In late December, OSHA published a Notice of Proposed Rulemaking (NPRM) in the Federal Register for a new fit-testing protocol — the Abbreviated Bitrex Qualitative Fit-Testing (ABQLFT) protocol — under Appendix A of OSHA’s Respiratory Protection standard. The agency is accepting public comments until February 25, 2008.

“This proposed rule will add a new fit-test method that has a shorter exercise duration than the current methods,” said Assistant Secretary of Labor for OSHA Edwin G. Foulke, Jr. “This method will give employers additional flexibility in selecting procedures for conducting fit-testing.”The proposed rule would add the ABQLFT as an alternative to the four existing OSHA-allowed qualitative fit-test protocols. The ABQLFT protocol currently listed in the existing OSHA Bitrex fit-test protocol in the Respiratory Protection standard would shorten the duration for each of the seven fit-test exercises from one minute to 15 seconds.

The proposed protocol would apply to employers in general industry, shipyard employment, and the construction industry.Interested parties may submit comments at http://www.regulations.gov , the federal eRulemaking Portal, by sending three copies to the OSHA Docket Office, Room N-2625, U.S. Department of Labor, 200 Constitution Ave. N.W., Washington, DC, 20210; telephone (202) 693-2350; or if the written submission is ten pages or less, FAX to (202) 693-1648. All comments on the NPRM must include the docket number for this Federal Register notice, OSHA 2007-0006. See the Federal Register notice for more information on submitting comments.

OSHA cites San Antonio-based AA Foundries for willful, multiple serious safety and health violations

Federal OSHA has cited AA Foundries Inc. with one willful and 20 serious violations for exposing employees to excessive noise levels, lead and copper at the company’s work site in San Antonio. Proposed penalties total $107,600. This equates to nearly one violation and over $4,500 per worker at the foundry.

An investigation that began on Oct. 24, 2011, as part of OSHA’s Primary Metals National Emphasis Program found that employees were exposed to noise levels surpassing 85 decibels, as well as excessive airborne levels of lead and copper, while conducting operations such as pouring molds and grinding on metal cast.

The willful violation is for failing to ensure that employees underwent required annual audiograms. A willful violation is one committed with intentional knowing or voluntary disregard for the law’s requirements, or with plain indifference to worker safety and health.

“Exposing employees to excessive noise levels can cause hearing loss, and exposure to lead and other contaminants can seriously harm workers’ health,” said Jeff Funke, the agency’s area director in San Antonio. “OSHA’s standards exist to protect workers and must be followed to prevent these types of injuries.”

Serious violations include failing to implement effective lead compliance and air monitoring programs protecting employees from overexposure to lead and other heavy metals such as copper and cadmium, ensure medical surveillance included blood lead testing and monitoring, and provide annual training on hazards of working with lead. Additionally, the employer failed to ensure that employees were protected by effective hearing conservation and respiratory protection programs, respectively. A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known.

The citations can be viewed at:

http://www.osha.gov/ooc/citations/aafoundries_315628503_0428_12.pdf*

The company, which employs approximately 23 workers, has 15 business days from receipt of the citations to comply, request an informal conference with OSHA’s San Antonio Area Office or contest the citations and penalties before the independent Occupational Safety and Health Review Commission.

Proposed fines total $59,200

OSHA has cited History Construction Management LLC in Odell, Illinois, for 22 alleged serious health violations. OSHA opened an inspection in May in response to a complaint and found that some workers were exposed to airborne lead at more than 40 times the permissible limit. The company, which specializes in restoring windows for historical buildings, previously was cited by OSHA in 2009 for failing to provide a hazard communications program and require the use of personal protective equipment.

“Employers such as History Construction Management have a responsibility to ensure that operations are conducted in a way that eliminates or minimizes lead hazards, including exposure,” said Tom Bielema, director of OSHA’s Peoria Area Office. “Training workers to recognize lead hazards and take necessary precautions to prevent exposure is necessary to protect their health.”

Fifteen of the violations relate to OSHA’s lead standard, including failing to implement engineering and work practice controls to reduce exposure, collect full shift personal samples for monitoring, provide clean protective clothing, provide clean changing rooms or separate storage facilities for protective work clothing to prevent cross-contamination with street clothes, keep surface and eating areas free from lead dust accumulation, properly sweep up lead dust, provide training to employees about lead and post lead hazard warning signs.

Five violations of OSHA’s respiratory protection standard involve failing to implement a respirator protection program that includes proper respirator selection, medical evaluation, fit testing and training. The remaining two violations are using flexible electrical cords as a substitute for fixed wiring and improperly altering electrical cords.

