ML20134G211
| ML20134G211 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 10/31/1984 |
| From: | Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Guthrie S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20134G202 | List: |
| References | |
| NUDOCS 8508230169 | |
| Download: ML20134G211 (4) | |
Text
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l RECElVED w
FEB 151955 3"
October E:ri.984 y
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MEtiORANDUMFOR:S. Guth.g d
. Bin 4. p
- r. Resident Inspector epint Nuclear Station FROM:
L. R. Gre er, Chief y
Emergency
- Preparedness and Radiological Protection Branch
SUBJECT:
FACIAL HAIR RESTRICTION ON RESPIRATOR USE This memorandum is in response to your October 2,1984 memorandisa to James G. Keppler.
I have attached a clarification of OSHA regulations concerning respirator usage and facial hair (29 CFR 1910.134(e)(5)(1)). This clarification, which was provided by J. E. Wigginton, EGCB, IE, who has been coordinating IE's resolution of this natter, states that "any hair growth in the face sealing area is unacceptable." It appears clear that workers wearing
- r tight-fitting facepiece respirators must be clean shaven when wearing such-a respirator.
It is obvious that if workers' duties involve emergency response activities, where respirator usage may be required, they must remain clean, shaven if they are to respond quickly to emergencies.
i Mr. Wigginton also advised me that a memorandum will be issued soon by R. L. Baer, Chief EGCB, IE, to all five Regions concerning regulatory prohibitions against the use of tight-fitting respirators if facial hair intruces into the facepiece seal against the skin.
I assume that if they are not already doing so, all Regions will enforce these regulatory require-ments subsequent to their receipt of Mr. Baer's memorandum.
I will provide l
a copy of that memorandum to you when I receive it.
8508230169 G50816 PDR ADOCK 03000155 F
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V Octobsr 31. 1984
- s. Guthrie f
Subsequent to receipt of your October 2,1984 memorandum. Consumers Power Company was released from their comitment to this office to implement a facial hair policy by October 19, 1984, while I reviewed the matter. 'Upon receipt of the above referenced memoiandum from R. L. Baer. I expect to reestablish a comitment date with Consumers Power Company.
L. R. Greger, Chief Emergency Preparedness and
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Radiological Protection Branch
Attachment:
As stated cc w/ attach.:
Ron Siwarga, Chief S_teward Local 346. UWUA Jeff Bakker, Sec-Treas.,
Local 346. UWUA Mr. Dave Hoffman, Plant Superintendent, Big Rock Point J. G. Keppler, Regional
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Admin'strator, RIII
's J. E. Wigginton IE e
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li. v r to u 4 eve in. ot JR 131983 Harry C.yusse!!, Col., USAF, BSC Command Bioenvironmental Engineer Office of the Surgeon Department of the Air Force Headquarters Air Force 1.ogistics Command Wright-Patterson Air Force Base, Ohio 45433
Dear Colonel Russell:
i We are providing answers to the questions on beards and respirator wear which you asked in your letter of June 20,1983.
a.
Yes, any facial hair growth between the faceplece sealing surface and the skin that prevents a good sealing surface is a violation of 29 CFR l
1910.134(e)(3)(i).
b.
The OSHA standard is a minimum standarri. Any employer can set more
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stringent requirements than OSHA's. If tne bearded employee is exposed to a toxic material in excess of the Air Force standard but within the OSHA standard, the respirator should not be worn until the interferring hair is removed because the Air Force standard would have been violated even if the OSHA standard were not.
c.
.Yes, the situation described in your section C is still a violation of 1910.134(eX5Xi). The question is not whether the bearded person can pass the fit test on a given day, but whether he can pass the test everyday.
Since the density and texture of the beard is not unifcrm around the face, and because the density and bulk of beard is not the same over time, consistent fit test results cannot be obtained. Quantitative fit testing (QNFT) is the only available method which can accurately measure the fit.
testing result of a respirator. It is a time consuming process. The equipment is rather expensive and needs trained personnei to operate it.
For these reasons, the QNFT is generally conducted only annually. It is unreasonable to require the employer to conduct QNFT everyday to determine whether a satisfactory fit can be obtained from a bearded individual. Qualitative fit testing would yield less reliable results.
d.
OSHA's position is that any hair growth'in the f ace sealing area is unacceptable. Depending on the growth, density and texture of, beard, some bearded individuals cannot achieve a satisf actory seal even at the end of the shitt.
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e.
The language on beards and respirator wearing is adequate in
!#10.134(e)(3)(i). The third sentence in this paragraph only provides a partial list of the conditions that prevent a good face seal. The second sentence clearly prohibits respirator usewhen any such condition is present. Since the Air Force can adopt a standard which is more stringent than ours, you may consider adopting the current American National Standard Practices for Respiratory Protection, ANSI Z83.2,1980 (enclosed).
We are also enclosing two research papers on facial hair and a publication from the Fire Fighters Union which includes two U.S. Supreme Court decisions on the facial hair issue for your reference.
Sincerely, o
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ifhl'O' 4,
ard 3. Baier Director Technical Support, Enclosure,s
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