- Standard Number:
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.
September 17, 1992
Mr. John T. Marchese
Environmental Health and Safety
SUNY at Stony Brook
Suffolk Hall, Room 110
Stony Brook, New York 11794-6200
Dear Mr. Marchese:
This is in response to your inquiry of August 5, concerning the Occupational Safety and Health Administration's (OSHA) "Hazardous Waste Operations and Emergency response" (HAZWOPER) regulation, 29 CFR 1910.120.
Your question concerns clarification of personal protective equipment (PPE) for medical personnel treating victims contaminated with hazardous material, and, specifically, whether Level A PPE would be necessary.
Paragraph (g)(3)(iv) of the standard states that Level A totally encapsulating chemical protective suits "shall be used in conditions where skin absorption of a hazardous substance may result in a substantial possibility of immediate death, immediate serious illness or injury, or impair the ability to escape." Further, Appendix B, Part B(I), of the standard provides nonmandatory guidance on selection of the appropriate level of PPE, front which the following recommendations are drawn.
Level A protection offers the highest level of skin, eye, and respiratory protection and should be used whenever work functions involve a high potential for splash, immersion, or exposure via vapors, gases or particulates, to materials harmful to skin or capable of being absorbed through the skin.
Level B protection is appropriate when conditions require a high level of respiratory protection due to inhalation hazard but require less skin protection, because chemicals harmful to the skin or capable of absorption through the skin are not present as a splash or immersion hazard or in high concentrations in atmospheric contaminants.
Emergency response planning, including selection of PPE, is to be based on worst-case scenarios. If you were able to determine, in conjunction with the small industries in your community, that worst-case scenarios of contaminated victims arriving at your facility would not pose hazards requiring use of Level A gear, then a lower level of personal protective equipment would be appropriate.
We hope this information is helpful. If you have any further questions please feel free to contact us at (202) 523-8036.
Patricia K. Clark, Director
Directorate of Compliance Programs