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Ask the Experts
Respiratory Protection
Q: We recently had air quality monitoring conducted by an industrial hygienist, and the results were well within the PELs. It was determined that we could go with a program for the voluntary use of respiratory protection rather then a mandatory program for the use of respiratory protection and provide our employees who wish to use respiratory protection with N95 two strap dust masks as comfort masks.
However, in our powder coating operation we have had employees ask if they could bring in and use their own air supplied hood system for personal comfort and cooling and/or cartridge filter type respirators. Would this be allowed under a program for the voluntary use of respiratory protection considering that the employees are not required to use them and are doing so of their own free will? Also, would we have to conduct a health exam and training for the employees choosing to use them?
A: Voluntary use of respiratory protection by employees is covered under the OSHA respiratory protection standard 29 CFR 1910.134 (c)2. OSHA encourages the use of respirators, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. Prior to allowing voluntary use of respiratory protection, employers must determine that such respirator use will not in itself create a hazard. OSHA then requires employers to provide copies of Appendix D of the respiratory protection standard to employees in lieu of training when voluntary use of a respiratory protection is allowed. Appendix D provides awareness to voluntary respirator users of precautions to ensure that use of the respirator does not present a hazard.
When you provide employees with a filtering face piece such as an N-95 dust mask, the employer is not required to develop a written program. However, the voluntary use of elastomeric masks and other respirators requires that the employer have a written program and ensure the employee is medically able to use the respirator. Components of this written program must include 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. Fit testing is not required if respirators are used in atmospheres that are not hazardous.
Medical evaluations are not required by OSHA for voluntary use of a filtering face piece (dust mask). However, employees who use other respiratory protection including respirators such as air supplied positive pressure face masks or hoods must have a medical evaluation before use. A medical evaluation is a component of the employer's written program that must be implemented. OSHA requires that a physician or other licensed healthcare professional operating within the scope of his or her practice needs to medically evaluate employees to determine under what conditions they can safely wear respirators.
Loading Dock Safety
Q: We recently went through a construction project. The depth of our loading dock was shortened and our employees believe it to be unsafe because there is less room to maneuver the pallet jacks when unloading trucks. Is there a standard with or depth for a loading dock?
A: I assume when you refer to “depth or width” you mean the open space inside the building from the back of the dock leveler to the first obstruction (racks, walls, doors, etc.). To the best of my knowledge, there is not a “hard-and-fast rule” for the width or depth of this space.
When making changes to the loading dock, you should consider the following:
- Will you be shipping/receiving full truck loads and staging loads on the dock? If the answer is yes, you will want approximately 75 to 80 feet of dock width or depth.
- Will you be shipping/receiving LTL (less than truck) loads in a cross-dock or just-in-time environment? In this situation, you typically won't need as much space, as there will be little if any “staging" on the dock.
At a minimum, you should have enough space for two-way traffic, which is about 10 feet, running parallel to the wall or first obstruction behind the dock levelers.
Finally, please consult your loading dock representative for a complete loading dock design review.
Asbestos Hazards
Q: How should the OSHA requirements for asbestos training be applied to maintenance workers who are required to work around asbestos-containing materials, such as ceiling and pipe insulation, transite wall panels and old floor tiles, which fall under different classes of work?
A: The OSHA training requirements in the 29 CFR 1926.1101 construction industry standard for asbestos mirror those in the EPA's Asbestos Hazard Emergency Response Act ( AHERA) regulations, 40 CFR 763, Subpart E, within the context of the four classes of work in the OSHA standard. Each class of work has its own requirements for content and duration of training.
Since the reader asks about “maintenance workers,” we can disregard the Class I and II training requirements for workers who remove asbestos on abatement projects. The question thus revolves around what the maintenance workers are doing more than the type of asbestos-containing material (ACM) involved.
Class III work resulting in the disturbance of the ACM, or releasing fibers, requires from four to 16-plus hours of training, including hands-on exercises. The four-hour minimum is noted in a June 29, 1995, “correction” published by OSHA (Federal Register pages 33981 - 33982), and workers who only do one simple task like drilling holes through floor tile or siding can easily be trained in this time. At the other end of the scale, 16 hours or more of training may be needed to properly train workers for multiple or complex tasks. OSHA puts the burden of determining the required duration of training on the competent person. This “correction” makes it clear that just providing the minimum hours of training is not enough; the training must cover the work practices that the employees will actually be using.
If “work around” means just being near the ACM but not intentionally disturbing it, this is Class IV work that requires a two-hour awareness course. The course must cover health effects, types and uses of ACM, locations of ACM in the employees' workplaces, recognition of damaged ACM and avoiding damage. An important part of awareness training is the distinction between Class III and Class IV work. A good example is replacing a light bulb in a fixture attached to a plaster ceiling (Class IV) and removing the fixture from the ceiling (Class III). Awareness training constitutes the first two hours of any Class III training course.
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