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In the discussion on the subject topic, Peter Zavon's and Michael J.
Wright's information and/or comments about surgical masks versus NIOSH 42
CFR 84 certified respirators and/or health care respirators/surgical masks
for voluntary and/or routine use are correct; however, concerning the
selection and use of NIOSH certified Filtering Facepiece Respirators
(FFRs), several of you are providing information that is either hearsay,
technically incorrect and/or outdated.
Monona's statement below regarding the use of a HEPA Filter for substances
having an Occupational Exposure Limit (OEL), e.g., PEL or TLV, < 0.05 mg/m
3 (i.e., toxicity equal or greater than lead) and which formed the basis
of NIOSH 30 CFR 11 and selection and use of respirators per OSHA became
null and void with the advent of NIOSH 42 CFR 84 in 1995 and the revisions
to the OSHA Respiratory Protection Standard, 29 CFR 1910.134 in 1998.
Today, employers do not select filters based upon the OEL.
Except for certain OSHA Substance Specific Health Standards (general
industry and construction) which call out the use of HEPA Filters (N100,
R100 or P100) for respiratory protection (As, asbestos, Cd, cotton dust
where CONC > 10 X PEL, Pb and 4,4,-methylenedianiline), the selection of
filters is dependent upon whether when non-oil and/or oil-based
particulate matter (aerosols) are present and filter efficiency is not
specified, e.g., Cr(VI).
Although N95 FFRs are the most widely used, FFRs are not just those with a
Classification as N95. They can be N99 or N100, R95, R99 and R100 as well
as P95, P99 and P100.
The use of N95 FFRs < 5 x OEL (PEL) applies only to the Cotton Dust
Standard. Per the Assigned Protection Factor (APF) Table 1 in the OSHA
Respiratory Protection Standard, 29 CFR 1910.134(d)(3)(i)(A), FFRs are
half facepieces and have an APF = 10 as do elastomeric (rubber-type) half
facepieces.
Lynn K's statements regarding the Voluntary Use of Respirators needs
clarification as to the OSHA requirements per 29 CFR 1910.134(c)(2) as
captioned below with a summary table (not part of the standard).
1910.134(c)(2)
Where respirator use is not required:
1910.134(c)(2)(i)
An employer may provide respirators at the request of employees or permit
employees to use their own respirators, if the employer determines that
such respirator use will not in itself create a hazard. If the employer
determines that any voluntary respirator use is permissible, the employer
shall provide the respirator users with the information contained in
Appendix D to this section ("Information for Employees Using Respirators
When Not Required Under the Standard"); and
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).
Voluntary Use Requirements
ANY FFR
Other than FFR
Written Respirator Program (Limited)
X
Appendix D Training
X
X
Procedures on Cleaning, Maintenance & Storage
X
Medical Evaluation
X
Once the employer has documented that respiratory hazard(s) are below the
OEL or do not exist in the work environment, and decides to provide FFRs
for Voluntary Use, Appendix D Training is only required for any and all
FFRs (any N,R,P Class with Efficiency 95, 99 and 100).
In terms of the requirements for Voluntary Use, OSHA does not make a
distinction between N95 FFRs versus all other FFRs (R/P-95, N/R/P-99,
N/R/P-100).
Please note that employers may elect to be more conservative and institute
a full respiratory protection program for the Voluntary Use of FFRs, if
they desire. There would not be any OSHA fine and/or penalty if the
employers just provided respirator users with the information contained in
Appendix D.
If OSHA does cite and initiate a fine and/or penalty against an employer
where Voluntary Use is in place, it could be for a number of reasons,
including and not limited to (a) not documenting that respiratory
hazard(s) are below the OEL or do not exist in the work environment; b)
voluntary using respirators in areas where respiratory hazard(s) are at or
above the OEL or do exist in the work environment/regulated area; and, c)
finding FFRs hung in the work area, thrown on a work bench or laying on
the floor instead of placed in a designated waste receptacle or stored in
an appropriate container away from the work area at the end of the shift.
For any and all respirators other than FFRs, requirements include a
limited written respirator program with emphasis on Appendix D Training,
procedures on respirator maintenance, cleaning and storage and medical
evaluation.
If any one has any questions about respirators or other PPE or would like
us to facilitate a PDC at the ACS-DCHAS National or a Regional Meeting, do
not hesitate to contact me or Craig Colton, CIH, 3M OH&ESD Technical
Service - Division Scientist.
Best Personal Regards,
John
John B. Callen, PhD. | US/INTL Sales Development & Training Manager
3M Occupational Health & Environmental Safety
3M Center, 0235-02-W-70 | St. Paul, MN 55144-1000
Mobile: 612 845 1736 | Fax: 651 737 7881
jbcallen**At_Symbol_Here**mmm.com | www.3M.com | www.3M.com/OccSafety
From:
To:
Date:
01/26/2011 07:34 AM
Subject:
Re: [DCHAS-L] Do surgical masks = 'respirators'?
Sent by:
DCHAS-L Discussion List
Lynn has an excellent point. Any substance with a TLV of 0.05mg/m3 or
lower requires a hepa (N, R or P100) filter. No N95s. Same for asbestos,
although the TLV is in fibers/cc. And anything whatever that is expected
to be present in the air over 5 times it's TLV can't be used with any of
the masks. Monona
In a message dated 1/25/2011 6:01:00 PM Eastern Standard Time,
paracelcusbombastusvon**At_Symbol_Here**JUNO.COM writes:
As several have noted the "mask" must be NIOSH approved N95 with a "TC"
number on the mask. But, as Don noted, it still depends. What is the
material being milled? If there is any potential the material could
contain asbestos, glass fibers, ceramic fibers, or many other "hazardous
materials" the mask must be a HEPA respirator.
