3.2 Personal Protective Equipment (PPE)

The Label Is the Law for PPE

Under FIFRA, the pesticide label is a legally enforceable document. The PPE section of the label sets the minimum protective equipment you must wear. You may always wear more protection than the label requires, but you may never wear less, even if you believe the extra gear is unnecessary. Iowa Department of Agriculture and Land Stewardship (IDALS) inspectors can cite applicators for label PPE violations, and the violation is treated as pesticide misuse.

Where PPE Requirements Come From

PPE statements are derived from the product's acute toxicity category and its use pattern. EPA's Worker Protection Standard (WPS) and the product-specific label together set the requirements. When the label and WPS differ, follow the more protective requirement.

Common PPE Items

When Label PPE Can Be Reduced

The label itself may permit reduced PPE for specific engineering controls or work situations. Common reductions allowed only when the label expressly states them include:

• Closed mixing and loading systems - transfer concentrate from the container through sealed hoses, eliminating pour-splash exposure. Labels often allow dropping gloves and apron for the mixer.
• Enclosed cabs - a tractor or sprayer cab sealed with HEPA-filtered air can substitute for some respiratory and dermal PPE during application. The cab must meet the label's definition; an open station with a windshield does not qualify.
• Water-soluble packets - pre-measured packets that dissolve in the spray tank eliminate handling of the concentrate, often reducing the PPE required at mixing.
• Sealed or locked application equipment - some labels reduce PPE for applications made through irrigation lines or sealed systems.

If the label does not mention the reduction, you must wear the full PPE even if you are using the equipment. When in doubt, wear the full PPE.

Glove Material Selection

Not all gloves resist all pesticides. The label may specify a material such as 'chemical-resistant gloves made of butyl rubber, nitrile, or neoprene.' General guidance:

• Laminate film gloves (Silver Shield, 4H) resist the broadest range of formulations and are a safe default.
• Butyl rubber resists many organophosphate insecticides and fumigant salts.
• Nitrile resists many herbicides and some insecticides but degrades with certain solvents.
• Natural rubber latex is not chemical-resistant for most pesticides and should not be used.

Wear gloves inside sleeve cuffs when spraying downward so runoff does not channel into the glove, and outside sleeve cuffs when reaching overhead so spray does not run down the arm into the glove.

Respirator Programs

When a respirator is required, the applicator or employer must follow a respiratory protection program comparable to OSHA 29 CFR 1910.134:

1. Medical clearance to wear a respirator.
2. Fit-test before first use and at least annually.
3. Seal check each time the respirator is donned.
4. Cartridge change schedule based on the label, the contaminant, and work duration; if you smell or taste the chemical, leave the area and replace the cartridge.
5. Clean, inspect, and store the respirator away from pesticides after each use.

Facial hair that breaks the respirator seal disqualifies the wearer from using a tight-fitting respirator.

Cleaning and Maintaining PPE

• Wash PPE separately from family laundry using hot water and detergent; rinse the washer afterward.
• Discard gloves, aprons, and boots that show cracks, swelling, or chemical breakthrough.
• Replace respirator cartridges according to the change schedule, not when they 'smell strong.'
• Store clean PPE in a sealed bag or locker away from pesticide storage so contamination does not transfer.

Heat Stress

Hot Iowa summer days make full PPE dangerous in a different way. Heat stress can cause heat rash, heat cramps, heat exhaustion, and heat stroke. Symptoms include heavy sweating, weakness, dizziness, nausea, clammy skin, and elevated body temperature. To manage heat stress while wearing PPE:

• Schedule spraying for early morning or evening when temperatures are lower.
• Drink water frequently (small amounts every 15 to 20 minutes, not large amounts at once).
• Take breaks in a shaded area and remove PPE during breaks.
• Acclimate to heat over 7 to 14 days when starting work in hot conditions.
• Stop work and seek shade if confusion, hot dry skin, or loss of consciousness occurs; these indicate heat stroke, a medical emergency.

Minimum Age for Restricted Use Pesticides

EPA's Certification of Pesticide Applicators rule (40 CFR Part 171, 82 FR 952) set a nationwide minimum age of 18 for certified applicators and for noncertified applicators applying Restricted Use Pesticides (RUPs) under supervision. The federal rule allows a narrow exception for 16-year-old immediate-family members on family farms supervised by an immediate-family private applicator.

Iowa does not adopt that age exception. IAC 21—45.22(7)"a" states flatly that a noncertified applicator must be at least 18 years old to apply a restricted-use pesticide, and 21—45.22(2)"d" and (3)"d" set the same floor for commercial and private applicators. Iowa does keep an immediate-family supervision provision — 21—45.22(7)"b" lets a noncertified applicator use RUPs on property owned or rented by an immediate-family private applicator under that applicator's direct supervision — but the noncertified applicator must still be 18. Iowa also bars a noncertified applicator from using an RUP as a fumigant, through aerial application, or where the product contains sodium cyanide or sodium fluoroacetate, and requires instruction in the safe operation of mixing, loading, transferring, and application equipment within the last 12 months.