DCHAS-L Archives, Aug 11 2020 - Re: [DCHAS-L] Seeking Advice on Respirator Fitness Qualification

I feel much better now, John. Thanks. Monona

-----Original Message-----
From: John Callen <jbcallen**At_Symbol_Here**GMAIL.COM>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Tue, Aug 11, 2020 10:56 am
Subject: Re: [DCHAS-L] Seeking Advice on Respirator Fitness Qualification

ALL,

Piggy-backing on Peter, please read the OSHA Standard:

1910.134(e)

Medical evaluation. Using a respirator may place a physiological burden on employees that varies with the type of respirator worn, the job and workplace conditions in which the respirator is used, and the medical status of the employee. Accordingly, this paragraph specifies the minimum requirements for medical evaluation that employers must implement to determine the employee's ability to use a respirator.

1910.134(e)(1)

General. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.

1910.134(e)(2)

Medical evaluation procedures.

1910.134(e)(2)(i)

The employer shall identify a physician or other licensed health care professional (PLHCP) to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire.

1910.134(e)(2)(ii)

The medical evaluation shall obtain the information requested by the questionnaire in Sections 1 and 2, Part A of Appendix C of this section.

1910.134(e)(3)

Follow-up medical examination.

1910.134(e)(3)(i)

The employer shall ensure that a follow-up medical examination is provided for an employee who gives a positive response to any question among questions 1 through 8 in Section 2, Part A of Appendix C or whose initial medical examination demonstrates the need for a follow-up medical examination.

1910.134(e)(3)(ii)

The follow-up medical examination shall include any medical tests, consultations, or diagnostic procedures that the PLHCP deems necessary to make a final determination.

In the revisions of the OSHA Respiratory Protection Standard 29 CFR 1910.134 and going back through the history of certain OSHA substance specific standards such as Benzene in 1978, OSHA has/had to make an economic impact statement to insure that whatever it promulgates does not put employers out of business. In layperson terms, does the law justify the expense. In the case under discussion here, OSHA agreed in the hearings that instead of EVERYONE going through a MEDICAL EXAMINATION which might be expensive and cost-prohibitive, EVERYONE would go through a MEDICAL EVALUATION using a questionnaire as a screening tool. Based upon the answers, the PLHCP would then determine which employees would require a follow-up MEDICAL EXAMINATION, per 1910.134(e)(3)(ii) above.

Here is where it gets tricky. If employers have the money, time and other resources to have the PLHCP conduct MEDICAL EXAMINATIONS and certain medical tests or diagnostic procedures such as spirometry for ALL employees instead of a select few, that would be acceptable. The rule here is that you cannot be any less restrictive than what the standard requires but you can definitely be more restrictive.

So, before employees can go into the workplace wearing a tight-fitting NIOSH Certified Respirator, they must be able to clear the hurdles of Medical Clearance, Training and Fit Testing.

Since medical clearance is the first hurdle and per the OSHA Standard again,

1910.134(e)(6)

Medical determination.. In determining the employee's ability to use a respirator, the employer shall:

1910.134(e)(6)(i)

Obtain a written recommendation regarding the employee's ability to use the respirator from the PLHCP. The recommendation shall provide only the following information:

1910.134(e)(6)(i)(A)

Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator;

1910.134(e)(6)(i)(B)

The need, if any, for follow-up medical evaluations; and

1910.134(e)(6)(i)(C)

A statement that the PLHCP has provided the employee with a copy of the PLHCP's written recommendation.

that written recommendation allows the employee to proceed with training and then fit testing. And per Monona as she states below (certification equals written recommendation) without it, the fit tester must decline to preform a fit test on that individual.

During the time of the revisions of the asbestos and lead substance specific health standards and TB back in the late 1980's and early 1990's, when I was training and fit testing industrial, construction and healthcare workers and providers, if I didn't see medical clearance forms, I wouldn=E2=80™t train or fit test those workers without them.

Q.E.D.

Now, for the select few, if the PLHCP does require spirometry, what procedures does the PLHCP or employers have in place to throughly clean, disinfect and sterile the equipment so that it can be used from one person to the next. This is analogous to what the Respiratory Care Departments in Hospitals would have to do for the various instrumentation they use for endoscopy, bronchoscopy and induced sputum induction for patients.

