This OSHA Training blog is dedicated to enhancing knowledge of OSHA-related matters, especially in the areas of OSHA training and new/revised OSHA regulations.
This OSHA Training blog is dedicated to enhancing knowledge of OSHA-related matters, especially in the areas of OSHA training and new/revised OSHA regulations.
It has always been my understanding that a simple dust mask (for nuisance dust) has not been considered a respirator. It is provided by the employer and it's use is voluntary for the employee. I have also been told that if the dust mask has only 1 strap it is considered a nuisance dust mask, with 2 straps it is then considered a respirator (with all the qualifying stuff to go with respirators). If I interpret your article correctly, I must consider ALL dust masks, filtering piece in front or not, 1 or 2 straps, a respirator and treat them accordingly, unless it is voluntary for the employee to wear it. I'm getting confused....
ReplyDeleteSafetyGeek
SafetyGeek..
DeleteThe OSHA definition I referenced in the blog is pretty, as is the letter of interpretation; if it is a dust mask, regardless if it has one strap or two) is a respirator, and must be treated as such. Based on your comments, I believe some of your confusion may stem from OSHA's policy prior to the revision of this standard; back then they used to differentiate between one and two straps as far as use. Now, if a dust mask is worn because it is mandatory (worker exposed over the PEL), it must be a NIOSH approved dust mask (two straps). But if a dust mask is worn voluntarily for comfort reasons only, then the number of straps is irrelevant because there is no over-exposure. Hope this helps.
Good Afternoon Curtis,
DeleteIn order for filtering face pieces to be considered a respirator, it must be certified by NIOSH under 42 CFR 84. Not all dusk masks are certified by NIOSH, as such, you would not consider a dust mask that does not carry the NIOSH certification as a respirator. 1910.134 only apply to respirators, again in order to be classified as a respirator it must be NIOSH certified. I have had this discussion with OSHA compliance officers, as explained to me, if it is not considered to be a respirator (not NIOSH certified), 1910.134 does not apply.
Anonymous.
DeleteFirst of all, I really do appreciate you for taking the time to reply, even though you are in disagreement with what I stated, as it opens up / expands the good dialogue on a subject. And while I respect and understand your opinion, let me explain why I disagree with what you stated.
I too have heard a few compliance officers say a one-strap dust mask is not a respirator, but I have heard many, many more say that they are a respirator, just not NIOSH approved for hazardous environments. Just because a one-strap dust mask is not NIOSH approved does not mean that it's not a respirator, that only means it's not a respirator that is approved for use if the user is exposed to a concentration of contaminant above the OSHA PEL. When you look at the OSHA Quick Card titled "Respirators - Protect Yourself) they recently issued on their website (see link below), you will see that a single strap is shown. The caption does say it is not approved for mandatory use against hazardous materials, but could be used for nuisance particulate. And if that is the case, then Appendix D of 1910.,134 would have to be provided.
Also, consider that the hazards you are trying to warn users of a two-strap dust mask about with Appendix D would also be present is the user was wearing a one-strap dust mask, therefore they need the same protection (and info).
https://www.osha.gov/Publications/3280-10N-05-english-06-27-2007.html
Very good, as usual. A small point, but you are very exact, so I will mention it. I would have change paragraph three, line seven from "exam" to "evaluation". When trying to get employers to understand that they don't have to necessarily send employees in to the doctor to be "examined", I clarify the difference between an evaluation (usually a questionnaire) and an examination if medical conditions or answers to the questionnaire dictate additional medical intervention. (This statement should not be applied to the expanded chemical standards. They need to be complied with by following the specific standard.)
ReplyDeleteThanks for pointing that out, I should have been more careful. I made that change. Wish I had your name so I could give you credit for your help. Thanks again, Curtis
DeleteI have come across this issue a number of times…and I know I will again in the future. I again with your reasoning behind the definition…OSHA clearly defines a filtering facepiece as a respirator (and they use dust mask in their terminology), so yes a dust mask (regardless of the number of straps) is a respirator. Below I have expanded on additional reasoning on why at a minimum only N95s can be used in the workplace:
ReplyDelete• Is the respirator required?
o If so, then NIOSH masks required (minimum of N95, depending on hazard).
• Is the respirator voluntarily worn?
o If so, then follow Appendix D of 1910.134.
Taking note that OSHA clearly states “A label or statement of certification should appear on the respirator or respirator packaging” within Appendix D.
