S525 Certified Cabs Shouldn't Be Used in Lieu Of
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July 2002 Volume 15, No. 4 S525 Certified Cabs Shouldn’t Be Used in Lieu of PPE 1 S525 Certified Cabs Shouldn’t Be Used in Lieu of PPE The American Society of Agricultural Engineers (ASAE) now recommends using agricul- tural cabs certified to meet ASAE standard S525-1.1 as a supplement to personal protec- tive equipment (PPE), rather than as a replacement for it. S525 was initially created to 2 Pesticide Protection: Cabs certify specially equipped cabs intended to provide equivalent protection of some specific on Sprayers and Tractors PPE listed on pesticide labels. Two main features of S525-certified cabs are special cab filters for removing organic pesticide vapors, and positive-pressure ventilation. These cabs use filters with a tested and 3 Custom Hay Balers, Take proven efficiency at removing pesticide vapors to provide a supply of filtered air to the Note climate-control system in the cab. In addition, the cabs are well sealed and maintain higher pressure inside the cab, so any air leakage would be of filtered air leaking out rather than of contaminated air leaking in. An in-cab pressure indicator is required so the 3 Systemic, Local Systemic, operator can monitor the pressure and be assured that the filtration system is functioning or Translaminar: What’s the properly. Low in-cab pressure could indicate excessive air leakage (as from a poorly sealed Difference? door) or a plugged air filter in need of replacement. US–EPA personnel endorsed S525 in 1998, allowing operators of equipment with 4 Study Shows Turf certified cabs to spray without some specific forms of PPE. The standard was developed Pesticides Break Down with the expertise from many areas, including equipment manufacturers, regulatory Rapidly agencies, and universities. According to the ASAE, additional information has revealed more areas that need to be investigated and addressed besides what was initially considered during the development 5 Pesticide Update of the standard. Because of this, the ASAE recommends that S525-certified cabs not be used in lieu of PPE; rather they should be considered a supplement to PPE. All operators of sprayers equipped with such cabs should follow all pertinent PPE requirements stated on the pesticide label. (Mark Mohr; sources: ASAE press release from 5/22/02; ASAE Standard S525-1.1.) University of Illinois • U.S. Department of Agriculture Local Extension Councils Cooperating University of Illinois Extension provides equal opportunities in programs and employment. Illinois Pesticide Review Volume 15, No. 4, July 2002 2 Pesticide See the accompanying article on cabs • US–EPA pesticides programs, certified through ASAE standard S525 www.epa.gov/pesticides; or phone Protection: Cabs for more information (page 1). (703)305-7666 on Sprayers and Q: I bought carbon cab filters for my The WPS is in the Code of Federal old cab. Does that replace PPE? A: It Regulations. Exceptions to PPE require- Tractors takes more than a filter to exempt a ments pertaining to cabs are in 40 CFR, sprayer operator from wearing PPE. part 170.240 (d)(5). This is only the part Many sprayer operators enjoy the Simply replacing the standard paper cab on exceptions to PPE when using en- comfort and appreciate the added filter with a carbon filter does not fulfill closed cabs and is from the Government protection of modern sprayers and the requirement. In fact, most places that Printing Office Web site, www.gpo.gov. tractors equipped with cabs. But how sell replacement carbon filters promi- Remember, this information must be much of this perceived protection is real nently post that they are not replacements used in context of the entire WPS. depends on the cab. for other PPE. There are many other ways “(5) Enclosed cabs. If handling tasks for pesticides to enter a cab other than Q: What difference does a cab make? are performed from inside a cab that has through the air intake. Many cabs have A: One of the principles of risk reduction a nonporous barrier which totally sur- holes for running wiring, shift linkage, is Hazard + Exposure = Risk. For this rounds the occupants of the cab and and brake linkage. Door and window discussion, we can say that the less prevents contact with pesticides outside seals and many other cab features also exposure you have to a hazard (in this of the cab, exceptions to personal provide routes for pesticides to enter the case, a pesticide), the lower the risk. The protective equipment specified on the cab. Worker Protection Standard (WPS) product labeling for that handling activity allows for cabs on sprayers that reduce Q: If I get out of the cab, will I need are permitted as provided in paragraphs operator exposure well enough that their to have the PPE with me anyway? A: (d)(5)(i) through (iv) of this section. protection