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Frequently Asked Questions
Personal Protective Equipment
(The
following are Technical Interpretations provided
by the Florida Department of Labor and Employment
Security)
| Q: |
Is there a standard, either
OSHA or ANSI, that covers/requires employees
with long hair to put it in a hair net
while they are working on or near powered
machinery? |
| A: |
There
is no specific OSHA standard in either
1910 Subpart I (personal protective equipment)
or 1910 Subpart O (machinery and machine
guarding) regarding hair nets and usage.
However, if a machine guard does not provide
adequate protection and long hair could
become entangled in moving parts of machinery,
the employer should require that the employee's
hair be covered or confined. (OSHA
publication 2095, p. 14) Caps and
hair nets should be used to confine hair
to prevent the worker's hair from being
caught in machinery. (OSHA publication
3067, p. 10) Generally, employers
should cover this area in a safety policy
that prohibits such items as unconfined
neckties, dangling jewelry, as well as
unconfined long hair from being situated
near operating machinery where injury could
result. Certain workplaces have standards
on sanitation that may further influence
the workplace in this regard. {29
CFR 1910.132 (a)} |
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| Q: |
A manufacturer's MSDS recommends
the use of gloves. Is the employer required
to provide gloves for the employees use? |
| A: |
Yes,
if required on the MSDS. Whenever it is
necessary by reason of hazards of processes
or environment, CHEMICAL HAZARDS, radiological
hazards, or mechanical irritants encountered
in a manner capable of causing injury or
impairment in the function of any part
of the body through absorption, inhalation
or physical contact, personal protective
equipment for the extremities must be provided,
used, and maintained. {29 CFR 1910.132
(a)} |
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| Q: |
Are
there any personal protection requirements
for employees using household bleach in
the workplace? |
| A: |
Yes.
Employers are required to provide protective
gloves, chemical goggles, and a face shield
for employees who are exposed to corrosive
liquids. Household bleach (i.e., Clorox),
also known as sodium hypochlorite (CAS
No. 7681-52-9), is a strong eye, skin,
and mucous membrane irritant that is commercially
available in 5% and 12 % concentrations.
The extent of irritation depends on the
concentration of sodium hypochlorite and
the duration of exposure. {29 CFR
1910.132 & .133} |
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| Q: |
What
are the medical requirements for wearing
a respirator? |
| A: |
There
are no specific medical requirements for
wearing a respirator. A local physician
must determine what health and physical
condition is pertinent for the employee
to use the equipment and perform the work.
This medical determination may or may not
consist of a full or partial physical examination
of the employee. If, in the judgement of
the local physician, no physical examination
is deemed necessary, then a statement from
the physician indicating that the employee
may use the respirator at work is acceptable. {29
CFR 1910.134 (b) (10)} |
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| Q: |
Respirators
are used in a facility. Are physical examinations
required on an annual basis? |
| A: |
No.
The standard on respiratory protection
provides that persons should not be assigned
to tasks requiring the use of respirators
unless it has been determined that they
are physically able to perform the work
and use the equipment. The local physician
shall determine what health and physical
conditions are pertinent.
There is no
examination requirement for an annual physical
examination. However, this section recommends,
but does not mandate, that the respirator
user's medical status be reviewed periodically.
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| Q: |
What
is meant by medical evaluation and fit
testing for respirators? |
| A: |
29
CFR 1910.134 (a) (2) does require that
an employer provide respirators when such
equipment is necessary to protect the health
of the employee. This standard further
requires that an employer providing respirators
shall be responsible for the establishment
and maintenance of a respiratory protective
program. The requirements of such a respiratory
protective program are listed under 29
CFR 1910.134 (b).
Medical examinations
are not required by 29 CFR 1910.134 (b) (10).
However, other specific standards, for example:
29 CFR 1910.1025 (j) (3), "Lead," and
29 CFR 1910.1001 (l) (1) - (3), "Asbestos," do
require medical examinations for certain
users of respiratory protection devices.
29 CFR 1910.134
(b) (10) describes one of the required elements
of a respiratory protective program. The
program must address the instruction that
persons who are not physically able to use
respirators should not be assigned to tasks
requiring respirator use. The standard does
not specify how the employer shall address
this issue. It does provide, however, that
any determination of whether or not a particular
condition of a specific employee precludes
him or her from respirator use shall be made
by a local physician.
29 CFR 1910.134
(b ) (10) does not require, but recommends,
periodic review of the medical status of
employees who use respirators. Other specific
standards, such as 29 CFR 1910.1011 (g) (1)
(ii), "4-Aminodiphenyl," and 29
CFR 1910.1017 (k) (2), "Vinyl Chloride," mandate
employers establish and maintain medical
surveillance programs providing employees
with periodic medical examinations at no
cost to the employee. These standards, however,
shield specific operations and do not apply
to other applications.
Examples of
policies that could be included within a
respiratory protective program to meet the
requirements of (b) (10) are: 1) requiring
each employee to bring a note from his or
her doctor saying that the employee is physically
able to perform the work and use the respirator,
2) providing medical exams for all employees
by a physician designated by the employer,
or 3) requiring each employee to respond
to a questionnaire which asks if the employee
has any existing condition or other reason
that would make him or her physically unable
to perform the work and wear a respirator;
any employee responding positively to the
questionnaire would not be assigned tasks
requiring use of respirator, unless a physician
determines that he or she is able to use
a respirator.
Fit-testing
for all users of respirators is required
by 29 CFR 1910.134 (e) (5). The American
National Standards Practices for Respiratory
Protection Z88.2-1969, incorporated by reference
in 29 CFR 1910.134c, defines a respirator
as: "A device designed to protect the
wearer from the inhalation of harmful atmospheres." The
procedures specified in 29 CFR 1910.134 (e)
(5) apply whenever respirators are used.
This means that whenever respirators are
required or permitted by the employer, any
employee who is a user of the respiratory
protective device must be fitted and fit-tested.
Fitting may be accomplished in accordance
with the manufacturer's facepiece fitting
instructions. The actual fitting and fit-test
are part of the employer's respirator training
program.
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