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Recommended Work Practices
The HSPP applies to manufacture, fabrication, installation, removal and other work settings where workers are subject to comparable exposures to SVFs. The Program is in compliance with all applicable provisions of the Hazard Communication Standard as already required by law. While NAIMA members are responsible for compliance with these voluntary guidelines in their own operations, NAIMA and its member companies undertake the activities described here to educate and encourage compliance with these guidelines by other employers and their workers within the scope of this proposal. Recommended PELPerhaps the most significant feature of the HSPP is the establishment of a voluntary permissible exposure limit (PEL) for fiber glass, rock and slag wool. This provision of the Program is important for several reasons. First, OSHA itself cited the absence of a formally recognized PEL for SVFs as one of the deficiencies under current regulations. The adoption of a voluntary one fiber per cubic centimeter (1 f/cc) PEL simply reaffirms the exposure limit that has been recommended by industry and government and various authoritative bodies for several years. Read additional information. Comprehensive Work PracticesThe HSPP commits NAIMAs members to use product design, engineering controls, work practices, respiratory protection or a combination of any or all of these measures to bring fiber exposure to the voluntary 1 f/cc PEL. To strengthen these control measures, the HSPP specifies comprehensive work practices for those working with SVFs. Part of the HSPP duties assumed by NAIMA is the sponsorship of training sessions to help educate workers and employers about the consolidated work practices. NAIMA provides educational tools such as video tapes and literature to further explain the recommended work practices. For additional information, click here. Recommended Respiratory ProtectionA fundamental aspect of the recommended work practices deals with when and where to use respiratory protection. The HSPP recommends respiratory protection whenever exposures on a job exceed the 1 f/cc 8-hour time-weighted average (TWA) PEL. The type of respirator mandated by the HSPP is an N95 series dust respirator certified by NIOSH. In addition to those tasks that traditionally exceed the TWA PEL, specific jobs have been designated as necessitating respiratory protection because of the possibility of exposures above 1 f/cc. These particular requirements may be revised if further research and evidence demonstrates a consistent pattern of low exposures. For additional information, click here. Exposure DatabaseThe HSPP commits NAIMA to provide an exposure database to help contractors and workers determine the level of potential exposure to fiber glass, rock wool or slag wool for a given task. Exposure monitoring and an exposure database are closely related to the respiratory protection guidelines and offer contractors a way to determine whether respiratory protection is necessary for a particular job. This will not only help contractors follow the HSPP, but may also greatly reduce the burdens that contractors would otherwise incur under the now existing Respiratory Protection Standard. NAIMA also has committed to supplement the database with additional information from exposure studies conducted during the implementation and compliance phase of the HSPP. For additional information, click here. |
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