Date: Wed, 4 Oct 2006 10:41:03 -0400
Reply-To: Mark Banister <markb2**At_Symbol_Here**ANDREW.CMU.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Mark Banister <markb2**At_Symbol_Here**ANDREW.CMU.EDU>
Subject: FW: [DCHAS-L] Hold on a minute, Dr. E.

There are two more wrinkles in this discussion that might be of interest. The first, is that this discussion started with a question about use of N95's. If you are talking a disposable N95 dust mask, then the requirements are different than if you are talking about a true respirator with N95 filtration. The second, is that the requirements are different depending on whether the item is for VOLUNTARY or MANDATORY use. For disposable dust masks, the difference is discussed in this OSHA letter of interpretation: S&p_id=22623 For respirators, I think the difference clearly outlined in the regulation. Mark R. Banister, CIH, CCHO, CHMM Assistant Director, Environmental Health and Safety Mellon Institute 313 Carnegie Mellon University 412.268.1493 -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Peter Zavon Sent: Tuesday, October 03, 2006 10:15 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] Hold on a minute, Dr. E. While OSHA standards do not apply to students specifically, the elements of a good respiratory protection program are well recognized and should be applied when respirators are used, regardless of the regulatory coverage. The list Dr. Elston gave are those elements. Their purpose is to ensure that the respirator is properly selected and fits the person using it, that the user knows how to don the respirator and keep it clean and usable as well as understanding what it is and is not suitable for, and that respirator use does not exacerbate some existing physical or medical condition. Peter Zavon, CIH Penfield, NY PZAVON**At_Symbol_Here** > -----Original Message----- > From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] > On Behalf Of Steve > Sent: Tuesday, October 03, 2006 6:49 PM > To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU > Subject: [DCHAS-L] Hold on a minute, Dr. E. > > Sadly, what Dr. Elston says about a structured respiratory > protection program would be true if 29 CFR 1910.134 applied > to students. According to > 29 CFR 1910.5, the General Industry Standards have no > applicability in the described academic situation because > students are not employees. > > I have not heard of any cases where the General Industry > Standards were applied to students. Since absence of evidence > does not prove absence; I would be interested in learning > what standards schools have been held to. I suppose that a > lawyer could argue that failure to follow OSHA standards is > evidence that reasonable and prudent precautions for > structuring a safety program were not taken...if a suit were > filed after an accident. No school would worry about an OSHA > inspection unless an employee were put at risk, and then, > only if a complaint were filed. > > Could it be that kids are in this gray area because they tend > to heal fast, or maybe because over-exposure symptoms tend to > manifest after graduation? > > JSBonnell, Mgr., Env. Svc. > Barr Laboratories, Inc. >

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