Do not ban disposable respirator use! That was ISEA’s principal message to California’s Division of Occupational Safety and Health (Cal/OSHA) on April 20 in response to its proposed amendments to existing lead exposure regulations. The state is proposing to reduce lead exposures to 10 micrograms of lead per cubic meter of air (µg/m3) over an 8-hour period from the current level of f 50 (µg/m3).
ISEA agreed that lowering the permissible exposure limit is a good move for worker safety, but we disagreed in how to protect workers.
In comments to Cal/OSHA, ISEA focused on the proposed ban on disposable respirator use when workers do any type of work that might expose them to lead dust. ISEA said there’s no science behind Cal/OSHA’s statement “filtering facepiece respirators are unlikely to provide adequate protection to employees, due to the difficulty in achieving and maintaining a satisfactory seal on the employee’s face.” (Statement of Reasons, page 18)
ISEA countered that disposable respirators have an Assigned Protection Factor of 10 from OSHA, and that this this number, derived through extensive research and science, indicates most disposable respirators will protect the wearer from inhaling airborne particles.
ISEA added two other comments:
- We told Cal/OSHA to make certain it protects those who work at commercial laundry services that clean workplace coveralls contaminated with lead.
- Ee recommended Cal/OSHA only use disposable paper towels in washrooms and breakrooms where workers remove any lead dust on their hands.