text:
Douglas County
This written program establishes policies
and procedures for the effective use of respirators to protect Douglas
County employees from airborne contaminate exposures. These procedures are
mandatory. This written program is based upon the respirator requirements
under Oregon Occupational Safety and Health Administration's rules 1910.134
- Respiratory Protection.
Supply the required respirator,
replacement parts, cartridges, filters, and appropriate cleaning
Supervisors/Safety Manager
Provide training in the maintenance
and use of the respirators and will audit work sites for compliance
with the requirements for the use of respirators. Supervisors are
also responsible to ensure employees wear appropriate respiratory
Wear an approved respirator,
properly fitted at all times while performing an operation defined
as hazardous.
Selection of
Only the National Institute of Occupational
Safety and Health (NIOSH) approved respirators have been selected for use.
The following Respiratory Protection Selection Guide shows the type of
respirator in relationship to the chemical/operations and condition of use.
These respirators have been chosen based on
the type of hazard and the type of protection given by the selected
respiratory equipment. Different sizes and styles of respirators are
available. The specific selection will be based on the fit testing
protocols to determine the best style for each employee to ensure proper fit
and comfort.
The use life of each respirator or
cartridges will vary depending on the job duties and actual time in use.
Each respirator will have some limitations, thus manufacturer instructions
and recommendations must be referred to. Air purifying respirators
(disposable mask, half or full face piece cartridge respirators) cannot
be used in confined spaces where the environment may have less than 19.5%
oxygen or in fumigation operations.
Abrasive: Air line with abrasive blasting helmet/hood
Welding &
Cutting cartridge
Fumes, gases
Half-face piece
respirator with fume or air-line respirator
Spray Painting
(organic solvents paints)
Half-face piece
with organic cartridge and paint spray mist over filter or Airline
system depending on type of paint.
Note: if lead
based paint must use a combination HEPA and organic vapor cartridge.
Dust/Construction Surfacing Activities
Depending on
levels from total or toxic dust disposable respirator, half-mask
face piece respirator with dust filter or HEPA cartridge.
Asphalt Fumes
Fume cartridge
half-mask and/or organic vapor cartridge (non-cancer form)
Herbicides/Pesticides Mixing or, If specifically required on
Depends on
formulation Dust Mists/Vapors
Check MSDS of new Herbicides
Sweepers and
other construction or lawn maintenance equipment (i.e. mowers)
Depending on
levels from total or toxic dust disposable respirator and half-face
piece dust/mist or HEPA cartridge.
Vehicle Exhaust
(i.e. in tunnels, sand sheds, or poor ventilated shops) complex
Carbon monoxide
(CO) Diesel emissions ( CO, oxides of nitrogen and
respirators or special approved gas masks with end-of-service life
Confined space
Atmosphere O2 deficiency Possible IDHL
If IDLH
environment a minimum of 5 min. escape cylinder is required to be
worn in conjunction with the airline
Emergency Fire
Breathing Apparatus (SCBA) O2 deficiency, dust
Smoke, Possible
Painting (organic solvents paints)
Half or full face piece with organic
cartridge and paint spray mist over filter or airline system
depending on type of paint.
if lead based paint must use a combination HEPA and organic vapor
cartridge at a minimum.
Lead based
paints require air-line supply for paint or abrasive blasting
All types of
respirator selected must be NIOSH/MSHA approved for the hazard
For tasks
involving airborne contaminants which are not listed, contact
supervisor or safety manager before beginning work
Appendix 1
Explanation on Cartridge and Filter selection
Appendix 2
Compressed Air Quality for airline or self-contained
breathing apparatus
Appendix 3
Assigned Protection Factors
Availability and
Use of Respirators
When required to wear a respirator, each
employee shall wear an approved respirator selected for the hazard the
person is exposed to. The respirator must be properly worn and fitted at
all times while performing job operations defined as hazardous.
Each employee that needs a respirator will
be issued one by the supervisor or safety manager with proper replacement
parts, cartridges and filters, and cleaning materials. The supervisor is
responsible to see that employees are provided respirators when they are
required by this policy.
Dust and mist disposable mask
Half-face respirator with filters
and chemical cartridges.
Full-face respirator with filters
and chemical cartridges.
Air-supplied respirators include air
lines and self-contained breathing apparatus (SCBA).
Supervisors are responsible to see that the
proper replacement parts, cartridges and filters are available and will be
issued as requested by the employee.
Each employee shall wear a properly fitted
respirator while performing an operation defined as hazardous in TABLE 1.
Employees must wear a respirator when in the immediate area where another
employee is performing a hazardous operation. To aid in defining this area
it will normally be within 10 feet for more than five minutes. This
definition would not apply in cases where regulated areas are established
for lead or asbestos or other chemical exposures.
Respirator requiring a tight face fit shall
not be worn when conditions prevent a good face seal. Such conditions may
The growth of a
beard and/or sideburns
A skull cap
that projects under the face piece
Temple pieces
on glasses
The selection of respirators that are not
listed in TABLE 1 should be based on information from the chemical material
safety data sheet (MSDS), safety equipment supplier and safety manager.
Availability of Respirators for Comfort -
BUT not Required
Respirators are available to employees for
comfort and not under mandatory overexposure situations. In these cases the
following must be required to meet Oregon OSHA basic regulations:
Ensure the employee is medically
able to use the respirator.
Select respirators to match the type
of contaminate.
Instruct employee on how to wear and
maintain the respirator.
Regardless of the use reason for the
respirator, they must be maintained in a clean and sanitary manner
and properly stored
The County requires that any employee using
a respirator voluntarily be medically able to use that respirator, and that
the respirator is cleaned, stored, and maintained so that its use does not
present a health hazard to the employee. The County will not require
detailed fit testing for employees who only wear respirators for comfort and
not as a health hazard safety device. As a result it is critical that
supervisors and the safety manager evaluate all situations where respirators
are being worn to determine the level of program need.
Employees voluntarily using filtering face pieces (dust masks) for their own
comfort where no particulate air contaminate exceeds permissible exposure
levels, will be exempt from the provisions of this program.
Training of Employees
Each respirator user will be trained on how
to use and maintain the respirator based on this program. The training will
be given by supervisor, safety manager or knowledgeable person. Refresher
training will be done every year or when employee changes type of respirator
or as otherwise needed to ensure that the respirator program is followed and
A record will be kept of those employees who
have been trained. Each user must understand and apply the contents of this
respirator program to the daily use, care and storage of the equipment.
To insure the availability of this program,
copies are located in each unit. Employees will be informed where copies
are available.
Fitting of
Prior to fit-testing an employee must
undergo a medical evaluation, provided by the County, to determine the
employee's ability to use a respirator. Employees not capable of wearing a
negative pressure respirator will not be assigned job tasks requiring
respirator use.
Proper fitting of respirators is essential
if employees are to receive the necessary protection from the airborne
contaminate hazards. Air which passes around the face piece of the
respirator, rather than through it, is not being filtered. In order to
ensure that a good face seal can be achieved, the respirator needs to be
carefully fitted.
The following procedures will be followed to
fit the initial wearer and then to be used each time the respirator is used:
(NOTE: See SECTION 3. for details on fit testing).
The respirator straps must be worn
in the correct place as shown in the manufacturer's instructions.
Adjust the head bands until they are tight yet comfortable.
To adjust the face piece properly,
position the chin firmly in the chin cup and manually shift the face
piece until the most comfortable
position is located. Make the final adjustments on the headbands
and do not break the nose seal.
No beards or facial hair are allowed
which interfere with the face fit. This may include long sideburns,
beards and other conditions which would prevent a good seal; also
temple pieces on glasses or a skull cap that projects under the face
A positive and negative pressure
test needs to be performed every time a respirator is worn.
The negative pressure test is
performed on a half or full face piece respirator designed for
filters or chemical cartridges. The test consists of covering the
air inlet lightly and inhaling slightly. If a leak exists, the air
can be felt as it enters. The common leak areas are around the nose
and chin.
The positive pressure test is
performed by blocking the exhalation valve and exhaling lightly.
Again, air leakage can be felt if a leak is evident. If such leaks
are found, the respirator is to be adjusted and retested.
For the initial fitting of a
respirator, a more elaborate test will be conducted on each new
employee or each time a new type of respirator is used. The banana
oil odor test is primarily uses. A knowledgeable person will
conduct the fit testing and may decide at times to use the irritant
smoke test.
Banana oil
(isoamyl acetate) test which can be used to check the respirator fit
when using organic vapor cartridges by determining if the wearer can
detect the odor of bananas.
Irritant smoke
test can be used with particulate filters by determining if the
wearer can detect the irritation of the smoke.
If a fit cannot be achieved,
then a different size or style face piece needs to be fitted.
Maintenance of
Respirators are to be cleaned after each
daily use with alcohol preps and placed dry in a clean container or plastic
bag for storage. More thorough cleaning is needed for dirty respirators or
those shared. This involves performing the following procedures:
Remove the cartridges or filters
from the face piece. The filters and cartridges must not be washed.
Immerse the piece in a warm water
solution of commercial disinfectant liquid. The respirator should be
scrubbed gently with a cloth or soft brush. Make sure that all
foreign material is removed from all the surfaces of the rubber
exhalation valve and plastic exhalation valve seats and face seal.
The inhalation, exhalation valves, valve cover, and cartridges will
be replaced during the quarterly cleaning.
After washing and disinfecting the
respirator, rinse in clean warm water and allow the respirator to
dry before storing.
After the respirator is dry, store
it in a clean container. Respirators should not be stored where
chemicals are used or stored. Respirators should not be hung from
nails on the walls or in chemical storage areas. The respirators
must be stored in a normal position which means that they should not
be stretched or stored under objects which could cause the
face-piece to become warped.
Any respirator malfunction shall be reported
to the supervisor who can evaluate the problem and ensure that proper
replacement parts or a new respirator is supplied to the employee.
