Is a water soluble bag considered a closed system?
A. Yes, for WPS purposes, a water soluble bag is considered a closed loading system and, unless prohibited by the product labeling, handlers may be permitted to wear reduced personal protective equipment (PPE) as outlined in 40 CFR part 170.240(d)(4). Once a water soluble bag is dissolved, broken, punctured, torn, or otherwise allows its contents to escape, it no longer a closed system and label specified PPE must be worn. In the case of routine mixing and loading with water soluble bags, label-specified PPE for the activity performed must be worn once the bags have lost their integrity, i.e., begin to dissolve in the tank, unless the mix tank and transfer system are closed systems. (February 24, 1994) 4.16 Enclosed cabs Q. What is the definition of an enclosed cab? What personal protective equipment is required when an enclosed cab is used? A. At 40 CFR part 170.240(d)(5), the WPS defines enclosed cabs and allows exceptions to labeling required personal protective equipment (PPE) when
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- Is a water soluble bag considered a closed system?