Scenario: You are the safety manager for a manufacturing company with about 500 employees. A spraying operation within your plant requires employees to use respiratory protection consisting of tight-fitting, full face air purifying respirators. The eight employees who work in this area (and therefore must wear a respirator) have completed the medical questionnaire, have been determined to be fit, have had fit tests conducted, and have been provided training as required by the OSHA standard.

Today, the supervisor of the area informs you that one employee, who has been working for over a year, is growing out his facial hair based on his new religious beliefs.  The employee still wants to work in the area and knows he must wear a respirator. He is willing to sign a waiver to release the company of any liability if it is later determined he may have been overexposed due to a poorly fitting respirator.

Question:  Does OSHA require employees wearing a tight fitting respirator to be clean shaven? Will OSHA allow the signing of a waiver or release if an employee chooses to have facial hair that interferes with the seal?  How far does OSHA expect an employer to go to accommodate a religious practice that could ultimately compromise the employee’s safety at work?

Answer:  There are a number of OSHA Directives and Letters of Interpretation that may assist us in determining the answer here.  First, the Respiratory Protection Standard 1910.134(g)(1), Facepiece seal protection, clearly states:

(i) 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; or

(B) Any condition that interferes with the face-to-facepiece seal or valve function.

In a letter of interpretation dated March 7, 2003 to Carl Levin of the United States Senate, OSHA states:

“OSHA’s respiratory protection standard (29 CFR 1910.134) specifies certain requirements for employers to follow when their employees must wear respirators, . . . the employer cannot permit respirators with tight-fitting facepieces to be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face, or that interferes with valve function. While the standard does not ban beards per se, it does require employers to ensure that bearded employees who are required to wear tight-fitting facepieces trim their beards so that they do not interfere with the sealing surface of the respirator or are not so large that they could interfere with valve function.”

As you can see, OSHA will not say point blank that beards are not allowed.  However, if beards are allowed, they can’t interfere with the seal or valve function of the respirator.

Now what about the waiver option?  In another letter of interpretation dated January 18, 1984 to Congressman James T. Broyhill, OSHA states “It is not permissible to negotiate individual exemptions from such requirements by signing a release as suggested.”  In another letter from OSHA on a similar issue dated May 14, 2007 to Mr. Robert M. Sklar, Loss Control Specialist with Pep Boys, OSHA states “. . . employers have duties under the OSH Act from which they cannot be released by having their employees sign waivers”. Therefore, based on these responses, a release or waiver is not an option.

The final question is how far does OSHA expect an employer to go to accommodate a religious practice that could ultimately compromise the employee’s safety at work?  In yet another letter of interpretation dated December 2, 1998 to Mr. William H. Kincaid of Lockton Companies, Mr. Lockton asks this very question.  OSHA’s response is “OSHA has not exempted any workers for religious reasons; however, we recognize that if such a situation should arise, there are respiratory protection alternatives such as loose-fitting hoods or helmets that will accommodate facial hair”.  So as you can see, they leave an opening for this issue that if the employer can accommodate the need with another form of acceptable protection, then the employer should explore that option.  The question that must be answered is can the employer reasonably accommodate the employee’s need and still achieve the necessary protection factor for the employee?

Fresh From Texas Inc. and iWorks Personnel Inc. fined a total of $135,200

Fresh From Texas Inc., a fresh fruit and vegetable processor for H-E-B Grocery stores and fast-food markets, and staffing agency iWorks Personnel Inc. have been cited for 18 violations by the U.S. Department of Labor’s Occupational Safety and Health Administration for exposing workers to damaging noise levels, chemical hazards and possible amputation hazards for failing to train machine operators on controlling hazardous energy. The total proposed fine for the complaint inspection that began in December 2013 is $135,200.

“Workers, whether employed directly by the company or as a temporary worker, require proper training on workplace hazards. In this case, both Fresh From Texas and iWorks failed to do so and put workers in danger,” said Kelly C. Knighton, OSHA’s area director in San Antonio. “Both host employers and staffing agencies have roles in complying with workplace health and safety requirements, and they share responsibility for ensuring worker safety and health.”

Fresh From Texas was cited for 12 serious safety and health violations, with a penalty of $76,100, for failing to prevent workers from exposure to hazardous chemicals; to identify and evaluate respiratory hazards in the workplace; and to ensure a hearing conservation program was implemented for workers exposed to noise levels that would cause permanent hearing damage. Regarding slicing and dicing machines, violations were cited for failing to establish a written lockout/tagout program for energy sources to ensure machines were turned off when workers were inside them; provide machine operators with training; guard rotating gears; and provide safety instructions on the machines.

Two repeat violations were cited, with a penalty of $49,500, for failing to ensure sufficient working space around electrical equipment and unobstructed access to fire extinguishers. Similar violations were cited in 2012. Three other violations, with a penalty of $3,300, were cited for failing to record injuries of temporary workers, review the log for accuracy and ensure safety instructions were clearly posted on dangerous machines.

