The Occupational Health and Safety Administration (“OSHA”) 1910.134 (a) (2) states the following:

1910.134(a)(2)

A respirator shall be provided to each employee when such equipment is necessary to protect the health of such employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program, which shall include the requirements outlined in paragraph (c) of this section. The program shall cover each employee required by this section to use a respirator.

1910.134(c)

Respiratory protection program. This paragraph requires the employer to develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The program must be administered by a suitably trained program administrator. In addition, certain program elements may be required for voluntary use to prevent potential hazards associated with the use of the respirator. The Small Entity Compliance Guide contains criteria for the selection of a program administrator and a sample program that meets the requirements of this paragraph. Copies of the Small Entity Compliance Guide will be available on or about April 8, 1998 from the Occupational Safety and Health Administration's Office of Publications, Room N 3101, 200 Constitution Avenue, NW, Washington, DC, 20210 (202-219-4667).

One of the most egregious mistakes that we see while in the field is the lack of attention to the above guidelines. Further the Texas Mold Assessment and Remediation Rules state:

MINIMUM WORK PRACTICES AND PROCEDURES FOR MOLD ASSESSMENT. MOLD ASSESSMENT.

 (c) Personal protective equipment for assessors. If an assessment consultant or company determines that personal protective equipment (PPE) should be used during a mold assessment project, the assessment consultant or company shall ensure that all employees who engage in assessment activities and who will be, or are anticipated to be, exposed to mold are provided with, fit tested for, and trained on the appropriate use and care of the specified PPE. The assessment consultant or company must document successful completion of the training before the employees perform regulated activities.

MINIMUM WORK PRACTICES AND PROCEDURES FOR MOLD REMEDIATION. MOLD REMEDIATION.

(c) Personal protective equipment. If an assessment consultant specifies in the mold remediation protocol that PPE is required for the project, the remediation contractor or company shall provide the specified PPE to all employees who engage in remediation activities and who will, or are anticipated to, disturb or remove mold contamination, when the mold affects a total surface area for the project of 25 contiguous feet or more. The recommended minimum PPE is an N-95 respirator. Each employee who is provided PPE must receive training on the appropriate use and care of the provided PPE. The remediation contractor or company must document successful completion of the training before the employee performs regulated activities.

Most new consultants and remediators are young and don’t think about the long-term exposure they are about to encounter working in the mold services industry. Workers in this industry are exposed to mold in different quantities, but all are exposed repeatedly. When scoping new jobs, most consultants and remediation contractors barely wear any protective respirator gear. The most basic N95 is the standard that we see in the field. This is a fatal flaw in their approach to working around mold and mold spores.  Employers/Supervisors must set the example. Remember, the health and safety of your employees depend on you following the guidelines and setting the example.

Sincerely,

Jake White