DCHAS-L Archives, Aug 12 2020 - Re: [DCHAS-L] Respirator physicals?

Ooooh. Sic 'em, OSHA thanks Yaritiza. Monona

-----Original Message-----
From: Yaritza Brinker <YBrinker**At_Symbol_Here**FELE.COM>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Wed, Aug 12, 2020 5:08 pm
Subject: Re: [DCHAS-L] Respirator physicals?

And if that doesn't convince them that N95s are classified as respirators, here's the link to OSHA's Enforcement Guidance on N95 Fit Testing. Which clearly refers to N95s as respirators.

Enforcement Guidance documents are written for OSHA Inspectors. This specific guidance ends by saying

"During this COVID-19 pandemic, OSHA field offices should exercise additional enforcement discretion regarding compliance with 29 CFR =A7 1910.134(f) when an employer switches to an equivalent-fitting make/model/size/style N95 or other filtering facepiece respirator without first performing an initial quantitative or qualitative fit test. Where the use of respiratory protection is required and an employer fails to comply with any other requirements, such as initial fit testing, maintenance, care, and training in the Respiratory Protection standard, cite the applicable section(s) of 29 CFR =A7 1910.134.".

https://www.osha.gov/memos/2020-04-08/expanded-temporary-enforcement-guidance-respiratory-protection-fit-testing-n95

Thank you,

Yaritza Brinker

260.827.5402

From: Yaritza Brinker
Sent: Wednesday, August 12, 2020 4:54 PM
To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton..EDU>
Subject: RE: [DCHAS-L] Respirator physicals?

OSHA standards are not really standards, they are requirements written into the CFR. OSHA guidance documents, in multiple places, reinforce the fact that N95s are respirators and must be issued within the framework of a respiratory protection program.

Here's a link to OSHA's National News Release from June.

https://www.osha.gov/news/newsreleases/national/06102020

Here is a link to OSHA's Covid-19 FAQ's page. Go to the Cloth Face Coverings section. It explains the distinction between the different types of masks and respirators, with CFR cross-references.

https://www.osha.gov/SLTC/covid-19/covid-19-faq.html#ppe

Here is a link to OSHA's Mask Fact Sheet.

https://www.osha.gov/Publications/OSHA3219.pdf

Thank you,

Yaritza Brinker

260.827.5402

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Ellisor, Tim
Sent: Wednesday, August 12, 2020 3:03 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Respirator physicals?

** External Email **

Dr. Callen,

I am so glad I read your post here. I have been fighting (to a degree) with my company about the mandatory use of KN-95 masks if workers have to work within 6 feet of each other. Instead of simply reaching out directly to OSHA with a letter of intent they are relying on in house counsel review and case law to justify suspension of ALL requirements for workers to be in the Resp. Prot. Program. That being said, management did say the likelihood of approval for work within 6 ft would be very hard to attain and anyone not comfortable doing the work and thus wearing the KN-95 would not be made to do so.

At this point I feel like I have more than done my due diligence in raising the concerns and frankly I am tired of sounding the proverbial horn and being ignored.

What are the possible ramifications that my company can look forward to and is there anything else I can do to point the company in the right direction to protect not only the workers but the company itself?

Thank you for your time and response,

Timothy A. Ellisor

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU] On Behalf Of John Callen
Sent: Wednesday, August 12, 2020 11:58 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Respirator physicals?

Jim, Joe, Roger & ALL,

What I relate below certainly dates me, but that is why you keep Monona and me around to "Stir the Pot."

You remind me of the Good O;' Days when we always took things very seriously (and not that people don=E2=80™t today) regarding respiratory protection regardless whether it was nuclear or non-nuclear. Those were the days when health physicists, industrial hygienists and safety professionals had the top authority and controlled the reins of respiratory protection equipment instead of differing to materials management and/or purchasing personnel or even distributors.

I had the privilege and honor of meeting and knowing K. Paul Steinmeyer, RRPT first when he worked at Northeast Utilities (1979 - 1984) and thereafter at Radiation Safety Associates, Inc. (Hebron, CT). He was part of the group of "Legends in Their Own Time" I knew back in the mid-1970's through 1980's as Alan Hack, Ed Hyatt and John Pritchard at Los Alamos, Larry Birkner (deceased) at Celanese Corporation/ARCO, Howard Cohen, Ph.D. at Olin Corporation/Yale University, Craig Colton at OSHA Training Institute/3M and Tom Nelson at DuPont/NIHS, Inc. and where they worked at that time.

