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March-April 2020

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26 PalletCentral • March-April 2020 palletcentral.com OSHA revised its views on respirator use, testing and maintenance. Many pallet companies either mandate or make available for use these N95 "dust masks"... OSHA now says that as long as employers make "good faith effort" to comply, it will not issue citations for violations of the annual fit testing mandate…The exception will expire once the public health crisis ends. whether face shields, surgical masks, and eye goggles were provided as interim protection. OSHA has no infectious disease standard, but it does have protections for workers from infection under its Blood Borne Pathogens rule. For airborne illnesses, there is no equivalent protection other than citing employers under its General Duty Clause (Section 5(a)(1) of the OSH Act) for failing to protect workers against recognized hazards that can cause death or serious injury/illness, and for which there is feasible abatement available. OSHA's guidance and recommended precautions, as well as the CDC guidelines, can impute such knowledge to employers. OSHA also has applicable respiratory protection rules (29 CFR 1910.134) governing both mandated and voluntary use of respirators, including the N95 masks (which are an APF 10 respirator). But cloth masks brought from home and voluntarily used by employees are not technically respirators and likely fall outside the standard. If employers do permit voluntary use of respirators, they must post Appendix D to 1910.134 in the workplace, and it is a best practice to document that the employees have received and read it. For mandatory respirator use, workers must undergo medical evaluation, fit testing and training (on the make and model respirator provided by the employer at no cost). OSHA's overarching PPE standards require that a hazard assessment must be documented in writing (1910.132) and governing such items as gloves and eye protection. Workers can be exposed by infectious droplets from coughs or sneezes that land on paper,

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