Monthly Archives

February 2021

Meet Victoria Sherrock

By | blog

My main role here at MSD is an Accountant in the Finance Department. I have been in this role for almost 8 years. Since RSM recently merged with MSD, my role has been changing some, but I love the different things that are thrown at me to learn and develop my skills in the department.

My husband, James, and I just had a baby boy in October 2020 (James V) so our lives these days revolve around getting to know this little man and enjoying the new things he does every day. We cannot wait for summer to be able to enjoy the outside with him.

If you could choose to do anything for a day, what would it be?

These days, I would take a “me” day and relax. Maybe get a massage or some much-needed sleep.

What two radio stations do you listen to in the car the most?

Sirius XM – the Highway OR Today’s Country on apple music.

What is your favorite family vacation?

Our honeymoon in Saint Lucia! It was so beautiful and so much fun; I would go back ASAP.

What is your favorite game or sport to watch and play?

 Watching football with my boys/family. (Bengals or Bills)

If you could live anywhere, where would it be?

I would go South, to Tennessee or somewhere near the mountains.

What is your proudest accomplishment?

Becoming a mother to my sweet baby boy.

 

 

 

 

 

 

 

Are Dust Masks Considered Respirators?

By | Uncategorized

December 1, 2013 – One question I always ask trainees when discussing personal protective equipment (PPE) during OSHA 10 hour training classes is whether or not OSHA considers a dust mask to be a respirator. It has been my experience that the vast majority of students in most classes answer “no, it is not”. But the simple answer to that question is “YES, dust masks are considered respirators per the OSHA respiratory protection standard”. However, the steps you must take to comply with that standard can vary greatly, depending on whether the employee’s use of the dust mask is voluntary or mandatory.

 

Let’s begin by looking at the definitions section of the OSHA respiratory protection standard (1910.134, paragraph b). The first thing you should note is that OSHA has provided definitions for a variety of specific types of respirators, such as “Atmosphere-supplying respirator”, “Demand respirator”, and “Self-contained breathing apparatus (SCBA)”. But I want to draw your attention to the definition for the term “Filtering facepiece”; there you will note the definition includes “dust mask” in parentheses, and then goes on to say it means “a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium.”  So that definition alone should clarify for everyone that a dust mask IS considered by OSHA to be a respirator. But if you are still in denial, read this OSHA letter of interpretation about the use of dust masks.

 

What this means is that all applicable rules in the OSHA respiratory protection standard that apply to the use of respirators would apply to dust masks; with “applicable” being the operative term here. For instance, if a worker must wear a dust mask because he or she is exposed to nuisance dust at a concentration that exceeds the OSHA permissible exposure limit (PEL), or even if the employer decides to make the use of a dust mask mandatory for a certain task, then all elements of the respiratory protection standard must be implemented, per paragraph 1910.134(c)(1). That includes, but is not limited to, the development of a written respiratory protection program with site-specific procedures, a medical evaluation and written clearance for that worker to wear the dust mask, an initial fit test of the dust mask to the user (yes, you can fit test a dust mask), which must be repeated annually, and initial respiratory protection training for users which must also be repeated annually. By the way, if you did not know there were PEL’s for dust exposure, refer to Table Z-3 in 1910.1000 and locate “Inert or Nuisance Dust”.

 

But what if the use of a dust mask is a voluntary act on the employee’s part, as opposed to a requirement of the employer?  If that is the case, then we refer to paragraph 1910.134(c)(2). First of all, subparagraph (2)(i) states that “an employer may provide respirators at the request of employees or permit employees to use their own respirators, if the employer determines that such respirator use will not in itself create a hazard.” That section then goes on to state that “if the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix to this section (“Information for Employees Using Respirators When Not Required Under the Standard”).  That means we must ensure that any respirator use will not in itself create a hazard (by ensuring that masks are not used if dirty or contaminated, and that their use does not interfere with the employee’s ability to work safely), plus we must provide the information in Appendix D to any worker who uses any type of respirator, including dust masks, on a voluntary basis.

 

The standard goes on to further require in subparagraph (c)(ii) that “In addition, the employer must establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user”.  So according to that part, we must still implement a written respiratory protection program (albeit an abbreviated version as compared to a full program), and must also have the respirator user receive a medical evaluation and get written clearance to wear the respirator voluntarily, and then we must train the user in applicable cleaning, maintenance, and storage procedures.

