March 31, 1998
John Steelnack, Project Director for the new OSHA Respiratory Protection standard said in a telephone call today that he anticipated the impacts of the standard on LANL to be minimal, since he characterized LANL’s and LLNL’s programs to be "state of the art." LLNL’s James Johnson testified for the record as OSHA’s expert witness and was quoted for the argument that respiratory protection programs must be written because of their complexity.
The language of the new standard fills 30 pages of the Federal Register; the existing standard took up 5 pages in the Code of Federal Regulations. With the revision, all provisions addressing respiratory use, selection and fit testing are deleted from OSHA’s substance-specific standards. Mr. Steelnack said the major changes in the standard provided clarification, definition or specificity to existing requirements, with respect to fit testing, medical evaluation and respirator selection processes, and the most important new requirement was that an employer must designate a respiratory program administrator. He said that, previously, the responsibility for the program was often so diffuse that there was no one person or point of contact available to coordinate the program.
Attached is a document prepared by the OSHA Office of Training and Education this month entitled, "Major Provisions of OSHA’s Respiratory Protection Standard 29CFR1910.134." Standard requirements outlined in this document have been reviewed by Don Trujillo of the respiratory protection section to verify that LANL is in compliance with the revised requirements. The revised standard requires employers to make a determination that respirator use is required by September 8, 1998. Compliance with all other standard provisions is required by October 8, 1998.
Mr. Steelnack pointed to the following as major changes/additions to the standard (revisions are in italics):
Other major revisions not mentioned by Mr. Steelnack were reviewed by Don Trujillo for confirmation of program compliance here at LANL. Mr Trujillo noted that the LANL program in some cases exceeded the requirements of the new standard, e.g., the revision allows acceptable training provided by another employer prior to initial respirator use for compliance with initial training requirements; LANL does not allow training by another employer to be considered as sufficient for initial respirator use training.