Updated NIOSH Guidance - Respirators and Facial Hair

September 17, 2018
The OSHA requirement for respirators has been interpreted as: When a respirator is required, an employer is prohibited from allowing respirators with tight-fitting facepieces to be worn by employees who have “facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function. Facial hair is allowed as long as it does not protrude through the respirator seal or extend far enough to interfere with the device’s valve function.”
 
OSHA and ANSI Z88.10-2010 prohibit fit testing respirators when facial hair is at the sealing surface of the respirator. OSHA’s Fit Testing Procedures, 29 CFR 1910.134 Appendix A, Part I, (A)(9), states The test shall not be conducted if there is any hair growth between the skin and the facepiece sealing surface, such as stubble beard growth, beard, mustache or sideburns which cross the respirator sealing surface. Any type of apparel which interferes with a satisfactory fit shall be altered or removed.”
 
Last month, NIOSH updated its guidance regarding facial hair and respirators as follows:
 
“Facial hair that lies along the sealing area of the respirator, such as beards, sideburns, moustaches, or even a few days growth of stubble, should not be permitted on employees who are required to wear respirators that rely on tight facepiece fit. Facial hair either growing in or protruding into the area of the primary sealing surfaces of the respirator will prevent a good seal. Any degradation to the respirator seal will degrade the ability of the respirator to deliver protection, in effect it will have a reduced protection factor. Respirators that normally support a negative pressure in the facepiece will have an increased potential to allow leakage of contaminated air into the facepiece. Respirators designed to maintain a positive facepiece pressure will suffer from reduced service time along with wasting breathing air during use. A worker should not enter a contaminated work area when conditions prevent a good seal of the respirator facepiece to the face.
 
This interpretation applies to all primary seals of tight-fitting full and half facepiece respirators, as well as tight-fitting respirator designs that rely on a neck dam seal.
 
This interpretation does not apply to loose fitting hood or helmet respirator designs such as those used on Powered Air Purifying Respirators, Supplied Air Respirators and Constant-Flow Escape type SCBAs that utilize only capes or shrouds for primary seals. With these type respirators, careful consideration must be given in using these loose fitting face coverings to assure that they do not have a neck dam, a face seal or an integrated, tight-fitting half mask. These respirators, utilizing only capes or shrouds as primary seals, may then be selected and used by workers with facial hair.
 
If a respirator covering includes a hood design and the primary seal around the neck of the wearer, facial hair, such as a full beard, cannot be present in the area of the seal. Additionally, if a hood design includes a primary seal within the hood, by including a component covering the mouth, nose and chin of the wearer (similar to a typical half mask), facial hair cannot be present in the area of the seal of this component. In the event that the respirator design incorporates any one of these sealing mechanisms, facial hair must be prevented from interfering with the sealing surface and the function of the respirator during use.
 
Escape-only types of air purifying respirators are not required by OSHA to be fit tested, but special care must be exercised whenever they are being carried for potential use. For all tight-fitting, escape-only respirators, precautions must be taken to assure that the seal needed for effective use will not be affected by facial hair or body hair in the event the respirators would be needed for escape from a toxic atmosphere.
 
Mouth-bit type escape only respirators are inherently unaffected by facial hair, face size, or neck size and their use and fitting characteristics are not dependent on these features.”
 
Hazardous Waste Training
 
Annual hazardous waste training is required for anyone who generates, accumulates, stores, transports, or treats hazardous waste. Learn how to manage your hazardous waste in accordance with the latest state and federal regulations. Learn how to complete EPA’s new electronic hazardous waste manifest, and the more than 60 changes in EPA’s new Hazardous Waste Generator Improvements Rule. Environmental Resource Center’s Hazardous Waste Training is available at nationwide locations, and via live webcasts. If you plan to also attend DOT hazardous materials training, call 800-537-2372 to find out how can get your course materials on a new Amazon Fire HD10 tablet at no extra charge.
 
NIOSH to Address Concerns on Extending Life of SCBAs
 
On October 5, 2017, the DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) issued special permit 16320 (DOT-SP-16320) Third Edition, to the Digital Wave Corporation. The special permit authorizes the extension of the cylinder original equipment manufacturer (OEM) 15-year service life for certain carbon-fiber reinforced aluminum-lined cylinders (DOT-CFFC) in 5-year increments, up to 15 additional years, for those devices that pass modal acoustic emissions (MAE) requalification testing. DOT-CFFC cylinders include those used by fire departments and first responders as a component of a NIOSH-approved SCBA.
 
NIOSH has heard from stakeholders who are concerned that allowing the requalification of SCBA beyond the original 15-year service life may result in health and safety issues for users. Therefore, NIOSH plans to publish a request for information in the Federal Register to seek information and data about safety problems documented by manufacturers or users.
 
