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June 11, 2020
EPA Provides Guidance on Respirator Shortages During COVID-19 Shortage
Last week the EPA issued temporary guidance on how pesticide handlers should deal with the current shortage of respirators. This shortage is the result of the increased demand for respirators from health care workers caused by the COVID-19 pandemic. In addition to a shortage of respirators, fit testing services have also been affected by stay-at-home orders. The full guidance memorandum can be viewed here. It outlines four options for compliance that the EPA has deemed satisfactory for the duration of the pandemic. 
 
The options for FIFRA compliance are the following:
  • Use a NIOSH approved respirator that meets or exceeds the level of protection of the respirator required by the pesticide label.
  • Use an alternative pesticide that fits the intended use but does not require a respirator.
  • Hire a commercial applicator that has the required respirators for the product to be applied and has fit testing capability.
  • If possible, delay the use of using the pesticide until additional compliance options become available.
If all of these compliance options are exhausted, the EPA provided these options:
  • Extend the use or reuse disposable N95 filter facepiece respirators.
  • Use filter facepiece respirators that are beyond their recommended service life.
  • Use filter facepiece respirators that have been certified in other countries or jurisdictions.
In terms of completion of respirator fit testing, the EPA provided the option of delaying the fit test. Following these options will allow pesticide handlers to conduct their work in the safest manner possible if COVID-19 respirator related shortages affect their ability to find respirators.
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