7.3 PPE Cleaning, Inspection, Storage & WPS Compliance

7.3 PPE Cleaning, Inspection, Storage & WPS Compliance

The protective value of PPE depends entirely on proper post-application decontamination, thorough inspection, and safe storage. Wearing contaminated or degraded PPE is often more dangerous than wearing no PPE at all, because trapped chemical residues continuously leach into the skin over extended working hours.

Furthermore, the EPA Worker Protection Standard (WPS) establishes strict federal legal responsibilities for agricultural employers regarding PPE provision, laundering, decontamination facility placement, and emergency eyewash availability.

Post-Application PPE Removal and Decontamination Sequence

To prevent transfer of pesticide residues to personal clothing, vehicle interiors, or home living spaces, applicators must follow a systematic stripping and decontamination procedure at the end of every work shift:

1. Wash Gloved Hands First: Before touching any facial gear or unzipping garments, wash the outside of chemical-resistant gloves thoroughly with soap and water.
2. Remove Outer Boots and Apron: Unbuckle and remove boots and aprons; wash them down with fresh water.
3. Remove Eye Protection and Respirator: Touch only the head straps or ear loops to remove goggles and respirators without touching the contaminated facepiece skin seal.
4. Remove Coveralls: Peel coveralls downward from the shoulders, turning the garment inside-out as it is pulled down to trap residues inside.
5. Remove Gloves Last: Peel chemical-resistant gloves off backward from the wrist, turning them inside-out.
6. Shower Immediately: Wash body and hair thoroughly with warm water and soap before putting on clean street clothes.

Protocols for Laundering Contaminated Work Clothing

Pesticide-contaminated work shirts, denim pants, and cloth coveralls require specialized laundering procedures to remove chemical residues effectively.

Mandatory Washing Rules

• Separate Laundry: NEVER mix pesticide-contaminated clothing with family laundry or household items. Store contaminated items in a dedicated plastic bucket or heavy plastic trash bag outside living areas.
• Pre-Rinse / Soaking: Pre-rinse contaminated clothes outdoors with a hose or soak them in a tub of clean water to dislodge surface residues prior to machine washing.
• Water Temperature: Wash clothing using HOT WATER (minimum 140°F / 60°C). Heat accelerates chemical solubility and residue release.
• Detergent Selection: Use a heavy-duty liquid detergent (e.g., concentrated detergent designed for grease/oil removal). Liquid detergents suspend organic pesticide formulations far better than powdered soaps.
• Load Size & Water Level: Wash in small loads set to the HIGHEST water level to maximize chemical dilution.
• Line Drying Recommended: Hang washed clothing outdoors on a clothesline to dry in direct sunlight. Sunlight (ultraviolet radiation) assists in photo-degrading trace chemical residues. Avoid using household clothes dryers, as heat can bake residual pesticide onto dryer drums.
• Clean the Washing Machine: After laundering pesticide garments, run the washing machine through a complete, empty cycle using hot water and detergent before putting in family laundry.

Saturated Garment Handling and Disposal Criteria

There is a critical distinction between work clothing exposed to light spray mists versus clothing contaminated by concentrated chemical spills.

CRITICAL DISPOSAL RULE: Clothing or fabric coveralls that have been heavily saturated with concentrated liquid pesticides (especially Toxicity Category I [DANGER/POISON] or Category II [WARNING] concentrates) CANNOT BE DECONTAMINATED. They MUST be discarded immediately.

Laundering heavily saturated fabric cannot remove deep chemical deposits trapped within fiber cores. Attempting to wash saturated clothing will contaminate the washing machine and transfer high chemical concentrations to subsequent clothes loads. Saturated garments must be rolled up inside a leak-proof plastic bag, sealed tightly, and disposed of in accordance with TDA and local hazardous waste regulations.

Cleaning and Maintaining Reusable Synthetic PPE

Rubber boots, nitrile gloves, chemical splash goggles, and elastomeric respirator facepieces require regular washing and inspection:

1. Gloves and Boots: Wash daily with warm water and heavy-duty detergent. Inspect for cracks, pinholes, thin spots, or stiffening. Perform an air-inflation test on gloves by rolling the cuff closed and squeezing to check for escaping air bubbles under water.
2. Goggles and Face Shields: Wash lenses with mild liquid dish soap and warm water; rinse thoroughly and dry with a soft lint-free microfiber cloth. Avoid solvent cleaners that degrade polycarbonate transparency.
3. Respirators: Remove filter cartridges. Wash the elastomeric facepiece in warm water (not exceeding 110°F) using a mild sanitizing detergent. Inspect inhalation and exhalation flapper valves for cracks, tears, distortion, or mineral deposits. Air-dry facepieces completely in a clean space before reinstalling cartridges.

Secure Storage Conditions for Clean PPE

Storing clean PPE improperly can lead to premature degradation or cross-contamination before use:

• Isolation from Pesticides: Clean PPE must NEVER be stored inside a pesticide storage shed, near chemical mixing areas, or in vehicle trunks alongside pesticide containers. Chemical vapors in storage sheds permeate rubber and plastic PPE, turning protective gear into a source of toxic exposure.
• Environmental Protection: Store PPE in a cool, dry, dark locker or sealed polyethylene bag away from direct sunlight (UV light degrades synthetic elastomers), extreme heat, moisture, and ozone sources (e.g., electric motors).

Employer Mandates Under the EPA Worker Protection Standard (WPS)

The EPA Worker Protection Standard (42 CFR Part 170) places strict legal requirements on agricultural employers (farm owners, nursery operators, forestry managers, commercial pesticide handling establishments) to protect pesticide handlers:

Employer PPE Duties

1. Provide Clean PPE: Employers must provide all required PPE listed on the product label in clean, operating condition to agricultural handlers.
2. Inspection & Maintenance: Employers must ensure PPE is inspected, cleaned, repaired, or replaced before each daily use.
3. Prevent Home Contamination: Employers must ensure handlers do not take contaminated PPE home and must provide a clean area for changing out of work clothing.
4. Laundering Notifications: Employers who send contaminated PPE to a commercial laundry service must inform the laundry operator that the items contain pesticide residues and provide safety handling protocols.

Mandatory Decontamination Supplies

Employers must supply decontamination sites for all agricultural handlers performing mixing, loading, or application tasks. Decontamination supplies must be located:

• At every mixing and loading site.
• Within 1/4 mile of all handlers working in field application areas (or at the nearest vehicle access point).
• Outside any area under a Restricted-Entry Interval (REI).

┌────────────────────────────────────────────────────────────────────────┐
│               MANDATORY WPS DECONTAMINATION SUPPLIES                   │
├────────────────────────────────────────────────────────────────────────┤
│  1. Clean Water      │ Minimum 3 GALLONS of clean water per handler    │
│                      │ (for washing hands, face, and emergency body)  │
├──────────────────────┼─────────────────────────────────────────────────┤
│  2. Soap & Towels    │ Plenty of fluid soap and single-use paper       │
│                      │ towels (no reusable cloth towels)               │
├──────────────────────┼─────────────────────────────────────────────────┤
│  3. Change of Clothes│ At least one clean coverall or change of clothes│
│                      │ per handler for emergency spills                │
├──────────────────────┼─────────────────────────────────────────────────┤
│  4. Emergency Eyewash│ System providing continuous gentle water flow   │
│                      │ (0.4 gpm for 15 minutes) at mixing sites        │
└──────────────────────┴─────────────────────────────────────────────────┘

PPE Maintenance & Compliance Summary Matrix