QUESTION:

NIOSH recently estimated that in nearly half of the 600,000+ work sites where respirators are used, they are used by employees on a voluntary basis. What are some of the reasons why respirators are used so widely when usage is not required by regulations?

ANSWERS:

1) If respirators are mandatory, OSHA requires the employer to establish and implement a respiratory program that includes certain elements such as a medical evaluation and fit testing. This can be costly and time consuming. Requirements for voluntary use of respirators, specifically filtering facepieces (dust masks) are much less. If the need for respirators is borderline, it’s likely the employer will classify their respirator use as voluntary.

2) Smaller companies that typically do not have a trained safety professional may not be aware of OSHA regulations or the hazards associated with contaminated air, and therefore do not require their employees to wear respirators, but provide them on the basis of good science.

3) Employees today are more aware of the long-term health effects associated with contaminated air and are more likely to ask for respiratory protection if they feel it’s needed.

John Vincent, Respiratory Product Manager, North Safety Products

Today’s workers are well-informed about materials and chemicals that they come in contact with on a daily basis. Companies today spend thousands of man-hours training their employees. This training has made a very educated employee who knows what risks are associated with different chemicals. Every company has a MSDS book posted in the work area for employees to review any new chemicals that enter the work environment. The more we train our workforce, the more you will see workers using respiratory protection products on a voluntary basis.

Ernie Younins, ISI, SCBA Product Manager

First, the OSHA respiratory program is too complex for most small businesses. Most of the owners look at the details and say, “I can’t do this.” In this tough, competitive economy how does a small manufacturer implement a program that meets the requirement? How does he identify and measure hazards, get medical surveys done, organize fit-testing and get reliable service life data? It’s so much easier for employers to somehow move into a safety penumbra, and classify respirator usage as voluntary.

Second, today there is a mixed message about when protection is necessary. Our national social conscience is divided on this issue, as are some of our regulations. For example, our healthcare workers are routinely exposed to deadly risks and yet advised to wear nothing more than low-grade respirators, a situation that would be intolerable in a workplace owned by, say, a large chemical manufacturer.

The solution? OSHA needs a much simpler program for small companies, and there must be a real effort to make sure that severe risks get high protection, no matter what the industry. Our purpose is to keep workers safe.

Ken Vaughan, Neoterik

Widespread, non-mandatory use of respiratory protection equipment in the United States is primarily due to one major factor — education of our workforce is such that our nation’s employees are much more aware of their surroundings. The environment we work and live in is in the news every single day of the week. Our employees hear the media reports, see the safety issues in their workplace, and understand the effects these environmental exposures can have on them. Respiratory protection is a simple means of preventing potential major problems, both now and in the future.

Micky D. Sullivan, Chief Executive Officer, OMI

When gas, vapors or particles are perceived to be present, people want to be over-cautious about what they might be inhaling into their lungs. Even when there is no danger present according to government standards, people don’t want to risk their health when something preventative can be done.

Tim English, Manager, Technical Support, OHD

There is generally a heightened awareness to the health risks posed by exposure to airborne contaminants. Employers are required to disclose these dangers to comply with OSHA’s Right to Know regulations. Second, even at exposure levels well below permissible exposure limits (PELs), many employees are sensitive to respiratory contaminants, and now that they are aware of the dangers, they want to take precautions even when respirators are not required.

Rick Sustello, VP Strategic Marketing, Respirators, Bacou-Dalloz

An almost infinite number of arguments can be made for voluntary respirator use. A basic fact is that all employees want to feel safe in performing their job functions. Additional rationale include:

• Respirators are sometimes worn as secondary protection in the event that the primary engineering controls fail.
• PELs are 8-hour time-weighted averages (TWA). Workers may see temporary excursions to concentrations higher than the published PEL but lower than the published ceiling value for the contaminant, where applicable. These higher short-term exposures can create temporary irritations or other effects that prompt the worker to request respiratory protection.
• PELs are defined as maximum safe levels for “nearly all” workers repeatedly exposed, day after day, without adverse health effects. Therefore, it is understood and accepted that “some” workers may respond to contaminant levels below the PEL.

Jay A. Parker, CIH, Technical Marketing Manager, Occupational Safety and Health, Bullard

If a worker senses an airborne contaminant, they may request a respirator even though the contaminant is not harmful or is not at a high enough concentration to be harmful. From a morale standpoint, it’s best to give the worker the respirator.

One of the main reasons why OSHA changed the respirator regulation to allow voluntary use of respirators without complying with most parts of the OSHA respirator standard was to address those times where the worker wants to wear a respirator in a situation where the employer does not require respiratory protection. Before the regulations changed, there was an administrative cost of allowing a worker to wear a respirator voluntarily.

The OSHA PELs are inordinately high (1968 ACGIH TLVs). So, technically an airborne contaminant may be at a concentration below the PEL, but at a high enough concentration that the worker gets dizzy or has other symptoms from breathing in the contaminant. So, in that situation, respirator use may be technically voluntary, but probably necessary.

Particles in air are easy to see, thereby making workers concerned that they may be breathing in bad stuff.

Julie A. Tremblay, CIH, CSP, MT (ASCP), Marketing Director, Respiratory Protection, Aearo Company

Respirators are often used voluntarily because there are substances that pose a nuisance to the employee, such as irritation, taste or smell, yet do not exceed the OSHA PELs. In such cases the employee may ask the employer for a respirator for relief from these nuisance substances. This provides the employee with a little more comfort to perform their job. Keep in mind that there are still elements of 29CFR1910.134 (OSHA’s respiratory protection standard) that the employer must comply with even for voluntary use.

Jeffrey S. Birkner, CIH, MS, VP Technical Service, Moldex-Metric