If you have questions or concerns about the application of DOT-SP-16320 to approved and deployed SCBA, review the user instructions, supplemental informational inserts, safety precautions, and SCBA warranty information provided by the NIOSH approval holder. NIOSH has encouraged approval holders to provide respiratory protection program administrators and SCBA users with current recommendations regarding DOT-SP-16320 and service life limitations.
 
Further questions can be addressed by the approval holder of NIOSH-approved SCBA with type CFFC originally marked with DOT-SP-10915, 10945, 11194, 13381, 13179, 13853, 14232, and 14339.
 
Jet-Air Dryers Should Not Be Used in Hospital Restrooms
 
Jet-air hand dryers in hospital toilets spread more germs than disposable paper towels and should not be used, say researchers. Writing in the Journal of Hospital Infection, they argue that the official guidance about how to prevent bacterial contamination in hospital buildings needs to be strengthened.
 
At the moment, the official Department of Health guidance says air dryers can be placed in toilets in the public areas of a hospital but not in clinical areas: not because of the risks they pose for cross contamination but because they are noisy. Mark Wilcox, Professor of Medical Microbiology at the University of Leeds who supervised the international study, said the guidance needed to focus on the infection risks, given the new evidence.
 
The new study looked at bacterial spread in a real world setting – in two toilets in each of three hospitals, which were in the UK, France and Italy. Each of the toilets had paper towel dispensers and jet-air dryers, but only one of these was in use on any given day.
 
Professor Wilcox said: “The problem starts because some people do not wash their hands properly. When people use a jet-air dryer, the microbes get blown off and spread around the toilet room. In effect, the dryer creates an aerosol that contaminates the toilet room, including the dryer itself and potentially the sinks, floor and other surfaces, depending on the dryer design and where it is sited. If people touch those surfaces, they risk becoming contaminated by bacteria or viruses.”
 
Jet-air dryers often rely on no-touch technology to initiate hand drying. However, paper towels absorb the water and microbes left on the hands and if they are disposed of properly, there is less potential for cross-contamination.”
 
The study, led by researchers from the University of Leeds and Leeds Teaching Hospitals Trust, was the largest of its type to investigate whether the way people dried their hands has an impact on the spread of bacteria. This research follows a previous laboratory-based study led by the same team, which found that jet-air dryers were much worse than paper towels or traditional warm air hand dryers when it came to spreading germs.
 
The hospitals used in the study were the Leeds General Infirmary in Yorkshire, Saint-Antoine hospital AP-HP in France, and the Hospital of Udine in Italy. On each day, over 12 weeks, levels of bacterial contamination in the toilets were measured, allowing comparisons to be made when either paper towels or jet-air dryers were in use.
 
Samples were taken from the floors, air and surfaces in each of the toilets. The main target bacteria were:
  • Staphylococcus aureus: responsible for a range of conditions from minor skin and wound infections to life-threatening septicaemia
  • Enterococci: bacteria that can cause difficult-to-treat infections, including in immunocompromised patients
  • Enterobacteria: including Escherichia coli. These bacteria cause a wide range of infections, including gastroenteritis, pneumonia and septicaemia
 
Across the three hospitals, bacterial counts were significantly higher in the toilets on the days that jet-air dryers were in use. In Leeds and Paris, at least five times more bacteria were recovered from the floors when jet-air dryers were in use, compared with paper towels.
 
In Leeds, Staphylococcus aureus (including MRSA) was found three times more often and in higher amounts on the surface of the jet-air dryers compared with the paper towel dispensers. Significantly more enterococci and multidrug resistant bacteria were recovered from either the floors or dust of toilets when the jet-air dryers rather than paper towels were in use. In Italy, the researchers found significantly fewer bacteria on the surface of paper towel dispensers compared with the jet-air dryers, although no significant difference on the floors.
 
Professor Wilcox said: “We found multiple examples of greater bacterial contamination on surfaces, including by faecal and antibiotic-resistant bacteria, when jet-air dryers rather than paper towels were in use. Choice of hand drying method affects how likely microbes can spread, and so possibly the risk of infection.”
 
Frédéric Barbut, Professor of Microbiology at Saint-Antoine hospital AP-HP, said: “The higher environmental contamination observed when using jet air-dryers compared with paper towels increases the risk for cross-contamination.
 
“These results confirm previous laboratory-based findings and support the recent French guidelines regarding hand hygiene, which discourage using jet-air dryers in clinical wards”.
 