OSHA inspectors found that temporary workers employed by iWorks Personnel were also exposed to chemical hazards and were not trained on chemical safety. As a result, OSHA cited iWorks for one serious safety and health violation, with a penalty of $6,300.

A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known. A repeat violation exists when an employer previously has been cited for the same or a similar violation of a standard, regulation, rule or order at any other facility in federal enforcement states within the last five years.

In April 2013, OSHA announced an initiative to improve workplace safety and health for temporary workers. During the inspection, OSHA inspectors paid special attention to the hazards facing temporary workers to determine the role the host employer and the staffing agency played in the dangers.

The citations can be viewed at:
http://www.osha.gov/ooc/citations/Fresh_From_Texas_Inc_953367_0627_14.pdf,
http://www.osha.gov/ooc/citations/Fresh_From_Texas_Inc_953588_0627_14.pdf and
http://www.osha.gov/ooc/citations/iWorksPersonnelInc_dba_PreferredStaffingLLC.pdf.

Welding company exposed employees to fire, chemical, respiratory hazards

BRAINTREE, Massachusetts – Guiseppe Falcone and Daniele Falcone, doing business as D & J Ironworks, failed to follow safety precautions, which fire officials indicated led to a fire that cost the lives of two Boston fire fighters, an investigation by the U.S. Department of Labor’s Occupational Safety and Health Administration determined.

The fire in Boston’s Back Bay neighborhood on March 26, 2014, was caused because the Malden-based welding company allowed its employees to install railings using arc welding equipment during high wind conditions. Fire officials said sparks from welding railings at 296 Beacon St. ignited clapboards on an adjacent shed at 298 Beacon St., which led to the fire.

“OSHA found that the company lacked an effective fire prevention and protection program, failed to train its employees in fire safety, did not have a fire watch present and did not move the railing to another location where the welding could be performed safely,” said Brenda Gordon, OSHA’s area director for Boston and southeastern Massachusetts. “This company’s failure to implement these required, common-sense safeguards put its own employees at risk and resulted in a needless, tragic fire.”

The company also failed to protect its employees against respiratory and chemical hazards associated with welding, cutting, drilling and painting operations. It failed to evaluate employees’ medical fitness to wear respirators or train employees how to clean, store and maintain respirators; evaluate respiratory hazards for workers; inform employees of chemical hazards associated with welding and how to address them; and maintain safety data sheets on hazardous chemicals.

OSHA cited D & J Ironworks for 10 serious violations of workplace safety standards and imposed fines of $58,000.  The citations can be viewed here.

WASHINGTON – The Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health today released the Hospital Respiratory Protection Toolkit, a resource for health care employers to use to protect hospital staff from respiratory hazards.

Respirators are used to protect against exposures to airborne transmissible infectious diseases as well as chemicals and certain drugs that may be used in healthcare settings. OSHA’s Respiratory Protection Standard requires that health care employers establish and maintain a respiratory protection program in workplaces where workers may be exposed to respiratory hazards.

“Hospitals are one of the most hazardous places to work,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “One of the ways that we can protect workers in a health care setting is by providing employers with the resources needed to ensure a safe workplace. This toolkit will help protect those workers who dedicate their lives to caring for others.”

“Appropriate respiratory protection is a vital line of defense against airborne hazards hospital workers might face on the job,” said NIOSH Director John Howard, M.D. “This toolkit is an important resource to help health care employers ensure their workers are out of harm’s way when it comes to respiratory hazards.”

The toolkit covers respirator use, existing public health guidance on respirator use during exposure to infectious diseases, hazard assessment, the development of a hospital respiratory protection program, and additional resources and references on hospital respiratory protection programs. Appendix D is an editable document that each hospital can customize to meet its specific needs.

To supplement the toolkit, The Joint Commission, an accrediting body for more than 20,500 health care organizations and programs in the United States, developed an educational monograph, Implementing Hospital Respiratory Protection Programs: Strategies from the Field, to assist hospitals in implementing respiratory protection programs. The monograph, produced in collaboration with NIOSH’s National Personal Protective Technology Laboratory, identifies common implementation challenges, provides specific examples of innovative strategies from healthcare organizations and examines the role of leadership, quality improvement, fit testing and training challenges, and program evaluation.

“Respiratory protection programs enhance safety for both workers and patients, but there are many common challenges associated with their implementation,” said Ana McKee, M.D., executive vice president and chief medical officer, The Joint Commission. “We hope that by showcasing the innovative and effective strategies used by health care organizations across the country to overcome some of these challenges, hospitals can learn from one another as they implement and improve their own respiratory protection programs.”