Each person assigned a respirator shall be
responsible to maintain the equipment and routinely inspect the respirator
before and after use for worn or dirty parts. WORN PARTS WILL BE REPLACED
Respirators will be periodically evaluated
by the supervisor or safety manager to assure that the equipment is in
proper working order condition and kept clean.
Routine inspection shall include an
evaluation of:
Regulatory and warning devices are
Tightness of the connections
Condition of the face piece
Condition of the headbands
Condition of the cartridges (for
respirators using cartridges)
Condition of the valves, and
Pliability and deterioration of the
face piece material
A written record of the inspections will be
kept by the supervisor. (see form Section 2. D).
Respirator Program Evaluation
It is important that both the respirator
wearer as well as the supervisor and/or safety manager evaluate respirator
use and program effectiveness. It is critical that the appropriate
respirator be worn correctly.
If an employee notices any of the following
they should immediately leave the area and replace the respirator if:
Breathing becomes difficult.
Dizziness or other distress occurs
(see supervisor).
Sense irritation, smell or taste
The respirator becomes damaged.
The overall program will be evaluated by the
safety manager. This includes:
Frequent unscheduled observation of
employee respirator usage during job operations requiring
protection to confirm proper respirator use.
Observation and discussion of the
respirator program with new employees and those who are
not following proper protocols.
Periodic discussions of respiratory
use procedures during safety and management meetings.
The safety manager will use the program
checklist at least annually to determine the overall effectiveness of the
program and needed updates. If deficiencies are found then additional
employee training will be given and more frequency evaluations will be made.
Medical Evaluations to Determine Suitability
for Respirator Use
Medical certification of an employee is required for respirator use by OSHA
rules 1910.1018 (h)(3)(iv) which state that if an employee has demonstrated
difficulty in breathing during the fitting test or during use of
respirators, he or she shall be examined by a physician trained in pulmonary
medicine to determine whether the employee can wear a respirator while
performing the required duty. The purpose of a medical evaluation
is twofold:
To determine if an individual is
medically fit to wear a respirator, provided appropriate health and
safety precautions have been taken in the work environment.
To determine if an individual needs
work restrictions, given the job that he or she is required to do.
NOTE: Job descriptions or job capacity
evaluations need to be available to the physician doing the evaluation.
Oregon OSHA rules 1910.134(e)(1) state that
"The employer shall provide a medical evaluation to determine the employee's
ability to use a respirator, before the employee is fit tested or required
to use the respirator in the workplace." In addition, some specific OSHA
standards for chemical substances or occupations may also contain
requirements for medical examinations. Both standards require that a
physician should determine what health and physical conditions are
pertinent, and that the respirator wearers' medical status should be
reviewed periodically.
In addition, some specific OSHA standards
for chemical substances or occupations may also contain requirements for
medical examinations. Both types of standards require that a physician
should determine what health and physical conditions are pertinent, and that
the respirator wearers' medical status could be reviewed periodically.
Oregon OSHA applies this standard when the
air contaminates level or conditions could result in overexposure to the
permissible exposure limit. Thus if filtering face pieces (dust masks) are
provided for comfort mandatory medical screening would not be required.
Pre-placement medical examinations should
screen out those who are physically or psychologically unfit to wear
respirators. As another part of this examination, medical tests pertinent
to the respiratory hazards that workers may encounter should be made to get
baseline data against which to assess physiological changes in respirator
The medical fitness program requires having
employees medically evaluated to ensure they are able to safely wear
respiratory equipment. The medical fitness evaluation process involves:
Step #1
Notification to the supervisor that
an employee needs to wear a respirator.
(Form A - Respirator Assignment and
Fit Testing Form).
Step #2
Health care provider gives the
health questionnaire and arranges for employee assessment.
Step #3
Supervisor and/or safety manager is
notified by the health care provider whether or not the employee can
wear a respirator.
If pass, then supervisor or safety
manager fits the employee in the appropriate respirator. The
Selection and Fit form is completed and the employee receives a copy
of the form which includes use and maintenance instructions.
If fail, the employee's letter will
have specific instructions for further medical evaluation.
Additional evaluations and/or
testing will be scheduled.
Upon completion of additional
evaluations and/or testing, Health care provider will notify the
Department and employee of a pass status.
If testing indicates additional
medical intervention, Health care provider will contact the
Department Head and Human Resources Department.
Currently, basic standards are available to
determine fitness for respirator use.
It is the responsibility of the evaluating physician to remain updated on
changes in the ANSI and NIOSH guidelines. The ANSI and NIOSH guidelines
also address the frequency of medical fitness determinations. (See Section 5
References: for NIOSH recommended medical protocols.)
The decision to certify an employee for
respirator use depends on many factors; IE: the individual's medical
history, physical examination, and test results (lung function tests, EKG,
stress tests). Thus the following recommended medical examinations and
tests are guidelines for the evaluating physician.
It is recognized that different types of
respirators create different levels of demands on wearers. For example,
wearing a half mask may be less demanding on a worker's physical capacity
than a self-contained breathing apparatus (SCBA). For this reason, and
depending on the employee's job duties, the examining physician may decide
on further medical evaluation based on the medical questionnaire and
physical evaluation that are part of this standard protocol.
It is important to note that the current
Oregon OSHA respirator regulations on medical examinations leave the actual
decision as to the type and detail of the examination up to the evaluating
physician. The ANSI standard and NIOSH decision logic only provide
recommendations. The final decision needs to be made by the evaluating
Additional medical tests may be needed
depending upon the medical findings. These test could include: chest X-ray,
an EKG or a stress test.
Medical testing frequency is not addressed
in the current OSHA respiratory Testing protection rules; however, NIOSH
provides the following recommendation. This Frequency is an area that the
evaluating physician will also need to be consulted. The
following is the
NIOSH suggested frequency of medical fitness determinations for respirator
WORKER AGE (years)
Most work conditions
requiring a respirator
Every 5 years
Every 2 years
Every 1-2 years
Strenuous work
with SCBA
Every 3 yrs
Every 18 months
NOTE: Interim testing would be needed if
changes in health status occur.
Several factors are involved to ensure that adequate reporting and record
keeping is done. Confidentiality of medical results is most important. For
this reason, the Medical Evaluation Report Form Section 2. C. has been
devised that could be used by the evaluating physician to report the
decision back to the employer. It should not list any medical diagnoses or
The employee should
receive notification from the evaluating physician as to the results of
the tests.
It should also be stressed, that the preservation of medical records is
according Medical to OSHA 1910.1020 (d) Preservation of Records
(General Safety and Health Provisions). This requires that the
records be retained for 30 years plus employment duration.
The medical records may be kept by the evaluating physician or in a
confidential file in their Personnel File if the employees agree to
the transfer of their records.
If an employee works for one year or less,
the County may give the employee their records and not retain them. If they
are not given to the employee, then the 30 years retention time is in effect
per the OSHA requirements.
The following tables indicate potential
chemical exposures in relationship to respiratory selection for various
operations. The selection for emergency use will always be Self-contained
Breathing Apparatus (SCBA) Respirators unless the Incident Commander gives
other directions based on an assessment of the emergency release or spill.
The respirator selection charts are based on
the County's data as to what potential chemical exposures can occur and
level of the employee exposures, OSHA, NIOSH, and manufacturer's
The color code system used for respirator
cartridges and canisters is based on ANSI K13.1973 Identification of Air
Purifying Respirator Canisters & Cartridges.
Acid Gas
Organic Vapors
Ammonia Gas
Acid Gas and Organic Vapor
Radioactive or Highly Toxic
HEPA filter
Purple (Magenta)
Dust, Fumes & Mists
Red or gray with a red stripe
Other Vapors & Gases not listed
A purple stripe shall be
used to identify radioactive materials in combination with any vapor or gas
An orange stripe shall be used to
identify dusts, fumes, and mist in combination with any vapor or as
Where labels only are colored to conform
with this table, the canister or cartridge body shall be gray or a metal
canister or cartridge body be left in its natural metallic color.
The user shall refer to the wording
of the label to determine the type and degree of protection the canister or
cartridge will afford.
Supplied Air: SCBA
Supplied Air Respirator:
Air Line
Abrasive Blasting Unit
Gas Masks
Powered Air
Purifying Respirators (PAPRs) Note: the specific
cartridges and
filters would have separate approval
Respirators: includes: HEPA, dust/mist, and dust/
Chemical Cartridges
Ammonia use
300 ppm
Chlorine use 10 ppm
Hydrogen Chloride use 50 ppm
Combination Cl2, HCL & sulfur
for use same as above and SO2 50
Organic Vapor use in general it is
1000 ppm
based on protection factor of 10
Paints with organic vapor & over
filter 1000 ppm
Note other approved
cartridges include:
Chlorine dioxide
Hydrogen fluoride
Hydrogen Sulfide
It is important to note that the listed
respirators are not for emergency or high exposure situations.
Air-purifying respirators are not to be used in conditions which are
immediately dangerous to life or health (IDLH).
Questions about the appropriate respirator
should be directed to the supervisor and/or safety manager.
High quality breathing air (not oxygen) is
required when supplied air respirators or SCBA's are used. The Oregon OSHA
codes (Oregon Administrative Rules Chapter 437, Division 2) require that at
least Grade D quality breathing air be supplied. The specifications for
Grade D breathing air are found in Compressed Gas Association Commodity
Specification G-7.1-1989.
Cylinders of breathing air or compressors
may be used. If compressors are used, it is preferable to use a carbon-vane
pump designed especially for supplied air respirator use. Such pumps are
electric or air-driven, oil-free, and are equipped with inlet and outlet
filters. They do not produce carbon monoxide, oil vapor, or oil mist, as
other compressors may.
If oil lubricated compressors are used, high
temperature alarms, CO monitors and special airline filters are required.
Fittings and couplings for air lines must be
incompatible with outlets for other gas systems to prevent inadvertent
servicing of airlines with irrespirable gases or oxygen.
