Providers of Medical Clearance and Respirator Fit Testing in Mississippi
Regulatory agencies will enforce the requirements of the federal Worker Protection Standard (Code of Federal Regulations, Title 40, Part 170) when you use a pesticide product with labeling that refers to the Worker Protection Standard. If you do not comply with the Worker Protection Standard requirements, you will be in violation of federal law, since it is illegal to use a pesticide product in a manner inconsistent with its labeling.
With the January 2, 2017, enforcement of the 2015 revised Worker Protection Standard for Agricultural Pesticides (WPS), employers and owners of agricultural establishments must ensure that every employee using a WPS-labeled pesticide that requires the use of a respirator (as stated on the pesticide labeling) is medically cleared to wear a respirator AND fit tested annually for each type of respirator required. In addition, employers must provide annual respirator training for these handlers. Employers are responsible for the cost of the medical clearance (including any related testing or office visits) and the respirator fit testing. Under the revised standard, employers must keep records of the annual fit testing and respirator training for at least 2 years. The written medical clearance must be kept for at least 2 years or until another medical clearance is conducted. See the How to Comply manual in the Resources section for full details.
Medical Clearance
All employees (including immediate family members of agricultural establishment owners) who need to wear respirators must first receive medical clearance to do so. The employee must fill out a confidential questionnaire (the “OSHA long form”) online, in person at a medical clinic, or by mail before being fit tested. The employer must supply information about the products to be used, the type of respirator needed, other personal protective equipment to be worn, extreme temperature or humidity conditions, and the amount of time and physical activity involved while wearing the respirator. A physician or licensed health-care professional will review the form, issue the clearance, or request additional testing. Approximately one or two people in ten require additional testing (such as a pulmonary function test or chest x-ray), as determined by their medical history. The agricultural employer or owner can stop the process at any time and assign the employee to other tasks that do not require the wearing of a respirator. The handler cannot use a respirator until the employer receives the written medical release.
Fit Testing
After the employee receives medical clearance to wear a respirator, the next step is to be fitted for the mask(s) required by the product labels. While the WPS does not require the testing to be done by a certified technician, employers should be aware that, for liability reasons, it may be preferable to do so. A qualitative fit test, where the employee is asked to detect an odor while wearing the mask, is less expensive and less accurate, and test subjects can influence the results. A quantitative fit test requires more sophisticated equipment, but the person being tested cannot influence the results. Some providers charge more for quantitative fit tests. If employers choose to do the testing of their employees, qualitative fit test kits, including instructions, can be ordered online.
Providers of Respiratory Protection Services
Depending on the number of employees that need to be medically cleared and tested, relative cost, and geographic location, employers and owners of agricultural establishments have options for complying with the new regulations, as illustrated in Tables 1–3. For large operations, it may be cost effective to hire a vendor to conduct the testing at the establishment. For just a few employees, attending a local fit-testing event may be best. In some areas of the state, walk-in clinics are a convenient option. Employees should be clean shaven for the fit test and bring: the mask they usually wear, including any attachments; any PPE that might affect the fit of the mask (e.g., goggles); and their written medical release if it was done in advance.
On-site services. The providers in Table 1 will conduct on-site fit-test events if enough people are precleared and prescheduled, bringing the equipment and staff necessary to perform fit tests and, in some cases, pulmonary function tests. They need to work in a room (approximately 10 by 12 feet) with electrical outlets, or they may bring a mobile unit (often more expensive). Some charge a flat fee per day, testing as many people as they can (usually 40 to 60 people, depending on additional testing that may be needed). Others will divide their expenses by the number of people prescheduled in order to determine the cost per person for the event. Several providers will bring samples of various respirator brands, models, and sizes to choose from in order to find the best fit for each person. If the vendor does not provide these, the employer should be prepared to do so.
Walk-in services. The providers in Table 2 operate walk-in clinics that offer respirator fit testing and related services. The clinics suggest making an appointment to reduce wait time.
Medical clearance services. The vendors in Table 3 offer online (and, in some cases, mail-in) medical clearance services. If the completed questionnaire raises no red flags, the employee (and sometimes the employer) will receive notice that the medical clearance has been granted. If the reviewer determines that additional testing is needed, the employee will be told what further procedures are needed. Once the employee can provide the reviewer with written documentation of the satisfactory completion of additional testing, the employee is cleared to wear a respirator and ready to be fit tested. The last two vendors also sell safety products, including fit testing kits, as well as provide resources on fit testing and safety.
Resources
Pesticide Educational Resources Collaborative and U.S. Environmental Protection Agency. 2016. How to Comply with the 2015 Revised Worker Protection Standard: What Owners and Employers Need to Know (EPA 735-B-16-001). Available online at http://extension.msstate.edu/publications/miscellaneous/how-comply-the-2015-revised-worker-protection-standard-for-agricultural (publication M2166).
Pesticide Educational Resources Collaborative (for sample forms, fact sheets, training resources) http://pesticideresources.org/wps/inventory.html.
See http://extension.msstate.edu/agriculture/pesticide-applicator-certification for the most up-to-date resources.
This document is an overview of the respiratory protection requirements of the revised WPS. In order to be fully compliant with the regulations, read How to Comply with the 2015 Worker Protection Standard for Agricultural Pesticides: What Owners and Employers Need to Know (publication M2166), available online at extension.msstate.edu/publications.
Publication 3023 (POD-5-17)
By Lois Connington, Extension Associate, Biochemistry, Molecular Biology, Entomology, and Plant Pathology.The information given here is for educational purposes only. References to commercial products, trade names, or suppliers are made with the understanding that no endorsement is implied and that no discrimination against other products or suppliers is intended.
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