You have probably already addressed each of these issues, but just in case I am providing the list of what I would accomplish.
1. Verify that all exposures for each process have been quantified.
2. Verify that all IH laboratory analysis have been accomplished by an accredited industrial hygiene analytical laboratory (easy).
3. Perform/document that IH sample results are above/below the 95% confidence interval to confirm your analysis.
5. Provide each affected employee the basis for removal from the respiratory protection program, you can summarize results, but have the supporting documentation readily available, remembering that:
a. You are required to maintain the medical exposure records of all employees.
b. The requirement to eliminate the respiratory protection requirements must be justified.
c. Employees must have access to their medical records.
d. I would provide a training class for all of the individuals affected, summarizing the results, interpretations and impact.
e. Any employee who does not understand your training session, or feels inhibited from freely asking questions and receiving answers is still free to call OSHA and file a complaint, to ensure their health/safety is being adequately maintained. Be thorough, take your time and ensure they understand and comprehend what you are saying!
f. This is not the opportunity to limit documentation to a simple sign-up roster. You need to make sure they, and you have properly documented that the opportunity to ask questions was offered (even blindly), to ensure that all have been identified, answered adequately and understood. Have you ever heard a response from a former Army person of "HUA"? Ever asked what that meant? It means "Heard, Understood and Acknowledged" HUA doesn't mean accepted and blindly followed. An illegal order will not be followed, even if HUA, the Uniform Code of Military Justice is followed above all. FYI, I am NOT former Army! Be patient, take your time! People learn at different rates. You'll be covering a lot of material that will be complicated for some people to understand and you'll probably be delivering at a pretty fast pace.
g. Provide a way for those effected personnel to ask (even blindly, if they don't want to identify themselves).
h. Make sure all questions are asked/answered to everyone's satisfaction. Have someone taking notes of questions asked and answered. You will get one shot at this.
i. If you provided recipe cards (or equivalent) for questions, collect them blindly before the session ends, answer as above and scan all of the responses with the attendance rosters and class notes.
j. I've been in similar situations in the past and have run into some pretty skeptical folks. They made there thinking clear, essentially surmounting to "this is just another opportunity for my company to stick it to me", which was totally incorrect, especially considering the capital required to implement the hierarchy of controls, engineering controls are very effective, but expensive! Essentially they needed additional education/clarification on why we are doing what we are (hierarchy of controls) and after further explanation, including showing references and citations. I proved to them that the changes made were effective, including reviewing the ACGIH Industrial Ventilation Manual, explaining flow rates, demonstrated the calculations, etc. compared to the lowest OELs to make them understand that we have indeed eliminated their exposures, quantified by valid laboratory analysis methods, utilized certified laboratories and WHY we arrived at the conclusions that we have and eliminated their respiratory protection requirements.
k. By taking this step you are "declaring your employees safe" and documenting so. Make sure the variables are identified and quantified. If the quantities or use rates chance, a reassessment is required, which must also be included in the training.
We have allowed employees to wear additional PPE if they prefer to, even when it is not a requirement based upon industrial hygiene sample results or required to directly support controlling exposures.
I believe it's called voluntary use in the respiratory protection standard. It's getting late and I'm hungry, so I'll let you look up the definition of elective use in the Respiratory Protection Standard.
I would like to offer my congratulations to you Barry! It takes a lot of effort to reduce exposures to below action levels!
Please let me know if you have any questions.
Well done sir!
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.
edu] On Behalf Of Ferm, Barret
Sent: Friday, August 26, 2016 6:00 PM
Subject: [DCHAS-L] Respirator program close-out
Hello folks. I would like to rescind our respirator program due to lack of need (no actionable levels for two years running). Are there any specific things that need to be done besides collecting the respirators that were distributed? Thank you kindly.
Chemical Hygiene Officer
Chemistry Laboratory Coordinator
EHS..."Everyone Home Safely"
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