It is crucial that air compressors or pumps
be placed in locations where the air is clean and breathable at all times.
Compressors and pumps DO NOT remove carbon monoxide, toxic chemicals, or
other air contaminants (other than large-size particulates which are
filtered out at the inlet filter. Inlet and outlet filters, as well as
other special filters with which some systems may be equipped, must be
replaced periodically.
type of respirator used by NIOSH and the
maximum concentration the specific type of respirator can be used for is
determined by:
Upper limit of exposure for type of
respirator = Protection Factor x Employees airborne concentration
Employee's wood dust exposure level was
10 mg/m3 and the OR-OSHA permissible exposure limit (PEL) is 5 mg/m3 -
what is the upper limit of exposure that a disposable respirator can handle?
5 mg/m3 x 5 (protection factor) = 25 mg/m3
The issue as to what level of protection
from a contaminate can be achieved by a particular type of respirator has
been established by general guidelines established by NIOSH (National
Institute of Occupational Safety and Health). County employees are required
to use respirators with the appropriate protection factors. Protection
factor is a numerical number based on the ability of a respirator to
maintain exposure levels below the permissible exposure limits.
The following is the overall guideline for
the commonly used respirators by Douglas County employees. The protection
factor number is set by the
Employee's exposed to toluene during
painting at 150 parts per million (ppm) the PEL is 100 ppm - what
is the upper limit of exposure that a half-mask with organic vapor cartridge
can handle?
- 100 ppm x 10 (protection
factor) = 1,000 ppm
When there are questions about the exposure
levels please contact the safety manager.
Assigned factors are in the following table:
Single use -
disposable mask or quarter face piece mask.
air-purifying half-mask respiratory including the new half-piece
disposable equipped with any type of particulate or chemical
cartridges (note some chemical cartridge may have approval for less
than 10 times the permissible exposure limit)
Any powered
air-purifying respirator (PAPR) equipped with a hood or helmet and
any type of particulate filter.
supplied-air respiratory equipped with a hood or helmet operated in
a continuous flow mode.
air-purifying full face piece respirator equipped with HEPA filters.
Any PAPR
equipped with tight-fitting face piece and HEPA filters.
supplied-air respirator equipped with a tight-fitting face piece and
operated in a continuous flow mode.
supplied-air respirator equipped with a half-mask and operated in a
pressure demand or other positive pressure modes.
supplied-air full face piece respirator in pressure demand used in
combinations with an auxiliary self-contained breathing apparatus
operated in a pressure demand or other positive pressure mode
cylinder of at least 5 minutes for escape.
self-contained respirator equipped with full face piece and operated
in a pressure demand or the other positive pressure mode.
The following forms are used to maintain
records on our selection, fitting, medical evaluation and program
Form A -
Respirator Assignment and Fit Record
First part of the form is filled out
by the assigning supervisor
Second part of the form is completed
by the person conducting the fit testing and training which may be
supervisor, safety manager or knowledgeable person.
Form B -
Respirator Medical Evaluation Report
This report is generated by the
outside medical provider as to the fitness of the employee for
wearing a respirator.
Form C -
Respiratory Protection Program Audit
This checklist will be used by
safety staff in evaluating the on-going respiratory protection
Respirator Assignment And Fit Test Record
Supervisor Completes the Following Information
Department in which
respirator is used_______________________________________
Operation for which
respirator is used________________________________________
How often and what duration
of time is respirator use needed ? _______________
Representative employee
exposure results ___________________________________
Date of FITNESS
EXAM______________________ Date respirator issued:_____________
Type & Size of
respirator issued ___________________________________________________
Respirator cartridges
supplied _____________________________________________________
Negative Fit Test: __________________________
Isoamyl Acetate Vapor Test:
Donning and
Doffing Methods
with the respirator which require immediately leaving the area and replacing
respirator or seek assistance from YOUR SUPERVISOR or REGION SAFETY
Breathing becomes
Dizziness or other
Sense irritation, smell or taste contaminants
1. The employee
understands that a respirator must fit properly in order to be effective. I
have had my respirator tested for face-to face seal. I have worn a
respirator in normal air to familiarize myself with it, and have then worn
it in a testing atmosphere.
2. I have received
written & demonstrated practice instructions on wearing a respirator. I know
how to adjust it & determine if it is fitting properly. I am aware that I
am in violation of safety code if wear the respirator with a beard,
sideburns or skull cap. I also understand that proper seal cannot be made
over the temples of eye glasses.
3. I understand that I
am responsible for the daily cleaning (or after each use) and proper storage
of the respirator.
Employee Signature
_________________________________________ Date _______________
Supervisor Signature
________________________________________ Date ________________
Medical Evaluation Report
Physician (or other) Licensed Health Care
Respirator Recommendation
Employer Name:
The employee is able to use a
respirator according to the supplemental information provided by
The employees' medical condition
requires the following limitations regarding use of a respirator.
The employee is unable to use a
respirator until further medical evaluations are performed.
Appointment Date:
"Authorization to Disclose Medical
Records" (attached to employee's copy)
The employee has been provided with a copy
of the PLHCP Respirator Recommendations.
PLHCP Signature:
mailed to employer
mailed to employee Occuhealth copy
Completed by:
____________________________ Date: ___________________________
Respiratory Program Evaluation Checklist
____1. Is there a
written policy which assigns program responsibility, accountability, and
____2. Is overall
program responsibility given to one person who is knowledgeable and can
coordinate all aspects of the
____3. Can feasible
engineering controls or work practices eliminate the need for respirators?
____4. Are there
written procedures/statements covering the various aspects of the respirator
program, including:
______designation of authority and responsibility;
______respirator selection;
______purchase of approved equipment;
______medical aspects of respirator usage;
______issuance of equipment;
______maintenance, storage, and repair;
under special conditions;
and where respirators are required?
1. Respiratory
protective equipment selection
______ Have work area
conditions and worker exposures been properly evaluated?
______ Are respirators
selected on the basis of hazards to which the workers are exposed?
______ Are selections
made by persons knowledgeable of proper selection procedures?
______ Are only NIOSH
approved respirators purchased and used?
______ Do the
respirators provide adequate protection for the specific hazard in the
concentration found?
______ Has a medical
evaluation of the prospective user been made to determine physical
and psychological fitness to
wear the selected respirator?
______ Where practical,
have respirators been issued to single users?
2. Respiratory
protective equipment fitting
______ Are the users
given the opportunity to try on several respirators to determine the one
with the best fit?
______ Is the fit
tested before the wearer begins using the respirator in the work area, both
on initial assignment, and on a
daily basis (positive and
negative pressure tests)?
______ Are users who
wear glassed properly fitted?
______ Is the face
piece-to-face seal tested using one of the methods described earlier?
______ Are workers
prohibited from entering contaminated work areas when they have facial hair
or other characteristics
which prohibit the use of
tight-fitting face pieces?
3. Respirator use in
the work area
______ Are respirators
being worn correctly?
______ Are workers
keeping respirators on all the time while in the work area?
4. Maintenance of
respiratory protective equipment
______ Are respirators
cleaned and sanitized after each use (when different people use the same
device) or as frequently as
necessary (for devices issued
to individual users)?
______ Are respirators
stored so as to protect them from dust, sunlight, heat, and chemicals?
______ Is storage in
lockers, tool boxes, or work areas permitted only if the respirator is in a
carton, carrying case, or
closed container?
______ Are respirators
inspected before and after each use, and after cleanup?
______ Are individuals
instructed in inspection methods?
______ Are cartridges
and filters changed on a regular basis?
______ Are respirators
designated as "Emergency Use" inspected at least monthly (in addition to
after each use), and is a
record kept of such
______ Are replacement
parts of the same brand as the respirator?
______ Are repairs made
by manufacturers or manufacturer-trained persons?
5. Special use
conditions (if applicable)
______ Is there a
procedure for respirator use in atmospheres immediately dangerous to life
and health?
______ Is there a
procedure for confined space entry?
6. Training
______ Are users
trained in proper respirator use, cleaning, and inspection?
______ Are employees
trained in the health effects of the respiratory hazard present?
______ Are users
evaluated, using competency-based evaluation, before and after training?
SECTION 3. Respirator Fit Testing
Respirator fit is
extremely important. Respirator fit testing is used to test how well the
tight fitting respirator face piece seals against the face. If there is not
a good face-to-face piece seal, the contaminants may pass around the face
piece and be breathed into the lungs. The results of the fit test are to be
recorded on Form A - Respirator Selection and Fit Record. Respirator fit
testing must be conducted annually.
Respirator fit testing may be done using two
basic methods: qualitative or quantitative fit testing. Most employers use
qualitative methods since quantitative procedures may be expensive and
require complicated equipment. Currently only certain rules required
quantitative fit test which include lead and asbestos regulations once
exposure levels reach a certain exposure level.
Quantitative fit testing uses sophisticated
equipment to measure the amount, if any of test material that leaks into the
face piece of the respirator. County operations do not have exposures of
the type of contaminates that requires quantitative fit testing.
Qualitative fit testing must to be done upon
initial assignment of a respirator and annually there after. Once the
employee passes a fit test using a proper respirator, they should perform a
simple daily negative or positive pressure test to ensure that the
respirator is properly worn.
Respirators that are mandatory are not to be
worn if the wearer has facial hair (beards or stubble). Head coverings,
scars, and missing dentures or teeth can also affect respirator fit.
Glasses will interfere with fit when using a full face piece. Full face
piece can be fitted with spectacle inserts.
No one is permitted to cut off respirator
straps, leave the straps off or wear them too loosely.
Positive and Negative Pressure Tests
Each time a respirator is put on, and prior
to the qualitative fit testing procedures, the wearer should conduct a
positive and a negative pressure test to ensure that the respirator is
seated correctly against the face.
