This article is by Ben Phillips and Craig Anderson, Michigan State University.
The Worker Protection Standard (WPS) is a regulation designed to protect farm workers from dangerous exposure to pesticides. A recent update in 2015 has aligned the WPS with most of the Occupational Safety and Health Administration (OSHA) provisions for using respirators. The revised WPS includes specific requirements for the use of respirators when using pesticide products under the Agricultural Use Requirements that requires the use of a respirator. This revision requires all those who mix, load and apply pesticides (including self-employed pesticide handlers) to have a medical evaluation, and annual fit-tests for each type of respirator required by the pesticide product label and annual training regarding the proper use of each respirator to be used by the handler. The medical evaluation must occur before the employee is fit tested or required to use the respirator in the workplace.
When using a pesticide for uses other than those covered in the Agricultural Use Requirements section of the label, the worker exposure is subject to the requirements of the OSHA Hazard Communication Standard, and either MIOSHA Part 700 or Part 451, including the need for respiratory protection. The Safety Data Sheet for a pesticide would indicate if you need a respirator for non-agricultural uses.
At this years’ Great Lakes Fruit, Vegetable, Farm Market and Greenhouse Growers EXPO, in Grand Rapids, MI, MSU Extension has invited the Great Lakes Bay Health Centers to perform these medical evaluations for growers and their employees who may need to use respirators, free of charge. In addition, Tom Smith, of the National Pesticide Safety and Education Center will be sharing space with the medical team to offer growers all of the resources they need to comply with the revised Worker Protection Standard. Respirator fit-testing will not be provided on site.
The EPA-approved medical evaluation forms are questionnaires that employees must fill out for a physician or other licensed health care professional (PLHCP) to review. The forms are available in English and Spanish. Forms will be provided on-site at EXPO, or can be downloaded and printed from the links above and brought to the EXPO. There will be two licensed health care professionals and two assistants on site to review the forms and provide medical clearances.
How employers must handle the forms. What do they need from you?
Sections 1 and 2 of Part A of the form are required by the law, and must be completed in private by the employee during normal working hours or at a time and place that is convenient for them. While the regulation does not require all of the following information, the employer must complete the following information for the health care provider:
- The type and weight of respirator that the employee will use.
- How long and how frequently the employee will use the respirator.*
- How much physical work the employee will do while using the respirator.*
- Other PPE the employee will use.*
- The temperature and humidity extremes of the working environment.*
*Not required, but the questions can be found in Part B, Section 2 of the medical form.
The health care provider may determine that additional questions about the respirator activities is necessary and/or a physical examination. These could include the questions in Part B, Section 1, a pulmonary function test (PFT), or electrocardiogram (ECG). However, the health providers at the Great Lakes EXPO will not be able to perform these tests on site. The most that may happen at EXPO is listening to lungs with a stethoscope and some discussion about the evaluation answers in Part A Sections 1 and 2. Employees may be recommended to seek physical examinations elsewhere.
How health care providers must handle the forms. What do you need from them?
The health care provider will give the employer and the employee a written medical determination (medical release) of the medical evaluation results. An employee cannot use a respirator until this written medical determination is received allowing such use. The determination will include the following information:
- Whether the employee is medically able to use a respirator.
- Any restrictions on the employee’s use of the respirator.
- The need for follow-up medical evaluations.
- Verification that the health care provider has given the employee a copy of the written medical determination.
Once complete, employers must keep records of the medical determination listed above. It should not include any completed medical questionnaires or detailed notes from any additional medical examinations. That information is confidential and should not be in the possession of the employer.
For more information see: