As growers are aware, the Worker Protection Standard (WPS) requirements for handlers of agricultural chemicals have changed.
While most are familiar with the new requirements and have worked hard to be sure they are meeting the intent of keeping agriculture workers and handlers of chemicals healthy, it doesn’t hurt to review the respirator requirements.
The WPS has two categories for agricultural employees: handlers and workers. Handler employees are required to use respirators when the product label indicates this form of personal protective equipment is necessary. Handlers are those people that:
- mix, load, or apply pesticides;
- clean or repair pesticide application equipment; or
- assist with the application of pesticides
These handlers are the employees that need to follow the respirator medical and fit test requirements set forth by the WPS. Remember that it is the employer’s responsibility to provide the necessary training and equipment to the employee for the safe application of chemicals.
If the chemical label requires the use of a respirator, then the medical evaluation, fit test and training are required. Respirator use adds physical stress to the user because it takes effort above what is usual to inhale and exhale through the respirator check valves. A medical evaluation is either done online or by a physician or licensed health care professional who is making sure the handler can accept this additional stress and is medically able to use the respirator. The online option requires a fee and is offered by various providers, including 3M.
The 3M website claims that 98% of those requiring the medical evaluation are certifiable through the online option. If you have an on-going medical condition that may hinder your ability to use a respirator, it may be beneficial for you to see a medical professional for your evaluation rather than doing the on-line evaluation. Because the online medical evaluation option is also directed toward OSHA users, the WPS applicants can ignore the portion about the written respirator program.
In most cases the medical evaluation is good for a long term. Sometimes the medical evaluation may only be good for a certain period of time if the evaluator has concerns and would like the evaluation redone within a specific amount of time. Additional reasons requiring a new medical evaluation are changes in the workplace expectations or conditions, the employee reports signs or symptoms related to respirator use, or some other information indicates the need for a re-evaluation.
Following the medical evaluation, the fit of the respirator is tested. This fit testing is done with the handler using the respirator that will be used on the job. Because different people have different facial structures, not all respirators will work with every person.
Two types of fit tests
Qualitative
This type of fit test is the most common, with a pass/fail relying on the employee’s response to a test agent. The OSHA test agents include saccharin, banana oil (isoamyl acetate), Bitrex or an irritant smoke. The employee wearing the respirator places a hood (with a clear viewing area as part of the hood) over their head. A predetermined amount of test agent is placed inside the hood, and the employee indicates if they can taste or smell the test agent. There is a procedure for moving the head up and down, side to side, and talking while in this hood to test the respirator seal while the head is in motion. If the employee and respirator passes this testing then the fit test is completed. If the test agent is detected by the employee, then the testing needs to be done again with adjustments to the respirator or with a different respirator. This is why it is important to use the same respirator during the fit testing as will be used when mixing or applying the chemicals.
Quantitative
This type of fit test does not rely on the employee indicating the presence or absence of a test agent. Rather this uses a difference in pressure or a particle counter to mechanically detect a good seal or a poor seal between the respirator and the face. This requires more expensive instrumentation than the qualitative test but does not rely on the impartiality of the employee. Quantitative fit test equipment can be purchased or rented from safety suppliers to complete this type of testing (ex. Premier Safety).
Fit testing can be accomplished in a number of ways:
- Someone at the orchard or facility can do the fit testing. Purchase a fit test kit from a safety equipment provider (ex. Gemplers, Grainger, Premier Safety, etc.) and follow the directions included or found in resources to do the fit testing. A resource that includes the fit test procedure is listed at the end of this article.
- Fit testing can be found at many occupational safety and health providers. Because OSHA has required fit testing for a number of years, the WPS has chosen to use OSHA fit testing as their standard as well. Searching on the internet for providers of occupational safety and health will often find medical providers that will offer this service for a fee.
- Occasionally the local fire company offers fit testing. Because fit testing is required for those using the self-contained breathing apparatus often used by fire companies, they sometimes are equipped to do the testing themselves and offer this as a community service.
When the fit test is completed, this needs to be recorded and the record kept by the employer for two years. While the medical evaluation is not needed every year, the fit test does need to be redone every year. Handler training is required annually and this needs to be recorded by the employer as well, with the record of training kept for the two year period.
Respirator training includes:
- Why the respirator is necessary and how improper fit, usage or maintenance is bad;
- Limitations and capabilities of respirators;
- What to do if the respirator malfunctions during use;
- How to inspect, put on, remove, use, and check the seals;
- Proper respirator maintenance and storage;
- Recognition of medical signs and symptoms that limit or prevent effective respirator use
A loose fitting powered air purify respirator (PAPR) will exempt the Handler from the fit test, but does not exempt the Handler from the medical evaluation portion of the requirement.
So in a nutshell, the handler requirements are:
- Medical evaluation: once, and then only again when required by changing conditions or medical reasons. Keep the record until the next medical evaluation or for 2 years.
- Respirator fit test: every year. Keep the record for 2 years.
- WPS training: every year. Keep the record for 2 years.