The negative pressure test is performed on
any respirator with a tight fitting face piece. For cartridge respirators,
the test consists of covering the air inlet lightly and inhaling lightly,
then holding the breath for a few seconds. For SCBA and supplied air
respirators, block the end of the breathing tube so it will not allow air
in. Inhale lightly and hold the breath for a few seconds. In either type,
if a leak exists, the air can be felt as it enters. The common leak areas
are around the nose and chin.
The positive pressure test is performed on
respirators with tight fitting face pieces and both inhalation and exhalation
valves. It is done by blocking the exhalation valve and exhaling lightly.
Again, air leakage can be felt if a leak is evident.
If such leaks are found, the respirator should
be adjusted and retested. If a fit cannot be achieved, then a different size or
style face piece needs to be fitted.
A qualitative fit test must be done again once
the initial positive or negative pressure tests are completed.
Qualitative Fit Testing:
The following methods may be used to determine
if the respirator wearer can achieve a basic fit with the respirator style and
size selected. Exposures to some air contaminants, such as lead, arsenic, and
asbestos in certain concentrations require quantitative fit testing.
1. Banana Oil (isoamyl acetate) Test
This test is used for half or full face air
purifying respirators. This type of test is not required for Type C (supplied
air pressure demand) airline respirators and SCBA devices, since they are
operated in a positive pressure mode.
Air purifying respirators must be equipped with
organic vapor or pesticide cartridges for this test. The test chemical smells
like ripe bananas. The test consists of administering the chemical and having
the respirator wearer determine whether or not he/she can smell the odor of
The chemical can be purchased in test ampules
from safety equipment supply stores. Each of the various brands has specific
instructions which you should follow.
The basic approach is to have the respirator
Put on their respirator.
Conduct a positive or negative
pressure test to see if the respirator is seated properly against the face.
Open one of the ampules and pass it
close to the sealing surface of the respirator.
Have the wearer move their head up,
down and to the side and speak out loud to ensure that the fit is maintained
during activity.
If no odor is detected, then the
respirator fits the individual.
If an odor is detected, then the
individual needs to be refitted in another size or style face piece until fit
can be
The banana oil test has certain disadvantages.
Some individuals cannot smell the banana oil, so employees should be tested
after the fit test to ensure that they can indeed detect the odor. Also, if an
individual smells higher concentrations of the banana oil, they can develop an
odor fatigue and upon immediate retesting, and may not be able to detect the
2. Banana Oil Testing in an Enclosure
There are additional methods using the banana
oil where you actually construct a test environment using a large, clear
plastic bag and known concentrations of banana oil. This method was developed by
3. Saccharin Mist Test Kit
This test, developed by the 3M Company, is used
for disposable dust and mist respirators and for half or full face respirators.
Respirators must be equipped with particulate cartridges for this test.
The test kit includes a saccharin solution that
is poured into a nebulizer that generates a mist of saccharin that is sprayed
around the respirator face seal. The wearer is asked to breathe through their
mouth, and if they sense a sweet taste then the respirator does not fit
properly. If they notice no taste then the respirator has an adequate fit.
Since this is a taste test, it is important that
the test subjects do not eat any sweet foods or drink sweet beverages just
before the test.
The specific protocols are
given in the kit instructions but basically include:
Put on the respirator and
conduct a positive or negative pressure test to see if the respirator is seated.
Spray the saccharin mist
close to the sealing surface of the respirator.
Have the wearer move their
head up and down and to the side, and speak out loud to ensure that the fit is
maintained during activity.
If no taste is detected,
then the individual has an adequate fit.
If a taste is detected,
then the individual needs to be refitted in another size or style face piece
until fit can be
4. Irritant Smoke Test
Smoke tubes (stannic oxychloride smoke tubes)
used to test ventilation systems can also be used as an effective chemical to
test a respirator wearer's fit. This test can be used for half or full face air
purifying respirators.
Since the chemical used to produce the smoke is
irritating to the eyes and mucous membranes, additional care has to be taken in
conducting this type of fit test. Smoke tubes are available from safety
equipment supply stores.
The respirators must be equipped with high
efficiency (HEPA) cartridge filters before starting the test. The basic
procedures are:
Put on the respirator.
Conduct a positive or
negative pressure test to see if the respirator is seated.
Have the wearer close his or her eyes before
administering the smoke.
Open one of the smoke
ampules and pass smoke about two feet from the
subject. If no leak is
detected, then move closer passing smoke around the
sealing surface of the
respirator. Avoid the eyes.
Have the wearer move their
head up, down and to the side and speak out
loud to ensure that the
fit is maintained during activity.
If no irritation is
detected, then the individual has an adequate fit.
If an irritation is
detected, then the individual needs to be refitted in another
size or style face piece
until fit can be achieved.
The smoke test can also be administered in an
enclosure like the one described with the banana oil.
SECTION 4. Training Respirator Wearers
The respiratory protection regulations require
that employees need to be informed about the type of hazards that they may be
exposed to and the reason for the respiratory protection. Employees are to be
instructed on:
1. The type of respiratory hazard present
and its effect on the body,
2. How to wear the respirator,
3. How to check for proper fit,
4. How to clean, inspect and store the
5. How to determine when to change
respirators or cartridges, and
6. Who to contact and what to do if they
have breathing difficulties or problems with the respirator.
The training allows the respirator user the
opportunity to handle the respirator and wear it in normal air before it is worn
in the actual work setting. Demonstrations and hands-on practice with the
respirators are essential for good training. This is done by the supervisor,
safety manager and/or knowledgeable person during respirator fit testing.
Once a respirator is assigned, the employee is
responsible to:
Check the respirator fit after
each time you put it on,
Use the respirator as the
instructions state,
Report any possible
Store in a dry, clean
Use proper personal hygiene in
relationship to all personal protective equipment,
Regular hand and face washing,
Sanitize and maintain their
The respiratory protection regulations require
that employees must be informed about the type of hazards that they may be
exposed to and the reason for the respiratory protection. Employees are to be
instructed on:
1. The type of respiratory hazard
present and its effect on the body,
2. How to wear the respirator,
3. How to check for proper fit,
4. How to clean, inspect and
store the respirator,
5. How to determine when to
change respirators or cartridges,
6. Who to contact and what to do
if they have breathing difficulties or problems
with the respirator.
The following program is advisory only. It does
not necessarily list all approaches to respiratory protection or address all
rule compliance issues. This information is not intended to be all inclusive of
workplace safety/health issues. Other additional information may be necessary
for compliance with safety and health regulations.
1. Introduction. Why would you need to wear a
Respiratory protection may be needed to control
employee airborne exposures to various contaminates under certain conditions. In
the work place the inhalation of chemicals as gases, vapors, dusts, fumes,
liquid mists is generally the most important route of entry into a persons body.
Chemical Exposure through Inhalation
Inhalation is generally viewed as the primary
route of acute occupational exposure. The alveolar tissue (minute air sacs) in
the lungs is estimated to have about 70 sq. meters of surface area. This tissue
is extremely thin to allow for efficient gas exchange. This expansive and
delicate tissue is the only barrier between inhaled toxic vapors and gases and
the circulatory system. It is obvious that with this vast exposure area,
significant and sometimes fatal toxic concentrations can quickly enter the
body. Examples of these gases are chlorine.
Virtually any gas or vapor can enter the body
through the respiratory system. Dusts and fumes may also be toxic to the
respiratory system. Toxic dusts and fumes include: silica, welding fume.
Specific OSHA required respiratory protection
1. Where exposures to airborne
contaminants exceed legal limits, such as:
engineering controls do not exist and are not feasible
engineering controls are not efficient enough to control exposures
2. Where an intermediate protective
method is needed until engineering controls can be installed and tested.
3. When non-routine or emergency
situations exist and exposure levels may not be known, but could reach
hazardous levels.
4. When chemical presents a hazard
even though it may not be regulated by a permissible exposure limit.
Respirator Selection
Respirators are selected based on the type and
degree of respiratory hazard. Different respirators are needed for different
types and degrees of hazard. It is important to consider when selecting a
respirator, the nature of the work process, the time period for which protection
is needed, and the activity level of the workers.
Physical and functional characteristics of the
respirator, and respirator protection factors should also be considered.
Because exposures to contaminants will vary not only in terms of the physical
state of the material (dust, vapor, liquid, gas) but also in the material's
toxicity and the way the material is used, it is important to select the proper
Only respirators approved
by the National Institute for Occupational Safety and Health (NIOSH) should be
used. The NIOSH approval should be for the use intended. A NIOSH approval number
will be noted on the respirator, cartridges, filters and other parts.
Respirators are of two main types:
Air purifying - Air
purifying respirators use chemical or mechanical filter cartridges to clean the
contaminated air
before it is breathed in by the
Air supplying - Air
supplying respirators provide the wearer with uncontaminated breathing air, by
use of an air
compressor, tank, or cylinder.
Within each major category, there are several
types of devices, each of which is appropriate for different uses.
The following table provides a chart showing
potential chemical exposures in relationship to respiratory selection for
various operations.
The color code system used for respirator
cartridges and canisters is based on ANSI K13.1973 Identification of Air
Purifying Respirator Canisters & Cartridges.
Color Assigned
Acid Gas
Organic Vapors
Ammonia Gas
Acid Gas & Organic
Radioactive or
Highly Toxic Particulate/Fumes HEPA filter
Purple ( Magenta)
Dust, Fumes & Mists
Red or gray with a
red stripe
Other Vapors &
Gases not listed
How to Wear a Respirator
Employee procedures when donning a respirator -
Once a respirator is assigned the employee is
responsible to:
Check the respirator fit
after each time you put it on,
Use the respirator as the
instructions state,
Report any possible
Store in a dry, clean
Use proper personal hygiene
in relationship to all personal protective equipment,
Regular hand and face
Sanitizing and maintains the
NOTE: Trainer is to review the specific
procedures for each type of respirator being assigned to the employees. The
manufacturer's instruction manual will be used.
If the respirator does not
fit you, it will offer no protection. You must check the fit of this respirator
each time you use it, following these Fitting Instructions.
