"If we are above the PEL, suspect we could be above the PEL, or we want to err on the side of safety and have our Lead RRP workers wear N-100s, do we really have to go through all that 29 CFR 1910.134 regulatory stuff?"
"What? No depends...no maybe...none of your usual ifs and buts were candy and nuts regulatory speech?"
None of that. Sorry, there is no easy out on this. If you must wear a N-100 or require workers to wear a N-100 then you must comply.
Because they are defined as both a respirator and tight fitting. Here is what the CDC has to say about these types of disposable dust masks:
There are important differences between facemasks and respirators. Facemasks do not seal tightly to the face and are used to block large droplets from coming into contact with the wearer’s mouth or nose. Most respirators (e.g. N95) are designed to seal tightly to the wearer’s face and filter out very small particles that can be breathed in by the user.So, if a tight fitting respirator - such as a N-100 - is "required" it now falls under OSHA's 29 CFR 1910.134 requirements. Respirators then must be used in the context of a comprehensive respiratory protection program which includes:
- fit testing
- medical evaluation
- training of the worker.
- and N-100s cannot be used by workers with facial hair that interferes with the face seal.
Yes. Here is what 3M - a reputable manufacturer of these types of respirators - has to say about that:
Either the FT-10 Qualitative Fit Test Apparatus, which uses a saccharin aerosol, or the FT-30 Qualitative Fit Test Apparatus, which uses a bitter aerosol, is appropriate for fit testing these products. These 10–20 minute procedures demonstrate whether an employee can attain a good face fit with a given style respirator.
Additional fit tests must be conducted whenever a different respirator (size, style, model, or make) is used and if changes in facial structure of the wearer develop that could affect respirator fit."Wow, a fit test on a paper dust mask - did not see that one coming. I suppose next you are going to tell me that the worker must also do a fit check when they put the thing on?"
Yes. Here is what 3M has to say about that:
To perform a user seal [fit] check [d]on the respirator according to the user instructions. Next, place both hands completely over the respirator and exhale. If air leaks between the face and the face seal of the respirator reposition it and readjust the nose clip for a more secure seal. If air leaks around the respirator edges, adjust the position on the face and the straps along the sides of the head and recheck fit. If a proper fit cannot be achieved, do not enter the area requiring respiratory protection."Well that's just great Mr. Rain on my parade. You regulatory safety geeks just make my job harder with all your requirements."
Well then, don't wear a respirator.
"Ahh...I thought you were this "beyond compliance" believer. Now you want me to not wear PPE?"
I only want you to wear PPE that makes sense. PPE has as many downsides as it can have benefits. That's why they wrote the RRP rule the way they did - so that the RRP contractor will do everything to avoid creating dust that would require the use of a respirator. If the lead dust is below the PEL there is no harm. No harm, no silly OSHA required administrative requirements such as a fit check and medical approval to wear a paper mask. Wearing PPE does not provide ultimate employee protection. Even OSHA acknowledges that in the first paragraph of the respiratory standard:
"the primary objective shall be to prevent atmospheric contamination"See, OSHA, the EPA, HUD, CDC have designed regulations and policy that give you a legitimate out. Control the stuff in the air and you will not need to wear a respirator.
If that's not win-win-win I don't know what more can be said.