As an analytical laboratory, we operate under the Laboratory Standard 1910.1450 of the OSHA regulations.  We have excellent engineering cont rols, and have done monitoring for the the atmosphere contaminants that wou ld be of concern.  We don’t meet the OSHA threshold for any of those.

 

That being said, we sometimes have to grind samples in knife mills, an d this can generate some dust (though still well below the threshold).  ; Per 1910.134 Appendix D (http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STAND ARDS&p_id=9784) we conduct and document training to ensure that our employees have a firm b asis upon which to choose a dust mask appropriate to their task and comfort .

 

Now, my toxicology group wants to order surgical masks, and since 1910 .134 defines a “respirator” as:

 

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

 

In light of the above definition, I am forced to ask:  is a surgi cal mask considered a ‘respirator’?  Do I now need to docu ment a) that there is no condition which requires use of a respirato r/surgical mask/form of protection in the toxicology section and b) that if not, all of the toxicologists are also trained in accordance with Appendix D to 1910.134?

 

<sigh>

 

 

 

Dr. Bradley K. Norwood

Laboratory Director

Arista Laboratories

1941 Reymet Road

Richmond, VA  23237

(804) 271-5572 ext. 307

(804) 641-4641 (cell)