• I am only aware of NIOSH certified respirators, therefore at minimum only a N95 would be ok (dependent on the hazard of course).
o OSHA goes to contradict itself in an interpretation here: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22788
Take note of the following paragraph: “The reason OSHA does not require employers to select NIOSH approved respirators for voluntary use is because voluntary use is only permitted in an environment that presents no health hazard. However, as a matter of promoting safe work practices, OSHA continues to encourage voluntary users to select NIOSH-approved equipment.”
Wow! What a great discussion. Everyone seems to have a good representation supporting their stance. Here is mine.
ReplyDeleteA tight fitting respirator must be fit tested using either qualitative or quantitative means. The current qualitative fit testing using a banana oil or irritant smoke cannot be filtered out from a dust mask because it does not contain the HEPA (99.97% effective, filtering down to .3 Microns) rating. For quantitative fit testing you need to achieve a true number of at least 500, which you cannot find any dusk mask (That I know of) to measure the external resistance and the internal resistance above that 500 number. (Technology may have changed)
So for the fit testing alone I would say that a dusk mask is a form of respiratory protection for personal use. When it is assigned by an employer however, it would not satisfy the regulations from my humble opinion.
The intent of protection should be governed by process management. If you are simply trying to eliminate dust from worker exposure, Engineering controls would most likely be employed first, since the OSHA hierarchy of controls must be implemented into process management, and only after exhausting these various other controls would a worker be allowed into PPE.
If a person is saying chipping up concrete it should be mandatory with any company to protect that worker from harm. Dust in concrete can cause silicosis and it doesn't take years to develop it. It just depends on the task that your employee is doing at the time.
ReplyDeleteAll these arguments fail to point out that even good workplace controls that reduce dust exposure levels to well below the PEL rarely reduce dust levels to zero. In my opinion, no amount of dust is "acceptable" to breathe when it can easily be filtered out through the use of a NIOSH dust mask. To provide the healthiest environment for our employees, we have dust control systems but we also provide and encourage voluntary use of NIOSH dust masks. We converted Appendix D to a form that can be signed and train employees so that they know how to safely use the dust masks. Its not that complicated and it is the right thing to do.
ReplyDeleteIn response to reading the other replies, a mask is not a respirator. People call respirators but in fact a mask is not appreoed by NIOSH, & does not have a NIOSH # affixed to it. a surgical mask is designed to keep the surgical field sterile. If the surgeon coucgs, his/her germs are caught inside the mask. A mask also does not provide an acceptable face piece seal. A single strap dust mask does not carry a NIOSH # and does not come under the requirements of the OSHA respiratory protection standard. There is no reason to test a single strap disposable mask unless you are trying to prove that the user has protevction even though he/she is using the wrong item.
ReplyDeleteOn the other hand, a respirator has a NIOSH # and by design is able to provide an acceptable facepiece seal, if in fact it properly fits the user. Please note that N95 respirators are classified as dust/ mist respiratiors for nusience levels of contaminant. People should be made aware that dispite the fact that the mask may sit on one's face they may not have the intended level of protection that an approved respirator would offer.
Just because a one-strap dust mask is not NIOSH approved does not mean that it's not a respirator, that only means it's not a respirator that is approved for use if the user is exposed to a concentration of contaminant above the OSHA PEL. When you look at the OSHA Quick Card titled "Respirators - Protect Yourself) they recently issued on their website (see link below), you will see that a single strap is shown. The caption does say it is not approved for mandatory use against hazardous materials, but could be used for nuisance particulate. And if that is the case, then Appendix D of 1910.,134 would have to be provided.
DeleteAlso, consider that the hazards you are trying to warn users of a two-strap dust mask about with Appendix D would also be present is the user was wearing a one-strap dust mask, therefore they need the same protection (and info).
https://www.osha.gov/Publications/3280-10N-05-english-06-27-2007.html
Great discussion, but as Ryan points out, dust masks are pretty limited in their protection factor. While they may be technically "respirators", they tend to provide a false sense of protection to the user. I have had employees fail fit tests after having passed them for years, indicating that even experienced and trained users can't be certain on a day to day basis of the protection a dust mask is providing. As safety professionals, we should keep our expectations of how much protection these "respirators" are providing pretty low.
ReplyDeleteWhat if the dust mask is worn, not to protect the employee from a hazard, but to protect an immune-compromised research subject from the employee?
ReplyDeleteHere is a link to an OSHA publication regarding that issue: https://www.osha.gov/Publications/respirators-vs-surgicalmasks-factsheet.pdf
DeleteNice topic! Just wanted to attach the website link to the OSHA Technical Manual regarding "Respiratory Protection" which is one of the resources the CSHOs use as a reference.
