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Lots more research is necessary, here. Aerosols appear to be an important means of COVID-19 transmission, however the evidence still points to large droplet spread as being the predominant means of transmission. (Fomite transmission contributes also, but in minor way.) Thus, in public areas, the six foot distancing rule is an every effective for reducing transmission and should be one of our key messages, along with mask-wearing, hand washing and not touching one's face.
Regarding aerosols and droplets, we still don=E2=80™t know how many virus particles will cause an infection, but it is likely that a droplet will contain more of them than a finer particle. Further, distance, space, dispersion will all generally result in a lower probably of an infectious dose landing on your mucus membranes. Your risk will always be higher when standing within six feet from an infectious person than if standing twenty feet away.
p.s., Yale has 100,000 KN95 masks and we can=E2=80™t fit people to any of them.
p.s.s., We don't normally do spirometry as part of our respirator medical evaluations, unless the person's medical history indicates its necessity.
p.s.s.s., Re the "medical paper mask" comment, ASTM surgical masks used in hospitals are effective droplet protection and do provide some filtration. Years of evidence has proven their effectiveness in preventing disease in healthcare workers. See https://www.cebm.net/covid-19/what-is-the-efficacy-of-standard-face-masks-compared-to-respirator-masks-in-preventing-covid-type-respiratory-illnesses-in-primary-care-staff/ For infection control, these same masks are used in healthcare facility for "source control" (e.g., transporting a TB patient), which I agree is not PPE.
Pete Reinhardt, Yale EHS Director
Yes Peter, but the 6 foot rule for the obsolete droplet theory does assume zero velocity air movement.. The droplets will NOT settle within 6 feet if the air is moving away from the source. What ever the speed of that air flow will shift the settling distance of those droplets. Do the math.
Sent: Wed, Aug 12, 2020 8:04 pm
Subject: Re: [DCHAS-L] Respirator physicals?
The 6' number is NOT based on zero air velocity. It is based on the Infection Control community's use of the obsolete concept that respiratory infections are spread only by "droplets" which they define as being what we would call the very large emitted aerosols that settle rapidly under the influence of gravity and so, theoretically, can travel no more than about 6 feet (2 meters) from the point of emission. The Industrial Hygiene community, on the other hand, recognizes a continuum of particle sizes from very large to micron size, all of which could contain viral particles, and some of which will not settle for hours, even after their water content has evaporated.
And individual incidents have shown that COVID19 can be spread by the smaller particles. No large scientific studies on that, yet, because of the stress on the entire system, and the difficulty of assessing such matters with precision.
Peter Zavon, CIH
Tim & ALL,
You are more than welcome!
Adding to what Yaritza Binker (Thank you Yaritza!) has given you in the back-to-back eMails below with factual information and corresponding references, you should have enough ammunition to counter company management and legal counsel. Reaching out to OSHA and/or consultants would definitely help.
I'm not an expert in ventilation and I would certainly defer to D. Jeff Burton, Roger O. McClellan and others, but realize that that 6' number is based upon air movement or velocity equalling ZERO. So regardless of whether workers are side-by-side, 6', 12' or more apart from one another, the key consideration is always going to be the results from a workplace assessment which would include monitoring the air quality for contaminants. Monitoring the air quality for exposure to asbestos, benzene, beryllium, cadmium, - , and vinyl chloride is easy to do and COVID-19 not so easy to do. That's why some believe that blood and antigen body testing may be better for bioaerosols. In lieu of bioaerosol testing, you may want to base your decisions on an assumption that EVERYONE has COVID-19 in much the same way that healthcare institutions in the 1980's and early 1990's believed that ANYONE & EVERYONE who walked into their premises had HIV/AIDS.
Also, your query could not have come at a more opportune time with the publication today of August 2020 issue of Industrial Safety & Hygiene News (ISHN) and Dan Markiewicz' Column "Managing Best Practices" topic, "Check your OHS Legal requirements."
The four key words as a take-away from the article are "GENERAL DUTY CLAUSE" and "NEGLIGENCE." NEGLIGENCE and "FAILURE to WARN or TAKE ACTION" are words your legal counsel should know about.
