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EPA issues final rule on PPE for agricultural workers.

I a move that many anticipate will increase demand for nonwovens in the agricultural industry, the U.S. Environmental Protection Agency Environmental Protection Agency (EPA), independent agency of the U.S. government, with headquarters in Washington, D.C. It was established in 1970 to reduce and control air and water pollution, noise pollution, and radiation and to ensure the safe handling and  (EPA EPA eicosapentaenoic acid.

eicosapentaenoic acid

EPA, See acid, eicosapentaenoic.

) has released its long-awaited final rule on personal protective equipment (PPE PPE (Brit) n abbr (Univ) (= philosophy, politics, and economics) → Studiengang bestehend aus Philosophie, Politologie und Volkswirtschaft

PPE n abbr (BRIT ) (SCOL
) for agricultural workers. The rule basically requires that, beginning October 20, 1992, PPE must be provided to any workers who handle pesticides or are sent into areas where pesticides have recently been used. The rule has been EPA consideration since 1988

While the rule does not require that single-use PPE be provided to workers, it does contain provisions that could make single-use products more attractive to employers than reusables.

INDA worked closely with EPA personnel during the development of this final rule and is pleased that it has been released, although it would have preferred that stronger language be included encouraging the use of single-use products.

The Final Rule

Under provisions of the final rule, PPE is to be provided to any person who handles pesticides and to any person who enters a treated area before the expiration of a "restricted entry interval." PPE requirements for these two types of workers varies.

The rule requires that pesticide products be labeled so that the approximately PPE is specified. EPA recognizes four different levels of toxicity - Class I being the most toxic, Class IV, the least - for pesticides, and three different "routes of exposure": dermal toxicity dermal toxicity,
n an adverse skin reaction to the application of essential oils and other substances; includes irritation, (inflammation, itching) sensitization (reactions occurring after initial contact), and phototoxicity, (increased vulnerability to sun).
 (skin contact), inhalation inhalation /in·ha·la·tion/ (in?hah-la´shun)
1. the drawing of air or other substances into the lungs.inhala´tional

2. the drawing of an aerosolized drug into the lungs with the breath.

 toxicity and eye irritation potential.

With Class I and II pesticides, workers must be protected against all three routes of exposure. At a minimum, a chemical-resistant suit or coveralls worn over a long-sleeved shirt and long pants must be provided, along with chemical-resistant footwear (which includes standard footwear protected by chemical-resistant shoe coverings), chemical-resistant gloves, a respiratory protection device and protective eye wear.

With Class IIl pesticides, a long-sleeved shirt and pants must be worn, as well as shoes, socks and chemical-resistant gloves. Class IV pesticides require the same PPE as Class III, except gloves are not necessary. EPA designed the requirements so that an incentive would be provided to use the least toxic pesticides.

Single-use Versus Reusables

EPA recognizes that PPE is currently the best means of preventing exposure to pesticides, but the agency is also aware of comfort issues when workers are required to wear an extra layer of clothing while performing manual labor during summer months.

Therefore, while the rule specifies that coveralls may be provided if worn as a second layer of clothing on top of a long-sleeved shirt and pants, when working with Class I pesticides, the EPA also notes that (workers may) wear a chemical-resistant protective suit as an alternative to two layers of clothing. The development of various types of disposable chemical-resistant garments made of nonwoven non·wo·ven  
Made by a process not involving weaving. Used of textiles.

Material or a fabric made by a process not involving weaving.
 materials... gives pesticide users a wide choice of protective materials."

With Class II pesticides, employers are given the option of providing a chemical-resistant suit or coveralls worn on top of a T-shirt and shorts.

In all cases, the EPA recognizes that a chemical-resistant suit will be more comfortable for workers and offer greater protection than two layers of clothing.

In fact, language in the rule's prologue pro·logue also pro·log  
1. An introduction or preface, especially a poem recited to introduce a play.

