From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Medical Evaluations
Date: Fri, 15 Jan 2021 12:43:02 +0000
Reply-To: Monona Rossol <actsnyc**At_Symbol_Here**CS.COM>
Message-ID: 787483417.2275070.1610714582081**At_Symbol_Here**

Yes, as I said yesterday, I filed the Letter of Interpretation you sent on this subject and that makes it clear that they make a distinction between masks and elastomerics as far as medical certification for voluntary use.    Monona

-----Original Message-----
From: John Callen <jbcallen**At_Symbol_Here**GMAIL.COM>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Thu, Jan 14, 2021 5:41 pm
Subject: [DCHAS-L] Medical Evaluations

Monona and ALL,

Monona, per your statement,

Just reread the medical certification section and appendix D and they just say "respirators" without any classifications.  So I think that's not a requirement for elastomerics.  Monona

your thought is incorrect and let me explain.  But first, please be aware that our discussion relates only to negative and positive pressure tight-fitting facepiece respirators.

When you look at the OSHA Respiratory Protection Standard, 29 CFR 1910.134 and its Appendices A-D, when it was first promulgated in 1998 and revised in certain passages thereafter, there was/will always be questions as to what a given word or statement directly or indirectly means or implies.  That is where OSHA Instruction, Directive Number CPL-02-00-158 (Inspection Procedures for the Respiratory Protection Standard) and OSHA Letters of Interpretation come into play.  Consequently, you just can't take the Standard and what it says for "face value," and consequently you must proverbially "peel the onion" and ask OSHA for guidance and especially if something is unclear and needs further clarification or interpretation.

My reply to Peter Reinhardt is correct:

"Here is the OSHA Letter of Interpretation regarding Voluntary Use of Elastomeric Facepiece Respirators, which I missed attaching to my earlier response to you.  Please see Paragraph 2, beginning at the end of Line 5 under "Response."

Here is the pertinent passage from the Letter of Interpretation:

"if employers allow the voluntary use of elastomeric facepiece and powered air-purifying respirators (again, after determining that such use will not itself create a hazard), the employer must implement the elements of a written respiratory protection program necessary to ensure that employees voluntarily using such respirators are medically fit to do so, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. See 29 CFR 1910.134(c)(2)(ii). The preamble to the standard explains that medical evaluation is necessary even for voluntary use of negative pressure (tight-fitting) respirators because they impose a significant physiologic burden on the respirator user, and it is crucial to determine that the user can withstand that burden without suffering adverse health consequences (63 Fed. Reg. at 1190).

That passage is abstracted from CPL-0200-00-158:

and in particular, E. Medical Evaluation - Paragraph (e) on  Page 22 which states,

"These evaluations are required for all respirator users except for employees who voluntarily use dusts masks and for those whose only respirator would be the use of escape-only respirators."

As you know by OSHA  definition, a "Filtering Facepiece Respirator"  (FFR) is a "Dust Mask":

Filtering facepiece (dust mask) means a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium. 

By deduction, if you remove FFRs from all tight-fitting facepiece respirators, you are left with elastomeric facepiece tight-fitting respirators. Q.E.D.

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

Be Safe and Stay Healthy!

All My Best,

John B. Callen, Ph.D.
3M Personal Safety Division - Retired
ACS/DCHAS Founding Member
(312) 632-0195

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