Appropriate personal protective equipment: Pesticide label requirements or safety data sheet requirements

The Material Safety Data Sheets (MSDS) have in the past and continue to be the standard safety references for chemical products. Revised MSDS documents are now referred to as Safety Data Sheets (SDS) and these references include numerous safety requirements such as personal protective equipment (PPE) that are also listed on the corresponding pesticide labels. In some instances the requirements on the SDS (MSDS) references have a different protective requirements listed for PPE than what appears on the pesticide label for identical products. This presents some confusion for applicators and handlers when determining which set of requirements offers the appropriate level of personal protection for pesticide applicators and handlers. This is of particular importance when PPE list include respirators and the two references have differ in requirements. Previous research suggests that safety warnings must be understood by the intended target audience to be effective. The inconsistencies between pesticide labels and SDS documents could increase risks to applicators and handlers. This inconsistency is further complicated by the changes proposed for the Worker Protection Standard (WPS). Under the proposed WPS changes, OSHA standards which are reflected on SDS documents, must be adopted for respirator requirements. Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), SDS (MSDS) requirements that conflict with the FIFRA approved pesticide label requirements will be problematic. To provide clarification and compliance guidance, the EPA has recommended that pesticide registrants insert FIFRA label information and a brief explanation of any differences on the corresponding SDS. For their health and safety, it is critical for pesticide applicators and handlers to understand pesticide personal protective information. The reading, comprehension, and compliance with of pesticide labels has in the past been problematic for agricultural producers and workers and this will be further complicated by the proposed WPS requirements. Data are reported on training activities supported by a NIOSH agricultural safety and health center pilot project funding. Continued education and training is needed to assure that people exposed to pesticides use appropriate PPE.