April 2011- Respiratory Protection & Stormwater

Q:  If employees have a beard or moustache, is their respirator still effective?

A:  Tight-fitting facepiece respirators must not be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function. Respirators that do not rely on a tight face seal, such as hoods or helmets, may be used by bearded individuals.

Q:  Is training required before a respirator is used?

A:  Yes, training must be provided to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This training should include at a minimum:

  • Why the respirator is necessary and how improper fit, use, or maintenance can compromise its protective effect
  • Limitations and capabilities of the respirator
  • Effective use in emergency situations
  • How to inspect, put on and remove, use and check the seals
  • Maintenance and storage
  • Recognition of medical signs and symptoms that may limit or prevent effective use
  • General requirements of OSHA's respirator standard, 29 CFR 1910.134

Q:  What are the employer's obligations when respiratory protection is not required but employees wear respirators on their own accord?

A:  The employer must implement those elements of the written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so its use does not present a health hazard to the user. Also, employers must provide the voluntary respirator users with the information contained in Appendix D of 29 CFR 1910.134. Employers are not required to include in a written respiratory program those employees whose only use of respirators involves the voluntary use of filtering facepieces (dust masks).

Q:  Who is in charge of the respirator program?

A:  The program must be administered by a trained program administrator who is qualified and knowledgeable in respiratory protection to run all aspects of the program.

Q:  Can a respirator be used by more than one person and how often should it be cleaned and disinfected?

A:  Disposable respirators cannot be disinfected, and are therefore assigned to only one person. Disposable respirators must be discarded if they are soiled, physically damaged, or reach the end of their service life. Replaceable filter respirators may be shared, but must be thoroughly cleaned and disinfected after each use before being worn by a different person, using the procedures in Appendix B-2 of 29 CFR 1910.134, or equally effective procedures recommended by the manufacturer. 


Q:  To which industrial facilities does the Stormwater Multi-Sector General Permit(MSGP) apply?

A:  Facilities must develop and implement a Storm Water Pollution Prevention Plan (SWPPP) to outline the procedures and equipment in place to prevent contaminants from getting into the storm water. A Storm Water permit must also be obtained from the state or local regulatory entity.  Depending on your local regulations and SIC Code periodic reports may be required.

Operators of industrial facilities requiring an NPDES Stormwater Permit are eligible to obtain coverage under the MSGP if their activities are included within one of 29 industrial sectors AND the facility is located in an area where EPA is the NPDES permitting authority. Where an authorized state is the permitting authority,operators of regulated industrial operations should apply to the state forindustrial stormwater permit coverage.

Q:  How does a facility determine whether they need to obtain an NPDES Stormwater Permit?

Step 1. Determine whether the facility or site discharges to a municipal separate storm sewer system (MS4) or to waters of the United States. If it discharges to one or both, proceed to Step 2, otherwise no permit is needed.

Step 2. Determine if the facility's industrial activities are listed among the eleven Categories of Industrial Activities, provided in the federal regulations at 40 CFR122.26(b)(14) or it the facility's SIC code falls within one of the sector/subsectors identified.  If its activities are listed, proceed to Step 3, otherwise no permit is needed.

Step 3. Determine if the listed facility or site may qualify for the "no exposure" exclusion under the federal regulations at 40 CFR 122.26(g).

Q:  How does a facility terminate coverage?

A:  A Notice of Termination (NOT) form for Industrial Activity must be submitted to EPA's NOI Processing Center (address identified on the NOT form) in order to terminate coverage. Permittees may submit an NOT when their facility no longer has any stormwater discharges associated with industrial activity as defined at 40 CFR 122.26(b)(14), or when they are no longer the operator of the facility.

For more detailed information on the requirements of Stormwater Discharges from Industrial Facilities … Stormwater Discharges from Industrial Facilities

Disclaimer: These Regulatory Reminders are not intended to be an exhaustive source for all of your particular facility’s compliance issues. They are designed to address the basics requirements with which most companies are required to comply. Following the Regulatory Reminder’s deadlines and Monthly Focus will not guarantee your compliance as these reminders are simply designed to help in your environmental/safety compliance efforts. You should always refer to the federal and your state’s regulations for all your requirements. Ultimately, your compliance with federal and state regulations is your responsibility. E&SSG assumes no liability for your compliance or the resources provided in these “Reminders”.

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