From the Nov/Dec 1999 issue of Clay Times
This is the first of two columns that will discuss the Occupational Safety and Health Administration’s (OSHA) regulations for respirators and how they apply to ceramic workers.
Dust masks are respirators. First, let’s correct a common misconception that “dusts masks” are exempt from OSHA fit testing, training, and other rules. They are not. OSHA considers masks just another type of respirator and defines them this way:
“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.”
The only dust masks not covered by OSHA are the pollen dust masks that can be purchased at most drug stores and some loose-fitting masks used in the medical profession. These masks are labeled with warnings that they do not provide protection against toxic substances.
Employer Obligations. If you are employed to teach or produce ceramics and you regularly use a respirator in your work, your employer must provide:
• A written program explaining how your employer will meet all the requirements below.
• A written hazard evaluation to determine hazards you face on the job and the employer’s rationale for selecting particular respirators.
• A medical evaluation to determine your ability to wear the selected respirator safely. The evaluation may be done by either a physician or a “licensed medical professional.”
• Formal fit testing at least annually by a qualified person using one of the approved methods.
• Documented training annually to ensure that you are familiar with the use and limitations of the equipment; procedures for regular cleaning, disinfecting, and maintaining all respirators; how to put them on, take them off, and do a “seal check” before each use; and other technical matters.
• Periodic program evaluation to ensure that respirator use continues to be effective.
Fit testing. You cannot know whether or not your respirator is protecting you unless you have been fit tested by a “qualified person.” If you are employed, this qualified person must be provided by your employer. If you are self-employed, you will have a hard time arranging for fit testing. The companies that sell respirators rarely provide fit testing. You can hire a consultant or industrial hygienist, but this is expensive. Some ceramicists mistakenly think they can test themselves by “fit checking.”
Fit checks. Confusion between the terms “fit test” and “fit check” have caused OSHA to change the term “fit check” to “user seal check.”
A “user seal check” for a mask is done by putting it on and seeing if it will briefly maintain negative pressure when you inhale or positive pressure when you exhale. You know it doesn’t fit if you feel air escaping near your nose, under your chin, or from some other place where the seal is broken.
To perform a user seal check for a cartridge respirator, you need to close the exhalation valve with your hand and exhale into the facepiece. Next you want to block air coming into the cartridges with your hands an inhale. The facepiece should not let air leak in or out on either procedure.
Employers are required by OSHA to provide trainers who will give workers hands-on instruction on how to seal check. Workers should do this check each time they put on a respirator or mask.
Real fit tests. Under OSHA rules, the employer must provide fit testing of all respirators (including masks). Your employer may hire a consultant or have an employee specially trained to do the job. The OSHA regulations describe in detail the various approved methods for doing the two basic types of fit testing:
1. Qualitative fit testing depends on the wearer’s ability to sense an odor, taste, or irritation from one of four approved chemicals delivered in a controlled way to an enclosure around the user’s head. These tests are not allowed for full-face negative pressure and supplied air pressure demand respirators.
2. Quantitative fit testing. This type of fit testing is done by measuring and comparing the pressure or contaminants inside and outside the mask or respirator. This equipment is expensive but the tests are allowed for all types of respirators, they are more accurate, and they create a document which makes it easy for employers to keep on file the required written records.
Beards. Many potters mistakenly think that they can successfully wear their respirator over a beard. They can’t. The new OSHA rules contain very explicit wording about facial hair. Under 29 CFR 1910.134(g), Use of Respirators, it states:
“Facepiece seal protection. The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have: (A) Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function...”
In addition, in the mandatory fit testing procedures it states: “The [fit] test shall not be conducted if there is any hair growth between the skin and the facepiece sealing surface, such as stubble beard growth, beard, mustache, or sideburns which cross the respirator sealing surface...”
Employers who let their bearded workers wear respirators risk OSHA citations. In fact, employers can require their OSHA-covered workers to shave.
Saving the beard. A hooded supplied-air system will work for most workers who are determined to keep their beards. These respiratory protection systems are expensive and require the purchase of a special compressor that can produce air that is safe to breathe. Ordinary shop compressors must not be used for this purpose. The complete supplied-air system usually costs well over $1000.
Monona Rossol may be reached at ACTS, 181 Thompson St. #23, New York, NY 10012-2586; (212) 777-0062; e-mail: firstname.lastname@example.org.
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