FAQ Regarding the New Worker Protection Standard – Part 2

 

 

The new respirator requirements for the updated Worker Protection Standard requires growers complete a respirator fit test annually.

 

In Part 1 of this article, Michigan State University Extension covered the federally-mandated Worker Protection Standard (WPS), the reasons for its implementation and what updates to the WPS occurred in January of 2018. In this article, we will cover commonly asked questions about the new respirator requirements for the updated WPS.

 

 

Under the WPS requirements that went into effect in 2017, the employer must “provide the handler with a free medical evaluation, fit testing and respirator training in compliance with the Occupational Safety and Health Administration’s (OSHA’s) Respiratory Protection Standard.” In addition, employers are required to keep records of the medical evaluations, completed fit tests and employee training for a minimum of two years.

 

 

What sort of medical evaluation is required for pesticide handlers and applicators according to the new WPS requirements?

 

The employer must pay for or provide a respiratory medical evaluation for employees who will need to be applying pesticides requiring use of a respirator. In the greenhouse, most pesticide handlers are also applicators. This may not be true in other areas of agriculture. For pesticide applicators, the respiratory medical evaluation needs to occur prior to using the respirator for the first time and if any “significant health changes” occur (e.g., weight gain/loss, new respiratory illness etc.), or if job duties or the working conditions change in ways that put more stress on the wearer (e.g., longer hours in warmer conditions while wearing a respirator).

 

Employers must identify a licensed health care professional (PLHCP) to do the respiratory medical evaluation to ensure the employee is able to perform duties requiring a respirator. A medical evaluation can also be done online through services such as 3M Online Respirator Medical Evaluation. Occupational Medicine clinics across the state provide services such as respiratory medical evaluations and fit testing.  A searchable list of locations by county may be found here at Statewide Clinic List by County.

 

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

 

 

The regulation does not give a timeline in terms of frequency for medical evaluations.

 

OSHA does not definitively require annual questionnaire completion, and frequency of medical evaluation is determined by four specific circumstances.

 

According to OSHA’s Respiratory Protection Guide, employees are required to complete questionnaires for initial certification and subsequently only if:

Although not required by OSHA on an annual basis, questionnaire completion and review is a relatively low-cost, effective way to document employees’ suitability to wear respirators and to potentially identify the need for further medical examination.

 

 

What type of respirators are there?

 

There are six types of respirators according to OSHA. They are listed in the order of increasing protection:

For pictograms and descriptions of the different types of respirators available, and for more detail, check out “Protect Yourself Respirators: OSHA Quick Card.”

 

 

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 had a respirator medical evaluation and respirator fit test prior to working with pesticides.

 

 

Read and make sure you understand the labels of the pesticides you may use during this growing season. The label of the pesticides will state if a respirator is required and is based on class of pesticide and application method (drench, spray etc.). For more information, check out the “Respirator Label Language” section in the recent MSU Extension article, “Vegetable pesticide series: Does it require a respirator?”

 

 

All employees who will need or be required to use a respirator as a part of their job will need a respiratory medical evaluation and receive certification that documents the employee is medically able to wear a respirator as a part of their job.  

 

 

There are two types of respirator fit tests: qualitative and quantitative. Qualitative fit tests use four OSHA-approved test reagents (sensory agents):

Qualitative fit tests do not determine the actual amount of leakage into the respirator, but are only based on if the wearer detects a leak as the individual undergoing the fit test will smell or taste the test reagent. For example, if you are fit-tested using isoamyl acetate, which smells like bananas, and you detect that smell, you know your respirator is not fitting properly. Another commonly-used compound for respirator fit-tests is bitrex, a bitter-tasting compound.

 

Quantitative fit tests measure the actual amount of leakage through the respirator seal 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 WPS.

 

 

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

Annual respirator training recordkeeping:

 

Tight-fitting respirators may only be worn by individuals without facial hair (including a single day of growth). Therefore, fit-testing of tight-fitting respirators can only be performed on individuals without facial hair that interferes with the seal of the mask. Individuals with beards, mustaches or other facial hair can wear a tight-fitting respirator if it is trimmed in a way that doesn’t interfere with the mask seal. If the facial hair does interfere with the mask seal, the individual must plan to use a powered-air purifying respirator with a hood. These do not require fit testing, just proper knowledge of how to wear the apparatus.

 

 

Employees can find a local clinic by searching for occupational health clinics in Michigan. You can also see your physician or licensed healthcare professional (PLHCP). You can also find the complete list by county on the Statewide Occupational Health Clinics and Hospitals list.