EPA releases guidance regarding respirators during COVID-19 PPE shortages.

By: Ernie Lugo, ESD

UPDATE: THIS IS NO LONGER IN EFECT

The use of crop protection products in Arizona requiring respiratory protection are not as common as they once were but when a respirator is required, it must be used.

The EPA has released guidance for agricultural pesticide handlers and handler employers due to uncertainty about the availability of respiratory protection equipment (and related fit testing services) during the COVID-19 emergency. The full guidance document released by the EPA is available by clicking on this link: https://www.epa.gov/sites/production/files/2020-06/documents/covid19statementrespirators.pdf.

However a summary of the document is included below:

Agriculture has been deemed critical infrastructure, and pesticides are a vital tool in agricultural production. Pesticide handlers must wear respiratory protection when a label requires it. By far the most common type of respiratory protection required by pesticide labels is the filtering face-piece respirator (FFR). EPA offers guidance on acceptable ways to overcome potential shortages of respirators due to heightened healthcare demand. This guidance is presented as a tiered system; handlers and handler employers must try the solutions from the first list before resorting to options in the other lists.

If the label-required respiratory protection is in short supply or unavailable, try one or more of the following solutions:

• Use a NIOSH-approved respirator that is equally or more protective than what the label requires.

• Use an alternative pesticide product that does not require respiratory protection to be worn.

• Hire a commercial applicator who has the necessary equipment, fit test, and training.

• When possible, delay pesticide applications until one or more of these compliance solutions are available.

If all the above compliance solutions have been exhausted, several additional options are available. These options are presented in two separate lists. Use the first list if compliant respirators cannot be acquired or are in short supply. Use the second list if compliant fit testing cannot be acquired. All of these options can only be used if certain conditions are met. See the full document for details on these conditions.

If compliant FFRs cannot be acquired or are in short supply, try these options (in order):

1. Use N95 respirators for longer than normally allowed and/or reuse N95 respirators for more than one pesticide application.

2. Use N95 respirators that are past their expiration date.

3. Use FFRs that have been certified in certain other countries. EPA cautions handlers and handler employers to watch out for fraudulent respirators if using this option.

If fit testing cannot be acquired because of COVID-19, try these options:

• Delay annual fit tests.

• Delay fit tests for handlers who have previously been fit tested for an FFR that is equivalent to the one they will wear in 2020.

For more information on respirators you can contact AZDA's Pesticide Safety Consultant, Roberto Rios at 602-542-0985 or via email at: rrios@azda.gov. For any other questions regarding the Worker Protection Standard, call 928-344-7909.