 

However, the standard continues with the following footnote; “Exception: Employers are not required to include in a written respiratory protection program those employees whose only use of respirators involves the voluntary use of filtering facepieces (dust masks)”.  Unfortunately, I find that many employers (and employees) see this exception and mistakenly surmise that dust masks are not covered at all by OSHA.  If you read this excerpt carefully, you will see that it does excuse the employer from having to develop a written respiratory protection program if the only voluntary use of respirators by their workers is dust masks. This footnote also excuses the employer from having to get a medical clearance for the worker using a dust mask voluntarily, as well as the training requirements spelled out in subparagraph (2)(ii). BUT, this exception does NOT excuse the employer from the requirement that they present the voluntary user of a dust mask with the information in Appendix D of the OSHA respiratory protection standard.

 

So, to recap; the use of any type of respirator, including a dust mask, that is mandatory because of employer requirements or because of worker exposure to a respiratory hazard exceeds OSHA PEL’s would require the employer to implement all of the elements of a full respiratory protection program. However, if the use of a respirator is voluntary, the actions of the employer will depend on whether the respirator is a dust mask or some other type of respirator. If the respirator is not a dust mask type, the employer must present the voluntary user with the information appearing in Appendix D of the OSHA respirator standard. They must also implement an abbreviated written program, have the employee receive medical clearance to wear the respirator, and give training to that worker on cleaning, maintenance, and storage of their device. But if the voluntary use of the respirator is restricted to a dust mask, then the only requirement is to present the worker with the information in Appendix D.

 

By the way, it is important to note that even though the 1910.134 OSHA respiratory protection standard being discussed in this blog is a general industry standard, it also applies to all other work environments covered by OSHA (construction, maritime, and agricultural).

 

I’ve always said that when it comes to understanding OSHA regulations, the devil is in the details. And that is why it is so important to read the definition section of OSHA standards (see related blog post). Otherwise, you might fall into that group of people who do not know the correct answer to the simple question; “Are dust masks considered respirators?” But more importantly, you would miss the details that spell out which step(s) you must implement to be in compliance with applicable portions of the OSHA respiratory protection standard that are related to voluntary respirator use.

 

If you have questions or comments you would like to share with readers on this topic, please enter that information in the “Comments” section by clicking here and then scrolling down the page to the “Comments” box. And last but not least, I encourage you to Share This Blog Post with Others in Your Network who might benefit from reading this post.

Author:  Curtis Chambers, MS-OSH, CSP

2020

  • 301 citations
  • $3,930,381 fines issued
  • Citation trends:
    • 134 (c)(1) – Written Respiratory Program
    • 134 (e)(1) – Medical Evaluations
    • 4 (a) – Recordkeeping
    • 134 (f)(2) – Fit Testing
    • 134 (a)(2) – Providing Respirators

In 2020 OSHA issued nearly $4,000,000 in citations related to Covid-19. Most of which related to respiratory programs or the lack there of. You must be careful as to what your employees are wearing as face coverings. If what they are wearing falls under the OSHA definition of a respirator, you must follow respiratory standard. In some instances, even a simple dust mask can fall into this category as stated in the article above.

 

Good luck and stay safe!!

 

PHCC Future President Elect

By | blog

I was raised in various towns in Southwest Ohio growing up with the best parents I could have asked for. Growing up I was blessed to be educated in trades work as well as lucky enough to spend time in Mexico as a foreign exchange student. I learned a lot about the value of the freedom we are fortunate enough to have in the United States. I currently reside in Kettering, Ohio with my wife Cheryl. We will be married 25 years in October of 2021. I have an amazing hard-working stepdaughter, Sydney, and her husband David to spend time with. On the weekends I enjoy hunting & applying at least 6 coats of wax on my Jeep Wrangler. My wife and I also enjoy the beaches and spending time on cruises.

Lucky for me I was fortunate to start at a very young age receiving hands-on training.  I started in the trade field at the age of 10 in my father’s commercial refrigeration company. I started out aggravating the technicians and hanging out in the service trucks. I spent every one of my days off school learning from valuable people who taught me the value of customer service. The rewarding feeling to fix something that was a burden to others was motivating for me.  Overall, I have gained 42 years of experience. I received instructional training from many co-workers and manufacturers during my time in the refrigeration field. Scotsman Ice System offered me the position of factory trainer where I was able to travel to service companies and provide their employees with the Manufacturer’s Technical Service Information. Throughout my time of gaining experience, I have attended multiple sales training and personal growth development courses such as Dale Carnegie, Sandler Sales Training, Ed Foreman Successful Life Courses, and Zig Ziglar Courses.

