outrage," Robinson said. The lack of toilets is embarrassing and degrading, she added, in part because many of her co-workers are men.

"If I were a man, I wouldn't ever allow my wife to work in the fields," she said. "And for these farmers to get up and say we don't need the toilets, my Lord, some of them must be crazy."

"This is a very difficult issue for us, public relations-wise," said Chuck H. Fields, assistant national director of the Farm Bureau. "But the truth of the matter is that some farmers would have to provide toilets at considerable cost, and then find that workers don't use them."

North Carolina is among the 13 states with some field sanitation standards, but its law requires farms to supply only water and not toilets. Of the 13 with such laws, nine require toilets, including California, Texas and Florida, the biggest agricultural states.

Advocates of a federal standard for field sanitation say OSHA underestimates the dangers of the current situation. They cite medical testimony at OSHA hearings that poor sanitation contributes to unusually high levels of parasitic disease, urinary infections, diarrhea, skin disease and other maladies among farm workers. John Briscoe, a University of North Carolina sanitary engineer, testified at public hearings that as many as 40 percent of the state's migrants have parasites, a rate he described as "exceptionally high . . . even for the Third World."

Farmers dispute the linkage of health problems and toilets, arguing that many diseases may arise from inadequate housing, diet and hygiene. "Nobody has shown it is caused in the work place . . . and most of the targeted workers are covered anyway" by state toilet rules, Fields said.

North Carolina Labor Commissioner John C. Brooks, in an interview, criticized OSHA's failure to enact a federal standard, saying there is "abundant" evidence to support federal action and adding that he believed that OSHA bowed to "political pressure."

Brooks, a Democrat, said he felt similar pressure when he adopted the state water requirement in 1983. "We got threatened . . . . We got threatened physically, politically, legislatively."