Be Safe, Secure, Vigilant and Well!

All MY Best,

John B.Callen, Ph.D. / ACS-DCHAS Founding Member

On Aug 11, 2020, at 8:40 AM, pzavon**At_Symbol_Here**rochester.rr.com <pzavon**At_Symbol_Here**ROCHESTER.RR.COM> wrote:

That is generally true - the respirator wearer must be medically approved to wear before being fit tested. But the approval can be through questionnaire and, if necessary, follow-up discussion with the medical professional. That generally covers all but a small fraction of those who have a need to use a respirator in the course of their employment. Going this route rarely results in a need for spirometry.

Peter Zavon, CIH
Penfield, NY

PZAVON**At_Symbol_Here**Rochester.rr.com

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Monona Rossol
Sent: Monday, August 10, 2020 6:25 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Seeking Advice on Respirator Fitness Qualification

Well that's depressing. I was informed that a fit tester is not allowed to test someone without certification. So until I see otherwise in some letter of interpretation or hear it from someone who is still in what's left of OSHA, I'll demur. Monona

-----Original Message-----
From: Michael Buczynski <mabuczynski**At_Symbol_Here**HOTMAIL.COM>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Mon, Aug 10, 2020 5:37 pm
Subject: Re: [DCHAS-L] Seeking Advice on Respirator Fitness Qualification

Joe

I am a former OSHA Industrial Hygienist CO. I will tell you to have them fit tested. The spirometer can be validated later in view of the currently. Crisis. The most important thing for now is that they are properly fit tested (passed)

Best to you

Mike Buczynski

CEO

PSCR Services Llc

On Aug 10, 2020, at 5:00 PM, Joseph Peters <0000133eb6fa8f3a-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:

=EF=BB=BF

All of our employees who are required to use respirators have had physicals (including spirometry) to ensure that they are physically able to use an Air Purifying Respirator (APR) and SCBA. Once they pass the physical, they are fit tested and trained on the proper use and care of the respiratory equipment.

We scheduled appoints with our occupational safety and health provider and were told that they are not allowed to conduct spirometry evaluations at this time due to COVID restrictions.

Have any members of the group experienced this and if so, how were they able to certify employees for respirator use in the absence of spirometry?

BTW, we are located in Massachusetts.

Joe

Joseph C. Peters, PE

Senior Director - Process Technology | Technip Energies

P +1 781 340 2901 | M +1 617 620 7120

Joseph.peters**At_Symbol_Here**technipfmc.com

TechnipFMC

56 Woodrock Road | E. Weymouth, MA | 02189

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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Ken Kretchman
Sent: Monday, August 10, 2020 3:12 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [WARNING - NOT REAL SENDER] Re: [DCHAS-L] Wearing FR masks when working with Pyrophorics during COVID pandemic?

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Hi Margaret

We did some testing here at the university some years ago with lab coats and t-butyl lithium following the referenced tragedy.

The most striking comparison was a 65-35 polyester /cotton blend which gave a very energetic flame spread vs

100% cotton, Nomex, or other treated fabrics.

I would certainly want to stay away from synthetic fabric masks for lab use.

Ken

Ken Kretchman, CIH, CSP   Director, Environmental Health and Safety

NC State University / Box 8007 / 2620 Wolf Village Way / Raleigh North Carolina 27695-8007

Email: Ken_Kretchman**At_Symbol_Here**ncsu.edu / Phone: (919).515.6860 / Fax: (919).515.6307

On Mon, Aug 10, 2020 at 2:18 PM James Keating <james.k.keating**At_Symbol_Here**gmail.com> wrote:

If you are working with phosphoric you need serious fire resistant PPE. Also limited amount of flammable material in hood area as well as in the cabinet under the hood.

Remember the Sherry Sanji tragedy.

Jim Keating

On Mon, Aug 10, 2020, 1:55 PM Margaret Rakas <mrakas**At_Symbol_Here**smith.edu> wrote:

For those organic synthesis research labs, is your EHS department recommending fire-resistant face masks? Or 100% cotton?

Many thanks

Margaret

--

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

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