This respirator should not be used by individuals with beards, or other facial
hair which passes between the sealing flange of the respirator face piece and
the wearer's face. Facial hair may cause leakage or interfere with the proper
operation of the respirator exhalation valve, thereby exposing the wearer to the
hazardous contaminants.
1. Remove the
face piece assembly and the air-purifying elements (filters, cartridges
or filter/cartridge combinations) from the cartons. If the N7500-6
dust/mist, N7500-10 paint spray/mist or N7500-23 pesticide replaceable
filters are being used, they should be assembled to the cartridges
before the cartridges are attached to the face piece. Place the filters
in the N7500-27 fit check/filter covers so that the entire outer edges
of the filters are seated evenly and securely against the inner wall of
the filter covers.
2. Snap the fit
check/filter covers with the filters seated evenly and securely, to the
3. Assemble
respirator by screwing air-purifying elements onto the inhalation
connectors mounted on the face piece. Check to be sure that each
air-purifying element is tightly sealed against the face piece.
4. After assembling
the respirator and air-purifying elements, inspect the respirator to
make certain the respirator has been damaged, the exhalation valve flap
is in place, and the sealing flange is not distorted.
Per OSHA requirements, a respirator
must be inspected by the wearer before and after each use to insure that
it is in good working condition.
5. To put on the
respirator, remove your protective
eyewear (if worn), then grab the front
of the respirator with one hand and the upper strap with the other
hand. Then place the portion of face piece containing the exhalation
valve under the chin.
6. Position the
narrow portion of the respirator on the nose bridge and place the cradle
sus-pension system on the head and the bottom
strip rests above
the ears, on the back of the head . Then hook the bottom headband strap
behind the neck, below the ears, and adjust the position of the face
piece on the face for best fit and comfort.
7. The lengths of
the headband straps are adjustable; tighten or loosen by holding the
respirator body of headband yoke with one hand and pulling on the
elastic material in the appropriate direction with the other hand. (For
a comfortable fit, the headband straps must be adjusted equally on both
sides of the respirator.)
8. Position the
face piece so that the nose section rests as low on the bridge of the
nose as is comfortable, and tighten the upper headband strap on both
sides just tight enough so that the respirator doesn't slide down on the
nose. Do not over tighten. (If the respirator pinches the nose, loosen
the upper strap slightly.)
9. Then, tighten
the lower headband strap on both sides just tight enough to secure the
respirator under the chin.
(NOTE: For proper
positioning and comfort, the upper headband strap must be adjusted
first, then the lower straps must be adjusted.) If you previously
removed your protective eyewear, put it back on at this time.
10. Prior to
entering the contaminated environment, check the fit of the respirator
as follows:
a. NEGATIVE
To conduct this
check, place the palms of the hands over the openings in the N7500-27
fit check/filter covers (if so equipped) or unscrew the air-purifying
elements from the respirator and place the palms of the hands over the
inhalation connectors, inhale and hold your breath for about 5 seconds.
If the face piece collapses slightly and no air leaks between the face
piece and the face are detected, a good fit has been obtained. If air
leaks are detected, reposition the face piece on the face and/or
readjust the tension of the elastic straps and repeat the negative
pressure check until a tight seal is obtained. If the cartridges were
removed, once a tight face piece-to-face seal is obtained, a co-worker
or a representative of the Safety of Industrial Hygiene Department must
assist the wearer by screwing the air-purifying elements onto the
inhalation connectors mounted on the face piece. (This must be done
without removing the face piece from the face.) Check to be sure that
each air-purifying element is tightly sealed against the face piece.
This check is
carried out by covering the opening in the exhalation valve guard
with the palm of your hand, and simultaneously exhaling. If the face
piece bulges slightly and no air leaks between the face piece and face
are detected, a tight fit has been obtained. If air is detected to be
leaking out between the face piece and the face, reposition the face
piece on the face and/or readjust the tension of the elastic straps to
eliminate the leakage. This check must be repeated until a tight seal
of the face piece to the face is obtained.
If you cannot
obtain a good seal with your respirator, try a smaller size face piece,
contact an Industrial Hygienist or North Safety Equipment Respiratory
Protection Product
Manager at 401-943-4400 for assistance prior to using this respirator.
11. To "park" the
respirator on your chest during a break:
Unhook the bottom
strap behind your head, and then slide the top strap down behind your
neck, allowing the respirator to sit on your chest.
12. To put the
respirator back on:
Put the upper
(cradle) strap on first, and then hook the bottom strap behind your
neck. If the respirator has been "parked" on the chest, make sure prior
to putting the respirator on that the sealing flange and interior of the
respirator are not dirty.
Do not remove or park the respirator while you are exposed to
contaminated air.
A respirator should not be
assigned to a person unless the person is given a qualitative or quantitative
respirator fitting test and the results of the test indicate the face piece of
the respirator fits properly. Instructions for carrying out qualitative and
quantative respirator fitting tests are given in publications such as the ANSI
Z88.2 American National Standard Practices for respiratory Protection and
respirator manuals published by government agencies such as NIOSH, ERDA, and
NRC. North Safety equipment has produced a respirator training film which
illustrates qualitative and quantitative fit testing.
Respirator Storage and Maintenance
Respirators must be maintained to ensure
effectiveness and to prevent chemical and bacterial contamination. Each
respiratory wearer is assigned their own individual respirators.
Maintenance of Respirators
Respirators are to be cleaned after each daily
use with alcohol preps and placed dry in a clean container or plastic bag for
Respiratory face pieces which are individually
assigned should be thoroughly cleaned periodically by the employee. This
involves performing the following procedure:
1. Remove the cartridges or filters from the
face piece. The filters and cartridges must not be washed. All cartridges will
be replaced during the quarterly cleaning.
2. Immerse the respirator face piece in a warm
water solution of commercial disinfectant liquid. The respirator should be
scrubbed gently with a cloth or soft brush. Make sure that all foreign material
is removed from all the surfaces of the rubber exhalation valve and plastic
exhalation valve seats and face seat.
NOTE: The inhalation, exhalation valves,
valve cover, and cartridges will be replaced during the quarterly cleaning.
3. After washing and disinfecting the
respirator, rinse in clean warm water and allow the respirator to dry before
4. After the respirator is dry, store it
in a clean container. Respirators should not be stored where chemicals are
or stored. Respirators should not
be hung from nails on the walls or in chemical storage areas. The respirators
be stored in a normal position
which means that they should not be stretched or stored under objects which
cause the face-piece to
become warped.
Any respirator malfunction shall be reported to
the supervisor and/or safety manager who can evaluate the problem and ensure
that proper replacement parts or a new respirator is supplied to the employee.
Each person assigned a respirator shall be
responsible to maintain the equipment and routinely inspect the respirator
before and after use for worn or dirty parts. WORN PARTS WILL BE REPLACED
The routinely used respirators will be
periodically inspected by the supervisor or safety manager in accordance with
the program evaluation protocols listed in the next section.
Cartridge and Filter Use Time - Replacement
1. Mechanical - Filter Respirators
These respirators provided protection against
particulate matter such as dust, mist and fumes. Usually a fibrous material is
used to trap the particulates, and its efficiency is dependent upon the size of
the particle relative to the filter size, particle velocity and, to some extent,
the composition and shape of both the particle and fiber.
No filter is 100% efficient in removing
particles, however there are high efficiency particulate air filters (HEPA) that
are 99.97% effective. These filters are designed to protect against particles
down to 0.3 microns and with a Permissible Exposure Limit of 0.5 mg/m3 or less.
Dust, mist and fume filters are designed to
99.5% effective for particles down to 0.6 microns. Dust and mist filters are
99.0% effective.
Filters must be replaced if the filter medium is
damaged or if the filter is difficult to breathe through. Damage to the
respirator or filter is usually evident and thus the wearer is able to easily
determine that the respirator or filter must be replaced.
There is no accurate method of predetermining
the service-life of the particulate respirator. The concentration of airborne
dust is the major factor influencing the service life.
The more dust in the air the more dust the
filter must be able to retain, and the faster the filter will clog. The
breathing rate of the wearer will also influence the service-life. If a worker
is doing light work, their breathing rate is approximately 20 lifters per
minute. If the workload is heavy, the breathing rate may be 60 liters per
minute or higher. This result in about three times the volume of air going
through the filter and thus three times as much dust to be filtered and retained
in the filter.
In summary the major limitations include:
Mechanical filters do not provided oxygen, so
they must not be used in oxygen- deficient atmosphere.
They provide no protection against gases or
There is a pressure drop through the filter
medium; therefore, there is some breathing resistance. As the filter loads
up this resistance increases; thus people with respiratory problems should
ensure that they are capable of wearing this type of respirator.
2. Chemical Cartridge Respirators
These respirators are vapor and gas-removing,
using a cartridge attached to the face piece containing chemicals to trap or
react with specific vapors or gases, and remove them from the air breathed.
The filtering medium is commonly activated
carbon which primarily removes organic vapors. Activated carbon can also be
impregnated with other substances to make it more selective against specific
gases and vapors.
There are a number of factors which influence
the service-life of a chemical cartridge respirator. They include:
Breathing rate
Duration of exposure
All these factors make it very difficult to give
a general statement as to how long a specific gas/vapor respirator will last.
In order to be NIOSH approved a gas/vapor
respirator must pass a number of service-life tests. One of the test
requirements is a minimum service-life which is determined when the permitted
penetration value is detected.
Since there is no easy method to determine
service-life the best policy is to replace the respirator or cartridge when:
An odor or taste is
detected, or symptom occurs
It becomes hard to
breath through
The cartridge or
respirator is damaged
There are number of limitations to the use of
chemical cartridge respirators which are important. These include:
They do not supply oxygen and thus cannot be
work in oxygen-deficient atmospheres.
These respirators are designed for protection
against specific gases or vapors. Thus users must take care that the proper
cartridge is selected.
