Hello All:

Great discussion indeed, and good to see the interest and diligence in
handling Nora's problems. It's been more than 20 years since I wrote my
last MSDS as a consultant in environment, health and safety matters. So,
I can't contribute much on present regulatory requirements, and my
comments are more general.

In her first posting Nora mentions that the University has many
workshops. I'm wondering whether one of those could be equipped with
adequate ventilation and dedicated to just handling spray paint work
requiring protection from VOC's.
Mixing wood dust and VOC's is not a good idea. The problems have been
well described in the ongoing discussion. But it's not only the proper
use of PPE but also the potential of dust and solvent explosions.
I see properly engineered workplace ventilation as the best general
solution. But teaching students awareness and responsibility for their
own safety must be part of the curriculum in the arts and crafts field.
We are used to wearing safety glasses and hearing protection. Knowing
when to don a face mask should be part of the same personal protection
routine.

Heinz Trebitz, PhD

On 8/26/2024 1:03 PM, Nora Dunkel wrote:
> Thank you to everyone who responded to my question! I appreciate all the responses you've sent, both on- and off-list. Whatever form the final policy takes, it will be stronger because of your input. This listserv is a wonderful resource and I'm glad so many of you were willing to contribute your two cents.
>
>
> Nora Dunkel, CHMM
> Chemical Safety Officer
> Webster University
> Office: Browning Hall/ISB 314
> 314-246-2244 (desk)
> noradunkel51**At_Symbol_Here**webster.edu<mailto:noradunkel51**At_Symbol_Here**webster.edu>
>
>
>
> From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Kleinman, Michael
> Sent: Friday, August 23, 2024 12:06 PM
> To: DCHAS-L**At_Symbol_Here**Princeton.EDU
> Subject: Re: [DCHAS-L] Undergraduate Student Respirator Use?
>
> CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
>
> This has been an interesting discussion. However, it is important to keep in mind what the occupational standards do. The time weighted average (TWA) exposure limits for a physical substance are set to protect adult workers who are exposed to that substance for 8hr/day, 5 days/week for their entire (~30 year) working lives. So, if someone is exposed to 1000 ppm to a VOC for 1 hr per day and 10 ppm for the other 7 hrs, their TWA = (1000 x 1 hr + 10 x 7 hr) / 8 hr = 133.75 pm. So, if we are considering workers exposed to a VOC under the proposed scenario with permitted exposure limit of 500 ppm, they would not be considered to have exceeded their limit.
>
> There are lots of ways to reduce the potential hazards for workers and students.
>
> 1. ALWAYS WEAR EYE PROTECTION!!!!
>
> * Other routine protection is lab coat or equivalent to protect skin, shoes that cover the feet, etc)
>
> 1. Reduce the use of more hazardous substances (substitute)
>
> * Pick spray paint that use less of the toxic VOCs and toxic metal components
> * Even in wood shop, keep in mind that some species of wood are more irritating and allergenic than others. When you have a choice, choose the less noxious material.
>
> 1. Use adequate ventilation to reduce concentration in the workers breathing zone
>
>
> 1. Minimize duration of exposure (administrative control)
>
>
>
> 1. Use personal protective equipment (masks, gloves etc.)
>
>
> As a point of information, the ACGIH publishes a book of Threshold Limit Values, which can help when evaluating product components. The appendix contains explanations and guidance about how to make the best use of health guidelines.
>
> Michael T. Kleinman
> Department of Environmental and Occupational Health
> Wen Public Health
> University of California, Irvine
> 856 Medical Sciences Quad
> Irvine CA 92697-1830
>
> ________________________________
> From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU<mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU>> on behalf of Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU<mailto:0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>>
> Sent: Friday, August 23, 2024 8:32:59 AM
> To: DCHAS-L**At_Symbol_Here**Princeton.EDU<mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU> <DCHAS-L**At_Symbol_Here**Princeton.EDU<mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU>>
> Subject: Re: [DCHAS-L] Undergraduate Student Respirator Use?
>
> Good thinking. They don't want to hear the truth, just what is expedient. It's why, when we get new members in our union with college degrees in technical theater, we know we have a LOT of very basic training to do.
>
> Monona
>
> On Friday, August 23, 2024 at 11:13:28 AM EDT, James Saccardo <james.saccardo**At_Symbol_Here**csi.cuny.edu<mailto:james.saccardo**At_Symbol_Here**csi.cuny.edu>> wrote:
>
>
>
> Monona, Thanks, and you're right, we're not preparing them for the work force. Everyone in all disciplines should have to take a risk assessment course. I was going to mention incorporating respiratory protection into the curriculum would be the best case, but I want to keep my job =).
>
>
>
> From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU<mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU>> On Behalf Of Monona Rossol
> Sent: Thursday, August 22, 2024 1:18 PM
> To: DCHAS-L**At_Symbol_Here**Princeton.EDU<mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU>
> Subject: Re: [DCHAS-L] Undergraduate Student Respirator Use?
>
>
>
> Right on, James, Monona
>
>
>
> On Thursday, August 22, 2024 at 11:37:18 AM EDT, James Saccardo <james.saccardo**At_Symbol_Here**csi.cuny.edu<mailto:james.saccardo**At_Symbol_Here**csi.cuny.edu>> wrote:
>
>
>
>
>
> 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.
>
>
>
> Just my $0.02
>
> James
>
>
>
>
>
> ________________________________
>
> From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU<mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU>> on behalf of Nora Dunkel <noradunkel51**At_Symbol_Here**WEBSTER.EDU<mailto:noradunkel51**At_Symbol_Here**WEBSTER.EDU>>
> Sent: Wednesday, August 21, 2024 1:02 PM
> To: DCHAS-L**At_Symbol_Here**Princeton.EDU<mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU> <DCHAS-L**At_Symbol_Here**Princeton.EDU<mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU>>
> Subject: [DCHAS-L] Undergraduate Student Respirator Use?
>
>
>
> * 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<mailto:noradunkel51**At_Symbol_Here**webster.edu>
>
>
>
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