When it comes to picking a career in trades…my first bit of advice is to pick a career that gets you up in the morning. I never have the “Monday Blues” meaning most people dread Sundays because they know Monday morning is right around the corner. In the trades, you will be doing meaningful tasks that affect those around you. Their comfort levels predict the start of their day – will it be a good day? a bad day? In the trade field, the goal is to have any customers or clients have a great day. Sometimes it might take a little extra work to get them to that point but that is all part of the reward. The best part of my career is each day is different. We are faced with different tasks and issues; our job is to resolve them. Every day ends with those who were affected by the issue gaining their comfort back. Providing resolutions that create a satisfied customer is the goal.

MSD, Inc has founded over 35 years ago and continues to be a family-owned business built on a reputation of quality work, service, and integrity. Our focus is to work as a committed partner from conceptual design through project completion and beyond. We value the opportunity to work as a committed partner and take pride in assuring our client’s expectations are met and or exceeded on a consistent basis. Our values and commitment drive me each day to make sure we are always providing the best to our clients.

As Strategic Account Manager, I focus on strengthening and building relationships with our clients. My goal is to ensure quality and value are always delivered. Our team has created a client-centric model. Our Client-Centric Model is based on Securing, Maintaining, Supporting, and Retaining Client Relationships through active listening, communicating, and delivering on promises. We provide phenomenal service with a ‘Live it, Breathe it’ mindset, exceeding client expectations.

Being a PHCC/AACO Ohio member means the world to me. I had not involved myself in organizations prior to this one but have found there are other members who have the same commitment to quality and value in the solutions they provide much like myself. Although I am not a business owner, these folks are not only dedicated to their customers but also to their employees and families affected by their daily business decisions. As president-elect of PHCC there is one perpetual thing I would like to see achieved during my tenure: keeping the integrity of the organizations and the trade. I want to be an advocate for licensed contractors so the consumer can trust the work being provided.

 

-Joe Shank

 

https://online.pubhtml5.com/yksc/gbol/?fbclid=IwAR0AV_nyjzp6vu-6lYWL1-qdY6xrFkSJRQsTnhPcww6ZeBY_iXvXmChBqCU#p=1

Are Dust Masks Considered Respirators?

By | blog

December 1, 2013 – One question I always ask trainees when discussing personal protective equipment (PPE) during OSHA 10 hour training classes is whether or not OSHA considers a dust mask to be a respirator. It has been my experience that the vast majority of students in most classes answer “no, it is not”. But the simple answer to that question is “YES, dust masks are considered respirators per the OSHA respiratory protection standard”. However, the steps you must take to comply with that standard can vary greatly, depending on whether the employee’s use of the dust mask is voluntary or mandatory.

 

Let’s begin by looking at the definitions section of the OSHA respiratory protection standard (1910.134, paragraph b). The first thing you should note is that OSHA has provided definitions for a variety of specific types of respirators, such as “Atmosphere-supplying respirator”, “Demand respirator”, and “Self-contained breathing apparatus (SCBA)”. But I want to draw your attention to the definition for the term “Filtering facepiece”; there you will note the definition includes “dust mask” in parentheses, and then goes on to say it means “a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium.”  So that definition alone should clarify for everyone that a dust mask IS considered by OSHA to be a respirator. But if you are still in denial, read this OSHA letter of interpretation about the use of dust masks.

What this means is that all applicable rules in the OSHA respiratory protection standard that apply to the use of respirators would apply to dust masks; with “applicable” being the operative term here. For instance, if a worker must wear a dust mask because he or she is exposed to nuisance dust at a concentration that exceeds the OSHA permissible exposure limit (PEL), or even if the employer decides to make the use of a dust mask mandatory for a certain task, then all elements of the respiratory protection standard must be implemented, per paragraph 1910.134(c)(1). That includes, but is not limited to, the development of a written respiratory protection program with site-specific procedures, a medical evaluation and written clearance for that worker to wear the dust mask, an initial fit test of the dust mask to the user (yes, you can fit test a dust mask), which must be repeated annually, and initial respiratory protection training for users which must also be repeated annually. By the way, if you did not know there were PEL’s for dust exposure, refer to Table Z-3 in 1910.1000 and locate “Inert or Nuisance Dust”.

