Which respirator for pesticide application? Reading the label and the EPA requirements

What does the Worker Protection Standard require of the employer?

• The handler must use the respirator the labeling specifies, and the employer must provide it, clean and in proper operating condition.
• Before the handler does any task where the label requires a respirator, the employer must provide three things that conform to OSHA 1910.134: a fit test using the respirator the label specifies; training in the use of that respirator covering 1910.134(k)(1)(i) through (vi); and a medical evaluation by a physician or other licensed health care professional confirming the handler can safely wear it.
• Records documenting the fit test, training and medical evaluation must be kept on the establishment for two years.
• All PPE must be inspected before each day of use for leaks, holes, tears or wear, and damaged equipment repaired or discarded; it must be used as the manufacturer instructs.
• The employer must provide a place away from pesticide storage and use areas to put on and take off PPE and store street clothes, and must not let contaminated PPE go home with the handler.
• Where the label requires PPE, the employer must take appropriate measures to prevent heat-related illness.

When must filters and cartridges be replaced?

The Worker Protection Standard sets its own replacement rules, which are stricter than many workplace programs. A filtering facepiece is replaced when breathing resistance becomes excessive, when the filter is damaged or torn, when the manufacturer or the label says, whichever is sooner, and in any case after 8 hours of cumulative use if nothing else says otherwise. A gas or vapor cartridge or canister is replaced at the first odor, taste or irritation, when the maximum use time from a change schedule under 1910.134 is reached, when breathing resistance rises, when the manufacturer or label requires, and after 8 hours of cumulative use absent other instructions.

Which NIOSH filter or cartridge matches the label?

For a particulate statement, any NIOSH-approved N95, R95, P95 or 100-class filter meets it; a filtering facepiece is the simplest, and a P95 or P100 pad on a half mask is the reusable version. Most liquid pesticide sprays are water-based, but where the formulation contains oil or petroleum solvent, an R or P filter is the one rated for oil aerosols. For an organic vapor statement, an OV cartridge with a pesticide-approved prefilter, or a combination OV/P100 cartridge, on a half or full facepiece. A full facepiece also satisfies a label’s protective eyewear requirement, which the rule lists as goggles, a face shield, safety glasses with brow and temple protection, or a full-face respirator.

Cleaning and storage follow the Worker Protection Standard: PPE is cleaned per the manufacturer or the label before each day of reuse, kept separate from other laundry, dried before storage and stored apart from personal clothing and away from pesticide areas. A respirator that cannot be cleaned is made unusable and disposed of.

When is the label respirator not required?

Inside an enclosed cab with a properly functioning ventilation system, used and maintained per the manufacturer, a handler applying from the cab may leave off a filtering facepiece or dust/mist respirator the label requires for applicators; the other exceptions in that paragraph cover skin and eye PPE. A label that requires a cartridge or supplied-air respirator is not covered by that exception. Outside the enclosed-cab rule, the label statement stands.