Ber Safe, Secure & Sound, Vigilant and Well!
All My Best,
John B. Callen, Ph.D.
3M Personal Safety Division - Retired
On Aug 12, 2020, at 3:54 PM, Yaritza Brinker <YBrinker**At_Symbol_Here**FELE.COM> wrote:
OSHA standards are not really standards, they are requirements written into the CFR. OSHA guidance documents, in multiple places, reinforce the fact that N95s are respirators and must be issued within the framework of a respiratory protection program.
Here's a link to OSHA's National News Release from June.
Here is a link to OSHA's Covid-19 FAQ's page. Go to the Cloth Face Coverings section. It explains the distinction between the different types of masks and respirators, with CFR cross-references.
Here is a link to OSHA's Mask Fact Sheet.
** External Email **
I am so glad I read your post here. I have been fighting (to a degree) with my company about the mandatory use of KN-95 masks if workers have to work within 6 feet of each other. Instead of simply reaching out directly to OSHA with a letter of intent they are relying on in house counsel review and case law to justify suspension of ALL requirements for workers to be in the Resp. Prot. Program. That being said, management did say the likelihood of approval for work within 6 ft would be very hard to attain and anyone not comfortable doing the work and thus wearing the KN-95 would not be made to do so.
At this point I feel like I have more than done my due diligence in raising the concerns and frankly I am tired of sounding the proverbial horn and being ignored.
What are the possible ramifications that my company can look forward to and is there anything else I can do to point the company in the right direction to protect not only the workers but the company itself?
Thank you for your time and response,
Timothy A. Ellisor
Jim, Joe, Roger & ALL,
What I relate below certainly dates me, but that is why you keep Monona and me around to "Stir the Pot."
You remind me of the Good O;' Days when we always took things very seriously (and not that people don't today) regarding respiratory protection regardless whether it was nuclear or non-nuclear. Those were the days when health physicists, industrial hygienists and safety professionals had the top authority and controlled the reins of respiratory protection equipment instead of differing to materials management and/or purchasing personnel or even distributors.
I had the privilege and honor of meeting and knowing K. Paul Steinmeyer, RRPT first when he worked at Northeast Utilities (1979 - 1984) and thereafter at Radiation Safety Associates, Inc. (Hebron, CT). He was part of the group of "Legends in Their Own Time" I knew back in the mid-1970=E2=80™s through 1980's as Alan Hack, Ed Hyatt and John Pritchard at Los Alamos, Larry Birkner (deceased) at Celanese Corporation/ARCO, Howard Cohen, Ph.D. at Olin Corporation/Yale University, Craig Colton at OSHA Training Institute/3M and Tom Nelson at DuPont/NIHS, Inc. and where they worked at that time.
It was at the time when I had responsibility for calling on and working together with health physicists, industrial hygienists and safety professionals at Consolidated Edison, Northeast Utilities and New York State Power Authority nuclear and fossil fuel sites. I even worked with Stone and Webster during the construction of Millstone III helping to train and fit test the construction workers on respiratory protection equipment. For all of these, NO medical clearance with spirometry, NO training with an exam (YES, an exam) and NO fit testing for tight-fitting respirators meant NO RESPIRATOR! Also and as a corollary for fit-testing, tight-fitting respirator wearers had to be clean shaven so that facial hair did not interfere with the sealing surface of the respirator faceiece or interfere with valve function. That meant NO 5 O'Clock shadow on up to a full beard with wiskers for men and NO "peach fuzz" for women (special case)!
I would strongly suggest that everyone as part of the Division of Chemical Health & Safety, regardless of current responsibilities, read and thoroughly understand the contents of USNRC 10 CFR 20, specifically Subpart H (Sections 20.1701 - 20.1705) and also NUREG/CR-0041 Revision 1. These documents are readily available online. I always carried around with me the paper copies of the 1980's editions (My Bibles), which dates me long before laptops and the internet.
