Pub. 8 2019-2020 Issue 4

30 San Diego Dealer What are the key differences between cloth face coverings, surgical masks, and respirators? Cloth face coverings: • May be commercially produced or improvised (i.e., homemade) gar- ments, scarves, bandanas or itemsmade from t-shirts or other fabrics. • Are worn in public over the nose andmouth to contain the wearer’s potentially infectious respiratory droplets produced when an infected person coughs, sneezes, or talks and to limit the spread of SARS-CoV-2, the virus that causes Coronavirus Disease 2019 (COVID-19), to others. • Are not considered personal protective equipment (PPE). • Will not protect the wearer against airborne transmissible infectious agents due to loose fit and lack of seal or inadequate filtration. • Are not appropriate substitutes for PPE, such as respirators (e.g., N95 respirators) or medical face masks (e.g., surgical masks) in workplaces where respirators or face masks are recommended or required to protect the wearer. • May be used by almost any worker, although those who have trouble breathing or are otherwise unable to put on or remove a mask without assistance should not wear one. • May be disposable or reusable after proper washing. Surgical masks: • Are typically cleared by the U.S. Food and Drug Administration as medical devices (though not all devices that look like surgical masks are medical-grade, cleared devices). • Are used to protect workers against splashes and sprays (i.e., droplets) containing potentially infectious materials. In this capacity, surgical masks are considered PPE. Under OSHA’s PPE standard (29 CFR 1910.132), employers must provide any necessary PPE at no cost to workers. 1 • May also be worn to contain the wearer’s respiratory droplets • Will not protect the wearer against airborne transmissible infectious agents due to loose fit and lack of seal or inadequate filtration. • May be used by almost anyone. • Should be properly disposed of after use. Respirators 2 (e.g., filtering facepieces): • Are used to prevent workers from inhaling small particles, including airborne transmissible or aerosolized infectious agents. • Must be provided and used in accordance with OSHA’s Respiratory Protection standard (29 CFR 1910.134). COVID-19 FREQUENTLY ASKED QUESTIONS: FACE MASKS, SURGICAL MASKS & RESPIRATORS • Must be certified by the National Institute for Occupational Safety and Health (NIOSH). OSHAhas temporarily exercised its enforcement discretion concerning supply shortages of disposable filtering facepiece respirators (FFRs), including as it relates to their extended use or reuse, use beyond their manufacturer’s recommended shelf life, use of equipment from certain other countries and jurisdictions and decontamination. Need proper filter material (e.g., N95 or better) and, other than for loose-fitting powered, air-purifying respirators (PAPRs), tight fit (to prevent air leaks). • Require proper training, fit testing, availability of appropriate medical evaluations and monitoring, cleaning, and oversight by a knowledgeable staffmember. Automotive body shops aremandated to follow this requirement when refinishing automobiles. OSHA has temporarily exercised its enforcement discretion concerning annual fit testing requirements in the Respiratory Protection standard (29 CFR 1910.134), as long as employers have made good-faith efforts to comply with the requirements of the standard and to follow the steps outlined in the March 14, 2020, and April 8, 2020, memoranda (as applicable to their industry). When necessary to protect workers, require a respiratory protection program that is compliant with OSHA’s Respiratory Protection standard (29 CFR 1910.134). OSHA consultation staff can assist with understanding respiratory protection requirements. • FFRs may be used voluntarily if permitted by the employer. If an employer permits voluntary use of FFRs, employees must receive the information contained in Appendix D of OSHA’s Respiratory Protection standard (29 CFR 1910.134). Are employers required to provide cloth face coverings to workers? Cloth face coverings are not considered personal protective equipment (PPE) and are not intended to be used when workers need PPE for protection against exposure to occupational hazards. As such, OSHA’s PPE standards do not require employers to provide them. • The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act, requires each employer to furnish to each of his employees’ employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm. Control measures may include a combination of engineering and administrative controls, safe work practices like social distancing and PPE. We at CSI recommend that employers provide face protection at no cost to employees and enforce mandatory usage. Visitors should be provided with masks at no cost and be required to wear them while on the premises. Certain counties and cities have mandated their use by all when in a commercial establishment. • When transmission risk cannot be controlled through engineering or administrative controls, including social distancing, employers can use cloth face coverings as a means of source control. By Sam Celly, BChE MChE JD CSP, Celly Services, Inc.