NIOSH is the Federal agency that conducts research and makes recommendations for preventing work-related injuries and illnesses. It was created under the Occupational Safety and Health Act of 1970 and is part of the U.S. Centers for Disease Control and Prevention. More information about NIOSH can be found at www.cdc.gov/niosh.

OSHA has a suite of resources on protecting workers from safe patient handling hazards on its Worker Safety in Hospitals Web page.

OSHA cites San Antonio-based AA Foundries for willful, multiple serious safety and health violations

Federal OSHA has cited AA Foundries Inc. with one willful and 20 serious violations for exposing employees to excessive noise levels, lead and copper at the company’s work site in San Antonio. Proposed penalties total $107,600. This equates to nearly one violation and over $4,500 per worker at the foundry.

An investigation that began on Oct. 24, 2011, as part of OSHA’s Primary Metals National Emphasis Program found that employees were exposed to noise levels surpassing 85 decibels, as well as excessive airborne levels of lead and copper, while conducting operations such as pouring molds and grinding on metal cast.

The willful violation is for failing to ensure that employees underwent required annual audiograms. A willful violation is one committed with intentional knowing or voluntary disregard for the law’s requirements, or with plain indifference to worker safety and health.

“Exposing employees to excessive noise levels can cause hearing loss, and exposure to lead and other contaminants can seriously harm workers’ health,” said Jeff Funke, the agency’s area director in San Antonio. “OSHA’s standards exist to protect workers and must be followed to prevent these types of injuries.”

Serious violations include failing to implement effective lead compliance and air monitoring programs protecting employees from overexposure to lead and other heavy metals such as copper and cadmium, ensure medical surveillance included blood lead testing and monitoring, and provide annual training on hazards of working with lead. Additionally, the employer failed to ensure that employees were protected by effective hearing conservation and respiratory protection programs, respectively. A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known.

The citations can be viewed at:

http://www.osha.gov/ooc/citations/aafoundries_315628503_0428_12.pdf*

The company, which employs approximately 23 workers, has 15 business days from receipt of the citations to comply, request an informal conference with OSHA’s San Antonio Area Office or contest the citations and penalties before the independent Occupational Safety and Health Review Commission.

Scenario: You are the safety manager for a manufacturing company with about 500 employees. A spraying operation within your plant requires employees to use respiratory protection consisting of tight-fitting, full face air purifying respirators. The eight employees who work in this area (and therefore must wear a respirator) have completed the medical questionnaire, have been determined to be fit, have had fit tests conducted, and have been provided training as required by the OSHA standard.

Today, the supervisor of the area informs you that one employee, who has been working for over a year, is growing out his facial hair based on his new religious beliefs.  The employee still wants to work in the area and knows he must wear a respirator. He is willing to sign a waiver to release the company of any liability if it is later determined he may have been overexposed due to a poorly fitting respirator.

Question:  Does OSHA require employees wearing a tight fitting respirator to be clean shaven? Will OSHA allow the signing of a waiver or release if an employee chooses to have facial hair that interferes with the seal?  How far does OSHA expect an employer to go to accommodate a religious practice that could ultimately compromise the employee’s safety at work?

Answer:  There are a number of OSHA Directives and Letters of Interpretation that may assist us in determining the answer here.  First, the Respiratory Protection Standard 1910.134(g)(1), Facepiece seal protection, clearly states:

(i) 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; or

(B) Any condition that interferes with the face-to-facepiece seal or valve function.

In a letter of interpretation dated March 7, 2003 to Carl Levin of the United States Senate, OSHA states:

“OSHA’s respiratory protection standard (29 CFR 1910.134) specifies certain requirements for employers to follow when their employees must wear respirators, . . . the employer cannot permit respirators with tight-fitting facepieces to be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face, or that interferes with valve function. While the standard does not ban beards per se, it does require employers to ensure that bearded employees who are required to wear tight-fitting facepieces trim their beards so that they do not interfere with the sealing surface of the respirator or are not so large that they could interfere with valve function.”

As you can see, OSHA will not say point blank that beards are not allowed.  However, if beards are allowed, they can’t interfere with the seal or valve function of the respirator.

Now what about the waiver option?  In another letter of interpretation dated January 18, 1984 to Congressman James T. Broyhill, OSHA states “It is not permissible to negotiate individual exemptions from such requirements by signing a release as suggested.”  In another letter from OSHA on a similar issue dated May 14, 2007 to Mr. Robert M. Sklar, Loss Control Specialist with Pep Boys, OSHA states “. . . employers have duties under the OSH Act from which they cannot be released by having their employees sign waivers”. Therefore, based on these responses, a release or waiver is not an option.