Also Jim, going back to 1970's and until I am "blue in the face" in 2020 today, how many times I have had to repeat and repeat, "A Surgical Mask does not provide respiratory protection but rather helps provide asepsis, a physical barrier between the wearer and the work environment or sterile field." This certainly applies to the "creative masks or face shields" individuals or companies are making to "help" with the social distancing.
Be Safe, Sound, Vigilant and Well!
All My Best,
John B. Callen, Ph.D.
3M Personal Safety Division - Retired
ACS/DCHAS Founding Member
Plutonium is a genuine serious toxic and radiological exposure risk, it is not some Covid 19 (Flu).
I would suggest a Certified Health Physicist (CHP) as the person to develop and implement a respiratory program for plutonium exposure control.
Regulations that apply here are USNRC 10 CFR 20 for radiation protection. This far more strict than just a respiratory protection program in accordance with 29 CFR 1910.134.
In your case there were also DOE requirements that are basically the same as 10CFR20.
By the way, These Corona virus paper and cloth handkerchiefs are in no way shape or form respirators. They are placebo for the general public. These handkerchiefs will probably exacerbate the risk of contracting the virus through inhalation. Moreover, the Covid 10 organisms are so small in relation to the weave of these face masks that they will pass through. Then almost all of the air exhaled will take the path of least resistance (differential pressure) and be forced through the gap between the face and mask and into the eyes.
These typical medical paper masks are worn to prevent water droplets containing the virus or bacteria from reaching a patient when a doctor or nurse coughs or sneezes when close to that patient. They are not designed to protector the doctor.
The handling of this "pandemic" should have been handled by high risk people (very old and already severely compromised persons taking responsibility and quarantining themselves. While those not at serious risk move on and continue to work, get this flu, get over it and allow "Herd" immunity to solve the problem as is the case with seasonal flu problems.
If that were the policy from the beginning we would be past this "crisis" by now.
What we have done is extend the crisis by our state policies.
I am uncertain of the basis for rules that curtail important services at a time when they are most needed.
Decades ago I was faced with a ridiculous situation that pushed me to take drastic action for a research laboratory, the Lovelace Inhalation Toxicology Research Institute in Albuquerque, NM. ITRI had 225 to 250 employees including about 40 doctoral staff and was funded by the US Department of Energy My solution was to replace our RN with a Nurse Practitioner and conduct all medical exams in an on site clinic. Previously, the medical exams had been conducted off site by an MD at our health care providers clinic. The on site exams included spirometric assessments on all employees irrespective of whether their work involved masks or more elaborate protective gear. As an aside , we worked with Plutonium and other nasty materials as aerosols . (As an aside, an aerosol is a relatively stable suspension of particles and/or droplets in a gaseous media, a definition lost in the current Covid-19 crisis.)
The spirometry results helped convince a lot of individuals to quit smoking. Employees really liked the NP and I still cross paths with former employees who relate that medical conditions, not work related, but identified in the on site clinic had huge impact on their health. I had a highly qualified Occupational MD provide oversight for a few hours a month. The on site NP worked closely with our Health and Environmental Safety Unit staffed with two professionals (with lots of training and credientals) and three technicians. The Head of our Health and Safety unit had authority that included lock down of any laboratory or operation irrespective of the rank of the staff responsible for the lab. Technicians were eager to get on the Institute's Health And Safety Committee and be part of the Institute's overall health and safety efforts.
I am disappointed when I learn the limited authority many CHAS members have in their academic positions.
Roger O. McClellan
Look more closely at the OSHA regulation on this. Most people can be adequately assessed by using a questionnaire, a clunky example of which is in that regulatory appendix, if I recall correctly.
Peter Zavon, CIH
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of DCHAS Membership Chair
Sent: Monday, August 10, 2020 4:55 PM
Subject: [DCHAS-L] Respirator physicals?
From: Joseph Peters <joseph.peters**At_Symbol_Here**technipfmc.com>
Date: Mon, 10 Aug 2020 20:06:57 +0000
Re: Respirator physicals?
We are currently trying to qualify two of our employees for respirator use.
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.
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
56 Woodrock Road | E. Weymouth, MA | 02189 TechnipFMC.com
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