It was at the time when I had responsibility for calling on and working together with health physicists, industrial hygienists and safety professionals at Consolidated Edison, Northeast Utilities and New York State Power Authority nuclear and fossil fuel sites. I even worked with Stone and Webster during the construction of Millstone III helping to train and fit test the construction workers on respiratory protection equipment. For all of these, NO medical clearance with spirometry, NO training with an exam (YES, an exam) and NO fit testing for tight-fitting respirators meant NO RESPIRATOR! Also and as a corollary for fit-testing, tight-fitting respirator wearers had to be clean shaven so that facial hair did not interfere with the sealing surface of the respirator faceiece or interfere with valve function. That meant NO 5 O'Clock shadow on up to a full beard with wiskers for men and NO "peach fuzz" for women (special case)!

I would strongly suggest that everyone as part of the Division of Chemical Health & Safety, regardless of current responsibilities, read and thoroughly understand the contents of USNRC 10 CFR 20, specifically Subpart H (Sections 20.1701 - 20.1705) and also NUREG/CR-0041 Revision 1. These documents are readily available online. I always carried around with me the paper copies of the 1980's editions (My Bibles), which dates me long before laptops and the internet.

Also Jim, going back to 1970's and until I am "blue in the face" in 2020 today, how many times I have had to repeat and repeat, "A Surgical Mask does not provide respiratory protection but rather helps provide asepsis, a physical barrier between the wearer and the work environment or sterile field." This certainly applies to the "creative masks or face shields" individuals or companies are making to "help" with the social distancing.

Be Safe, Sound, Vigilant and Well!

All My Best,

John B. Callen, Ph.D.

3M Personal Safety Division - Retired

ACS/DCHAS Founding Member

(312) 632-0195

On Aug 12, 2020, at 9:30 AM, James Keating <james.k.keating**At_Symbol_Here**GMAIL.COM> wrote:

Joe,

Plutonium is a genuine serious toxic and radiological exposure risk, it is not some Covid 19 (Flu).

I would suggest a Certified Health Physicist (CHP) as the person to develop and implement a respiratory program for plutonium exposure control.

Regulations that apply here are USNRC 10 CFR 20 for radiation protection. This far more strict than just a respiratory protection program in accordance with 29 CFR 1910.134.

In your case there were also DOE requirements that are basically the same as 10CFR20.

By the way, These Corona virus paper and cloth handkerchiefs are in no way shape or form respirators. They are placebo for the general public. These handkerchiefs will probably exacerbate the risk of contracting the virus through inhalation. Moreover, the Covid 10 organisms are so small in relation to the weave of these face masks that they will pass through. Then almost all of the air exhaled will take the path of least resistance (differential pressure) and be forced through the gap between the face and mask and into the eyes.

These typical medical paper masks are worn to prevent water droplets containing the virus or bacteria from reaching a patient when a doctor or nurse coughs or sneezes when close to that patient. They are not designed to protector the doctor.

The handling of this "pandemic" should have been handled by high risk people (very old and already severely compromised persons taking responsibility and quarantining themselves. While those not at serious risk move on and continue to work, get this flu, get over it and allow "Herd" immunity to solve the problem as is the case with seasonal flu problems.

If that were the policy from the beginning we would be past this "crisis" by now.

What we have done is extend the crisis by our state policies.

Jim Keating

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Roger McClellan
Sent: Monday, August 10, 2020 8:02 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Respirator physicals?

Joe:

I am uncertain of the basis for rules that curtail important services at a time when they are most needed.

Decades ago I was faced with a ridiculous situation that pushed me to take drastic action for a research laboratory, the Lovelace Inhalation Toxicology Research Institute in Albuquerque, NM. ITRI had 225 to 250 employees including about 40 doctoral staff and was funded by the US Department of Energy My solution was to replace our RN with a Nurse Practitioner and conduct all medical exams in an on site clinic. Previously, the medical exams had been conducted off site by an MD at our health care providers clinic. The on site exams included spirometric assessments on all employees irrespective of whether their work involved masks or more elaborate protective gear. As an aside , we worked with Plutonium and other nasty materials as aerosols . (As an aside, an aerosol is a relatively stable suspension of particles and/or droplets in a gaseous media, a definition lost in the current Covid-19 crisis.)