The final question is how far does OSHA expect an employer to go to accommodate a religious practice that could ultimately compromise the employee’s safety at work?  In yet another letter of interpretation dated December 2, 1998 to Mr. William H. Kincaid of Lockton Companies, Mr. Lockton asks this very question.  OSHA’s response is “OSHA has not exempted any workers for religious reasons; however, we recognize that if such a situation should arise, there are respiratory protection alternatives such as loose-fitting hoods or helmets that will accommodate facial hair”.  So as you can see, they leave an opening for this issue that if the employer can accommodate the need with another form of acceptable protection, then the employer should explore that option.  The question that must be answered is can the employer reasonably accommodate the employee’s need and still achieve the necessary protection factor for the employee?

Welding company exposed employees to fire, chemical, respiratory hazards

BRAINTREE, Massachusetts – Guiseppe Falcone and Daniele Falcone, doing business as D & J Ironworks, failed to follow safety precautions, which fire officials indicated led to a fire that cost the lives of two Boston fire fighters, an investigation by the U.S. Department of Labor’s Occupational Safety and Health Administration determined.

The fire in Boston’s Back Bay neighborhood on March 26, 2014, was caused because the Malden-based welding company allowed its employees to install railings using arc welding equipment during high wind conditions. Fire officials said sparks from welding railings at 296 Beacon St. ignited clapboards on an adjacent shed at 298 Beacon St., which led to the fire.

“OSHA found that the company lacked an effective fire prevention and protection program, failed to train its employees in fire safety, did not have a fire watch present and did not move the railing to another location where the welding could be performed safely,” said Brenda Gordon, OSHA’s area director for Boston and southeastern Massachusetts. “This company’s failure to implement these required, common-sense safeguards put its own employees at risk and resulted in a needless, tragic fire.”

The company also failed to protect its employees against respiratory and chemical hazards associated with welding, cutting, drilling and painting operations. It failed to evaluate employees’ medical fitness to wear respirators or train employees how to clean, store and maintain respirators; evaluate respiratory hazards for workers; inform employees of chemical hazards associated with welding and how to address them; and maintain safety data sheets on hazardous chemicals.

OSHA cited D & J Ironworks for 10 serious violations of workplace safety standards and imposed fines of $58,000.  The citations can be viewed here.

WASHINGTON – The Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health today released the Hospital Respiratory Protection Toolkit, a resource for health care employers to use to protect hospital staff from respiratory hazards.

Respirators are used to protect against exposures to airborne transmissible infectious diseases as well as chemicals and certain drugs that may be used in healthcare settings. OSHA’s Respiratory Protection Standard requires that health care employers establish and maintain a respiratory protection program in workplaces where workers may be exposed to respiratory hazards.

“Hospitals are one of the most hazardous places to work,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “One of the ways that we can protect workers in a health care setting is by providing employers with the resources needed to ensure a safe workplace. This toolkit will help protect those workers who dedicate their lives to caring for others.”

“Appropriate respiratory protection is a vital line of defense against airborne hazards hospital workers might face on the job,” said NIOSH Director John Howard, M.D. “This toolkit is an important resource to help health care employers ensure their workers are out of harm’s way when it comes to respiratory hazards.”

The toolkit covers respirator use, existing public health guidance on respirator use during exposure to infectious diseases, hazard assessment, the development of a hospital respiratory protection program, and additional resources and references on hospital respiratory protection programs. Appendix D is an editable document that each hospital can customize to meet its specific needs.

To supplement the toolkit, The Joint Commission, an accrediting body for more than 20,500 health care organizations and programs in the United States, developed an educational monograph, Implementing Hospital Respiratory Protection Programs: Strategies from the Field, to assist hospitals in implementing respiratory protection programs. The monograph, produced in collaboration with NIOSH’s National Personal Protective Technology Laboratory, identifies common implementation challenges, provides specific examples of innovative strategies from healthcare organizations and examines the role of leadership, quality improvement, fit testing and training challenges, and program evaluation.

“Respiratory protection programs enhance safety for both workers and patients, but there are many common challenges associated with their implementation,” said Ana McKee, M.D., executive vice president and chief medical officer, The Joint Commission. “We hope that by showcasing the innovative and effective strategies used by health care organizations across the country to overcome some of these challenges, hospitals can learn from one another as they implement and improve their own respiratory protection programs.”

NIOSH is the Federal agency that conducts research and makes recommendations for preventing work-related injuries and illnesses. It was created under the Occupational Safety and Health Act of 1970 and is part of the U.S. Centers for Disease Control and Prevention. More information about NIOSH can be found at www.cdc.gov/niosh.

OSHA has a suite of resources on protecting workers from safe patient handling hazards on its Worker Safety in Hospitals Web page.

by David McGill, CIH, CSP, CHMM

In a previous blog posting, we presented a basic overview of “What’s an Industrial Hygienist.”  In these next several articles, we’re going to drill down into some of the more fundamental concepts of industrial hygiene.  The goal is to provide you, the reader, with a basic understanding of the science of industrial hygiene.  While some of these concepts may seem rather intuitive on the surface, the underlying principles can be quite complex.

