Reprinted from the ACJ - September, 1998
Good air in, bad air out.
It used to be that easy. Then society began goofing things up. In caveman days, the air quality in your workplace be it a cave, jungle or glacier_
was crisp, clean and refreshing. As long as you stayed upwind of the Mammoth, there was no need for air purifying equipment.
Then the Industrial Revolution showed us that engineers could modernize production, build things and produce power. With it came exhaust, fumes, stinks, and smells. Modern medicine wasn't too far behind in discovering that some fumes and gases were not good for us and that no amount of blood letting or leeches would cure us of the sickness these fumes sometimes caused. Then one of those "you got peanut butter on my chocolate" sort of collisions occurred between engineers and doctors, and the industrial hygienist sprang forth.
His job was to assess the hazards in our workplace and suggest ways to prevent them from making us sick. The government saw these guys and wanted some of the glory, so they kidnapped a few and violá, OSHA was born. In a fashion similar to Mom telling you to "eat your peas and liver," OSHA has always had employees' best interest in mind when regulating the workplace and keeping us safe. You don't like it, it doesn't swallow easy, but you know it is good for you, so you do it.
On the menu, for your consumption, fresh from the dairy case, it's OSHA's new Respiratory Protection Program regulations, 29CFR 1910.134. These new regulations replace the old regs and cover all situations where respiratory protection is required. Dust masks, full mask, half-mask, self-contained breathing apparatus (SCBA), cowboy bandannas_ they're all subject to this set of regulations.
The regulations lay out rather specific rules and guidelines on how employers must assess hazards, provide protection, assess employee health as it relates to respirator use, and provide training. "Hold your breath" just won't cut it any more.
There are nine sections to address in order to comply with the regulations and keep your employees/coworkers healthy and safe. Section 1 covers hazard assessment and respirator selection. You will need to assess the airborne contaminants in the shop: lead, flux fumes, paint fumes, etc. Then measure the levels at which these chemicals are present. Airborne lead sampling can be used here. Also, "Drager" type tube samplers are available to check contaminant levels. Look in your favorite safety catalog to find these. Now with the help of that safety supply catalog, look for respirators that protect against those hazards at the levels you detected.
Section 2 addresses Employee Medical Evaluations, designed to evaluate your employees' ability to wear respirators. This is done through the use of a questionnaire followed by a physical examination performed by a physician familiar with respirator programs. Having Ed run up and down the stairs while breathing through a pillow may be fun to watch, but it won't replace an actual "physical stress" test.
OK, now you know what to protect against, what equipment to use, and that your coworker won't turn blue and drop over while wearing that protection. Next step, make sure the respirator fits. The regulations say you need to provide "adequate styles and sizes to ensure a proper fit for each employee."
This section was probably written by safety equipment people eager to show you the whole product line. So, while 20 types and sizes may be excessive, you can't just cinch up the twist-tie on the plastic bag when placing it over a small guy's head and call it a different "size" respirator.
Once fitted, there is a "sniff" test to make sure that no fumes are leaking in (make up your own jokes here). Don't get disheartened though, because there is some entertainment potential in the fit test. It is required that the respirator wearer perform certain physical movements while wearing the respirator to confirm it stays sealed during real work. The subject must look up, look down, grimace, turn their head, etc. You may be able to sneak in "flap your arms, strut, and make chicken noises" if they aren't paying close attention.
Realize that embarrassing them in this step may make the next more difficult: training. The respirator wearer must be familiarized with the following: proper use of the respirator (this end up), the nature of the hazards present, limits to respirator effectiveness, proper fit, seal checks, and factors curbing its usefulness (such as beards, sideburns, perspiration, making clucking noises while wearing, etc.).
They also need to know the proper cleaning and storing procedures, as well as how to tell when the cartridges have expired. (Hopefully before the wearer expires.)
By now, like me, you are thinking "How can I get out of this?" One way is to install "engineering solutions," such as exhaust, to reduce the air contaminant levels in the shop to below OSHA action levels. This method is actually encouraged by OSHA over respirator use. OSHA prefers this because it continuously reduces the levels of contaminants rather than fill the room with "nasties" and hope people wear protection.
So it may be a wise first step to install or upgrade the exhaust system in the shop before sampling for contaminants. Some lucky shops will find that the fume levels are not above OSHA's limits and that respirator use isn't required. Being nice guys, some of these shops will still provide respirators for their employees just in case they "want" to use one.
Not to let a good deed go unpunished, OSHA has rules for that situation as well. Employers are still required to make sure that anyone wanting to wear a respirator is physically fit enough to do so. They must also provide information so that the employee can assess how to select, fit, and maintain the equipment.
OSHA provides copies of this regulation, 29CFR 1910.134, on its web site at www.osha.gov. It is also producing a "Small Entity Compliance Guide" that should be available by now. You can write to: OSHA, Office of Publications, Room N 3101, 200 Constitution Ave., Washington, DC 20210.
After everything is in place, you can give yourself a pat on the back and realize that you have taken industrial hygiene into the 21st century. But we can't stop there. We must always look ahead. So, allow yourself a method to evaluate your program effectiveness and update it as needed. Something like, Respirator Program Assessment-Suggestions: "Have employees hold breath," "Good air in, bad air out" or maybe, "Stay upwind of the Mammoth..."
The above article was written by David M. Brown, Chief Engineer of Johnson Manufacturing Company, Inc. and is published by JOHNSON with the expressed approval of the National Automotive Radiator Service Association and the Automotive Cooling Journal. Other reproduction or distribution of this information is forbidden without the written consent of JOHNSON and NARSA/ACJ. All rights reserved.
JOHNSON MANUFACTURING COMPANY
114 Lost Grove Road / PO Box 96 / Princeton, Iowa 52768-0096
Phone 563-289-5123 or Fax 563-289-3825