2. An introduction or introductory chapter, as to a novel.

3. An introductory act, event, or period.
 specifically states that "a chemical-resistant suit... is more protective than a coverall cov·er·all  
A loose-fitting one-piece work garment worn to protect clothes. Often used in the plural.

Noun 1. coverall - a loose-fitting protective garment that is worn over other clothing
 or a long-sleeved shirt and long pants." Pesticide manufacturers are also allowed to label products so that use of a chemical-resistant apron apron,
n a piece of clothing worn in front of the body for protection.

apron band,
n a labioincisal or gingival extension of an orthodontic band that aids in retention of the band and in proper positioning of the bracket.
 is required.

Employer Responsibilities

The rule places all PPE cleaning, decontamination decontamination /de·con·tam·i·na·tion/ (de?kon-tam-i-na´shun) the freeing of a person or object of some contaminating substance, e.g., war gas, radioactive material, etc.

 and maintenance requirements on employers.

It is the employer's responsibility to insure that all PPE be inspected for leaks, holes, tears or worn areas every day before use. Employers must provide facilities to insure that PPE is cleaned every day before use according to according to
1. As stated or indicated by; on the authority of: according to historians.

2. In keeping with: according to instructions.

 manufacturer's instructions. Before being stored, all clean PPE is to be dried thoroughly or put in a well ventilated ven·ti·late  
tr.v. ven·ti·lat·ed, ven·ti·lat·ing, ven·ti·lates
1. To admit fresh air into (a mine, for example) to replace stale or noxious air.

 place to dry. PPE contaminated contaminated,
v 1. made radioactive by the addition of small quantities of radioactive material.
2. made contaminated by adding infective or radiographic materials.
3. an infective surface or object.
 with pesticides is to be washed separately from any other clothing and laundry.

The rule requires that warnings be provided to any person who cleans or launders PPE that may be contaminated with pesticides. Such warnings are to outline the potentially harmful effects of exposure to pesticides as well as proper ways to clean and handle contaminated garments.

The rule also makes the employer responsible for preventing workers from wearing or taking home any contaminated PPE.

All of these requirements could encourage employers to provide employees with single-use products.

Moreover, in terms of disposal, employers are responsible for complying with all federal, state and local laws regardless of whether the item being disposed of is a single-use product or a damaged reusable re·use  
tr.v. re·used, re·us·ing, re·us·es
To use again, especially after salvaging or special treatment or processing.


Penalties for not complying with the rule are stiff. Commercial applicators can be fined up to $5000 for each offense and private applicators can be fined up to $1000 per offense. In addition, for "knowingly" violating the law, commercial applicators can be End up to $50,000 and be sentenced to a year in jail Private applicators can be fined up to $25,000 and sentenced to a year in jail.

As with the OSHA OSHA
Occupational Safety and Health Administration, a branch of the US Department of Labor responsible for establishing and enforcing safety and health standards in the workplace.
 Bloodborne Pathogens rule, this EPA action should provide an opportunity to increase markets for nonwoven protective apparel.

While the rule does not specify that nonwovens be used to protect workers, it does provide employer requirements that could open doors for our industry.

Since nonwovens are more comfortable, do not need to be cleaned and are inspected by the manufacturer prior to sale, they will eliminate many of the compliance requirements Compliance requirements are a series of directives established by United States Federal government agencies that summarize hundreds of Federal laws and regulations applicable to Federal assistance (also known as Federal aid or Federal funds).  - and potential liability - that employers will face under this rule.

It is now up to our industry to take full advantage of this new rule through aggressive marketing to the agricultural industry.

Peter Mayberry is the director of government affairs for INDA, Association of the Nonwoven Fabrics Industry. He works out of the Washington, DC offices of Keller & Heckman, INDA's legal counsel. This Capital Comments column appears monthly in NONWOVENS INDUSTRY.
COPYRIGHT 1992 Rodman Publications, Inc.
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1992 Gale, Cengage Learning. All rights reserved.

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Title Annotation:Environmental Protection Agency; personal protective equipment
Author:Mayberry, Peter
Publication:Nonwovens Industry
Date:Nov 1, 1992
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