The study was funded by the European Tissue Symposium, a trade organization representing companies that manufacture paper towels. However, the research was independently conceived, designed, conducted and interpreted, and was peer-reviewed by experts not involved in the study.
 
Sawmill Cited for Safety Violations
 
OSHA has proposed penalties of $199,183 to American Walnut Company LLC for two repeated and 14 serious safety violations. OSHA initiated an inspection of the St. Joseph sawmill after an employee suffered fatal injuries when he fell into a machine.
OSHA’s safety investigation of the March 12, 2018, incident found the company failed to evaluate job hazards, control hazardous energy, and ensure machines were equipped with adequate guards. The investigation also found the company exposed workers to hazards associated with falls, ladders and electrical safety.
 
“Employers must continually evaluate job hazards and ensure safety guards are in use to protect workers from known hazards in their facilities,” said OSHA Kansas City Area Office Director Karena Lorek. “Employers and workers with questions on OSHA standards can contact OSHA for guidance on creating an effective safety and health program.”
 
Observed noise hazards prompted a subsequent health inspection in April 2018 that found the company exposed workers to hazards associated with combustible dust, noise and the use of chemicals in the facility.
 
Ohio Wood Pallet Manufacturer Cited for Employee Amputation
 
OSHA has cited pallet manufacturer Buckeye Diamond Logistics Inc. – which operates as BDL Supply – for lockout/tagout hazards after an employee suffered an amputation at the Columbus-based company. OSHA proposed penalties of $191,794 for two repeated and four serious violations.
 
The employee suffered a finger amputation while working with an energized pallet stack machine. OSHA investigators determined that the company failed to develop lockout/tag out procedures, install machine guards, and train employees on procedures to prevent machines from starting during service and maintenance; and exposed employees to electrical hazards. OSHA cited the company for similar violations at its Lima and South Charleston, Ohio, facilities in 2016.
 
Researchers Highlight Neglected Evidence on the Cardiovascular Risks of Toxic Metals
 
Exposure to arsenic, lead, copper, and cadmium is associated with increased risk of cardiovascular disease and coronary heart disease, finds a comprehensive analysis of the evidence published today in The BMJ. An accompanying editorial by Ana Navas-Acien at the Columbia Mailman School of Public Health and colleagues points to metals as an important but neglected source of cardiovascular risk.
 
“Despite widespread distribution of toxic metal contaminants, technical reports from environmental and public health agencies often disregard the mounting evidence of associated cardiovascular risk,” Navas-Acien and her co-authors write. “Similarly, metal exposures are neglected by the organizations that produce cardiovascular prevention guidelines.”
 
The editorial calls the new meta-analysis an “important call for attention,” adding that because metals are associated with cardiovascular disease even at relatively low levels of exposure, “population-wide strategies to minimize exposure can further contribute to overall cardiovascular prevention efforts.”
 
In their meta-analysis, Sara Shahzad at the University of Cambridge and colleagues identified 37 separate studies involving almost 350,000 participants. A total of 13,033 coronary heart disease, 4,205 stroke and 15,274 cardiovascular outcomes were reported across the studies, which include several by Columbia Mailman Environmental Health Sciences Professors Navas-Acien and Joseph Graziano. Shahzad and colleagues conclude exposures to arsenic, lead, cadmium, and copper are associated with an increased risk of cardiovascular disease and death.
 
The editorial cites national surveys documenting a marked reduction in population exposure to lead and cadmium (the metals monitored for longest), which the authors say largely reflect public health policies on the control of tobacco, reduction of air pollution, remediation of hazardous waste, renovation of drinking water infrastructures, and banning of lead in gasoline. Concomitant with these reductions, cardiovascular mortality rates decreased by 43%; nearly a third of this decline is explained by a decline in lead and cadmium exposures.
 
However, Navas-Acien and co-authors highlight substantial sources of exposure today: widespread soil contamination; persistence of past uses (house paint and plumbing for lead); continuing industrial uses (plastics and batteries); and presence in tobacco and tobacco smoke, drinking water and ambient air, and dust near industrial and waste sites. Particularly, in low- and middle-income countries, including many countries in Africa and Asia, exposure to high levels of arsenic and lead “is still a serious threat to public health that requires urgent action,” they write.
 
An emerging source of metals is electronic cigarettes, where exposure seems to be the heating coil, from where metals leach into the inhaled aerosol. (Navas-Acien is the co-author of a National Academies of Sciences, Engineering, and Medicine report on e-cigarettes published earlier this year).
 
Alabama Woodworking Company Cited for Exposing Employees to Fire and Explosion Hazards
 
OSHA cited Harrison Industries LLC – operating as Structural Wood Systems Inc. – for exposing employees to multiple hazards at its Greenville, Alabama, worksite. The company faces $85,362 in proposed penalties.
 