In this article, we are focusing on respiratory protection.  So let’s dive in.  Fundamentally, there are two types of respirators – air supplying and air purifying.  An air supplying respirator (ASR) provides no air filtration.  It depends on an external source of “clean” air.  An air purifying respirator (APR) purifies the surrounding air removing unwanted contaminants and/or particulates.  So an ASR just provides external clean air and an APR cleans the air.  That’s the fundamental difference.

Clearly, the most commonly used and often seen respirator is the air purifying respirator (APR).  These respirators simply remove air contaminants through a filtering mechanism.  “Dirty” air passes through a chemical, mechanical, or combined chemical/mechanical filter, gets cleaned, then inhaled by the user.  That’s all there is to it.  The filter is specifically designed for a particular contaminant or group of contaminants.  For example, there are filters specific for particulate dust, chlorine gas, ammonia gas, carbon monoxide, acid gases, and organic vapor.  Non-particulate filters (chlorine gas, ammonia, etc.), have a chemical in the filter designed to react with the specific contaminant.

Particulate filters are a bit more complicated.  There are 3 series of particulate filters with 3 efficiency levels within each series, so there are a total of 9 classes of particulate filters (3 X 3 = 9).  N-series filters can only be used in oil-mist free environments, R-series filters can be exposed to oil mist but only for 1 shift, and P-series filters can be exposed to oil mist for more than one shift.  For efficiency ratings, the 3 types are 95, 99, and 100 which represent a filtration efficiency of 95%, 99%, and 99.97%.  Therefore, a particulate filter can be rated:  N95, N99, N100, R95, R99, R100, P95, P99, or P100.  Obviously, the P100 filter is the most versatile and the most protective.

Years ago, P100 filters were called HEPA (High Efficiency Particulate Air) filters.  That term is no longer used for respirator filters; although you will still see that term used for air handling filters (asbestos, mold, etc.).  If you’re wondering what happened to HEPA filters, they are now called P100.

The class of respirator you need depends on your work environment.  Normally, an N95 respirator provides adequate protection against typical levels of particulate dust in a standard industrial environment.  I say this with caution because, as always, individual circumstances can vary greatly.  To be sure of the respirator filter class you need, we recommend an evaluation of your work environment by a qualified industrial hygienist.

OSHA cites San Antonio-based AA Foundries for willful, multiple serious safety and health violations

Federal OSHA has cited AA Foundries Inc. with one willful and 20 serious violations for exposing employees to excessive noise levels, lead and copper at the company’s work site in San Antonio. Proposed penalties total $107,600. This equates to nearly one violation and over $4,500 per worker at the foundry.

An investigation that began on Oct. 24, 2011, as part of OSHA’s Primary Metals National Emphasis Program found that employees were exposed to noise levels surpassing 85 decibels, as well as excessive airborne levels of lead and copper, while conducting operations such as pouring molds and grinding on metal cast.

The willful violation is for failing to ensure that employees underwent required annual audiograms. A willful violation is one committed with intentional knowing or voluntary disregard for the law’s requirements, or with plain indifference to worker safety and health.

“Exposing employees to excessive noise levels can cause hearing loss, and exposure to lead and other contaminants can seriously harm workers’ health,” said Jeff Funke, the agency’s area director in San Antonio. “OSHA’s standards exist to protect workers and must be followed to prevent these types of injuries.”

Serious violations include failing to implement effective lead compliance and air monitoring programs protecting employees from overexposure to lead and other heavy metals such as copper and cadmium, ensure medical surveillance included blood lead testing and monitoring, and provide annual training on hazards of working with lead. Additionally, the employer failed to ensure that employees were protected by effective hearing conservation and respiratory protection programs, respectively. A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known.

The citations can be viewed at:

http://www.osha.gov/ooc/citations/aafoundries_315628503_0428_12.pdf*

The company, which employs approximately 23 workers, has 15 business days from receipt of the citations to comply, request an informal conference with OSHA’s San Antonio Area Office or contest the citations and penalties before the independent Occupational Safety and Health Review Commission.

The post OSHA Doubles Down on Double A Foundries appeared first on Advanced Safety & Health.

Does OSHA require employees wearing a tight fitting respirator to be clean shaven?

Scenario: You are the safety manager for a manufacturing company with about 500 employees. A spraying operation within your plant requires employees to use respiratory protection consisting of a tight-fitting, full face air purifying respirator. The eight employees who work in this area (and therefore must wear a respirator) have completed the medical questionnaire, have been determined to be fit, have had fit tests conducted, and have been provided training as required by the OSHA standard.