These cartridges can only be used for
protection against contaminants with good warning properties (smell, taste,
irritation). The respirator works at 100% efficiency until the capacity of the
sorbent is reached, then the contaminant passes through the sorbent material
and is inhaled by the wearer. Thus there must be a warning system that alerts
the wearer that the chemical cartridge is used up.
The cartridges are not approved for high
concentrations of the contaminants.
The respirator must be protected from the
atmosphere while in storage because they tend to pick up water vapor from the
air and reduces the service life.
Oregon OSHA rules 1910-134(b)(10) state that no
one should be assigned a task requiring use of respirators unless found
physically able to do the work while wearing the respirator. In addition, some
specific OSHA standards for chemical substances or occupations may also contain
requirements for medical examinations. Both types of standards require that a
physician should determine what health and physical conditions are pertinent,
and that the respirator wearers' medical status should be reviewed periodically
if specified by the PLHCP.
Oregon OSHA applies this standard when the air
contaminate level or conditions could result in overexposure to the permissible
exposure limit. Thus if respirators are provided for comfort and additional
protection mandatory medical screening would not be required.
Pre-placement medical examinations should screen
out those who are physically or psychologically unfit to wear respirators. As
another part of this examination, medical tests pertinent to the respiratory
hazards that workers may encounter should be made to get baseline data against
which to assess physiological changes in respirator wearers.
The Douglas County medical fitness program
involves our medical services administering a health questionnaire and an
evaluation and medical testing by health care providers at locations convenient
to our employees. The protocols are given on the following pages.
The medical fitness evaluation process involves:
Step 1 Notification for the supervisor
that an employee needs to wear a respirator.(Form A Respirator Selection and Fit
Testing Form).
Step 2 Safety Manager gives the health
questionnaire and arranges for medical evaluation.
Step 3 The employee's supervisor and/or
Safety Manager is notified as to whether or not the employee can wear a
If yes, then
the Safety Manager fits the employee in the appropriate respirator. The
Selection & Fit
Form is completed and the employee receives a copy of the form which includes
use and
maintenance instructions.
If no, then it
is determine what type of work restrictions were given and works with the
concerning the work assignments.
Evaluation of the Program's Effectiveness
Respirator Program Evaluation
It is important that both the respirator wearer
as well as the supervisor evaluate respirator use and program
effectiveness. It is critical that the appropriate respirator be worn
If an employee notices any of the following they
should immediately leave the area and replace the respirator if:
1. Breathing becomes
2. Dizziness or other
distress occurs (see supervisor),
3. You sense
irritation, smell or taste contaminants,
4. The respirator
becomes damaged.
The overall program will be evaluated by the
safety manager. This will involve:
1. Frequent unscheduled
observation of employee respirator usage during job operations
requiring protection to confirm
proper respirator use.
2. Observation and discussion
of the respirator program with new employees and those
who are not following proper protocols.
3. Periodic discussions of
respiratory use procedures during safety and management meetings.
Self-Contained Breathing Apparatus (SCBA)
County employees are not normally assigned SCBA
therefore, the following information may only apply in very limited manner but
is provided based on potential for emergency response use or in case of confined
space entry rescue responsibilities.
SCBA and Air Quality
Respirators which supply air where the user
carries a supply of respirable air is called a SCBA unit. The air quality must
meet Grade D standards of the Compressed Gas Association Specification 67.1.
This means that the carbon monoxide level must not exceed 20 ppm, carbon dioxide
not to exceed 1000 ppm and the condensed hydrocarbons must not exceed 5 mg/m3.
Note: it is prohibited to use oxygen in place of air.
Positive Pressure-Demand SCBA
SCBAs with positive pressure-demand regulators
are designed to permit entry into an immediately dangerous to life situation.
The units are the primary respiratory protection of fire fighters and hazardous
material responders.
A cylinder of high pressure (2000-4500 psi)
compressed air supplies air to a regulator that reduces the pressure for
delivery to the face piece. This regulator also serves as a flow regulator by
passing air to the face piece on demand. The regulator is either mounted
directly to the face piece or a flexible corrugated hose connects the regulator
to the respiratory inlet covering, usually a full-face piece.
The regulator provides pressure to the face
piece at all times and then additional air based on wearer demand. Because of
the positive pressure any leakage should be outward; therefore a pressure-demand
SCBA provides good protection. The designed air flow rate is approximately 350
- 400 liters per minute.
Contrary to common belief, the pressure-demand
SCBA has the same service times as a demand version of the same device, if it
seals well on the wearer's face. Any leakage increases air consumption and
decreases service time.
Some open-circuit SCBA can be switched from
demand to pressure-demand operation. The demand mode should be used only for
donning and adjusting the apparatus in order to conserve air and should be
switched to "pressure demand" for actual use.
Safety Features
Several required safety features are on all SCBA
units certified for entry which provide additional protection include:
1. Pressure gauges visible to
the wearer which indicates the quantity of gas of
remaining in the cylinder.
2. Remaining service life
indicators or warning devices that signal alarm when
only 20-25% of service
time or service volume remains.
3. Bypass valves, in case the
first and second stage reducer or regulator fails
and it is necessary to
conserve or provide respirable air.
4. Fittings on devices that
use compressed air which are incompatible with
other compressed fittings.
Escape Only SCBA Units
SCBAs are also certified by NIOSH for escape
from IDLH environment. These escape-only SCBA are generally of short duration,
3, 5, or 10 minutes, and are small in both size and weight. These compressed
air cylinders are usually hip or back-mounted with air valve in a readily
assessable position to have positive air pressure inside the respiratory inlet
covering which is usually a hood.
NOTE: At least a 15-minute supply of air is
required for entry into an IDLH environment for rescue of containment purposes.


text:
Riddle, Brooks Win Augie Pride Awards
Associate Dean of Students Tracy Riddle and Office of Admission Coordinator Marsha Brooks received "Augie Pride" awards for exceptional service at the Augustana Service Awards Presentation and Celebration yesterday.
Hurley Wins Covenant Award for Excellence
Senior Rachel Hurley, a biology and ACS chemistry double major, has received the Covenant Award for Excellence. During her time at Augustana, she has been involved with the Augustana Band and Wind Ensemble, NSO, Outreach Ministries, Pre-Med Club and the Biology Honor Society.
Textbook Rental Program Coming to Augustana Bookstore
Beginning in June, the Augustana College Bookstore will offer a new, multi-channel textbook rental program that will allow students to rent select textbooks for less than 50 percent of the cost of purchasing a new printed textbook.
Theatre Season Concludes with 'The Winter's Tale'
The Augustana Theatre and Music Departments will present "The Winter's Tale," Shakespeare's classic tale of jealousy, love, loss and reconciliation, May 4-8 at the Edith Mortenson Center Theatre. The play is directed by Jayna Fitzsimmons.
Autism Conference to Feature Author, Advocate Eustacia Cutler
Eustacia Cutler, award-winning author and mother of animal behavioral scientist and autism advocate Temple Grandin, will speak at "Lighting the Way," an annual, two-day conference on autism spectrum disorders. The conference will be held at Gilbert Science Center June 9-10.
Six Students Named Christopherson Scholars
Six Augustana students who exemplify scholarship and campus/community service have been awarded Fred C. and J. Marie Christopherson Scholarships for the 2011-2012 academic year.
Dr. Murray Haar Named Interim VP for Academic Affairs, Dean of the College
Dr. Murray Haar has been named interim vice president for Academic Affairs and Dean of the College. Dr. Haar succeeds Dr. Mark Braun, who was recently named Provost and Dean of the College for Gustavus Adolphus College.
In The News: 'Augustana Celebrates 150 Years'
On Saturday, alumni, students, faculty and staff and community members honored 15 decades of history at The Spark, the gala event to celebrate Augustana at 150. The event featured historic photo galleries, an awards ceremony, the premiere of 'Skol! Augustana at 150,' a documentary film, live music and dancing.
Five Honored With Spirit of Augustana Awards
Before a crowd of more than 1,200 people, Augustana College honored five area individuals for their efforts to advance humanitarianism, ministry, innovation, leadership and creativity last night at The Spark, the gala event to celebrate the College's 150th anniversary.
Augustana PRSSA Honored for Social Media Campaign
The Augustana Public Relations Student Society of America (PRSSA) took home a Student Classics Award at the annual Minnesota Public Relations Society of America (MPRSA) Classics Awards Ceremony. The win came in the New Media/Technology category for the group's social media campaign.

subset: commoncrawl


text:
Statement by Dr. Shirley Charter,
Commissioner of Social Security,
October 5, 1995
Alternative Medicare Hearing
Mr. Chairman and Members of the Committee:
I want to commend you for calling this hearing to discuss the proposal pending in Congress to make $2 70 billion in cuts in the Medicare program over the next seven years. It is essential that the public have the facts to understand the ramifications of these cuts and to determine if, in reality, reductions of this magnitude are necessary at all.
There are two issues I wish to discuss in my testimony. As a member of the Board of Trustees for the Medicare Trust Funds, and as a signatory to the 1995 annual report issued by that Board this past April, I would like to discuss the rationale being used to justify a $270 billion Medicare cut. I believe it is necessary to point out how the April 1995 trustees report is being distorted and misused to justify an unnecessary and destructive action.
It is important to remember, though, the recent history of how Medicare solvency issues have been handled by the White House and Congress. Nine times in the past, the Medicare trustees have warned that the trust fund would be insolvent within seven years. Each of those times, the President and Members of Congress responded in a statesmanlike manner, taking the necessary actions to strengthen the fund.
But this statesmanlike approach is not seen at this time, not when some members of Congress are unfairly distorting the 1995 Trustees Report to suggest that Medicare is facing such an extraordinary financial crisis that it can only be saved by cutting the program by $270 billion. Not only is such a claim unwarranted. It is also untrue.
The Medicare trustees have reported that it would take $89 billion, not $270 billion, to keep the Hospital Insurance (Part A) trust fund solvent for another 10 years through 2006. There is simply no reason, no logical reason, to take such an extreme action.