OSHA cited the woodworking manufacturer for failing to ensure employees used protective eyewear and respirators, implement a respiratory protection and permit-required confined space program, and use guards on a motorized roller conveyer table; and for allowing combustible wood dust to accumulate, exposing employees to fire and explosion hazards. The inspection was conducted under OSHA’s National Emphasis Program on Combustible Dust and the National Emphasis Program on Amputations.
 
“This investigation is an example of why employers must implement effective safety and health programs to identify and address recognizable hazards that can cause serious injuries to employees,” said OSHA Mobile Area Office Director Joseph Roesler.
 
Grants for Worker Safety Available in Michigan
 
The Michigan Occupational Safety and Health Administration (MIOSHA) announced that companies with 250 or fewer employees can apply for a matching grant of up to $5,000 to make improvements in workplace safety and health. The MIOSHA Workplace Improvement to Safety and Health program is designed to create a safer and healthier work environment while reducing the risk of injury and illness. The grant period begins October 1, 2018 and continues on an ongoing basis until the $250,000 in funding is expended.
 
To qualify for the MIWISH grant program, an employer must meet the following conditions:
  • Have 250 employees or less, company-wide
  • Come under the jurisdiction of MIOSHA
  • A qualified safety professional or safety committee must have conducted a site-specific evaluation justifying the equipment purchase
  • The grant project must be consistent with the recommendations of the safety and/or health evaluation and must directly relate to improvements that will lead to a reduction in the risk of injury or disease to employees
  • The employer must have the knowledge and experience to complete the project and must be committed to its implementation
  • The employer must be able to match the grant money awarded and all estimated project costs must be covered
 
Recommended actions must be in the form of equipment or work area modifications to be used to reduce workplace hazards. Only items referenced in the application can be considered eligible, within the proposed project.
 
Some equipment examples include:
  • Residential Fall Protection Systems
  • Lifting Equipment or Portable Lifting Equipment for In-home Care or Small Nursing/Residential Care Facilities
  • Monitoring Equipment for Confined Space Entry
  • Noise Reduction Engineering Controls
  • Lock Out/Tag Out Systems
  • Cooling Systems for Agriculture-based Worksites
  • Eyewash Stations for the Accommodations Industry
 
For more information about the MIWISH grant program and how to apply, go to www.michigan.gov/mioshagrants, or contact MIOSHA’s Consultation Education and Training grant administrator at 517-284-7811.
 
The MIWISH grant program follows the success of the MIOSHA Safety and Health Improvement Program (MiSHIP) grants that were offered in 2015 in conjunction with MIOSHA’s 40th anniversary.
 
Preparedness and Safety Messaging for Hurricanes, Flooding, and Similar Disasters
 
The Centers for Disease Control and Prevention (CDC) developed a reference document that contains key messages on hurricane and flood related health threats. The Preparedness and Safety Messaging for Hurricanes, Flooding, and Similar Disasters can help local responders quickly create and adapt health communication products for affected communities. The document contains messages on various topics including food safety, carbon monoxide poisoning, waterborne diseases, and mold.
 
ToxTutor Expanded
 
The National Library of Medicine ToxTutor has added new content and topics:
Section 3 (Toxic Effects):
  • “Microbiome” topic added
Section 5 (Toxicity Testing Methods):
  • Additional “Finding Information about Alternatives to Animal Testing” content
  • Microphysiological Systems as used in “tissue chip” and “Organs-on-chips” models added
  • “Human-on-a-Chip” content added
  • Induced Pluripotent Stem Cells (iPSCs) as an emerging approach added
  • Combining “chips” AND iPSCs information topic added
Section 6 (Risk Assessment):
  • Adverse Outcome Pathways (AOPs) content added
  • “What to Consider when Reading about a New Exposure Study” topic added
Section 7 (Exposure Standards and Guidelines):
  • Food Safety in the European Union topic added
 
New sections:
Section 15 Intuitive Toxicology and Risk Communication
Section 16 Environmental Toxicology, Environmental Health, and One Health
 
ToxTutor is a self-paced tutorial covering key principles of toxicology for users of the National Library of Medicine (NLM) chemical and toxicology databases. While a knowledge of anatomy and physiology is not required for viewing ToxTutor, the Introduction to the Human Body from the National Cancer Institute provides a good introduction to the topic.
 
This course is approved for 3 contact hours for California Registered Environmental Health Specialists (REHSs) and National Environmental Health Association’s (NEHA) REHS/RSs. To take the tutorial and receive a certificate, please register and complete the tutorial.
 
Safety News Links