Hi List,

I thought I would chime in on the respirator thread because I have been
thinking about issues related to the OSHA standard recently myself. I am
certainly not a safety expert; although I am looking forward to eventually
getting ASCP certified as a Specialist in Safety :) I've got a lot to learn
before I am ready!

As far as the requirement to use respirators if using formalin:

The OSHA Regulations (Standards - 29 CFR) Occupational exposure to hazardous
chemicals in laboratories 1910.1450 states:

(f) (2)  "Exception. Whenever the employer has established that feasible
engineering and work practice controls cannot reduce employee exposure to or
below either of the PELs, the employer shall apply these controls to reduce
employee exposures to the extent feasible and shall supplement them with
respirators which satisfy this standard."

I take this to mean that if regular and appropriate monitoring as defined by
OSHA is being carried out and the exposure limits are below the PEL, then
respirators are not required.

We have never tested above the PEL in our lab but still provide respirators
to those who have exposure while pouring or disposing of the formalin. We do
fit testing and have a regular QC program. We originally had these employees
medically monitored. My question is: If we provide respirators that are not
required, do we still have to have each employee medically monitored each
year as is required for those required to wear a respirator. (whew!)

Thanks!
Marg
Supervisor, Anatomic Pathology
Eisenhower Medical Center
39-000 Bob Hope Drive
Rancho Mirage, CA 92270