ReplyDeletehttps://www.osha.gov/dts/osta/otm/otm_viii/otm_viii_2.html#app_viii:2_1
Curtis,
ReplyDeleteGreat item for discussion. Although this post may be a bit of a departure from "Is a a dust mask a respirator?", I believe it serves as an example of further confusion on the topic. I can only shake my head in disbelief when I know that an employer is largely responsible for enforcing OSHA safety regulations but I read the OSHA LOI concerning an employer not being required to ensure the proper use of a respirator for voluntary use. I strongly believe this dilutes the argument of PPE worn according to manufacurer's recommendations.The relevant text is included below:
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25342
Dear Mr. Miller:
Thank you for your March 29, 2004 letter to the Occupational Safety and Health Administration (OSHA), Directorate of Enforcement Programs, concerning the voluntary use of filtering facepiece respirators. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions or situations not delineated within your original correspondence. Your questions are repeated below along with our response.
Question #1: Does a principal employer have an obligation to prohibit the voluntary use of filtering facepieces by workers who have beards or other facial hair that interfere with the functioning of the filtering facepieces? Does an employer have an obligation to prohibit the voluntary use of filtering facepieces by contractor employees working on the principal employer's premises who have beards or other facial hair that interfere with the functioning of the filtering facepieces?
Response: No, the voluntary use of respirators in atmospheres which are not hazardous does not require the mask to be fit tested or the wearer to a maintain a tight fit, so beards that could interfere with the faceseal or functioning of filtering facepieces would be not be prohibited by the standard.
Question #2: Does an employer have an obligation to ensure that a voluntarily used filtering facepiece is properly donned in accordance with manufacturer's instructions and worn properly (e.g., can the employer prohibit using a filtering facepiece if the user cuts off one of the straps)? Does an employer have an obligation to ensure that a voluntarily used filtering facepiece of a contractor employees working on the principal employer's premises is properly donned in accordance with manufacturer's instructions and worn properly (e.g., can the employer prohibit using a filtering facepiece if the user cuts off one of the straps)?
Response: The standard does not require employers to ensure that workers, voluntarily using filtering facepiece respirators in atmospheres which are not hazardous, wear these respirators according to the manufacturers' instructions, as long as the use of the mask itself is not creating a hazard. Employers may, however, prohibit such misuse as part of their respirator program.
I just wanted to say that I find your blogs extremely helpful and enlightening. I had this situation come up today and remembered you had recently written on this topic. This information will help me work with the policyholder. Thank you, Stacy
ReplyDeleteAre bbp kits required on work trucks now? I am in sales and have heard and seen companies investing money to get their trucks equipped with them yet can't find anywhere where it says its mandatory.
ReplyDeleteBBP kits are not required for forklifts, but are required for the facilities in general.
DeleteI would like to know why filtering facepieces (dust masks) with activated charcoal for protection against some vapors or gases are only for exposures of vapors or gases under PEL?
ReplyDeleteHello Frank. The manufacturers of these masks add the charcoal to help control "nuisance-level" odors; that means they are not intended nor approved for higher levels that reach/exceed the PEL's. Many people find certain odors disagreeable at low levels, even below the PEL's, so they are made available to serve that portion of the work population only. Hope this helps.
DeleteDoes anyone have an example of a voluntary use policy for Dust mask?
ReplyDeleteWhat is the least intrusive means to distribute the Appx D info? Can I have the information on a bulletin board next to the issue area? Must I hand each person a hard copy of the Appx D info with their dust mask? Must I require them to sign a "I have read and understand..." type of statement?
ReplyDeleteOSHA leaves it up to the employer to decide how to handle this, as long as the affected workers are provided with the info. So if you post on a bulletin board, you'd have to make sure it is located where all affected workers have a chance to see it. Also, if an employee cannot read, then were they really provided with the info? Although it is not specifically required, I usually recommend employers hold a toolbox talk/briefing on this subject, and then document the session/topic/date/signatures . . . But that is just my general recommendation.
DeletePosting in an area such as where you mentioned is a great idea. A high visibility/high traffic area where perhaps the 300A is posted, areas where performance metrics and other requisite documents are posted (OSHA posters, labor law posters, etc...). From a training perspective, App D can be incorporated into a very brief CBT module in a training system. Employees can read the info and acknowledge doing once the review is completed. Literacy issues obviously have to be handled on a case by case basis...there's no one recommendation that will ensure all are aware of the guidance.
DeleteI, for one, appreciate the hierarchy of safety controls regarding this issue in so far as nuisance dusts would never approach established PELs requiring all this administrative burden and regulatory risk, and rather leave me with some training and Appendix D
ReplyDelete