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From:Bert Dotson <>
To:"Hagerty, Marjorie A." <>
Date:Fri, 24 Sep 1999 08:28:02 -0400 (Eastern Daylight Time)

Marg, The short answer is yes. As long as you provide a respirator 
for an individual, the fitting, training and medical monitoring must 
take place. This is because they may use a respirator and the 
respirator itself may cause injury. 
The solution, if possible in your situation, is to limit the number 
of people fitted for and allowed to use respirators. For example, we 
have about twenty technical personnel in our labs. We have two that 
are fitted for respirators. These individuals are the designated 
first response spill team in our grossing area. Spill plans call for 
these two to contain the spill while others evacuate the area until 
the pros arrive. This solution works for us because we have 
more than adequate engineering controls for other high exposure risk 
activities. The important thing is that a good hazmat program not 
only monitors normal exposures but does a thorough job of assessing 
the risk for accidental exposures. For instance Mary Stevens asked 
about the need for a respirator if you mix your chemicals in a fume 
hood. If the hood is designed to contain a spill of the largest 
volume of chemical mixed in it, the answer is no. If this is not the 
case then there should be a policy to contain and evacuate the area 
in case of spill or some employees should be fitted for respirators. 

To answer Mary's second question: the laws that govern occupational 
exposures and hazmat programs are federal. While the CAP may check 
for compliance, OSHA has jurisdiction over all places of work in the 


On Thu, 23 Sep 1999 10:56:51 -0700 "Hagerty, Marjorie A." 
<> wrote:

> 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
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

Bert Dotson

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