Today, the supervisor of the area informs you that one employee, who has been working for over a year, is growing out his facial hair based on his new religious beliefs.  The employee still wants to work in the area and knows he must wear a respirator. He is willing to sign a waiver to release the company of any liability if it is later determined he may have been overexposed due to a poorly fitting respirator.

Question:  Does OSHA require employees wearing a tight fitting respirator to be clean shaven? Will OSHA allow the signing of a waiver or release if an employee chooses to have facial hair that interferes with the seal?  How far does OSHA expect an employer to go to accommodate a religious practice that could ultimately compromise the employee’s safety at work?

Answer:  There are a number of OSHA Directives and Letters of Interpretation that may assist us in determining the answer here.  First, the Respiratory Protection Standard 1910.134(g)(1), Facepiece seal protection, clearly states:

(i) 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; or

(B) Any condition that interferes with the face-to-facepiece seal or valve function.

In a letter of interpretation dated March 7, 2003 to Carl Levin of the United States Senate, OSHA states:

“OSHA’s respiratory protection standard (29 CFR 1910.134) specifies certain requirements for employers to follow when their employees must wear respirators, . . . the employer cannot permit respirators with tight-fitting facepieces to be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face, or that interferes with valve function. While the standard does not ban beards per se, it does require employers to ensure that bearded employees who are required to wear tight-fitting facepieces trim their beards so that they do not interfere with the sealing surface of the respirator or are not so large that they could interfere with valve function.”

As you can see, OSHA will not say point blank that beards are not allowed.  However, if beards are allowed, they can’t interfere with the seal or valve function of the respirator.

Now what about the waiver option?  In another letter of interpretation dated January 18, 1984 to Congressman James T. Broyhill, OSHA states “It is not permissible to negotiate individual exemptions from such requirements by signing a release as suggested.”  In another letter from OSHA on a similar issue dated May 14, 2007 to Mr. Robert M. Sklar, Loss Control Specialist with Pep Boys, OSHA states “. . . employers have duties under the OSH Act from which they cannot be released by having their employees sign waivers”. Therefore, based on these responses, a release or waiver is not an option.

The final question is how far does OSHA expect an employer to go to accommodate a religious practice that could ultimately compromise the employee’s safety at work?  In yet another letter of interpretation dated December 2, 1998 to Mr. William H. Kincaid of Lockton Companies, Mr. Lockton asks this very question.  OSHA’s response is “OSHA has not exempted any workers for religious reasons; however, we recognize that if such a situation should arise, there are respiratory protection alternatives such as loose-fitting hoods or helmets that will accommodate facial hair”.  So as you can see, they leave an opening for this issue that if the employer can accommodate the need with another form of acceptable protection, then the employer should explore that option.  The question that must be answered is can the employer reasonably accommodate the employee’s need and still achieve the necessary protection factor for the employee?

What if the Respirator use is voluntary?

OSHA Quiz: Are Beards Allowed When Respirator Use is Voluntary?

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In a previous blog posting, we presented a basic overview of “What’s an Industrial Hygienist.”  In these next several articles, we’re going to drill down into some of the more fundamental concepts of industrial hygiene.  The goal is to provide you, the reader, with a basic understanding of the science of industrial hygiene.  While some of these concepts may seem rather intuitive on the surface, the underlying principles can be quite complex.

In this article, we are focusing on respiratory protection.  So let’s dive in.  Fundamentally, there are two types of respirators – air supplying and air purifying.  An air supplying respirator (ASR) provides no air filtration.  It depends on an external source of “clean” air.  An air purifying respirator (APR) purifies the surrounding air removing unwanted contaminants and/or particulates.  So an ASR just provides external clean air and an APR cleans the air.  That’s the fundamental difference.

Clearly, the most commonly used and often seen respirator is the air purifying respirator (APR).  These respirators simply remove air contaminants through a filtering mechanism.  “Dirty” air passes through a chemical, mechanical, or combined chemical/mechanical filter, gets cleaned, then inhaled by the user.  That’s all there is to it.  The filter is specifically designed for a particular contaminant or group of contaminants.  For example, there are filters specific for particulate dust, chlorine gas, ammonia gas, carbon monoxide, acid gases, and organic vapor.  Non-particulate filters (chlorine gas, ammonia, etc.), have a chemical in the filter designed to react with the specific contaminant.

Particulate filters are a bit more complicated.  There are 3 series of particulate filters with 3 efficiency levels within each series, so there are a total of 9 classes of particulate filters (3 X 3 = 9).  N-series filters can only be used in oil-mist free environments, R-series filters can be exposed to oil mist but only for 1 shift, and P-series filters can be exposed to oil mist for more than one shift.  For efficiency ratings, the 3 types are 95, 99, and 100 which represent a filtration efficiency of 95%, 99%, and 99.97%.  Therefore, a particulate filter can be rated:  N95, N99, N100, R95, R99, R100, P95, P99, or P100.  Obviously, the P100 filter is the most versatile and the most protective.

