From:
Alex Hagen <fischera**At_Symbol_Here**UW.EDU>
Subject:
Re: [DCHAS-L] Undergraduate Student Respirator Use?
Date:
Aug 22, 2024 16:37 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<DM3PR08MB9587457A6D96431296A9300BA38F2**At_Symbol_Here**DM3PR08MB9587.namprd08.prod.outlook.com>
In-Reply-To:
<DS0PR14MB554106C656457F92AB55B9FCA28F2**At_Symbol_Here**DS0PR14MB5541.namprd14.prod.outlook.com>
Good morning, Nora,
Our University has a respirator program that involves does not differentiate between staff and students for respiratory use. Instead, it focuses on when use of the respirator is needed. You can find more information
about the program here:
https://ehs.washington.edu/workplace/respiratory-protection, including a copy of the program manual.
I do agree with what James stated in his response below. I hope you can find solutions that work for everyone on your campus!
Regards,
~Alex
ALEX HAGEN, CCHO
Laboratory Safety Inspection Program Manager
Environmental Health & Safety Department, University of Washington
206.221.2339
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of James Saccardo
Sent: Thursday, August 22, 2024 7:13 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Undergraduate Student Respirator Use?
You not going to find anything addressing students because labor laws only cover employees, but yes, they should be afforded the same protection as employees. Sound like the program lacks good safety culture.
As for defaulting to PPE, remember engineering and administrative control should be used first, PPE is a last line of defense. A respiration protection plan can be complicated and a good deal of work (time and
money) that it might be more cost effective in the long run to upgrade the ventilation.
If the hazard can be mitigated with admin and engineering controls, it should. The VOC in the spray paint will be most difficult N95's won't work, you will have to do monitoring, use carbon absorption cartridges, and
not rely on breakthrough for change outs.
Perhaps if they do not have the proper engineering controls, they should not be doing this work.
* This email originates from a sender outside of CUNY. Verify the sender before replying or clicking on links and attachments. *
Is anyone aware of a university whose respiratory protection plan specifically includes students? My employer (a small, liberal arts university with a highly active theater department) has a lot of student shops, where ventilation is
inadequate or whose dust collectors can’t keep up. There’s also a lot of spray paint use. I’m working to develop a respiratory protection plan that addresses the need for student respirator use (N95’s, mainly). I’ve received pushback from a few deans, asking
for evidence that other universities require their students to wear respirators in theater/fine arts/communications contexts, particularly in wood shops.
I’ve found a few institutions where the RPP explicitly permits students to *voluntarily* wear a respirator, but are there any that have rules governing *required* student use of respirators in the face of actual hazardous
air contaminants? These are situations where an employee would absolutely be required to wear an N95 or P100. It seems like best practice would be to have students follow the same rules for wearing respirators as employees, if they’re doing the same tasks
in the same atmosphere…but I can’t seem to find anything that explicitly addresses this issue.
The administration is unwilling to move forward and approve student respirator use without evidence that other schools do it too. Asking the students to leave the shop and have W2 employees take over when the wood dust levels get too
high is both impractical and rude to the students, who are supposed to be learning by doing. Long term, the answer would be to improve ventilation, etc., but that’s not in the cards financially at this point.
Any suggestions are appreciated.
Thanks for your time!
Nora Dunkel, CHMM
Chemical Safety Officer
Webster University
Office: Browning Hall/ISB 314
314-246-2244 (desk)
noradunkel51**At_Symbol_Here**webster.edu
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