As the Fires continue to burn throughout much of California, many of you have asked for more information on the use and training/compliance requirements for providing and authorizing the use of “Respirators”. For your review and consideration please see the attached documents:
T8 CCR §5144 “Attachment D” (see Attached) requirements when authorizing employees to wear (use) while working a N95 type Respiratory (Voluntary).
Safety Message – Wildfire Smoke Source:www.cdc.gov/features/wildfires
You may use this as a “Tailboard” or as a general safety message.
Also attached is a Wildfire alert message posted by CalOSHA (10-17-2017) as a brief summary from several regulations addressing the wildland fires. [Cal/OSHA’s Wildfire-Safety-Notice-for-Employers Cal/OSHA Notice published October 14, 2017, addressing the Fire Storms of 2017. The information is still valid and appropriate guidance.]
Note: As Wildfires are a part of California (and other States, we highly recommend you save these messages and build them into your annual safety-compliance training program. If you have questions or comments please send me a note and we’ll discuss your concerns.
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RESPIRATORY PROTECTION PROGRAM Manual for your files and review.
Respirator Protection requirements
A formal (written) Respirator Protection Program may not be a requirement under “normal” operating conditions, therefore many companies do not have a formal written Respirator Protection Program.
If your company has a current respirator protection program, I highly recommend you review it and consider expanding (if it does not already) it cover “smoke – from wild fire conditions” if you are in a region that is prone to Wildland fires. If your operations “normally” would not necessitate the
The Cal/OSHA Standard that addresses Respirator Protection is: T8 CCR §5144
Within that Standard there is a section known as Appendix D which covers “volunteer use” of a particular (dust) mask. The conditions dictate that the employer has conducted a proper hazard assessment of the workplace and has assurances that are no “known or suspected” hazards in which a complete respirator protection program is warranted.
Given the “air” throughout many areas of both northern and southern California are thick with smoke, many employees have requested or simple have taken a safe precaution of wearing a dust-mask. Most of these dust masks are actually N-95 respirators.
Additionally, it may be prudent to review / add a section addressing the effects of local “wild fires” in your emergency action plan (EAP). If you have any specific questions or other compliance issue, please send a detailed email to me and I will address them as quickly as I can.
For those that have employees that may be affected by the smoke-filled air as a result of normal operations within the cast of the smoke-filled air I have attached a safety message and the Appendix D requirements, that may be helpful in this situation. Please keep in mind the “safety message” it is not intended to be used as training to meet the CalOSHA Respirator Standard. It is simple a tool to get people to think and take precautions using a dust-mask.
Emergency Action Plan (EAP) requirements T8 CCR§3220
Most people will concur that It is a good idea for every employer to have an Emergency Action Plan (EAP). When creating an EAP, employers should read and follow the information found in T8 CCR §3220, keeping in mind Cal/OSHA will issue citations for technical failures to adhere to this standard, should an inspection ever occur.
If you have any questions or concerns, send me a note and we can schedule a review of your safety programs and EAP to ensure they are compliant and meet your company needs.
************ DISCLAIMER AND GENERAL MESSAGE ****************
On a personal note, the fire storm situation we are currently facing is highly dangerous. Fires are unpredictable and kill many who thought they were “safe” or who “can make it out”. If the order comes to evacuate, do not hesitate, leave immediately. If you are in an area of concern, prepare a “bug-out bag”. Be ready. Plan a head, move valuable to a distance location (friends or family homes well clear of the fire areas.
This safety alert was crafted because of the fires throughout California. Employer must ensure reasonable safety measures are taken for any employee who may be exposed to the hazards of “smoke” from these fire storms. The use of dust mask or nuisance dust mask may be an option for employees who are in contact with the smoke particulates in the air.
If your employees are working in an area heavy with smoke, you may wish to consider halting normal operations until the smoke has decreased or until you have conducted a thorough review of the potential hazards from the smoke and have crafted a proper action plan.
Greetings from OSHA Compliance Services!
Many of you have been receiving safety messages and “shop talk” emails from me addressing safety and compliance issues I’ve come across in the field over the past several years and have hopefully benefited from them. Over the past several months, the list has grown from a select few to near… well a lot.
My expectation is that you will use the information to support your safety program and share appropriately. Please keep in mind, the information presented is my opinion based solely on my personal experience, observations and training. What I’ve learned during my 24 years’ experience as a safety professional including my time as an Associate Safety Engineer with the CalOSHA High Hazard Unit can be simplified in one sentence. “No one knows everything and so much is open to interpretation”. I’d also add “Trust but verify!” The information offered in these safety messages is not intended to be legal advice nor replace formal training. It is for your information and designed to provoke thought regarding workplace safety and compliance issues.
I ask you forgive the minor spelling and grammar issues and of course if you have a question or comment regarding any issue presented in these messages, please send me a note as soon as possible. If you wish to forward on to a colleague, please do. I will add anyone who wishes to receive these messages.
As we all get dozens if not hundreds of email daily, if any anytime do not wish to receive these messages, please email me asking to be removed from my list.
Respectfully
Paul
Paul Andersen
REA STS CHST OWSI CSHO
OSHA Compliance Services LLC
www.OSHAComplianceservices.com
(925) 787-0220
DISCLAIMER AND GENERAL MESSAGE: The information within the email and attached document is not intended to be legal advice or serve as formal training. Employers are responsible for ensuring they meet all appropriate compliance standards and regulatory requirements.
“Are you compliant or complacent?”
Wildfire-Safety-Notice-for-Employers_CaLOSHA Notice
CDC Wildland Smoke Awareness and cautionary measures _OSHA Compliance Services_(JULY 2018)-FINAL
Wildfire SMOKE N95 _OSHA Compliance Services_(JULY 2018)-FINAL
RESPIRATOR-VOLUNTARY USE _ T8 5144 Appendix D (Fires)
