Respirator Guidelines to Meet New Worker Protection Standards
Requirements for a medical evaluation, fit testing and specific training for use of respirators and the associated record keeping became effective Jan. 2, 2017. At this time, most growers are aware of this revision to the Worker Protection Standards (WPS) regulation that requires pesticide handlers and applicators to wear a respirator during mixing/handling, spray applications and potential other uses as outlined on pesticide labels. Additionally, those who use pesticides with respirator requirements must receive documentation from a physician or licensed health care professional (PLHCP) that has “respirator evaluation” as part of their license to ensure the pesticide handler is medically able to use a respirator.
Not all PLHCPs are qualified to provide the respirator evaluation, but primary care physicians should be able to refer patients to appropriate medical personnel. Alternatively, growers can contact local occupation and environmental health professionals who are more likely to have the credentials needed to provide the appropriate respirator medical evaluation and documentation. Please review the following guidelines to help address some of the recent questions Michigan State University Extension has received from growers.
Who needs to receive a medical evaluation and how often?
Employees that could be exposed to hazardous airborne contaminants may be required to wear a respirator; respirators and respirator use requirements will be outlined on individual pesticide labels. Some pesticides may require respirators for employees that mix spray material or require applicators to wear a respirator during applications of certain pesticides. Employers are responsible for ensuring employees receive the appropriate equipment, evaluation, respirator fit test, training and record keeping that conforms to Occupational Safety and Health Administration (OSHA) standards.
According to the Environmental Protection Agency (EPA), the medical evaluation is required one time per employee unless another evaluation is required due to one of the following reasons:
- The medical determination is only good for a specified length of time.
- The employee reports medical signs or symptoms related to respirator use.
- The PLHCP, supervisor or program administrator recommends a re-evaluation.
- Fit-test or other program information indicates a need for re-evaluation.
- When changes in the workplace increase respirator stress on an employee.
- The initial medical examination demonstrates the need for a follow-up medical examination.
Who provides the evaluation? What kind of evaluation and documentation are needed?
A PLHCP with respirator evaluation as part of their license will provide the appropriate evaluation using a medical questionnaire or exam that conforms to the OSHA standard. Contact the PLHCP to determine whether a questionnaire or exam will be used and to receive appropriate paperwork. Prior to completing the questionnaire or exam, employers must provide employees with:
- The type and weight of the respirator the handler will use.
- How long and how frequently the handler will use the respirator.
- How much physical work the handler will do while using the respirator.
- Other personal protective equipment (PPE) the handler will use.
- The temperature and humidity extremes of the working environment.
Contact a primary care physician to receive a referral for a licensed professional, if necessary. Another low-cost (about $25) and fast alternative for a medical evaluation is t OshaMedCert, an online service that involves filling out a form and sending it for approval or denial by a PLHCP; individual’s health information remains confidential throughout the process. A respirator fit test (see below) will be needed after receiving the medical determination from OshaMedCert.
A written medical determination of the respirator evaluation for each employee is required before the employee can use the respirator. The employer must keep the medical determination documentation for two years. According to EPA, the required written information to be provided by the PLCHP to the employer must only include:
- Whether or not the employee is medically able to use a respirator.
- Any limitations on respirator use in relation to the medical conditions (if any) of the employee or workplace conditions.
- Need for any follow-up medical evaluations.
- A statement that PLCHP provided the employee with written recommendation; in some cases, this recommendation may simply state that the applicator/person that will use the respirator is capable of wearing a respirator.
Again, the information outlined above is the only information that should be provided in the PLHCP’s recommendation to the employer to protect the employee’s private medical information and avoid violation of Health Insurance portability and Accountability Act (HIPAA) laws.
What’s next? Respirator fit tests.
After receiving a medical evaluation, a fit test is needed to ensure the respirator forms an adequate seal with an employee’s face to provide appropriate inhalation exposure protection. A new fit test is required annually or whenever there is a change to the respirator or a physiological change to the employee that could affect the seal between the respirator and the user’s face. Furthermore, fit tests are required for each type of respirator that will be used as indicated by pesticide labels. Finally, employees must undergo the fit test using a respirator with the exact specifications of the respirator that will be used on the job.
Fit tests must follow OSHA protocols, and there are two methods for fit testing. The quantitative fit test (QNFT) requires special equipment and a trained person to conduct the testing. Fit test kits are also available to perform qualitative fit tests (QLFT) by a person that can accurately prepare test solutions, calibrate equipment, perform the test properly, recognize invalid tests and ensure test equipment is working properly. Sources for fit tests include pesticide suppliers or companies such as Gempler’s or Grainger.
A primary care physician may be able to provide additional options and referrals for fit test providers in the area. We confirmed that Munson Medical Center’s Occupational Health and Medicine Clinic (550 Munson Ave. Traverse City, MI 49686; phone: 231-935-8590) is equipped to perform the appropriate respirator exam (about $80) and the fit test (about $25) in one visit by appointment only. Spectrum Health Services in other areas of Michigan provide similar services. Patients that wish to only receive a fit test need to provide appropriate respirator exam result documentation prior to the test.
Additional information regarding respirator requirements and other WPS revisions can be found in the EPA’s “How to Comply with the 2015 Revised Worker Protection Standards for Agricultural Pesticides.”
Source: Michigan State University