Pesticides

Respirator Requirements

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RespiratorDo you or your employees make applications in enclosed places such as greenhouses or grain bins?  Do you come into contact with harmful dusts, gases, vapors or mists?  Then you may be required to wear a respirator!

Why have respirator requirements changed under the Worker Protection Standard?

  • To ensure that respirators are providing the intended protection
  • Respirators may place a physiological burden on the wearer
  • All other industries require these protections

Medical Evaluation

  • Employees must provide a medical evaluation at no cost to the employee, prior to any respirator use
  • Employee fills out standard OSHA questionnaire and may submit to a physician or licensed health care professional. Convenient online services are also available
  • Medical clearance is only required once unless medical problems arise, or a fit test indicates a need for reevaluation

Fit Testing

  • An annual fit test is required for all tight-fitting respirators where required by the pesticide label
  • Must be completed after receiving a medical clearance
  • Must be conducted with the same size, make, model and style of the respirator to be worn
  • Includes particulate filtering face-piece respirators (dust/mist respirators)

Respirator Training

  • Required annually or when workplace conditions change, or a new type of respirator is used
  • How to inspect, use and perform seal checks
  • Respirator maintenance and storage
  • How to select cartridge/canisters and change out schedule
  • How to recognize medical signs that limit effective use of respirators
  • How to use respirators in emergency situations

Recordkeeping

  • Records must be maintained for two years
  • Name of employee
  • Type of fit test performed
  • Make, model and size of respirator
  • Date and results of fit test

For more information on respirator requirements and fit testing locations in Ohio, see pested.osu.edu/wps/Respirator

Who Can Legally Spray for the Farm, Nursery, or Greenhouse?

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During this period while the Ohio Department of Agriculture has postponed pesticide license testing, many are asking who can legally apply pesticides on the farm.

Growers need a a private pesticide license to apply restricted-use pesticides in agricultural production on their own property, employer’s or rented land. Non-licensed family members or subordinate employees can make applications under the direct supervision of the private applicator under certain circumstances, as long as the pesticide label does not prohibit it.

What does the licensed private applicator need to provide to those working under direct supervision?

  • The private applicator does not have to be present, but must be available if needed during the application
  • Pesticide labels must be at the worksite if licensed applicator not present
  • Personal Protective equipment as required by label

Are there age requirements for unlicensed applicators working under direct supervision ?

  • If a family member, the only restriction is for pesticides with the “Danger – Poison” signal words – the family member must be 18
  • If an employee – they must be 18  (a Worker Protection Standard (WPS) requirement)

What are the training requirements for unlicensed applicators?

  • Subordinate employees must receive WPS handler training annually
  • Family members are exempt from annual WPS handler training (however, if using pesticides that require respirators, there is an annual respirator training requirement under WPS)

What pesticides do not allow direct supervision (may only be applied by a licensed applicator)?

  • Paraquat dichloride
  • Dicamba formulations used over the top of soybeans (Xtendimax, Engenia, FeXapan, and Tavium)
  • Any other pesticide that restricts use to certified (licensed) applicators

Finally, remember that private pesticide applicators are not required to have a license to apply general-use pesticides (which means they are not restricted-use). If a pesticide is restricted-use, that designation appears at the top of the first page of the pesticide label.

see Ohio Code

ORC 921.01 (Q) (2)

ORC 921.11 (A) (1) (d)

OAC 901:5-11-02 (D)  (1-3)

OAC 901:5-11-02 (B)  (3)

What is a Trained Serviceperson and Can They Legally Apply Pesticides in Ohio?

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Currently all pesticide applicator license exams are on hold until further notice from the Ohio Department of Agriculture.  What can pesticide application companies do about new employees that were hired to apply or assist in the application of pesticides?

In addition to the licensed commercial applicator, a trained serviceperson (TSP) may legally apply pesticides in the same situations as the commercial applicator, unless the pesticide label prohibits applications by a non-certified applicator. Ohio Pesticide Law has specific requirements for the training and supervision of TSPs.  People who assist with mixing, loading or application, clean or repair equipment with pesticide residues, and clean and dispose of pesticide containers also must receive TSP training.

Training Ohio Administrative Code 901:5-11-02 (A)(2)

Before the first occupational exposure to pesticides, the employee must read or be taught the content in the “Safety Training Guide for Trained Servicepersons.” The employee and immediate supervisor must  verify that the employee received this training; there is a form on page 6 of the manual for this purpose.  The signed and dated verification of training must be kept on file for the duration of the employee’s employment and for three years following termination. The written verification of training also must be available for inspection according to OAC 901:5-11-02 (A)(2)

The employee also must receive training on the proper use of any equipment and pesticides with which they will work.

Direct Supervision  Ohio Administrative Code 901:5-11-02(A)(3)

 Whenever the TSP is working with pesticides, a licensed commercial applicator must provide direct supervision, which under Ohio law requires the commercial applicator to be located either within 25 miles distance, OR within two hours’ travel time to the work site. If the licensed commercial applicator is not at the work site while the TSP is working with pesticides, the TSP must have all pesticide labels available for the products they are using.  Personal Protective Equipment required by the pesticide labels also must be provided.

