April 26, 2011
Mr. Ira Gurvitch
Elmridge Protection Products
6615 W. Boynton Beach Blvd.
Boynton Beach, FL 33437
Dear Mr. Gurvitch:
Thank you for your letter of August 23, 2010, to the Occupational Safety and Health Administration (OSHA) requesting further clarification of our earlier letter to you regarding OSHA's policy on the use of smoke escape hoods. This letter constitutes OSHA's interpretation only of the requirements discussed, and may not be applicable to any question not delineated in your original correspondence.
In your letter you ask whether OSHA's Respiratory Protection Standard at 29 CFR 1910.134 permits workers assigned to ensuring the evacuation of all areas in a structure (frequently designated as "area monitors") to use smoke escape hoods to perform this task. As stated in our meeting with you and in our previous letter to you, "Escape hoods/masks may be used only for escape and not used for purposes that would delay a safe exit from the building. OSHA regulations would prohibit the use of smoke escape hoods by workers required to respond to a fire incident, or to remain in the area in the event of an incident." Accordingly, employees designated as "area monitors" can use smoke escape hoods only for escape purposes, not for performing other tasks.
When there is no fire or smoke in the immediate area, workers assigned "area monitor" responsibilities may provide some crowd management, direct traffic, or make quick checks of the rooms on the floor to ensure proper evacuation, even without wearing any mask. However, once smoke and/or fire enters the immediate area, they must exit that area at once for a safe location, whether or not they are using a smoke escape hood. In summary, when workers use smoke escape hoods, they must use them only for escape purposes, and not for purposes that would delay their safe exit from a structure.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set
by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Thomas Galassi, Director
Directorate of Enforcement Programs