Personal Protective Equipment
EPA requires certain Personal Protective Equipment be used when working with pesticides. The label outlines the PPE required. Without this PPE, the health of the pesticide handler and worker may be in jeopardy. EPA is proposing several changes to reduce exposure to pesticides using PPE.
Read the details of the proposed changes and the rationale before you comment.
All your comments are welcome but we have specific questions for you on changes to Personal Protective Equipment.
A. Chemical-Resistant PPE
- Are there alternatives to this proposal for determining chemical resistance of a garment that are both cost-effective and protective? Please provide details and any data that may apply.
B. Closed Systems
- Are the proposed standards for closed systems reasonable and achievable?
- Are the proposed standards for closed systems too specific? If so, please describe what aspects are too specific, why, and how to achieve sufficient protection while reducing the specificity.
- Do data exist on the number of establishments that use closed systems, the number that do not use closed systems because the current standard is not clear, and/or the number of establishments that use closed systems that meet the California criteria?
- Would people who currently use closed systems that do not meet the proposed standard upgrade their closed system or opt to use the label-required PPE? What information would impact this decision?
- What would be the cost to convert an existing system that does not meet the proposed standard to one that does?
- Should EPA consider eliminating any of the criteria listed in the proposal? If so, which criteria and why?
- What would be the benefits and draw backs of the requirement for the closed system to triple rinse the container? Is the technology available to provide this element at a reasonable cost?
- Would it be possible for agricultural and handler employers, handlers, and inspectors to measure the closed system’s PSI while the system is in use? If it would not be possible, should EPA consider eliminating this element?
C. Contaminated PPE
- Are there better ways to mitigate the risks associated with reuse of discarded PPE? Please provide rationale and data, as applicable, with your response.
D. Eyewear Protection for Open Cockpits
- Is the estimate of the cost reasonable? Please provide rationale and data to support your information.