Date: Tue, 25 Jan 2011 12:37:28 -0800
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
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From: Jim Johnson <jsjsrj**At_Symbol_Here**COMCAST.NET>
Subject: Re: Do surgical masks = 'respirators'?
In-Reply-To: <9375A4B942930D458099C4FB6E0874A893DF14C780**At_Symbol_Here**>

Dr. Norwood,
You present a great question. The answer should come from the workplace haz ards assessment and the concentration of contaminants your organization desi re to have in the workplace that your employees are exposed to. I am sure th ere is more background information on this topic but what is the specific re ason has resulted in this request? With this information a more informed dec ision on what type of mask or respirator is appropriate can be made. From yo ur description of the existing workplace you have no need from an OSHA persp ective to use respiratory protection. But if you wish to truly lower the emp loyee respiratory exposure, say an ALARA approach during the operations desc ribed a respirator should be considered. If you wish to go through the motio ns of doing something about reducing airborne exposure with limited to no su ccess a surgical mask is the choice. If you decide that your exposure concer n is a hand to mouth exposure contact the surgical mask may be a good choice .
Another key point to be considered is what do the actual workers feel is ne cessary. You should also consider the impact on your existing use of respira tors in the laboratories if appropriate.
My bottom line is action without an understanding of the purpose doesn̵ 7;t accomplish much and may create more problems in the long run.
Feel free to give me a call if your have additional questions.
Jim Johnson Ph.D., CIH, QEP

As an analytical laboratory, we operate under the Laboratory Standard 1910. 1450 of the OSHA regulations.  We have excellent engineering controls, and have done monitoring for the the atmosphere contaminants that would be o f concern.  We don’t meet the OSHA threshold for any of those.
That being said, we sometimes have to grind samples in knife mills, and thi s can generate some dust (though still well below the threshold).  Per 1910.134 Appendix D (http://www< /a> < sp.show_document?p_table=STANDARDS&p_id=9784> ) we conduct and do cument training to ensure that our employees have a firm basis upon which to choose 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 pressure par ticulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium (emphasis ad ded).
In light of the above definition, I am forced to ask:  is a surgical m ask considered a ‘respirator’?  Do I now need to document a ) that there is no condition which requires use of a respirator/surgi cal mask/form of protection in the toxicology section and b) that if not, al l of the toxicologists are also trained in accordance with Appendix D to 191 0.134?
Dr. Bradley K. Norwood
Laboratory Director
Arista Laboratories
1941 Reymet Road
Richmond, VA  23237
(804) 271-5572 ext. 307
(804) 641-4641 (cell)
brad.norwood **At_Symbol_Here** <mailto:brad.norwood**At_Symbol_Here**>
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