Occupational exposures above occupational exposure limits may be citable irrespective of appropriate respiratory protection
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Type:  Lessons Learned

Publisher:  URS CH2M Oak Ridge, Oak Ridge, TN

Published As:  Public

Date: 

Topics:  Respiratory Protection, Occupational Safety and Health

Based on a review of FY2014 workplace breathing zone measurements for asbestos, UCOR was issued a finding by the DOE when some portion of the data points were above the applicable time-weighted average or excursion concentration limits. Inasmuch as all Asbestos Containing Material and Presumed Asbestos Containing Material scope is undertaken within a 29 CFR 1910.134 compliant respiratory protection program, UCOR was pursuing its D&D mission under the paradigm that workplace exceedances within the maximum use concentration for the respiratory protection - while reason for attention - were not citable as violations.

For challenge agents such as asbestos that require laboratory analysis with its inherent time lag to quantify airborne concentrations, this compliance posture magnifies the worker protection challenges for non-routine activities such as decommissioning and demolition.

Lessons Learned: Where workplace concentration measurements demonstrate that airborne concentrations are in excess of applicable occupational asbestos exposure limits, the employer must be able to demonstrate BOTH:
- That respiratory protection in use by the occupants was sufficiently protective, AND
- That all feasible engineering and work practice controls have been applied to minimize
concentrations.

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