is considered equivalent to When you spray with an enclosed cab, “(i) Persons occupying an enclosed cab specific types of personal protection you need to have with you all relevant may substitute a long-sleeved shirt, long equipment (PPE). PPE listed on the label, even if you don’t pants, shoes, and socks for the labeling- have to wear it in the cab. If you get out Q: What can I not wear? A: What PPE specified personal protective equipment. of the cab (to inspect, adjust, or repair is needed depends on the cab and the If a respiratory protection device is something, for example) you need to pesticide being used. In brief, a cab may specified on the pesticide product wear the PPE. Keep the PPE in a be used to replace some PPE up to the labeling for the handling activity, it must pesticide-resistant container or bag. Wear effectiveness of the cab’s protection. Some be worn. it when out of the cab, but take it off PPE is always required, such as long before getting back in the cab so you “(ii) Persons occupying an enclosed cab pants, long-sleeved shirts, shoes, and don’t contaminate the surfaces inside the that has a properly functioning ventila- socks. If additional protection is required cab. tion system which is used and maintained on the label and beyond what your cab in accordance with the manufacturer’s can provide (for example, air-filtration Q: You didn’t answer my questions. written operating instructions and which type and efficiency), the additional PPE Where can I learn more? A: Below is the is declared in writing by the manufacturer must be worn. language from the WPS on PPE excep- or by a governmental agency to provide tions related to cabs. Read it, then get Q: Are all cabs equal? A: Not all cabs respiratory protection equivalent to or more information from are equal, so you must read the informa- greater than a dust/mist-filtering respira- tion from the cab manufacturer. The • your local UI Extension office, tor may substitute a long-sleeved shirt, WPS requires that cabs be certified in www.extension.uiuc.edu; or check long pants, shoes, and socks for the writing from either the manufacturer or a your local phone book labeling-specified personal protective government agency to provide certain • UI Extension Pesticide Safety Educa- equipment. If a respiratory protection levels of protection by filtering pesticides tion, www.pesticidesafety.uiuc.edu device other than a dust/mist-filtering from the air or supplying clean air. If respirator is specified on the pesticide • US–EPA worker protection Web site, your cab isn’t certified, you should wear product labeling, it must be worn. www.epa.gov/oppfead1/safety/ the respiratory PPE stated on the label. workers/workers.htm Your cab must also be properly main- tained according to the manufacturer’s instructions and in good working order. Illinois Pesticide Review Volume 15, No. 4, July 2002 3 “(iii) Persons occupying an enclosed Propionic acid is not a restricted-use properties. In addition to insecticides, cab that has a properly functioning pesticide, so farmers applying it as a hay several fungicides are available with ventilation system which is used and preservative for their own use do not need systemic activity, including mefenoxam maintained in accordance with the to be licensed. However, a custom/for- (Subdue Maxx) and fosetyl-aluminum manufacturer’s written operating instruc- hire hay baler using the acid must be (Aliette). In fact, Aliette is the only tions and which is declared in writing by licensed as a commercial applicator in the fungicide available that moves both up the manufacturer or by a governmental field crops category. Commercial applica- and down the plant’s vascular system. agency to provide respiratory protection tors must pay a $45 annual license fee However, this article primarily concen- equivalent to or greater than the vapor- or and provide a certificate of insurance. trates on the action and use of systemic gas-removing respirator specified on Contact your local University of insecticides. pesticide product labeling may substitute Illinois Extension office to obtain study Systemic insecticides are those in which a long-sleeved shirt, long pants, shoes, materials to help you prepare for the the active ingredient is taken up, prima- and socks for the labeling-specified general standards and field crops exams. rily by plant roots, and transported personal protective equipment. If an air- You may make an appointment with the (translocated) to locations throughout the supplying respirator or a self-contained Illinois Department of Agriculture to take plant, such as growing points where it can breathing apparatus (SCBA) is specified the examinations anytime during the year affect plant-feeding pests. Systemics move on the pesticide product labeling, it must by calling (217)785-2427 for the within the vascular tissues, either through be worn.