N-100 respirators & Lead RRP work. Part 2: The Voluntary Use of Respirators

In my last post the question of "do we have to wear a respirator when doing Lead RRP work?" was posed.

And the answer was - as usual - it depends.  The short answer is no - provided you do everything you can to keep the lead dust levels to below the PEL.  But what happens when employees want to use a respirator or the employee takes a 'to be on the safe side lets provide them' approach?  Well lets open that can-o-worms shall we?

Here is what OSHA has to say about the voluntary use of respirators:

Employers who allow their employees to wear respirators on a voluntary basis when not required by OSHA or the employer must implement limited provisions of a respiratory protection program. When a filtering face piece respirator is all that is used, the employee must be provided a copy of [29 CFR 1910.134] Appendix D.

Well maybe not a big ol' can-o-worms, but still, there is some effort the employer must expend if respirators are to be worn by their employees.  In a Lead RRP work environment, the term "filtering face piece respirator" may be of some help.  The question now to ask will be: "Is an N-100 disposable respirator a filtering face piece respirator?"  Here is what the CDC has to say about that:

Respirators: Unless otherwise specified, "respirator" refers to an N95 or higher filtering face piece respirator certified by the CDC/National Institute for Occupational Safety and Health (NIOSH).

So based on that definition the criteria under OSHA to head over to Appendix D of 29 CFR 1010.134 is a good thing because for all other respirators used on a voluntary basis OSHA further states:

For all other voluntary users, an additional written respirator program that covers medical fitness and proper maintenance procedures must be implemented.

Which in case you are wondering what those worms look like it means this:

[t]he 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.

Using a N-100 respirator on a voluntary basis gets you out of all this provided the employer does the following:

[d]etermines that such respirator use will not in itself create a hazard.

What this means is will the respirator itself cause a problem.  This could include restricted breathing, fatigue, restricting vision, rash, head aches from the straps, and on and on.  So if you say nope - none of that will take place all you need to do is head on over to Appendix D of 29 CFR 1910.134 and address these little tiny worms by giving the employee the following information:

1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirators limitations.
2. Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging.
3. Do not wear your respirator into atmospheres containing contaminants for which the respirator is not designed to protect against.
4. Keep track of your respirator so that you do not mistakenly use someone else's respirator.

OK, not so bad, just make sure of two things...it is a N-95, N-98, or N-100 type respirator.  N-100s are recommended for lead because the "100" is comparable to a HEPA filter's 99.97% efficiency for 0.3 micrometer airborne particles.

And the other?  See the last post.  To be voluntary you cannot put a worker in a hazardous atmosphere.

"So what happens if the lead dust is above the PEL?  Does a N-100 disposable mask meet the OSHA definition of a respirator requiring the same procedures as a "real" respirator?"

Yes.

"But it's a paper dust mask!"

Correct, but you still have treat it like a respirator because it is defined as a respirator

Next Post:  N-100 respirators & Lead RRP work. Part 3: designation as "tight fitting"


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