From: "Norwood, Brad"
Date: February 24, 2009 3:48:11 PM EST (CA) Subject: RE: dust masks Suzanne, We had a Virginia Department of Labor and Industry site visit (at our request). At the time, we had two workers who were, on their own, wearing dust masks. What the VaDoLI inspector told me was that if we continued to allow the practice, we had to either: 1) Institute a full respiratory program (particularly required if we provided the dust masks) Or 2) Document that they had been trained/informed per Appendix D to Section 1910.134 (this notwithstanding the fact that the actual OSHA standard that applies to laboratories is the 1910.1450). HTH, Brad Bradley K. Norwood, PhD Laboratory Director Arista Laboratories 1941 Reymet Road Richmond, VA 23237 (804) 271-5572 ext. 307 (804) 641-4641 (cell) brad.norwood**At_Symbol_Here**aristalabs.com === From: "Walter Garrow" Date: February 24, 2009 4:02:35 PM EST (CA) Subject: RE: [DCHAS-L] 3 RE: [DCHAS-L] dust masks Make sure that the mask has the NIOSH approval. There is a difference between the medical masks and the respirators. Basically, there is an OHSA provision of exemption. However, it only applies if the mask is warn for convenience and not for the purpose of OSHA compliance to reduce exposure to reduce air concentrations over OSHA exposure limitation know as "PEL's". If that is the case, OSHA still wants the employee to provide the employee with a copy of Appendix D of the OSHA Respirator program 29CFR1910.134. That explains the limitations. == From: Cat Conley Date: February 24, 2009 4:09:51 PM EST (CA) Subject: RE: [DCHAS-L] 3 RE: [DCHAS-L] dust masks Hi Suzanne, Here's what OSHA has to say: (Emphasis mine) 29 CFR 1910.134(c)(2)(ii): In addition, the employer must establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. Exception: Employers are not required to include in a written respiratory protection program those employees whose only use of respirators involves the voluntary use of filtering facepieces (dust masks). 29 CFR 1910.134(b): Filtering facepiece (dust mask) means a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium. So your answer would depend on whether the use of the dust mask was voluntary or required by the company. As long as the filtering facepiece is worn voluntarily and there atmosphere isn't hazardous, it can be worn without having to go through the full RPP procedure. If the company requires that a respirator be worn (filtering facepiece or otherwise) then the "employer must establish and implement..." as stated in 1910.134(c)(2)(ii) above, because that use wouldn't be voluntary. If respirators are worn voluntarily, the company should provide them with the information in 29 CFR 1910.134 Appendix D (Voluntary Use Form). This OSHA letter of interpretation is very helpful in regards to voluntary/required and dust mask/tightfitting facepiece: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETA TIONS&p_id=25342 Sincerely, Cat Cat Conley Chemical Hygiene and Safety Officer Department of Environmental Health and Safety Roger Williams University cconley**At_Symbol_Here**rwu.edu === From: "John Sacco" Date: February 24, 2009 4:11:19 PM EST (CA) Subject: RE: [DCHAS-L] 3 RE: [DCHAS-L] dust masks The short answers are: If they are used voluntarily then no. If their use is mandatory then yes. You have to consider why the respirators are used and what you are protecting against. John J. Sacco, P.E., CIH Earthshine Consulting, Inc. 916.435.9800 (Voice) 916.769.1434 (Cell) 916.435.0460 (Fax) === From: "LaCroix, Steve (DOH)" Date: February 24, 2009 7:30:14 PM EST (CA) Subject: RE: [DCHAS-L] dust masks If dust masks only are used and not required, no written program is required. Appendix D of the standard must be provided to these users Many firms have specific guidance on the use of worker provided =93dust masks". Steve LaCroix Quality Assurance and Safety Officer Department of Health Epidemiology, Health Statistics, and Public Health Laboratories 1610 NE 150th St. Shoreline, WA 98155 Phone: (206) 418-5437 Cell: 206-391-9025 FAX: (206) 418-5485 email: steve.lacroix**At_Symbol_Here**doh.wa.gov ergonomic information: http://dohweb/Risk/Ergonomicsnew.htm "The Department of Health works to protect and improve the health of people in Washington State" === From: "Chrismarlowe" Date: February 24, 2009 7:49:52 PM EST (CA) Subject: RE: [DCHAS-L] 3 RE: [DCHAS-L] dust masks Reply-To: Rachel: WRT: For situations where you can prove that the respirator is not needed (You will need air monitoring data for this.), I find myself in incomplete agreement with the sentence in parenthesis. You have to be dang sure that the respirators are NOT needed before you allow voluntary use of respirators, but I can be convinced by information other from air monitoring results. Stay healthy, Chris Marlowe 42 Highlander Dr Scotch Plains, NJ 07076 908 / 754 - 5160 (home) 732 / 539 - 8128 (cell) Krismarlowe**At_Symbol_Here**Verizon.net
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