April Letters

Respiratory Protection* … OSHA requires employers to institute engineering and work practice controls as the primary means to reduce and maintain employee exposures to air contaminants to levels at or below the OSHA permissible exposure limits (PELs). Primary reliance on engineering controls and work practices is consistent with good industrial hygiene practice. OSHA also relies on traditional adherence to a hierarchy of controls that prefers engineering and work practice controls over dependence upon respirators…. Comments 1. Page 28, middle column, 1st full paragraph — This paragraph should incorporate: “Where toxic substances are present in the workplace, OSHA requires employers to maintain exposure levels at or below the PEL by implementing engineering and work practice controls.”… Unfortunately, OSHA standard 29 CFR 1910.134(a)(1) fails to mention the ability of the employer to rely on work practice controls to reduce exposures…. 2. Page 28, right column, last paragraph — It is unclear what the author means when he states, “The aforementioned statistic reveals that too many workers are not employing appropriate protection from respiratory hazards on the job.” What does…