May 31, 2011 – Which One – MSDS or Label?
QUESTION:
I have been reviewing the Masterline Bifenthrin label and MSDS, but I am confused. The MSDS states that work clothing is to be laundered separate from nonwork clothing. The label, though, says only to wash CONTAMINATED clothing before reuse. I know the MSDS is written around the concentrated formula, Bifenthrin 7.9. Does the MSDS apply because of the brief mixing period? The label said a short sleeve shirt is fine for diluted formula though it wants long sleeves for mixing. I can imagine on some days I would really not want to wear long sleeves while spraying, though technically since a long sleeve shirt has been used to mix wouldn't that make it eligible for laundering according the MSDS? It seems rather silly and wasteful more than likely a safety precaution grounded in much practical preventative logic.
ANSWER:
I guess I'll start by saying that I did not find the Label statement allowing short-sleeve shirts to be worn when using the diluted material, although that's a lot of words on the Label and I may have overlooked it. But, in the initial Precautionary Statements it says that all pesticide handlers (including applicators) MUST wear long-sleeved shirt, pants, etc., and in the next line under "after the product is diluted" the statement is only that the applicator must wear "shirt, pants, socks, shoes, gloves", without the words "short sleeved". So, you may have misread this part, but even so long-sleeved shirts will be considered mandatory in pretty much every state. I understand that on hot summer days it would be nice to have a cool breeze on the arms, but I really doubt that any regulatory agency is going to allow this much more skin to be exposed. Let's just go with the idea that if you are in professional pest management you will be obligated to wear long sleeves and long pants for ANY pesticide application except wear a product label specifically prohibits it. This may be the case with some liquid fumigants, but I haven't examined those labels for this response. As far as laundering, I refer to the opinion in California, and that is that ANY clothing worn while applying pesticides should be considered "potentially contaminated", and it should be washed before wearing it a second day. The actual regulation states that if you use any Category 1 or 2 pesticides (Signal Word Danger or Warning) you MUST launder the clothing before wearing it a second day, but for Cat. 3 or 4 (Caution) you "should" launder it daily. I think in the interest of personal hygiene daily laundering is probably a good idea anyhow. Again, what you wear as outer clothing while applying any pesticide should be presumed to have gotten some pesticide on it (potentially contaminated), particularly if you applied a liquid spray. The general recommendation is that this contaminated clothing should never be laundered in the same batch as the family clothing. You don't want to run any risk whatsoever of transferring pesticides from your clothes onto your baby's pajamas, to use an example. This may be erring on the side of caution, but this is how regulatory folks prefer to be, and maybe that's not such a bad idea. This discrepancy in the specific wording on the MSDS versus the Label can be confusing. In general the MSDS recommendations should be followed when dealing with the concentrate, particularly spills and other hazardous situations. The Label should be followed when using the material in the normal manner for application. You may find other contradictory statements, such as the kind of eye protection you have to wear, and the Label recommendation is the one to follow for normal mixing, loading, diluting, and application. These are really good questions to go over with your local regulatory inspectors, because they are the ones who will cite you if you are not in compliance with the regulations in YOUR state or county. Way back in 1988 California completed revising the "Worker Safety Regulations", and this really did benefit our industry by providing much more specific requirements regarding these kinds of issues. It is really tough to enforce vague laws, so by making them more clear for us the regulators did us a favor. This includes specific guidelines on TRAINING - what kind, when, by whom, and how documented, and this is a good idea too.
View past Ask Mr. Pest Control questions.
I have been reviewing the Masterline Bifenthrin label and MSDS, but I am confused. The MSDS states that work clothing is to be laundered separate from nonwork clothing. The label, though, says only to wash CONTAMINATED clothing before reuse. I know the MSDS is written around the concentrated formula, Bifenthrin 7.9. Does the MSDS apply because of the brief mixing period? The label said a short sleeve shirt is fine for diluted formula though it wants long sleeves for mixing. I can imagine on some days I would really not want to wear long sleeves while spraying, though technically since a long sleeve shirt has been used to mix wouldn't that make it eligible for laundering according the MSDS? It seems rather silly and wasteful more than likely a safety precaution grounded in much practical preventative logic.
ANSWER:
I guess I'll start by saying that I did not find the Label statement allowing short-sleeve shirts to be worn when using the diluted material, although that's a lot of words on the Label and I may have overlooked it. But, in the initial Precautionary Statements it says that all pesticide handlers (including applicators) MUST wear long-sleeved shirt, pants, etc., and in the next line under "after the product is diluted" the statement is only that the applicator must wear "shirt, pants, socks, shoes, gloves", without the words "short sleeved". So, you may have misread this part, but even so long-sleeved shirts will be considered mandatory in pretty much every state. I understand that on hot summer days it would be nice to have a cool breeze on the arms, but I really doubt that any regulatory agency is going to allow this much more skin to be exposed. Let's just go with the idea that if you are in professional pest management you will be obligated to wear long sleeves and long pants for ANY pesticide application except wear a product label specifically prohibits it. This may be the case with some liquid fumigants, but I haven't examined those labels for this response. As far as laundering, I refer to the opinion in California, and that is that ANY clothing worn while applying pesticides should be considered "potentially contaminated", and it should be washed before wearing it a second day. The actual regulation states that if you use any Category 1 or 2 pesticides (Signal Word Danger or Warning) you MUST launder the clothing before wearing it a second day, but for Cat. 3 or 4 (Caution) you "should" launder it daily. I think in the interest of personal hygiene daily laundering is probably a good idea anyhow. Again, what you wear as outer clothing while applying any pesticide should be presumed to have gotten some pesticide on it (potentially contaminated), particularly if you applied a liquid spray. The general recommendation is that this contaminated clothing should never be laundered in the same batch as the family clothing. You don't want to run any risk whatsoever of transferring pesticides from your clothes onto your baby's pajamas, to use an example. This may be erring on the side of caution, but this is how regulatory folks prefer to be, and maybe that's not such a bad idea. This discrepancy in the specific wording on the MSDS versus the Label can be confusing. In general the MSDS recommendations should be followed when dealing with the concentrate, particularly spills and other hazardous situations. The Label should be followed when using the material in the normal manner for application. You may find other contradictory statements, such as the kind of eye protection you have to wear, and the Label recommendation is the one to follow for normal mixing, loading, diluting, and application. These are really good questions to go over with your local regulatory inspectors, because they are the ones who will cite you if you are not in compliance with the regulations in YOUR state or county. Way back in 1988 California completed revising the "Worker Safety Regulations", and this really did benefit our industry by providing much more specific requirements regarding these kinds of issues. It is really tough to enforce vague laws, so by making them more clear for us the regulators did us a favor. This includes specific guidelines on TRAINING - what kind, when, by whom, and how documented, and this is a good idea too.
View past Ask Mr. Pest Control questions.
