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 http://www.osha.gov.

May 14, 1984

 

 

MEMORANDUM FOR: BYRON R. CHADWICH
Regional Administrator
 
THRU: JOHN B. MILES, JR., Director
Directorate of Field Operations

EDWARD J. BAIER, Director
Directorate of Technical Support
 
FROM: RALPH E. YODAIKEN, M.D., Director
Office of Occupational Medicine
 
SUBJECT: Medical Interpretation - H2S and Respiratory Protection

 


In our opinion a perforated eardrum is not an impediment to wearing a SCBA positive pressure unless there is fluid behind the ear or other signs of an infection. This implies a proper medical examination by an experienced physician or an ENT specialist before use of the respirator.

However, working in a toxic environment with a perforated eardrum is contraindicated because of the possibility of direct absorption through the perforated drum so certainly we agree with the University of Texas that persons with perforated drums should not be in IDLH (H2S) situations. In fact it seems possible, although we have no confirmation, that the positive pressure may increase the possibility of increased absorption.



March 22, 1984

 

 

 

 

MEMORANDUM FOR: EDWARD BAIER, Director
Directorate of Technical Support
 
THRU: JOHN B. MILES, JR., Director
Directorate of Field Operations
 
FROM: BYRON R. CHADWICK,
Regional Administrator
 
SUBJECT: Medical Interpretation - H2S and Respirator Protection

 


This region recently held two training sessions on H2S requirements in the oil production industry. As part of that training, we used a film produced by the University of Texas on respiratory protection and H2S. The film stated that persons with perforated eardrums should not wear SCBA positive pressure in IDLH situations caused by H2S.

The safety director for Gulf Oil in this area called and asked that we review that statement since Gulf's medical department had stated as company policy that this situation was not a danger to employees.

I am requesting that your medical staff give us an opinion on this subject. If you need any other information on this, please contact Bob Glover of my staff. Your prompt attention would be appreciated.