Isn't there still liability
I recently had this question asked concerning the "Voluntary Use of Respirators" and I agree or at least think it is a fair question. BTW we are a public facilities maintenance unit with approximately 10 technicians that are essentially field service technicians, moving from place to place chasing work orders.
We have a hard enough time getting our folks to follow the rules that we are required to enforce let alone ones that are left up to the individual AND that directly effects their well-being.
I have a couple of specific questions such as;
1) Are you required to have a written policy if this is the
ONLY use of respirators?
2) What is there to prevent an employee wearing a
respirator that is not designed for the contaminant?
This is just the beginning of my questions but its a fair start!
Comments (3)
This is a pretty hairy dog you are trying to shave here anonymous!
I’m going to start with number 2 because I think you will understand where I am going, and that should answer number 1 too.
Have you evaluated every task, work area, and chemical application that these 10 techs are required work with? Are any of the chemicals corrosive or toxic? Many commercial building chemicals used for maintenance are. Those SDS’s usually recommend respiratory protection.
If the employees are supplying their own PPE because their employer isn’t, and it is required then…
However, if you are 100% certain that the techs never work in any conditions requiring a respirator, then walk them through the justification in training. Show them the SDS’s, explain the working conditions, tell them not to use grinding wheels on cured concrete or any painted surface that hasn’t been marked No Lead Based Paint, etc.
Respirators are better than they used to be, but they aren’t comfortable. My guys all groan when it comes to fit test or bag-house change time.
Question 1) Could you get away without one? Sure. But you’ll need aspects of one. First, what type of respirator are they wearing? Is it a filtering face piece? Meaning the disposal respirators that are usually N95? If so, you must present the workers with the I formation found in Appendix D of 1910.134. If it is any other type of respirator such as a half or full face you still have to do appendix d, but also send the employee for a medical evaluation and ensure that the respirators are cleaned and stored properly.
Question 2) It doesn’t matter, right? If it’s voluntary use, then by definition there’s not enough of a contaminant to worry about. If there is an exposure to a contaminant, you must do an exposure to assessment to determine what level of respiratory protection is required.
Rick and Tim are right on!
I will answer from a HR perspective.
Follow Tim and Rick's advice, except if you allow voluntary use you must follow 1910.134 Appendix D Voluntary use of Respirators." and may have to have Medical Evaluations for respirators above N-95 (learned that from Drew Hinton). In my opinion that alone in my opinion you might as well have a full 1910.134 program including a Written Procedure.
Back to HR.
#1 A good consistent written policy! In that policy, you should say how an employee knows they are safe. When and wear they will wear the proper PPE including respirators. If they are going to wear respirators voluntarily you and they must follow 1910.134 Appendix D. You must train everyone in the this policy!
#2You must manage this policy to ensure compliance and enforce is consistently!
I agree with Rick especially, you are dealing with a "very hairy dog on a very slippery slope!" Good Luck!