From: Kristi Ohr <kohr**At_Symbol_Here**UMASS.EDU>
Subject: Re: [DCHAS-L] Face Shields & Legal Barriers to Enforcing Masks...
Date: Thu, 21 May 2020 11:57:54 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: BY5PR14MB33040770F88E926F19DF575DC7B70**At_Symbol_Here**

I agree, Margaret, that is the stance we have taken as well.


All the best,




From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Margaret Rakas
Sent: Thursday, May 21, 2020 7:24 AM
Subject: Re: [DCHAS-L] Face Shields & Legal Barriers to Enforcing Masks...


So I couldn't agree more about face masks giving the best protection from ones' exhaled breath BUT--what do you do about the person who says "I cannot wear a mask for medical reasons" yet will be in close contact with people?  At least in Massachusetts (and many other states), they do not need to disclose a reason and cannot be forced to wear one (at least through enforcement of state law; whether the employer can require it is a legal pickle beyond my capacity).


I was in a situation (wearing a mask) with someone who was not and frankly, would have much preferred they wore a face shield than nothing.   Keep in mind that some people--certainly the experience I had with my colleague --genuinely seem to have trouble breathing with a mask on.   (My colleague put on a surgical mask on when I put a face shield on over MY mask).  I could tell from his breathing that he was indeed having to breathe more deeply and more often when he put the mask on.  Now, for this individual I believe it was a psychological response--he had the mask on later when he was relaying the latest COVID-19 conspiracy theory to me, was talking animatedly and had no problem doing so.  But I believe we have to acknowledge that there will be people who, whether they have severe COPD or * just * psychological anxiety, will legally opt-out of wearing a mask.  They are not necessarily the angry protesters that might be in the media, and they too are afraid.


By all means, make it clear that a mask is the best and preferred option. If your institution/employer can legally require them to wear a mask, terrific.  If that isn't possible, either legally or because of 'the culture', then I see a disposable face shield as a way to at least reduce the spread of aerosols.  


Thoughts?  Is there another way to handle this?


Many thanks 



On Thu, May 21, 2020 at 6:19 AM Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**> wrote:

John,  The issue here is protection of non-essential workers like my film and TV people.  But shields clearly can't work and our workers are not chopped liver.  They get better precautions than some device that only makes them think they have some level of protection. 


 Others are saying it protects the eyes so it should be used, but there are better ways to do that with goggles or wearing a mask under the shield.   To protect the eyes while leaving the lungs unprotected makes no sense.


This just needs to go away as a solution.  




-----Original Message-----
From: John Callen <jbcallen**At_Symbol_Here**>
To: Monona Rossol <actsnyc**At_Symbol_Here**>
Cc: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Wed, May 20, 2020 12:39 pm
Subject: Face Shields



You did not miss any memo!


As far as I can tell, OSHA and the US CDC/NIOSH have not changed their position, guidance and enforcement on the use of eye protection (safety glasses, goggles, face shields and full face respirators) for infection control in health care settings.


A FDA Registered Surgical Mask and FDA Registered/NIOSH Approved N95 Particulate Respirator/Surgical Mask are cleared as Class II Medical Devices.  


Face Shields intended for a medical purpose are regulated by the FDA under 21 CFR 878.4040 - Surgical Apparel and are just Class I (General Controls) Devices and ARE NOT Class II Devices.  See Footnote #1 in the attached letter.  



Please note that this letter can be summarized in Footnote #5 and comes into parity with the DHHS PREP Act and EUA.


For PPE manufactured USA/globally but also sold in the USA, one should always contact the specific manufacturers and their Technical Service Departments for their guidance in the selection, use, misuse, maintenance, etc., per OSHA Regulations.


I hope that this information helps.


Be Safe & Well!


John B. Callen, Ph.D.

3M Personal Safety Division - Retired

DCHAS Founding Member

(312) 632-0195 


On May 20, 2020, at 10:23 AM, Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> wrote:


OK, class, I wrote this for my IH pals on another forum but it is not posted yet.  You get both barrels on the face shield thingie.