But what if the use of a dust mask is a voluntary act on the employee’s part, as opposed to a requirement of the employer?  If that is the case, then we refer to paragraph 1910.134(c)(2). First of all, subparagraph (2)(i) states that “an employer may provide respirators at the request of employees or permit employees to use their own respirators, if the employer determines that such respirator use will not in itself create a hazard.” That section then goes on to state that “if the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix to this section (“Information for Employees Using Respirators When Not Required Under the Standard”).  That means we must ensure that any respirator use will not in itself create a hazard (by ensuring that masks are not used if dirty or contaminated, and that their use does not interfere with the employee’s ability to work safely), plus we must provide the information in Appendix D to any worker who uses any type of respirator, including dust masks, on a voluntary basis.

The standard goes on to further require in subparagraph (c)(ii) that “In addition, the employer must establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user”.  So according to that part, we must still implement a written respiratory protection program (albeit an abbreviated version as compared to a full program), and must also have the respirator user receive a medical evaluation and get written clearance to wear the respirator voluntarily, and then we must train the user in applicable cleaning, maintenance, and storage procedures.

 

However, the standard continues with the following footnote; “Exception: Employers are not required to include in a written respiratory protection program those employees whose only use of respirators involves the voluntary use of filtering facepieces (dust masks)”.  Unfortunately, I find that many employers (and employees) see this exception and mistakenly surmise that dust masks are not covered at all by OSHA.  If you read this excerpt carefully, you will see that it does excuse the employer from having to develop a written respiratory protection program if the only voluntary use of respirators by their workers is dust masks. This footnote also excuses the employer from having to get a medical clearance for the worker using a dust mask voluntarily, as well as the training requirements spelled out in subparagraph (2)(ii). BUT, this exception does NOT excuse the employer from the requirement that they present the voluntary user of a dust mask with the information in Appendix D of the OSHA respiratory protection standard.

So, to recap; the use of any type of respirator, including a dust mask, that is mandatory because of employer requirements or because of worker exposure to a respiratory hazard exceeds OSHA PEL’s would require the employer to implement all of the elements of a full respiratory protection program. However, if the use of a respirator is voluntary, the actions of the employer will depend on whether the respirator is a dust mask or some other type of respirator. If the respirator is not a dust mask type, the employer must present the voluntary user with the information appearing in Appendix D of the OSHA respirator standard. They must also implement an abbreviated written program, have the employee receive medical clearance to wear the respirator, and give training to that worker on cleaning, maintenance, and storage of their device. But if the voluntary use of the respirator is restricted to a dust mask, then the only requirement is to present the worker with the information in Appendix D.

By the way, it is important to note that even though the 1910.134 OSHA respiratory protection standard being discussed in this blog is a general industry standard, it also applies to all other work environments covered by OSHA (construction, maritime, and agricultural).

I’ve always said that when it comes to understanding OSHA regulations, the devil is in the details. And that is why it is so important to read the definition section of OSHA standards (see related blog post). Otherwise, you might fall into that group of people who do not know the correct answer to the simple question; “Are dust masks considered respirators?” But more importantly, you would miss the details that spell out which step(s) you must implement to be in compliance with applicable portions of the OSHA respiratory protection standard that are related to voluntary respirator use.

If you have questions or comments you would like to share with readers on this topic, please enter that information in the “Comments” section by clicking here and then scrolling down the page to the “Comments” box. And last but not least, I encourage you to Share This Blog Post with Others in Your Network who might benefit from reading this post.

 

Author:  Curtis Chambers, MS-OSH, CSP

2020

  • 301 citations
  • $3,930,381 fines issued
  • Citation trends:
    • 134 (c)(1) – Written Respiratory Program
    • 134 (e)(1) – Medical Evaluations
    • 4 (a) – Recordkeeping
    • 134 (f)(2) – Fit Testing
    • 134 (a)(2) – Providing Respirators

In 2020 OSHA issued nearly $4,000,000 in citations related to Covid-19. Most of which related to respiratory programs or the lack there of. You must be careful as to what your employees are wearing as face coverings. If what they are wearing falls under the OSHA definition of a respirator, you must follow respiratory standard. In some instances, even a simple dust mask can fall into this category as stated in the article above.

Good luck and stay safe!!