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From: "Norwood, Brad" 
Date: February 24, 2009 3:48:11 PM EST (CA)
Subject: RE: dust masks

Suzanne,

We had a Virginia Department of Labor and Industry site visit (at our  

request).  At the time, we had two workers who were, on their own,  
wearing dust masks.

What the VaDoLI inspector told me was that if we continued to allow  
the practice, we had to either:

1) Institute a full respiratory program (particularly required if we  
provided the dust masks)

Or

2) Document that they had been trained/informed per Appendix D to  
Section 1910.134 (this notwithstanding the fact that the actual OSHA  
standard that applies to laboratories is the 1910.1450).

HTH,

Brad

Bradley K. Norwood, PhD
Laboratory Director
Arista Laboratories
1941 Reymet Road
Richmond, VA  23237
(804) 271-5572 ext. 307
(804) 641-4641 (cell)
brad.norwood**At_Symbol_Here**aristalabs.com

===
From: "Walter Garrow" 
Date: February 24, 2009 4:02:35 PM EST (CA)
Subject: RE: [DCHAS-L] 3 RE: [DCHAS-L] dust masks

Make sure that the mask has the NIOSH approval.  There is a difference  

between the medical masks and the respirators.

Basically, there is an OHSA provision of exemption.  However, it only  

applies if the mask is warn for convenience and not for the purpose of  

OSHA compliance to reduce exposure to reduce air concentrations over  
OSHA exposure limitation know as "PEL's".  If that is the case, OSHA  
still wants the employee to provide the employee with a copy of  
Appendix D of the OSHA Respirator program 29CFR1910.134.  That  
explains the limitations.

==
From: Cat Conley 
Date: February 24, 2009 4:09:51 PM EST (CA)
Subject: RE: [DCHAS-L] 3 RE: [DCHAS-L] dust masks

Hi Suzanne,

Here's what OSHA has to say: (Emphasis mine)

29 CFR 1910.134(c)(2)(ii):
In addition, the employer must establish and implement those elements  

of a written respiratory protection program necessary to ensure that  
any employee using a respirator voluntarily is medically able to use  
that respirator, and that the respirator is cleaned, stored, and  
maintained so that its use does not present a health hazard to the  
user. Exception: Employers are not required to include in a written  
respiratory protection program those employees whose only use of  
respirators involves the voluntary use of filtering facepieces (dust  
masks).

29 CFR 1910.134(b): 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.

So your answer would depend on whether the use of the dust mask was  
voluntary or required by the company. As long as the filtering  
facepiece is worn voluntarily and there atmosphere isn't hazardous, it  

can be worn without having to go through the full RPP procedure. If  
the company requires that a respirator be worn (filtering facepiece or  

otherwise) then the "employer must establish and implement..." as  
stated in 1910.134(c)(2)(ii) above, because that use wouldn't be  
voluntary.

If respirators are worn voluntarily, the company should provide them  
with the information in 29 CFR 1910.134 Appendix D (Voluntary Use Form).

This OSHA letter of interpretation is very helpful in regards to  
voluntary/required and dust mask/tightfitting facepiece: 
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETA
TIONS&p_id=25342

Sincerely,
Cat

Cat Conley
Chemical Hygiene and Safety Officer
Department of Environmental Health and Safety
Roger Williams University
cconley**At_Symbol_Here**rwu.edu

===
From: "John Sacco" 
Date: February 24, 2009 4:11:19 PM EST (CA)
Subject: RE: [DCHAS-L] 3 RE: [DCHAS-L] dust masks

The short answers are:

If they are used voluntarily then no.

If their use is mandatory then yes.

You have to consider why the respirators are used and what you are
protecting against.

John J. Sacco, P.E., CIH
Earthshine Consulting, Inc.
916.435.9800 (Voice)
916.769.1434 (Cell)
916.435.0460 (Fax)



===
From: "LaCroix, Steve (DOH)" 
Date: February 24, 2009 7:30:14 PM EST (CA)
Subject: RE: [DCHAS-L] dust masks

If dust masks only are used and not required, no written program is  
required. Appendix D of the standard must be provided to these users  
Many firms have specific guidance on the use of worker provided =93dust  

masks".

Steve LaCroix
Quality Assurance and Safety Officer
Department of Health
Epidemiology, Health Statistics, and Public Health Laboratories
1610 NE 150th St.
Shoreline, WA 98155
Phone: (206) 418-5437
Cell: 206-391-9025
FAX: (206) 418-5485
email: steve.lacroix**At_Symbol_Here**doh.wa.gov
ergonomic information: http://dohweb/Risk/Ergonomicsnew.htm
"The Department of Health works to protect and improve the health of  
people in Washington State"

===

From: "Chrismarlowe" 
Date: February 24, 2009 7:49:52 PM EST (CA)
Subject: RE: [DCHAS-L] 3 RE: [DCHAS-L] dust masks
Reply-To: 

Rachel:

WRT: For situations where you can prove that the respirator is not  
needed
	(You will need air monitoring data for this.),

I find myself in incomplete agreement with the sentence in  
parenthesis. You have to be dang sure that the respirators are NOT  
needed before you allow voluntary use of respirators, but I can be  
convinced by information other from air monitoring results.

Stay healthy,

Chris Marlowe
42 Highlander Dr
Scotch Plains, NJ  07076
908 / 754 - 5160 (home)
732 / 539 - 8128 (cell)
Krismarlowe**At_Symbol_Here**Verizon.net

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