The workers I protect are in the arts and entertainment fields.  These folks are the ultimate tough audience.  So my training PowerPoints and the articles and books I write must be unambiguous, graphic, and occasionally funny.  I use all of my 80 years of entertainment experience, starting with my first professional work in Vaudeville at age three.


The inclusion of the recommendation to use face shields instead of masks in the AIHA back-to-work plans has made in necessary for me to use this experience to address this topic.  I couldn't find a study on the shield in the journals I monitor, so I Googled "masks v face shields" and read the articles and interviews of those recommending the shields. 


Aha! My first point will be that the proponents of the shields are all medical doctors and professors.  I've been on the Board of Advisors of Mt. Sinai's Occupational Medical Clinic for decades so I know that hospitals have industrial hygienists on staff.  Doctors are fit tested and follow the recommendations of industrial hygienists, not the other way around.  If the doctors are qualified to make industrial hygiene recommendations, then perhaps I could ask members of AIHA to remove my appendix.  I'm sure, by now, there are some who would.


The article is in JAMA, not in an IH publication.  The article is in the "Viewpoint" section and not a study - it is an opinion. The  JAMA article has a figure which is bullet points comparing the face mask and face shield.  The shield wins on every point except the very first one - the one that counts.  This one says the shields are "open on the sides--providing some possibility for aerosols and particles to float in." 


SOME POSSIBILITY?  Particles may FLOAT IN?  Instead, every time the person in the shield inhales they suck in the air and its particles from the sides and from under the shield.  Every time they exhale their own breath and particles go out every which-a-way.  That shield is "breathing."  (Here I intend to add an artist's graphic.)


In my PPE PowerPoint I have flash pictures of the large and small particles created when people sneeze both out in the open and when wearing a mask.  And yes, some small particles do come through the surgical mask.  But I can hardly WAIT to see a picture (or another graphic) of a sneeze behind a face shield!  A close up of the person's face and shield right after the sneeze would be equally of interest.


And the final reason the doctors say we should use shields is that the surgical masks and cloth masks don't work at all.  Well, there is some data showing they sorta do.  Off-line, a kind CIH sent me 5 supportive studies to add to my collection.  One was a prepublication copy of an article called Face Masks Against COVID-19: An Evidence Review (doi:10.20944/preprints20204.0203.v1).  The 19 authors from all over the world synthesized data from 46 studies and they concluded that the masks help and should be used. We can quibble about the data, but at least there IS data.


On the shield side, there is not one study, not one sneeze picture, bobkes.  Common sense, science, and my industrial hygiene training dictate: no data, no go.



-----Original Message-----
From: Michael Schaffer <MichaelS**At_Symbol_Here**PSYCHEMEDICS.COM>
Sent: Wed, May 20, 2020 5:43 am
Subject: Re: [DCHAS-L] DRAFT - Please review and send comments.

We have adopted the policy of utilization of both face shields along with cloth face masks, social distancing and gloves worn in the laboratory as well as rotating staff two weeks on and two weeks off.

We have installed purell dispensers throughout the building and are swapping all manual operations to automated  ones as much as possible.

We take temperatures of anyone entering the building. 

We show mandatory videos on safety and health as it now relates to Covid-19 to all employees.

We are always looking for suggestions to make the lab a safer place for our staff.

Thank you




Michael I. Schaffer, Ph.D., F.A.B.F.T., NRCC-TC

VP Laboratory Operations

Psychemedics Corporation

5832 Uplander Way

Culver City, CA 90230

310-216-7776 (phone)

310-216-6662 (Fax)

(800) 522-7424 (toll free) Extension 140



THIS ELECTRONIC MAIL TRANSMISSION AND THE DOCUMENTS ACCOMPANYING IT CONTAIN INFORMATION BEING SENT BY  PSYCHEMEDICS CORPORATION AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND/OR EXEMPT FROM DISCLOSURE.  The information is intended only for the use of the person(s) named above.  If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this information is strictly prohibited.  If you have received this transmission in error, please immediately notify us by telephone at (800) 522-7424 and delete/destroy all copies.  Your receipt of this message is not intended to waive confidentiality or any privilege.  The above name and title are not intended to constitute any form of signature.