Years ago, P100 filters were called HEPA (High Efficiency Particulate Air) filters.  That term is no longer used for respirator filters; although you will still see that term used for air handling filters (asbestos, mold, etc.).  If you’re wondering what happened to HEPA filters, they are now called P100.

The class of respirator you need depends on your work environment.  Normally, an N95 respirator provides adequate protection against typical levels of particulate dust in a standard industrial environment.  I say this with caution because, as always, individual circumstances can vary greatly.  To be sure of the respirator filter class you need, we recommend an evaluation of your work environment by a qualified industrial hygienist.

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Welding company exposed employees to fire, chemical, respiratory hazards

BRAINTREE, Massachusetts – Guiseppe Falcone and Daniele Falcone, doing business as D & J Ironworks, failed to follow safety precautions, which fire officials indicated led to a fire that cost the lives of two Boston fire fighters, an investigation by the U.S. Department of Labor’s Occupational Safety and Health Administration determined.

The fire in Boston’s Back Bay neighborhood on March 26, 2014, was caused because the Malden-based welding company allowed its employees to install railings using arc welding equipment during high wind conditions. Fire officials said sparks from welding railings at 296 Beacon St. ignited clapboards on an adjacent shed at 298 Beacon St., which led to the fire.

“OSHA found that the company lacked an effective fire prevention and protection program, failed to train its employees in fire safety, did not have a fire watch present and did not move the railing to another location where the welding could be performed safely,” said Brenda Gordon, OSHA’s area director for Boston and southeastern Massachusetts. “This company’s failure to implement these required, common-sense safeguards put its own employees at risk and resulted in a needless, tragic fire.”

The company also failed to protect its employees against respiratory and chemical hazards associated with welding, cutting, drilling and painting operations. It failed to evaluate employees’ medical fitness to wear respirators or train employees how to clean, store and maintain respirators; evaluate respiratory hazards for workers; inform employees of chemical hazards associated with welding and how to address them; and maintain safety data sheets on hazardous chemicals.

OSHA cited D & J Ironworks for 10 serious violations of workplace safety standards and imposed fines of $58,000.  The citations can be viewed here.

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WASHINGTON – The Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health today released the Hospital Respiratory Protection Toolkit, a resource for health care employers to use to protect hospital staff from respiratory hazards.

Respirators are used to protect against exposures to airborne transmissible infectious diseases as well as chemicals and certain drugs that may be used in healthcare settings. OSHA’s Respiratory Protection Standard requires that health care employers establish and maintain a respiratory protection program in workplaces where workers may be exposed to respiratory hazards.

“Hospitals are one of the most hazardous places to work,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “One of the ways that we can protect workers in a health care setting is by providing employers with the resources needed to ensure a safe workplace. This toolkit will help protect those workers who dedicate their lives to caring for others.”

“Appropriate respiratory protection is a vital line of defense against airborne hazards hospital workers might face on the job,” said NIOSH Director John Howard, M.D. “This toolkit is an important resource to help health care employers ensure their workers are out of harm’s way when it comes to respiratory hazards.”

The toolkit covers respirator use, existing public health guidance on respirator use during exposure to infectious diseases, hazard assessment, the development of a hospital respiratory protection program, and additional resources and references on hospital respiratory protection programs. Appendix D is an editable document that each hospital can customize to meet its specific needs.

To supplement the toolkit, The Joint Commission, an accrediting body for more than 20,500 health care organizations and programs in the United States, developed an educational monograph, Implementing Hospital Respiratory Protection Programs: Strategies from the Field, to assist hospitals in implementing respiratory protection programs. The monograph, produced in collaboration with NIOSH’s National Personal Protective Technology Laboratory, identifies common implementation challenges, provides specific examples of innovative strategies from healthcare organizations and examines the role of leadership, quality improvement, fit testing and training challenges, and program evaluation.

“Respiratory protection programs enhance safety for both workers and patients, but there are many common challenges associated with their implementation,” said Ana McKee, M.D., executive vice president and chief medical officer, The Joint Commission. “We hope that by showcasing the innovative and effective strategies used by health care organizations across the country to overcome some of these challenges, hospitals can learn from one another as they implement and improve their own respiratory protection programs.”

NIOSH is the Federal agency that conducts research and makes recommendations for preventing work-related injuries and illnesses. It was created under the Occupational Safety and Health Act of 1970 and is part of the U.S. Centers for Disease Control and Prevention. More information about NIOSH can be found at www.cdc.gov/niosh.

OSHA has a suite of resources on protecting workers from safe patient handling hazards on its Worker Safety in Hospitals Web page.

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