Section 6: How should I review worker protection labeling?

Step 2. Identify additional product-specific handler protective clothing (apron and headgear).

If the product under review has been classified as toxicity category I or II for either the acute dermal study or the primary skin irritation study, review Table 2 in Chapter 10, Section VI of the Label Review Manual to determine the additional product-specific PPE.

Step 3. Identify product-specific gloves for handlers.

The specific glove or gloves that are acceptable to meet the requirements for handler PPE must be listed on the label. Table 3 in Chapter 10, Section VI of the Label Review Manual lists the chemical-resistant gloves that are required for all products classified as Toxicity Category I, II, or III for acute dermal toxicity or primary skin irritation. The glove selection for liquids is based on the solvent contained in the product. Refer to Table 4 in Chapter 10, Section IV of the Label Review Manual to determine the type of glove needed based on the solvent. Review the types of chemical-resistant gloves listed in Table 3, and determine if the label lists the appropriate glove type based on the solvent in the product formulation.

Step 4. Identify product-specific respiratory protection devices (RPD) for handlers.

RPD(s) are required for all products classified as Toxicity Category I or II for acute inhalation. Review the RPD types in Table 5 in Chapter 10, Section VI of the Label Review Manual, and determine if the label lists the appropriate type based on the product description and toxicity category.

Step 5. Compare product-specific PPE with PPE required by the regulatory assessment document.

Consider the PPE required for the active ingredient by the regulatory assessment document (such as an RED document), if one has been published. A combination of the most protective PPE specified in the acute toxicity review and the regulatory assessment document must be used to determine the appropriate product labeling. For guidance on which PPE is considered more protective, consult Table 7 in Chapter 10, Section VI of the Label Review Manual.

Note that all end-use occupational use products (WPS or non-WPS) must have the minimum baseline handler PPE of long-sleeved shirt, long pants, socks, and shoes.

Resource

To determine handler PPE statement language, see Chapter 10, Section VI.A of the Label Review Manual.

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