FAQ regarding new Worker Protection Standards changes

Frequently asked questions regarding the new Worker Protection Standards requirements for medical evaluations and fit testing for respirator use.

Under the new Worker Protection Standards, pesticide applicators and handlers will be required to have and document their medical evaluations and fit testing in order to use pesticides that require respirators. The following are frequently asked questions regarding these new changes.

What are the changes to Worker Protection Standards with respect to respirators?

Prior to the changes to the Worker Protection Standards, the employer must provide a respirator and ensure it fits. Under the new Worker Protection Standards requirements that went into effect in 2017, the employer must “provide the handler with a medical evaluation, fit testing and respirator training in compliance with the Occupational Safety and Health Administration’s (OSHA’s) Respiratory Protection Standard.” Now, employers must keep records of the completion of fit test, training and medical evaluation for two years.

What sort of medical evaluation is required for pesticide handlers and applicators according to the new Worker Protection Standards?

The employer must pay for/provide a medical evaluation for employees who will need to be using pesticides requiring a respirator. The medical evaluation needs to occur prior to using the respirator for the first time and if any “significant” changes occur. Employers must identify a licensed health care professional (PLHCP) to do the medical evaluation to ensure the employee is able to perform duties requiring a respirator.

For more information, watch “Medical Evaluations for Workers Who Use Respirators” by OSHA.

Are pesticide applicators and handlers required to wear respirators?

Yes, pesticide applicators and handlers are required to wear respirators if the pesticide label calls for them to do so. Therefore, applicators and handlers need to have medical evaluation and respirator fit testing prior to use.

Which pesticides require respirators?

Growers should look at the labels of the pesticides they may use during this growing season. The label of the pesticides will state if they require a respirator or not. The requirements will not only vary with the pesticide class and label requirements, but with the application methods (drench, spray etc.).

What is a respirator quantitative/qualitative fit test?

A respirator fit test is a test that ensures the respirator is properly working and protecting the worker when mixing, loading or applying some pesticides. It makes sure the respirator forms a complete seal with the person’s face. The fit test needs to be performed with the same make, model, style and size of the respirator that will be used during work duties. The fit test will also involve a positive and negative pressure check to check the seal of the mask to the user.

What types of respirator fit testing are there?

There are two types of respirator fit tests: qualitative and quantitative. Qualitative fit tests use four OSHA-approved methods using isoamyl acetate, saccharin, bitrex or an irritant smoke to test the fit of respirators. They do not measure the actual amount of leakage into the respirator, but are only based on if the wearer detects a leak. For example, if you are tested using isoamyl acetate, which smells like bananas, and you detect that smell, you know your respirator is not fitting properly.

Quantitative fit tests measures the actual amount of leakage from the respirator and does not rely on your senses of taste or smell as with the qualitative fit testing. It uses a machine for testing. Occupational clinics can perform this type of fit testing.

Either of these fit tests are acceptable for the new Worker Protection Standards. Qualitative fit tests are most commonly used for partial face respirators.

What records are required for fit testing?

Employers must keep the following records of the fit testing for two years:

  • Name of handler tested
  • Type of fit test performed
  • Make, model, size of respirator tested
  • Date of fit test
  • Results of the fit test (pass or fail for qualitative tests or fit factor, and strip chart recording or other record of the test results for a quantitative fit test)

Annual respirator training recordkeeping:

  • Name and signature of handler trained
  • Date of training
  • Trainer’s name
  • Training topics

For more information on fit testing, watch “Respiratory Fit Testing” by OSHA.

To learn more about the types of respirators, watch “Respirator Types” by OSHA.

To learn more about Worker Protection Standards, read “Are you ready for changes in the Worker Protection Standards?” by Michigan State University Extension.

Thank you to Craig Anderson, Michigan Farm Bureau, for his review.

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