A simple Worker Protection Standard-compliant respirator program for agricultural employers
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EmailReduce liability and improve workplace safety with a simple and effective respirator program.
Author’s note: The guidance presented in this article pertains to regulatory requirements for respirator use by pesticide handlers as specified in the U.S. Environmental Protection Agency Worker Protection Standard (WPS). Respiratory protection under WPS does not meet other regulatory agency (OSHA, MIOSHA) protective requirements that apply when agricultural workers perform work not covered by the WPS while wearing a respirator.
Agricultural work is often quite dirty and can expose people to a number of respiratory hazards. Chronic exposure to toxic vapors and dusty particles can degrade the natural defenses of the respiratory system and weaken what would otherwise be a healthy set of lungs. It is in the best interest of every business owner to minimize the risk of injury to their employees while they're on the job. Not only does it reduce liability, but it demonstrates that they care about the well-being of the people that work for them.
The Worker Protection Standard (WPS) is designed to reduce the risk of pesticide accidents and lays out explicit requirements for respirator use by pesticide handlers and applicators. Because there are many rules that agricultural producers need to observe, keeping track of regulatory compliance can seem like a daunting task. Fortunately, a simple respirator program can help agricultural employers accomplish some of this with relative ease. This guide can help you set up a system for keeping respiratory protection records to meet the WPS requirements as well as other pesticide handler employer responsibilities related to respirator use.
Overview of requirements
The following information is a summary of respirator-related requirements specified in the WPS. Note that some states may have instituted additional requirements.
Respirator selection
Employers are obligated to select the correct type of respirator based on the types of products their employees will be applying. Consult the pesticide label and the WPS Respiratory Protection Guide published by the Pesticide Educational Resources Collaborative (PERC) for more information.
Medical evaluation
Handler employers are obligated to provide a medical assessment to every handler who will need to use a respirator as mandated on the pesticide product label. The evaluation must be performed by a physician or other licensed health-care professional (PLHCP) to ensure their ability to use a respirator without compromising their health. Before the employee is evaluated, the employer is expected to provide the PLHCP with a description of the physical demands, environmental conditions and required respirators for each type of work. Employers should be sure that the medical evaluation occurs prior to the handler using the respirator and before the fit test is administered.
Note also that handlers do not need to be re-evaluated annually unless there is cause for concern. Please see the WPS Respiratory Protection Guide for a list of situations in which handlers should be re-evaluated by a medical professional.
Respirator fit testing
Handlers must undergo fit testing using the same make, model, size and type of respirator(s) they will be using while they handle pesticides. This is necessary to ensure the face-to-facepiece seal is airtight and does not leak. Unlike medical evaluations, fit testing must occur on an annual basis. It should also be performed if the handler has experienced physiological changes that might affect the way the facepiece fits on their face (e.g., notable weight loss/gain) or if there is a change to the respirator facepiece itself.
Respirator training
If a pesticide label requires the use of a respirator, then the employer is obligated to provide training to every handler that uses that pesticide. Training must occur annually and in a manner that the handler can understand. Handlers must demonstrate to their employer that they know how to properly use a respirator. To make things easier for employers, a list of seven criteria for a successful demonstration can be found under the “Training” section in the PERC WPS Respiratory Protection Guide.
Recordkeeping
Documentation is a crucial component of respirator-related WPS compliance. Employers of pesticide handlers are required to retain medical evaluation, fit testing and training records for each handler for at least two years. The following information should be retained:
Medical evaluations: The PLHCP is required to provide employers with a written medical determination for each handler. Be sure to keep these on file for at least two years.
Fit testing results: As explained in the WPS Respiratory Guide, fit test documentation should include:
- Name of handler
- Type of fit test performed (i.e., quantitative or qualitative)
- Make, model, and size of respirator
- Date of the fit test
- Results of the fit test
Records should be maintained for at least two years from the date of the fit test.
Training: Employers are expected to retain written records of respirator training for a minimum of two years, but there are no specifications on what information should be included in those records. PERC recommends the following:
- Name and signature of handler
- Date of training session
- Trainer’s name
- Training topics
Although it may seem like a lot of details, maintaining WPS respirator compliance should become a relatively smooth process for employers once they develop a system. To assist with this task, PERC offers several checklists that allow employers to keep track of respirator-related requirements for each pesticide handler at their operation. As an added benefit, we have included a quick-reference sheet that outlines the requirements discussed in this article. Note that this reference sheet provides no interpretation.
Download: Respirator Program Checklist and Quick-Reference Sheet
While the contents of this article are intended to be an inclusive overview to the WPS requirements for respirator use by pesticide handlers, they should not be considered a substitute for the advice from a professional consultant or agricultural labor attorney.
The material presented here has been synthesized from the Code of Federal Regulations and Pesticide Educational Resources Collaborative. As with any subject related to regulatory compliance, please consult official sources for interpretation and final rulings.
Ed Parsons is a certified safety professional and investigator for the Michigan Fatality Assessment and Control Evaluation (MIFACE) research program in the Division of Occupational and Environmental Medicine at Michigan State University. More information on work-related injuries and illness can be found at their website: oem.msu.edu