On May 19, 2020, at 6:12 PM, Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**> wrote:


This Message Originated Outside the Company

Yes, John, I have a question that is slightly off this topic, but as a former respirator expert, you might be best person to answer this question.


The AIHA back-to-work plans and two other union plans I have evaluated suggest using a face shield alone instead of any kind of mask. Now I've see a lot of mask studies, some even on DIY masks.  While the protection they offer is not perfect, they at least do SOMETHING.  But a piece of plastic that the air can go freely around on three sides which is hung a couple inches from the face, clearly stops almost nothing -- nothing going out, and nothing coming in.  What memo did I miss here?


I even have a fact sheet from Canada warning healthcare workers to refuse to comply when employers tell them that the face shield alone is enough.  So this monster has legs.


I've suggested workers tell employers they will comply with this face shield plan the minute the employer shows them one peer reviewed study demonstrating the efficacy of this procedure.  And since there doesn't appear to be one anywhere, they are safe so far.  


Monona Rossol


-----Original Message-----
From: John Callen <jbcallen**At_Symbol_Here**GMAIL.COM>
Sent: Tue, May 19, 2020 7:40 pm
Subject: Re: [DCHAS-L] DRAFT - Please review and send comments.

Thanks Ralph for your comments below.


Again, I want to emphasize from my previous suggestions that PREPARE/CHECK FACILITIES should include how to control public and semi-private bathrooms which are "high touch" areas.  I mentioned that faucets, soap and towel dispensers, toilets and drinking fountains should be motion activated and NO hand dryers, please!   The one other item which also must be addressed is access in/out of the bathroom and toilet stalls themselves.  To avoid touching door handles, knobs or plates, access should be automatic as for physically challenged individuals or remove the door completely and place a partition in front of it as you find in many of the airport concourses.  As for the toilet stalls, maybe we should go back to open stalls without doors; however, I do not know if that would be a Federal, State or Local Department of Health violation or just a public outcry regarding privacy.  Regardless, many institutions will have to increase their custodial staff to service and maintain their public bathrooms on a more frequent basis or have full time attendants.


In much as bathrooms are an area of "high touch" so are vending machines for tools, PPE and other supplies and those for beverages and/or snacks.  What disinfection/sanitation procedures must be established for them before and after each use?


For Barrier/Location Marking, while some institutions do have the luxury of having a "Sign and Graphics Department," many do not.  As a FYI, although there are many local or regional suppliers, there are at least two national manufacturers who could help with your needs and you may know of them already: ARC (San Ramon, CA) and The Brady Company (Milwaukee, WI).  You may want to check their websites so you don't have to proverbially "reinvent the wheel."


If you have any questions or comments, please let me know.  Thanks!


Be Safe and Well!


John B. Callen, Ph.D.

3M Personal Safety Division - Retired

DCHAS Founding Member

(312) 632-0195



On May 19, 2020, at 5:15 PM, Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU> wrote:


Maybe thinking practically opens up people to too much liability?

You make good points about the challenges that reopening with very little fundamental data available about the epidemic and the subsequent cultural shifts that will be required available.

However, my sense is that liability is not the concern; the most recent list of operating scenarios for how we might open here had 11 possibilities. These are too many to think about practically at operational safety level. This list is being winnowed down as more data becomes available (financial and student count data as much as scientific data), but I suspect that it will be another month before there's enough clarity to get concrete planning underway.

Thanks for raising these considerations that we are all working with.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859


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Margaret A. Rakas, Ph.D.
Lab Safety & Compliance Director
Clark Science Center
413-585-3877 (p)

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