Mr. Chairman, clearly we can better protect low-income elderly citizens-- the people who will truly suffer without an effective Medicare program -- by taking this kind of comprehensive approach, which has been proposed by the President.
I thank you for the opportunity to testify on this very important
issue. And I look forward to continuing to work with this
Congress, both as Commissioner of Social Security and as a
Trustee of the Social Security and Medicare Trust Funds.


text:
Recently viewed
Item specifics
|Hair Extension Type:
|Virgin Remy Brazilian Hair
|Hair Texture:
|#1 Natural Black
|Net Weight:
|3pcs/lot (300g)
|Model Number:
How long do hair extensions last?
In general, the lifespan of human hair extensions depends on how well you take care of them, how you wash them, and how often you wear them. Our hair is 100% human hair that has all its cuticles intact. It features a strong hair shaft, and if taken care of well, 7A Grade hair can last up 3-6 months, 8A can last up to 12-18 months or longer.
How many bundles of hair do I need?
A few factors go into choosing how many bundles of hair you need, all depending on:
1. Your desired look and how full you want it.
2. Length: all bundles are the same weight (3.5oz), meaning shorter length bundles are thicker than longer lengths. We suggest you choose 2 bundles for lengths under 16 inches and 3-4 bundles for lengths above 18 inches.
3. Texture: straight hair and curly hair are on opposite ends of the density spectrum. 2-3 bundles of curly style hair are usually enough for a natural, full look. You might need more bundles to create a full look if choosing straight bundles.
4. The size of your head: 4 bundles of our hair are enough for a large head.
Can our hair extensions be dyed or bleached?
Our hair extensions are 100% human virgin hair without any blends. Virgin hair extensions have the best type of weaves for dyeing and bleaching! So you can dye or bleach many times.
How do I take care of my hair extensions, and how often should I wash them?
You can take care of your extensions the same way you would your own hair. We also recommend using a deep conditioning mask frequently for at least 4-6 hours (or overnight) after washing your hair extensions, as this will help retain moisture and keep the hair smooth and silky.
Since hair extensions do not receive natural oils from the scalp like our own hair, they do not need to be washed as often. Please keep in mind that the less you wash your extensions, the longer they will last you.
How to prove our extensions are 100% human hair?
There is one easy way for teaching you how to know if your hair is human hair. Cut a small sample of the hair and burn it. The smell of human hair burning is like a natural burn odor and feels like charcoal. It burns quickly and turns to ash. Synthetic hair smells like burning plastic; there is a small flame and the hair feels viscous when burnt.
What's common point of 7A, 8A?
They all are make of 100% human virgin hair, we require the sequence of the hair to be sewing on the weft same as the growth direction of our natural hair, so that all of our hair are carefully selected by worker a piece by a piece.and they sewing the hair on weft like our natural hair, head to head and end to end. so that will not tangle when you comb.All our hair will not processing by chemical ,we keep the cuticle for the hair to prolong life-span.
What's different point between 7A and 8A hair?
a) 8A hair can be dyed more light color than 7A hair. As the technician of the hair suggests, 7A hair with a high cost performance can meet most of your requirements actually!
Will you send me a tracking number, and where can I check the progress of my shipment?
Yes, the tracking number will be updated in your account, and you will receive an email from us with your tracking details within 24 hours after your order ships. Any shipping information can be checked at www.dhl.com. By the way, we do not ship to P.O. Box addresses, so please give us your physical address.
Do you do wholesale? What is the minimum order?
Yes, we do wholesale. Minimum order is 15 bundles of mixed lengths and styles.
Still got a question?
Hair Measurement: Please measure the hair when pulled straight, the wavy/curly hair show shorter than straight hair.
Hair Color: Please understand pictures may not reflect the actual color of the item accurately due to different color settings of each monitor.
- Review by Patrice
Took a while, but was highly worth it. Def seeing me again:) hopefully with faster shipping thou
- Review by Tasha S.
For the delivery to be free and it came extra earlier than I expected was wonderful. I just installed the hair today my hair stylist liked it so look forward for more orders from me.
- Review by Karen
Good quality. An came right on time.
- Review by Desjae
This is my second order from Abby and she was great.Answered all my questions and I love the hair very soft & pasted the burn test . Thanks!
- Review by Sinead
it feels so nice and soft and delivery was fast!!
- Review by Victoria
The hair was very soft, a great thickness, and a beautiful wave!


text:
This coat is for an 'A' measurement of 26 inches. Please ensure you measure your dog before ordering.
A durable coat that is both waterproof yet breathable. Designed to cope with the heaviest wind driven rain for the life of the garment. It has a tough flexible coating to withstand rigorous use while unaffected by dirt, salt and other contaminants.
Reflective strips as shown in the image are available as an optional extra.
Machine washable at 40 degrees with a non-bio detergent.
Measure 'B' and 'C' all the way around
How to measure your dog


text:
Private labeling has emerged as a hot topic in the electrical wholesaling industry over the past few months. With several of the largest electrical distributors in the United States now private-labeling products, and certain name-brand manufacturers private-labeling products for some electrical distributors, there is much debate on this subject.
As with any decision on the product lines distributors carry, customer acceptance is key. Electrical distributors must ask themselves, "If I offered a line of private-labeled products, would my customers support it? What's most important to them about the products I sell?" Distributors ask themselves the same questions when they make major brand conversions for key products such as lamps, wiring devices, switchgear, or tools.
To find out what electrical contractors think about privately labeled products, Channel Marketing Group, Raleigh, N.C., and Allen Ray Associates, Kennedale, Texas, teamed up with Electrical Construction & Maintenance (EC&M) and sister publication, Electrical Wholesaling, to conduct an e-survey to explore the value of brands in the electrical marketplace and the exposure and acceptance level of non-branded products. Approximately 12,000 e-mails were randomly selected from EC&M's database. A 4.7% response rate was received, equating to 564 participants. To validate open-ended responses, a number of follow-up telephone interviews were conducted.
Based on this research, almost 20% of the respondents said they know at least one distributor selling private-label products. The most frequently mentioned distributors were: Rexel Inc., Dallas (19.8%); City Electric Supply, Orlando, Fla. (12.1%); Graybar Electric Co., St. Louis (12.1%); and W.W. Grainger, Lake Forest, Ill. (5.5%). While respondents mentioned independent distributors infrequently, 35% of distributors who responded to a different e-survey from Channel Marketing Group/Allen Ray Associates in November 2006 said they were offering or considering offering private-label products ("private label" could also mean no brand associated with the product; not necessarily a sourcing relationship).
Brand sensitivity
To better understand the commitment of end-users to brands, electrical contractors were questioned about their purchasing habits. Specifically, they were asked if they request a certain manufacturer's products, totally rely on the distributor's choice of brands, or use generic descriptions for their needs (4-inch steel box, for example). As expected, most contractors use multiple methods, so responses totaled more than 100%. Here is what the survey revealed:
66% of respondents ask for specific manufacturer names when they order products from electrical distributors.
44% of the time electrical contractors place orders not using a specific manufacturer's name and instead request a certain type of product using generic terms.
23% of the time electrical contractors mention a specific distributor name when they order products.
Contractors frequently know which lines their distributors carry, so it was no surprise that responses were skewed toward manufacturer names. The frequency with which electrical contractors place orders by product type or in generic terms wasn't all that surprising, either. It's safe to say respondents were "brand apathetic" in these situations and that they were willing to accept any manufacturer's brand or a distributor's own brand. The product categories that scored less than 30% brand-sensitive in Table 1 are most susceptible to pricing pressure, and therefore less-expensive private-labeled products.
On the flip side, electrical contractors are quite brand-sensitive in certain product categories, and they often will request a specific manufacturer or are willing to accept a known manufacturer of a specific type of product. This includes products such as switchgear, tools, and circuit breakers. To establish the level of brand support within each product category, survey respondents were asked to rate which product categories were brand-sensitive.
For the purposes of this survey, "brand-sensitive" meant the customer requests a specific manufacturer or is willing to accept any known manufacturer. "Brand apathetic" means the customer is willing to accept any manufacturer, doesn't care who the manufacturer is, or is willing to accept a distributor brand.
Research and market activities have shown product categories that scored 30% or more "apathetic" are more likely to be considered as early private-label opportunities for distributors. A clear delineation exists between "electrified" and "non-electrified" products. Based upon the open-ended responses, it appears concerns about product liability are a prime issue. As expected, brand sensitivity or apathy depended on whether the customer's work was focused in the industrial, commercial, or residential markets.
Industrial installers
According to the survey, industrial contractors favor brand-name products as a measure of quality but said lack of pricing competitiveness can provide opportunities for less expensive lines. When input from customers involved primarily in maintenance and repair operations (MRO) was solicited, some respondents were surprisingly willing to try non-branded products that were UL-listed or used in non-critical systems. Respondents fell into two camps on this front: those who are willing to try/use private-labeled products or those who are focused on name brands for quality and support issues. Those customers who were willing to use private-label products said specs written "or equal" are moving to non-branded products because of price considerations.
One industrial contractor who is partial to branded products said, "We specify proven products in order to provide a durable, reliable project to our clients. Non-branded products may cost less, but they may not last or perform as well over time compared to the branded product specified."
When asked if he would use private-label products, another industrial contractor said it would depend on the application. "I place less importance on the quality of brand-name products versus un-branded for secondary (not system-critical) products like cable ties or wire-pulling lubricant," he said. "Where the quality of brand names is more important is in the critical system material."
Others indicated they simply choose the best brand for the job. "I sometimes get overridden by supervisors who want cheaper products that I know aren't going to last in the application," said one respondent. "But I have to use them."
The quality of a product has to be adequate, added another contractor. "This ensures we don't have an unacceptable rate of call-backs. As long as the items are of equal quality, price and availability become the deciding factors."