The spirometry results helped convince a lot of individuals to quit smoking. Employees really liked the NP and I still cross paths with former employees who relate that medical conditions, not work related, but identified in the on site clinic had huge impact on their health. I had a highly qualified Occupational MD provide oversight for a few hours a month. The on site NP worked closely with our Health and Environmental Safety Unit staffed with two professionals (with lots of training and credientals) and three technicians. The Head of our Health and Safety unit had authority that included lock down of any laboratory or operation irrespective of the rank of the staff responsible for the lab. Technicians were eager to get on the Institute's Health And Safety Committee and be part of the Institute's overall health and safety efforts.

I am disappointed when I learn the limited authority many CHAS members have in their academic positions.

Best regards,

Roger O. McClellan

On Monday, August 10, 2020, 04:28:17 PM MDT, pzavon**At_Symbol_Here**ROCHESTER.RR.COM <pzavon**At_Symbol_Here**rochester.rr.com> wrote:

Look more closely at the OSHA regulation on this. Most people can be adequately assessed by using a questionnaire, a clunky example of which is in that regulatory appendix, if I recall correctly.

Peter Zavon, CIH
Penfield, NY

PZAVON**At_Symbol_Here**Rochester.rr.com

-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of DCHAS Membership Chair
Sent: Monday, August 10, 2020 4:55 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [DCHAS-L] Respirator physicals?

From: Joseph Peters <joseph.peters**At_Symbol_Here**technipfmc.com>
Date: Mon, 10 Aug 2020 20:06:57 +0000
Re: Respirator physicals?

We are currently trying to qualify two of our employees for respirator use.

All of our employees who are required to use respirators have had physicals (including spirometry) to ensure that they are physically able to use an Air Purifying Respirator (APR) and SCBA. Once they pass the physical, they are fit tested and trained on the proper use and care of the respiratory equipment.

We scheduled appoints with our occupational safety and health provider and were told that they are not allowed to conduct spirometry evaluations at this time due to COVID restrictions.

Have any members of the group experienced this and if so, how were they able to certify employees for respirator use in the absence of spirometry?

BTW, we are located in Massachusetts.

Joe

Joseph C. Peters, PE
Senior Director - Process Technology | Technip Energies P +1 781 340 2901 | M +1 617 620 7120 Joseph.peters**At_Symbol_Here**technipfmc.com

TechnipFMC
56 Woodrock Road | E. Weymouth, MA | 02189 TechnipFMC.com

This email has been sent by or on behalf of TechnipFMC plc, a company registered in England and Wales with registered no. 09909709, and with its registered office address at One St. Paul's Churchyard, London, EC4M 8AP, or one of its subsidiaries.

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
Follow us on Twitter **At_Symbol_Here**acsdchas

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas..org Follow us on Twitter **At_Symbol_Here**acsdchas

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

This email transmission is confidential Louisiana Energy Services, LLC and intended solely for the person or organization to which it is addressed. If you are not the intended recipient, you must not copy, distribute or disseminate the information or take any action in reliance of it. Any views expressed in this message are those of the individual sender, except where the sender specifically states them to be the views of any organization or employer. If you have received this message in error, do not open any attachment but please notify the sender (above) and delete this message from your system. Please rely on your own virus check, as no responsibility is taken by the sender for any damage arising out of any bug or virus. --- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

Electronic Transmission Confidentiality Notice

The information contained in this electronic transmission is private, confidential, the property of the sender, and intended for the use of the recipient(s), only. If you are not the addressee, any disclosure, copying, distribution or use of this information for any purpose is strictly prohibited. If you have received this information in error, please notify the sender, YBrinker**At_Symbol_Here**fele.com, immediately by e-mail and then delete this message. Thank you.
[FE.EN.1]

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

About This Archive \|	DCHAS-L 2020 Index \|	DCHAS-L Yearly Index
Search All Posts: Advanced Search Disclaimer