DCHAS-L Discussion List Archive
Date: Tue, 25 Jan 2011 12:25:42 -0500
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From: Don Abramowitz <dabramow**At_Symbol_Here**BRYNMAWR.EDU>
Subject: Re: Do surgical masks = 'respirators'?
In-Reply-To: <AANLkTimgRnEjFKLE=gAH61V_vmwUk4kQJx_J7PwbQFTo**At_Symbol_Here**mail.gmail.com>
<
div style='font-family: Times New Roman; font-size: 12pt; color: #000000'
>The regulatory/respirator issues around an individual piece of equipment o
r a process are generally based on the level of exposure of airborne contam
inants experienced by the operator. The short answer is, "it depends.
" Depends on the material being processed, the particle size, the ven
tilation in the area, the operating time, work habits, and other vari
ables. The traditional industrial hygiene approach is to evaluate the
exposure by conducting air sampling in the operator's breathing zone and c
omparing the results to PELs or TLVs. Regulations are generally drive
n by whether or not a given task exceeds a permissible exposure limit, as o
pposed to a rule that says if you operate X machine with material Y, you sh
all wear respirator Z.
In some settings, depending on the resources
available, it sometimes makes sense to just say, gee, that's pretty dusty.&
nbsp; Maybe we should put that mill in a fume hood, or otherwise proceed di
rectly to control measures and skip the evaluation step. It's general
ly better to control the source than to fiddle with a respiratory protectio
n program, when feasible.
Don
Donald Abramowitz, CIH
Env
ironmental Health & Safety Officer
Bryn Mawr College
Bryn Mawr, PA<
/span>
Hello:
I have an associated question to Bradley's that shows my lack of knowl
edge: what is/are the respiratory regulatory issues surrounding the operati
on of a grinder/mill, specifically one that can generate over 1 kilogram of
material?
Thanks in advance, Jim
On Tue, Jan 25, 2011 at 8:53 AM, Norwood, Brad <
span dir="ltr"><
Brad.Norwood**At_Symbol_Here**aristalabs.com> wrote:
All,
As an analytical laboratory, we operate under the Laboratory Standard
1910.1450 of the OSHA regulations. We have excellent engineering cont
rols, and have done monitoring for the the atmosphere contaminants that wou
ld be of concern. We don=E2=80=99t meet the OSHA threshold for any of
those.
That being said, we sometimes have to grind samples in knife mills, an
d this can generate some dust (though still well below the threshold). 
; Per 1910.134 Appendix D (
http://www.osha.gov/pls/oshaweb/owadisp.show_docume
nt?p_table=STANDARDS&p_id=9784) we conduct and docum
ent training to ensure that our employees have a firm basis upon which to c
hoose a dust mask appropriate to their task and comfort.
Now, my toxicology group wants to order surgical masks, and since 1910
.134 defines a "respirator=" as:
Filtering facepiece (dust mask) means a negative pressur
e particulate respirator with a filter as an integral part of the facepiece
or with the entire facepiece composed of the filtering medium (emph
asis added).
In light of the above definition, I am forced to ask: is a surgi
cal mask considered a =E2=80=98respirator=E2=80=99? Do I now need to
document a) that there is no condition which requires use of a respi
rator/surgical mask/form of protection in the toxicology section and b) tha
t if not, all of the toxicologists are also trained in accordance with Appe
ndix D to 1910.134?
<sigh>
Dr. Bradley K. Norwood
Laboratory Director
Arista Laboratories
1941 Reymet Road
Richmond, VA 23237
(804) 271-5572 ext. 307
(804) 641-4641 (cell)
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