Section 6: How should I review worker protection labeling?

Handler Personal Protective Equipment Statements

As mentioned in Module 2, labels for products subject to the Worker Protection Standard (WPS) can include four categories of worker protection statements in the precautionary statements section. One of these four categories is handler personal protective equipment (PPE) statements, the requirements of which are described below.

The correct handler PPE is determined by comparing the product-specific handler PPE specified in a product's acute toxicity review with the chemical-specific handler PPE requirements specified in the regulatory assessment document (such as a reregistration eligibility decision [RED] document). In most cases, the reviewer uses a combination of the most protective statements given in the acute toxicity review and the regulatory assessment document to determine the correct handler PPE labeling. (EPA will approve additional state-required language if it is clear that it applies only in that state.)

You can determine the correct product-specific handler PPE by consulting a product's acute toxicity review and the information provided in Chapter 10, Section VI.A of the Label Review Manual, which is summarized in the steps below.

Step 1. Identify the correct product-specific handler protective clothing.

Once the correct toxicity category has been established, you can identify the product-specific handler PPE. Reviewers may obtain the correct product-specific handler protective clothing from the Acute Toxicity Review. Table 1 in Chapter 10, Section VI of the Label Review Manual shows which product-specific handler PPE corresponds with which toxicity category for each of the relevant acute toxicity studies.

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