Very important point. Wearing a respirator causes breathing stress, so even if the use of the respirator is voluntary, you need to know that the person will not be harmed by wearing it. And the employer is required to give each voluntary wearer a copy of Appendix D of 1910.134.
The other problem you mentioned: "the work environment evaluated," is a part of the regulation I'm just not sure how to address. OSHA requires that the concentration of the hazardous substance in air be determined, usually by personal monitoring, on a typical day so the type of respirator and cartridge can be selected. We don't have any typical days. Every day on a movie location or in a scene shop is different: different chemicals, different numbers of people, different production methods. We can't monitor every production every day.
I'm also the only IH in the entire IATSE International with over 100,000 members all over the country and some working in other countries. I can only be one place at one time, so I try to train the charge artists to at least have a clue when they need to put on the respirators. And I'm available 24/7 to answer questions.
It's really sick that the producers of these big movies don't budget a little bit of the multimillion $ salaries of the directors and stars for their own IHs to help keep the rest of the crews health and safe. The money is not the problem. The major film companies have some IHs on salary in their California offices, but in my experience, they only send them out when there is a dispute or after someone is injured or dead. In my experience, they write phony reports to protect their bosses liability and to help them avoid actually doing something to correct the problem. I thought we IHs were mostly all "good guys" until I met them.
Thanks for listening. I feel a lot better now.
In a message dated 1/26/2011 8:48:46 AM Eastern Standard Time, paracelcusbombastusvon**At_Symbol_Here**JUNO.COM writes:
Voluntary use of a NIOSH approved respirator above the N95 dust mask level in an environment which contains no hazard requiring respiratory PPE will result in an OSHA citation and fine (personal experience) if the individual has not been trained, medically evaluated, the work environment evaluated, and a written policy is in place. Don't rely on the voluntary use defense. Even if N95 dust masks are allowed the employees must be trained in the use and limitations of the masks.
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