Where to find the “Safety Training Guide for Trained Servicepersons”

Link to Ohio Administrative Code 901:5-11-02 Trained servicepersons, safety and restrictions

http://codes.ohio.gov/oac/901:5-11-02v1

Safe and Effective Use of Cleaners and Disinfectants

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Before discussing how to clean and disinfect surfaces it’s important to understand some terminology. Cleaners are products that remove dirt or contaminants (including germs) from surfaces. Soaps and detergents also attack the lipid membrane of some viruses (part of the reason that washing your hands with soap and water is effective) but in this brief “how to” summary, the primary purpose of the cleaner is to remove dirt as well as contaminants. Disinfectants destroy or inactivate germs on surfaces and prevent them from growing.  Disinfectants do not clean the surface or even necessarily remove the inactivated germs.

Disinfectants are registered pesticides – registered by the US EPA.  Disinfectant products are meant to be used on surfaces, not on people, not sprayed into the air, which can be a health hazard.  In Ohio, a pesticide license would only be required to use a restricted use disinfectant, not for common household disinfectants. For disinfectants for use against SARS-CoV-2, the novel coronavirus that causes COVID-19, see EPA’s List N: Disinfectants for use against SARS-CoV-2

To use disinfectants safely, as with any pesticide, READ THE DISINFECTANT LABEL. Use only EPA-registered disinfectants. Disinfectant choice is an important consideration for people with health conditions – some disinfectants may exacerbate asthma or other health conditions. Provide adequate ventilation, wear gloves to protect the skin, – both gloves and eye protection if using bleach, plus any other PPE required by label. Do not mix disinfectants together, or with other substances.  For example, mixing bleach with ammonia produces a toxic gas.

Before disinfecting, CLEAN the surface thoroughly with soap or detergent, rinse, and dry – these three preliminary steps are important to remove dirt and contaminants that may interfere with the disinfectant. Don’t skip any of the steps! All are important – for example the drying step removes contaminants and residues.  Next, apply the disinfectant product following the label instructions. If the product is mixed with water, use the dilution recommended on the label.  Remember MORE IS NOT BETTER.  Thoroughly cover the surface and apply a sufficient amount so that the surface remains visibly wet for required contact time (anywhere from 15 seconds to 10 minutes depending on the product). If you are using disposable wipes, discard them in the trash, not the septic system. For surfaces used for food, be sure to rinse with a potable water source after disinfecting. When finished with the job, remove gloves and other PPE and thoroughly wash and dry the hands.

Much of this information was gleaned from an excellent webinar offered 4/9/2020- . Safe and Proper use of Disinfectants & Household Cleaners  hosted by the Partnership for Air Matters, with the Tribal Healthy Homes Network, the WA State Department of Health, Environmental Protection Agency, Center for Disease Control and Indian Health Service. See link below.

Disinfectant Webinar recording (Northern AZ Univ):

https://mediaspace.nau.edu/media/THHN+WebinarA+Safe+and+Proper+use+of+Disinfectants+%26+Household+Cleaners/0_gywugqfv

Other useful resources:

Cleaning and Disinfecting for Households – CDC  https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/cleaning-disinfection.html

EPA Registered Disinfectants for use against SARS-CoV-2, the novel coronavirus that causes COVID-19.  https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2

EPA Safer Choice Cleaning Product Search Engine (these not necessarily effective against SARS-CoV-2 ) https://www.epa.gov/saferchoice/products

Mary Ann Rose
Director, Pesticide Safety Education Program
pested.osu.edu

 

 

PPE Shortages for Pesticide Applicators

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This spring pesticide applicators are likely to encounter a new challenge getting the personal protective equipment (PPE) required to make their pesticide applications.  The emergency needs that our first responders and medical care providers have for PPE in the COVID-19 war have led to shortages of all types of PPE, even for types not typically worn by medical personnel.  By the time that PPE become more readily available, it will likely be too late for many spring (or even summer) pesticide applications.

Every pesticide product label includes a list of the required personal protective equipment. So … what should farmers and pesticide applicators do in this situation? First, If you can’t acquire and properly use the label required PPE, don’t make the application of that pesticide. Carefully review the labels of the pesticide products you plan to use for the coming growing season to learn what PPE are required to use those products. If there are any PPE items that you do not have (or cannot get), then choose another pesticide product that does not require the PPE. One possible solution that has been advanced is to purchase higher level protection types of PPE that are not used by health care providers. Disadvantages to this approach are that these are usually hotter and more uncomfortable, more expensive, and availability perhaps just as limited, especially of replaceable parts such as the cartridges used in respirators.

Alternative products or alternative control methods that don’t require the PPE are probably your best bet. Many common pesticides require only: long sleeved shirt, long pants, shoes, and socks. Other products have more stringent PPE requirements. Online product label databases such as Agrian.com are very useful for searching out the PPE requirements for agricultural pesticides before purchase.  Whatever the label says, you must be in compliance.  Your health and safety is at stake and, – the label is the law!

Used and modified from the original with permission of Dean Slates, Ohio State University Extension Agriculture Educator, Emeritus.

Online resources

Respirators in short supply due to COVID-19

Respirator infographic