Respirator Compliance

In the May 7, 1998 Federal Register, EPA has issued a policy statement regarding the use of non-powered, air-purifying particulate respirators by pesticide handlers. The policy statement is necessary because the certification requirements for these respirators are in the process of changing. Previously EPA required all pesticide handlers to use respirators certified under 30 CFR Part 11 (part 11) (TC21c or TC23c respirators) when particulate respirators were required. NIOSH has recently developed changes to the 42 CFR Part 84 (part 84) regulations that establish standards for these respirators and EPA has determined that all part 84 respirators meet or exceed all part 11 respirator requirements. EPA will allow pesticide handlers to use either part 11 or part 84 respirators to satisfy non-powered, air-purifying respirator requirements for pesticide applications. EPA's determination reads in part:

...a pesticide user may substitute a part 84 non-powered, air-purifying particulate respirator for a part 11 respirator even though the pesticide product label requires use of a part 11 respirator, and EPA will not initiate an enforcement action for misuse of the product. This substitution will only be allowed until the pesticide product label change from part 11 to part 84 respirator requirements have been completed.

NIOSH is requiring that manufacturer and certification of part 11 respirators cease July 10, 1998. It is currently estimated that supplies of the part 11 respirators will not be exhausted for approximately 3 years. Because of the phase out of part 11 respirators, EPA plans to require manufacturers to add part 84 language to current product labels in a two-step process. First EPA will require that manufacturers alter labels to allow the use of both the part 11 and part 84 respirators, then, after the supply of part 11 respirators has been used, EPA will require a second label change to only allow use of the part 84 respirators. EPA is issuing this policy statement as authorization for the use of the part 84 respirators until such time as these label changes have been made.(Page 25168)

Return to the Table of Contents for the July 1998 issue

Return to the Agrichemical & Environmental News Index