Respiratory Protection: Optional?

With all of the attention by OSHA to dental laboratories now and in recent years regarding the laboratory’s use of silica and beryllium, plus, the newly revised TLV (Threshold Limit Value) for silica being reduced by 50 percent to 0.25mg/m3, we at Safelink have been educating our clients and attendees at workshops about respiratory protection. Itís important for an employer to take the necessary steps to determine if personal protective equipment (PPE) is mandatory or voluntary.  In order to make the determination that voluntary use of PPE is allowed in the areas mentioned above, or other areas where hazardous chemicals are used, air sampling is required.

We have a new consultant at Safelink, April McDowell.  April has an extensive background and education as a safety engineer.  Now that April has had the pleasure of visiting some dental laboratories and becoming more familiar with the safety issues, I asked her to share with you her take on the issue of mandatory use of PPE and air sampling.

April stated, “Due to us to becoming wiser about energy conservation, we have taken actions that have resulted in reduced amounts of outside air entering and leaving our buildings. In other words, our buildings are tighter. Although these changes needed to be made, we’re now experiencing the scientific fact that for every action, there is an equal and opposite reaction. These changes affect us because with less fresh air coming into and out of our buildings, there is the potential build-up of indoor air contaminants. Added to the mix, in the case of dental laboratories, is the use of products that can be harmful if not properly controlled, i.e. monomers and silica containing materials.”

As April and I agree, an employer’s first instinct is to slap a mask or other PPE on employees, but what if the contaminant levels are not significant? PPE is uncomfortable and can be costly. Let’s go about this from a different tack. We should evaluate and take the following steps for workplace hazards:

(1)          Identify the hazards.

(2)           Eliminate the hazard by substitution.

(3)          Institute engineering controls to remove or lessen the exposure.

(4)          Measure the severity level of the hazard.

(5)          Implement PPE.

(6)          Continually enforce and evaluate hazards periodically to see if steps 2 or 3 can be implemented.

We know we don’t always take the time to do steps 2 and 3 and, in many cases, we jump straight to 5 because that’s the way it’s always been done. The step that often gets overlooked is 4. In both the case of silica dust inhalation and monomer vapor inhalation, do you know what your exposure levels are?

I asked April to explain the steps that you should take when deciding to have air sampling performed. Her response was:

   1. Identify a reputable, experienced industrial hygiene-monitoring consultant. This individual, when asked, should tell you they follow the NIOSH sampling strategies. You can even go online to NIOSH/CDC’s site and learn what those strategies are so you will be informed. Also, OSHA has very specific sampling methods that must be used as a minimum acceptable guideline. If not followed, the sampling you paid for may be for nothing should there ever be a court case regarding an exposure.
   2. Get quotes for the sampling and ask for the sampling technician’s/consultant’s qualifications. Remember, you get what you pay for. Ask if the laboratory that analyzes their samples is AIHA accredited. This is a designation that sets them apart from other laboratories as they are recognized by the American Industrial Hygiene Association as following recommended sampling and analysis strategies.
   3. If the sampling results are well below the TLV (Threshold Limit Value) set by the ACGIH (American Conference of Governmental Industrial Hygienists) or OSHA’s PEL (Permissible Exposure Limit), then you do not need to move on to step 5 (PPE) listed above. You must, however, re-sample if you introduce a new employee, equipment, process or product. 

The primary concern regarding air sampling seems to be the cost, so I asked April if she would share with you the usual cost for air sampling. She stated,

“Typical personal samples from a reputable company sampling one employee in a worst case scenario could be:

a.     Silica percent content as a respirable dust - eight hour personal sample (in employee’s breathing zone) analyzed by x-ray diffraction will range from $350 to $1,000 depending on detail of report, travel costs, etc.

b.     Monomer - eight-hour sample using a passive dosimeter, $100 - $1,000 depending on travel costs.”

Not an inexpensive process to go through. You also have the option of calling the OSHA consultation division in your state and asking them to visit your laboratory to conduct a limited service of air sampling. There is no charge for this service.  Some of my clients have requested this service. In one situation, there was over-exposure to the worker to silica dust in the partial framework investing area. In another investing area where workers are in a voluntary use mask program, the results proved that the levels of exposure were well below the TLV.  In the laboratory where there was over-exposure, engineering controls have been installed and further personal sampling by OSHA indicated safe conditions for the worker.

Do you have to sample? No, but how do you answer the following:

(1)             Are all of your employees wearing their PPE while working with these materials 100 percent of the time?

(2)             Is your level of PPE appropriate for the level of the hazard?

(3)             Is your PPE working as it should?

(4)             Do you have a written Respiratory Protection Program?

(5)             Are you conducting fit testing of the respirators to ensure fit?

(6)             Have your workers completed medical questionnaires for submission to a qualified physician to determine if the worker can medically wear a respirator?

(7)             Are you willing to enforce the use of PPE to the point of termination of an employee who refuses to wear the PPE?

(8)             Do you have evidence to support your position if you have not conducted air sampling and have implemented a voluntary respirator program?
Remember, if you have had air sampling performed in the past and have experienced an increase in production, number of workers, changed to different products, installed new equipment, etc., you need to have the air sampling performed again.  Call us at Safelink if you need additional information about air sampling.