As an analytical laboratory, we operate under the Laboratory Standard
1910.1450 of the OSHA regulations. We have excellent engineering cont
rols,
and have done monitoring for the the atmosphere contaminants that would be
of
concern. We don’t meet the OSHA threshold for any of those.
That being said, we sometimes have to grind samples in knife mills, an
d
this can generate some dust (though still well below the threshold).
Per
1910.134 Appendix D (
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_
table=STANDARDS&p_id=9784)
we conduct and document training to ensure that our employees have a firm b
asis
upon which to choose a dust mask appropriate to their task and comfort.
Now, my toxicology group wants to order surgical masks, and since 1910
.134
defines a “respirator” as:
Filtering facepiece (dust mask) means a negative pressur
e
particulate respirator with a filter as an integral part of the facepiece <
U>or
with the entire facepiece composed of the filtering medium (emphasis
added).
In light of the above definition, I am forced to ask: is a surgi
cal
mask considered a ‘respirator’? Do I now need to document
a) that there is
no condition which
requires use of a respirator/surgical mask/form o
f
protection in the toxicology section and b) that if not, all of the
toxicologists are also trained in accordance with Appendix D to 1910.134?
DIV>
<sigh>
Dr. Bradley K. Norwood
Laboratory Director
Arista Laboratories
1941 Reymet Road
Richmond, VA 23237
(804) 271-5572 ext. 307
(804) 641-4641 (cell)
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