9.1 Protective Clothing and Chemical-Resistant Materials

40 CFR 171.103(c)(2)(vi) is a Core competency of its own: commercial applicators must know the need for, and proper use of, protective clothing and personal protective equipment (PPE). On the New Jersey closed-book Core, that federal sentence is stacked with two operational rules. N.J.A.C. 7:30-12 adopts the agricultural Worker Protection Standard (WPS) handler-PPE definitions in 40 CFR 170.507. N.J.A.C. 7:30-9.9(c) then reaches every employer whose employees use, apply, transport, or otherwise handle any pesticide — a Category 7A crew in Essex as well as a Category 3B crew in Burlington — and requires working safety equipment plus training.

The label is the floor, not a suggestion

40 CFR 170.507(a) is the handler rule: any person who performs handler activities involving a pesticide product must use the clothing and PPE specified on the pesticide product labeling, except the narrow closed-system and enclosed-cab exceptions in 40 CFR 170.607. Wearing more than the label is lawful and often wise when the job is windy, the mix is a concentrate, or the site is a school. Wearing less is using a registered pesticide in a manner inconsistent with its labeling — a federal violation under FIFRA Section 12(a)(2)(G) and a New Jersey violation under N.J.A.C. 7:30-10.2(a).

WPS draws a line that Core items exploit. Long-sleeved shirts, short-sleeved shirts, long pants, short pants, shoes, and socks are not PPE. They are work clothing. The employer must still see that they are worn if the label requires them. PPE is the extra layer: gloves, coveralls, chemical-resistant suit, chemical-resistant apron, chemical-resistant footwear, chemical-resistant headgear, protective eyewear, and respirators.

Read both the Agricultural Use Requirements box (when the product is subject to WPS) and the product-specific handler statements. Mixing and loading often demand more PPE than dilute application of the same product. A turf herbicide may allow long sleeves, long pants, shoes, socks, and waterproof gloves for the spray pass, then add a chemical-resistant apron and protective eyewear for mixing. Putting on only the application set while pouring concentrate is still a label violation.

N.J.A.C. 7:30-9.9(c) is the New Jersey overlay that does not wait for a WPS agricultural establishment: all persons having employees who use, apply, transport, or otherwise handle any pesticide shall make available to such employees any necessary or appropriate safety equipment in good working order and shall train such employees in the proper operation of such safety equipment. Telling a commercial pesticide operator to “grab whatever is in the truck” does not satisfy that duty. 7:30-9.9(d) adds a product-specific floor: no person required to be registered as a pesticide applicator or commercial pesticide operator, or as a WPS handler, shall mix or load any restricted-use 2,4-D compound unless at least chemical-resistant gloves and eye protection (goggles or a face shield) are worn.

Chemical-resistant versus waterproof versus water-resistant

40 CFR 170.507(b)(1) defines chemical-resistant: the material allows no measurable movement of the pesticide being used through the material during use. That is product-specific. A glove that stops a water-based flowable can fail in minutes against an emulsifiable concentrate in an aromatic solvent.

40 CFR 170.507(b)(2) defines waterproof: the material allows no measurable movement of water or aqueous solutions through the material during use. Waterproof is the right specification when the label says “waterproof gloves” or “chemical-resistant gloves made of any waterproof material” — typical of EPA Chemical Resistance Category A dry and water-based formulations. It is not a free substitute when the label names a higher category or lists specific polymers.

Water-resistant or water-repellent fabric is weaker still. It may shed a light mist. It is not a WPS-defined stand-in for chemical-resistant or waterproof PPE. Do not treat a rain jacket as a chemical-resistant suit.

Labels point you to an EPA Chemical Resistance Category (A through H) and a selection chart. Materials that appear on that chart include barrier laminate, butyl rubber, nitrile rubber (often specified at 14 mil or thicker), neoprene rubber, polyvinyl chloride (PVC), polyethylene, and fluoroelastomer (Viton). Barrier laminate and fluoroelastomer cover more of the aggressive solvent categories; polyethylene and natural rubber often do not. You do not memorize every hour rating. You match the label’s listed material (or the category chart the label invokes) to the product in the tank.

40 CFR 170.507(b)(5) is the glove trap. Gloves must be the type specified on the labeling. Gloves made of leather, cotton, or other absorbent materials may not be worn for handler activities unless those materials are listed as acceptable on the labeling. Cotton work gloves and leather palmed “mechanic” gloves soak concentrate and hold it against the skin. That is the opposite of chemical resistance. Canvas and unlined fabric have the same problem.

Separable glove liners (lightweight cotton or poly glove-like coverings worn under chemical-resistant gloves) are allowed unless the labeling prohibits them. They must not extend outside the chemical-resistant glove. Discard them after a total of no more than 10 hours of use or within 24 hours of first putting them on, whichever comes first, and immediately if pesticide contacts the liner. Used liners are not reused. Chemical-resistant gloves with a non-separable absorbent lining are prohibited — the lining becomes a reservoir you cannot inspect or discard.