Commercial contractors
This type of end-user, based on survey feedback, is most concerned with product quality, and would prefer to "buy American" if price is comparable. They feel name-brand manufacturer benefits include warranty coverage and population of information in contractor billing/estimating systems. However, price can still be king, depending on the product category. One commercial contractor felt that private-label products don't stay in the market long enough to be a major factor.
"Manufacturer brands have been around a long time and have established a consistent quality product," said one respondent. "Generic products generally don't stay in the market long enough."
Residential contractors
These contractors are the most apt to purchase private-label or un-branded products due to price benefits, according to the survey. For the most part, they do not perceive product quality differences, and believe homeowners and their other customers (builders) don't know brands or see differences in quality. Additionally, the pricing benefits of non-branded products enable residential contractors to earn jobs and retain project profitability.
"Some un-branded products, such as recessed fixture trims, appear to be identical to branded products," noted one residential contractor. "We will not pay for a brand-name lamp if we can find a lower-priced alternative that will give satisfactory results."
Another contractor voiced his frustrations with the availability of new products at electrical supply houses, indicating that many new and improved products are available, but that distributors only carry what sells the most. "If you want a certain new product, it may have to be a special-order item, and no one can wait," he said.
According to another respondent, "In this period of unstable prices, using non-branded product brings some stability to keeping our cost in line with our estimates."
Multi-focused contractors
Twenty-eight percent of respondents said they were "multi-focused" (typically meaning industrial/commercial for larger contractors and commercial/residential for smaller contractors). These are core customers for many distributors. They expressed a preference for name brands due to concerns about quality, reliability, warranty, and product-liability coverage.
"I use national brands because that is what many of my customers require, and I sell the added value," said one contractor. "I also want to be protected if there is a failure."
Another contractor agreed. "I have serious quality concerns with un-branded electrical products and will not purchase or install them," he said.
However, due to pricing, an increasing number are willing to install non-branded products as long as the products are UL-listed and will pass inspection.
Price matters big-time
With product quality becoming less of a differentiator, price drives many decisions. According to one contractor, "Some name-brand product quality has declined over the years, as has local product support. I suspect we get more information via the Internet than from our distributors. Although our purchase volume has gone up with specific distributors, product and sales support are waning. Good prices allowed us to get the jobs."
Another respondent said, "We have 'price-house distributors' approach us all the time. For certain product groupings, they have great prices and deliver in a timely fashion. But more often than not, these same supply houses don't offer the name-brand product approved for a job. We become suspect of distributors when they substitute non-branded or products with their name without notifying us beforehand. While on most of our residential jobs, we are only concerned that the product is good for the first year, we have industrial contracts that demand certain brands, even when there is a substantial cost differential. I would say in those situations there is a perceived name value to our customer, as they are asking for it by name and part number. Outside of the industrial setting, price and delivery rule the landscape."
Electrical contractors are seeing significant price differentials, as exhibited by their acceptance of private-label products. Based on the survey's results, they will more readily accept non-branded products at the following discount levels:
22% of respondents will purchase non-branded products if they get a discount of 11% to 20%.
26% of respondents said they need a discount of 21% to 30%.
39% of respondents expect a discount of at least 31%.
The higher discounts would effectively eliminate a manufacturer's role, providing all of the cost-savings to the contractor. Electrical distributors would maintain no incremental gross-margin percentage on a lower dollar volume per unit, hence reducing their profitability.
Product substitutions
While some survey respondents insisted they do not allow substitutions, 84% said they knew distributors make product substitutions for either product availability or distributor profitability reasons. The top four reasons respondents allowed substitutions included:
An urgent need exists to get product.
They believe product quality is comparable among brands.
They trust the electrical distributor to make product substitutions.
They are more concerned about whom they buy from than the brand of the product.
Although it's understandable that product availability is critical, from a manufacturer's viewpoint, it's disconcerting that there is less recognition of quality differentiation and brand allegiance in the marketplace. For very fast-moving "A" and "B" items within a manufacturer's product portfolio, encouraging distributors to stock inventory is critical to capturing incremental business. However, this needs to be balanced against a distributor's interest in managing inventory investments.
At the same time, some electrical distributors routinely substitute non-branded products for their own profit reasons. Thirty percent of the respondents said they knowingly allow distributors to substitute with non-branded products. That way, the customer receives a lower price, and the distributor earns incremental margin.
Product liability
Product quality and liability are also important issues. For example, when respondents were asked to rate "which manufacturer services are of value to you," they showed the most interest (in descending order) in product quality, products made in the United States, UL/CSA certification, local sales force support, and product warranty.
"We have industrial customers who ask if the product carries a UL or CSA label, but there are smaller customers that don't seem worried about any type of certification as long as it works," said one respondent. "Some of our customers have shrunk their purchasing departments to where there is not the same product knowledge as five to 10 years ago. So acceptance of what appears to be 'or equal' product by function is acceptable more times than not. Price really becomes a consideration in the 'switch-out' of product."
Interestingly enough, while "made in the USA" is important, contractors typically are not willing to pay significantly higher prices for these products. According to industry sources, more than 70% of electrical materials are manufactured outside the United States. National pride is evident in a number of the open-ended responses, which is understandable given global concerns and the growth of China.
While liability is a concern for installers, it should also be a major concern for distributors. Of the 10% of respondents who have had product liability issues, 71% said a distributor was involved in subsequent legal action. Based upon invoices, all knew the distributor who sold them the product.
Source vs. brand
While much of the survey focused on the acceptance level of brands, contractors are also concerned with their sources of supply when they purchase products. Given that contractors purchase from multiple distributors, respondents were asked, "What is the most important reason you purchase from a distributor?" Respondents ranked each attribute based upon their importance level. The main decision drivers and their ratings are noted in Table 2. These findings speak to the electrical manufacturers' need to strengthen local brand awareness and identification of where their products are available.
Contractor acceptance of private-labeled products in the electrical market is growing due to pricing pressures, perceived lack of quality differentiation, and — in many product categories — indifference to brand. Private-label offerings by distributors are expected to grow due to national chain product sourcing efforts, industry consolidation, and the need by larger regionals to compete against national chains and margin pressures.
Gordon is a principal of Channel Marketing Group, Raleigh, N.C. Ray is a principal of Allen Ray Associates, Kennedale, Texas.


text:
Peter Towne
Peter Towne is an associate at Iannella & Mummolo in Boston, Massachusetts. He wrote this reflection while still a student at the law school.
"I came to New England Law | Boston knowing that I wanted to take advantage of the opportunities to get involved with public interest work. In fact, these opportunities, through the clinics and other law centers, were a major factor in my decision to attend New England Law.
"In the fall of my 2L year of law school, I took the Public Interest Law Clinic and Seminar. I was able to obtain an outside placement through the clinic at Greater Boston Legal Services (GBLS). I worked in the Health and Disability Law Department of GBLS and was given the opportunity to work on the Medicare Advocacy Project (MAP). I was given a list of my own clients and cases and within a week or two was handling multitude of tasks involved with each one, under the supervision of the unit's managing attorney.
"I was responsible for writing a number of client letters, filing appeals on behalf of clients with Medicare and its administrative courts, and researching different areas of administrative law and health law. Most importantly though, I spent most of my time on the phone with clients counseling them regarding the complex Medicare regulations. I gained a tremendous amount from the client contact alone and it taught me a number of important aspects of the practice of law. I learned how to tell clients that, although their situation is certainly less than ideal, there is not really anything you can do to help them. It is not the easiest task, but a crucial one. The seminar was also an important aspect of the clinic and the learning process. Through the classroom discussion and research paper I was able to bring the big picture of public interest law into perspective and more fully understand and appreciate its important place in the legal world.
"During the summer after my second year of law school I worked with the Commonwealth of Massachusetts through the Mental Health Legal Advisors Committee. This organization is funded by the state to work with those who have mental health issues and counsel them through their legal problems. This was again a very valuable experience for many of the same reasons. I was given a number of cases to handle on my own, and was also given the opportunity to participate in the intake process. I was able to perform the initial client interview and was responsible for the evaluation of the client's case as it came into the office. Through the office's many specialties, I was also given the opportunity to see many different areas of law practice, from family law and employment law to drafting legislation and lobbying at the statehouse.
"Finally, during my last semester of law school I worked in the Suffolk County District Attorney's Office through the Criminal Procedure II Clinic. This experience was tremendous for me and really helped round out the skills I have gained throughout the clinical experience. One of the main reasons for this is the frequency with which I was able to be in the courtroom and stand up in front of a judge. I was placed in the DA's office in the Roxbury District Court, which is one of the busiest in Suffolk County. My supervisor was very eager to get me into the courtroom every chance he got and within weeks of starting the clinic I was handling my own cases and taking part in every step of the prosecution process, from arraignment to trial.
"Although actually getting to do a trial of your own is hard to come by, due to the small number of cases that actually make it to trial, by the end of the clinic I was in front of a judge every day I went into work. Another great experience I drew from the clinic was the opportunity to work with a number of defense attorneys representing their clients. One of the most important tasks a prosecutor performs is negotiation and communication with opposing counsel. Whether it is negotiating a plea or communicating with them about discovery, it was an amazing opportunity to fully experience the job on a day-to-day basis (though I was only there a few days a week!).
"Overall the experiences I had with the clinics and public interest work I have done in law school were extremely positive. I am more than satisfied with the opportunities I have had during my law school career to go out into practice and learn the law from a hands-on perspective. I truly feel that the public interest work I have done here has given me the tools I need to be confident in saying that I feel prepared and ready to practice law as soon as I graduate and pass the bar."


text:
thehockeyguru wrote:IMO, the Pens need to do a better job of recognizing when teams are packing it in defensively and adjust accordingly. Less East-West passing and more getting shots on net / crashing the net. If teams want to pack it in and generate offense off of our turnovers we MUST simplify our game. This is how less talented teams will play us in the playoffs.
I mean it worked against Montreal in the playoffs a couple years ago.