In the discussion on the subject topic,
Peter Zavon's and Michael J. Wright's information and/or comments about
surgical masks versus NIOSH 42 CFR 84 certified respirators and/or health
care respirators/surgical masks for voluntary and/or routine use are correct;
however, concerning the selection and use of NIOSH certified Filtering
Facepiece Respirators (FFRs), several of you are providing information
that is either hearsay, technically incorrect and/or outdated.
- Monona's statement below regarding
the use of a HEPA Filter for substances having an Occupational Exposure
Limit (OEL), e.g., PEL or TLV, < 0.05 mg/m3
(i.e., toxicity equal or greater than lead) and which formed the basis
of NIOSH 30 CFR 11 and selection and use of respirators per OSHA became
null and void with the advent of NIOSH 42 CFR 84 in 1995 and the revisions
to the OSHA Respiratory Protection Standard, 29 CFR 1910.134 in 1998. Today,
employers do not select filters based upon the OEL.
- Except for certain OSHA Substance
Specific Health Standards (general industry and construction) which call
out the use of HEPA Filters (N100, R100 or P100) for respiratory protection
(As, asbestos, Cd, cotton dust where CONC > 10 X PEL, Pb and
4,4,-methylenedianiline), the selection of filters is dependent upon whether
when non-oil and/or oil-based particulate matter (aerosols) are present
and filter efficiency is not specified, e.g., Cr(VI).
- Although N95 FFRs are the most
widely used, FFRs are not just those with a Classification as N95. They
can be N99 or N100, R95, R99 and R100 as well as P95, P99 and P100.
- The use of N95 FFRs <
5 x OEL (PEL) applies only to the Cotton Dust Standard. Per the Assigned
Protection Factor (APF) Table 1 in the OSHA Respiratory Protection Standard,
29 CFR 1910.134(d)(3)(i)(A), FFRs are half facepieces and have an APF
10 as do elastomeric (rubber-type) half facepieces.
Lynn K's statements regarding
the Voluntary Use of Respirators needs clarification as to the OSHA requirements
per 29 CFR 1910.134(c)(2) as captioned below with a summary table (not
part of the standard).
Where respirator use is not required:
1910.134(c)(2)(i)
An employer may provide respirators at
the request of employees or permit employees to use their own respirators,
if the employer determines that such respirator use will not in itself
create a hazard. If the employer determines that any voluntary respirator
use is permissible, the employer shall provide the respirator users with
the information contained in Appendix D to this section ("Information
for Employees Using Respirators When Not Required Under the Standard");
and
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).
Voluntary Use Requirements
ANY FFR
Other than FFR
Written Respirator Program (Limited)
X
Appendix D Training
X
X
Procedures on Cleaning, Maintenance
& Storage
X
Medical Evaluation
X
- Once the employer has documented
that respiratory hazard(s) are below the OEL or do not exist in the work
environment, and decides to provide FFRs for Voluntary Use, Appendix D
Training is only required for any and all FFRs (any N,R,P Class with Efficiency
95, 99 and 100).
- In terms of the requirements
for Voluntary Use, OSHA does not make a distinction between N95 FFRs versus
all other FFRs (R/P-95, N/R/P-99, N/R/P-100).
- Please note that employers may
elect to be more conservative and institute a full respiratory protection
program for the Voluntary Use of FFRs, if they desire. There would
not be any OSHA fine and/or penalty if the employers just provided respirator
users with the information contained in Appendix D.
- If OSHA does cite and initiate
a fine and/or penalty against an employer where Voluntary Use is in place,
it could be for a number of reasons, including and not limited to (a) not
documenting that respiratory hazard(s) are below the OEL or do not exist
in the work environment; b) voluntary using respirators in areas where
respiratory hazard(s) are at or above the OEL or do exist in the work environment/regulated
area; and, c) finding FFRs hung in the work area, thrown on a work bench
or laying on the floor instead of placed in a designated waste receptacle
or stored in an appropriate container away from the work area at the end
of the shift.
- For any and all respirators
other than FFRs, requirements include a limited written respirator program
with emphasis on Appendix D Training, procedures on respirator maintenance,
cleaning and storage and medical evaluation.
If any one has any questions about respirators
or other PPE or would like us to facilitate a PDC at the ACS-DCHAS National
or a Regional Meeting, do not hesitate to contact me or Craig Colton, CIH,
3M OH&ESD Technical Service - Division Scientist.
Best Personal Regards,
John
John B. Callen, PhD.
| US/INTL Sales Development & Training Manager
3M Occupational Health & Environmental Safety
3M Center, 0235-02-W-70 | St. Paul, MN 55144-1000
Mobile: 612 845 1736 | Fax: 651 737 7881
jbcallen**At_Symbol_Here**mmm.com
| www.3M.com
| www.3M.com/OccSafety
From:
<ACTSNYC**At_Symbol_Here**CS.COM>
To:
<DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Date:
01/26/2011 07:34 AM
Subject:
Re: [DCHAS-L] Do surgical masks = 'respirators'?
Sent by:
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu>
Lynn has an excellent point. Any substance
with a TLV of 0.05mg/m3 or lower requires a hepa (N, R or P100) filter.
No N95s. Same for asbestos, although the TLV is in fibers/cc.
And anything whatever that is expected to be present in the air
over 5 times it's TLV can't be used with any of the masks. Monona
In a message dated 1/25/2011 6:01:00 PM Eastern Standard Time, paracelcusbombastusvon**At_Symbol_Here**JUNO.COM
writes:
As several have noted the "mask"
must be NIOSH approved N95 with a "TC" number on the mask. But,
as Don noted, it still depends. What is the material being milled?
If there is any potential the material could contain asbestos, glass
fibers, ceramic fibers, or many other "hazardous materials" the
mask must be a HEPA respirator.
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