Coveralls versus a chemical-resistant suit

Coveralls (40 CFR 170.507(b)(4)) are loose-fitting, one- or two-piece garments that cover, at a minimum, the entire body except head, hands, and feet. They are usually fabric. They beat a short-sleeve shirt against spray, but they absorb. They are not chemical-resistant.

A chemical-resistant suit (40 CFR 170.507(b)(3)) has the same coverage — entire body except head, hands, and feet — but it must be a chemical-resistant garment. Labels call for that suit when the concentrate, the fumigant, or the wet-mix is aggressive enough that fabric coveralls are not enough.

Other defined pieces:

Safety glasses without brow and temple protection do not satisfy “protective eyewear.” A baseball cap is not chemical-resistant headgear.

Inspect, wash, don, and doff

40 CFR 170.507(c)(2) requires inspection before each day of use for leaks, holes, tears, or worn places. Damaged equipment is repaired or discarded. Cracked nitrile, delaminated barrier laminate, and fogged goggles with a missing strap are out of service.

Clean reusable PPE according to the manufacturer or the labeling before each day of reuse. If there are no such instructions, wash thoroughly in detergent and hot water. Keep contaminated PPE separate from clean PPE, other clothing, and laundry, and wash it separately. Dry it thoroughly before storage. Store clean PPE apart from personal clothing and apart from pesticide-contaminated areas. Handlers need a place away from pesticide storage and use areas to store street clothes, put PPE on at the start of exposure, and take it off at the end (170.507(d)(9)).

Coveralls or other absorbent materials that have been drenched or heavily contaminated with a pesticide whose signal word is DANGER or WARNING must not be reused; they are disposed of so they cannot be worn as apparel. Anyone who handles that contaminated PPE must wear the mixing-and-loading gloves specified for the contaminant products.

40 CFR 170.507(d)(10) is a Core-level take-home rule: the handler employer must not allow or direct any handler to wear home or to take home employer-provided PPE contaminated with pesticides. Children hug a parent at the door. Pets lie on the laundry pile. That is how occupational residue becomes a household exposure, which is exactly what 40 CFR 171.103(c)(2)(ix) (keep children from pesticides) is trying to stop. Inform anyone who launders PPE that the equipment may be contaminated, how to clean it, and how to decontaminate afterward (170.507(d)(8)).

Where labeling requires PPE for a handler activity, 40 CFR 170.507(e) requires the handler employer to take appropriate measures to prevent heat-related illness. New Jersey summers plus a chemical-resistant suit are a heat-stress setup. Shade, water, rest, and not adding extra layers the label does not require are part of PPE use, not a separate luxury.

A workable donning and removal order

Don work clothing first. Then the coveralls or chemical-resistant suit. Then chemical-resistant footwear. Then gloves. Then the respirator (clean hands, seal against clean skin). Then protective eyewear and headgear so temple bars and brim edges are not shoved under a half-mask seal.

Remove in an order that keeps the most contaminated surfaces away from skin:

1. Wash the outside of the gloves while they are still on.
2. Remove eyewear and set it on a clean surface.
3. Remove the respirator without dragging the facepiece across the mouth.
4. Remove boots.
5. Peel the suit or coveralls inside-out so the outer surface is contained.
6. Remove gloves last, peeling them inside-out.
7. Wash hands, face, and neck immediately; shower and change into clean clothes as soon as possible.

Never shake dusty coveralls in a kitchen. Never wash PPE in the family load. 7:30-9.9(c) still requires the employer to furnish this equipment in good working order and to train the employee in that sequence — not merely to own a pair of gloves somewhere in the shop.

Worked New Jersey scenarios

Scenario A — mix/load PPE versus application PPE. A Category 3B label requires waterproof gloves, a chemical-resistant apron, and protective eyewear for mixing, and only long sleeves plus waterproof gloves for application. The mixer wears the application set “because we are only pouring for a minute.” That minute is still handler activity. The missing apron and eyewear are a label violation.

Scenario B — cotton gloves on an emulsifiable concentrate. An operator prefers cotton because “nitrile makes my hands sweat.” The label specifies chemical-resistant gloves such as barrier laminate, butyl, nitrile, or neoprene. Cotton is absorbent and is not listed. 170.507(b)(5)(i) forbids those gloves.

Scenario C — take-home laundry. A 7A owner tells operators to take coveralls home and run them with the household wash. If those coveralls are employer-provided and pesticide-contaminated, 170.507(d)(10) is violated, children in the house are exposed, and 7:30-9.9(c) is not met by pushing the decontamination duty onto a kitchen washing machine.