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Counterfeit Respirators: A Preventable Purchasing Failure

Sat, 20 Dec 2025 19:42:19 GMT

Respirator facepieces, cartridges, and filters are routinely counterfeited. Most buyers cannot verify whether what they received is authentic, and the marketplace isn’t set up to ensure authenticity.

Respiratory protection is especially vulnerable to counterfeits because the most safety-critical functions cannot be confirmed by visual inspection. A trained eye might catch subtle tells, inconsistent molding marks, off-color materials, or printing and labeling errors. But appearance does not verify performance. You cannot reliably determine by sight whether a cartridge contains the correct sorbent, whether a particulate filter actually meets its required performance rating, or whether facepiece materials and components will maintain a stable seal under real-world conditions over time.

A respirator’s protective performance is driven by materials and manufacturing tolerances, including the composition and consistency of the facepiece elastomer, the integrity of the lens and frame, strap and buckle hardware strength and elasticity, sealing surface geometry, and the design and quality of inhalation and exhalation valves. Small substitutions or dimensional changes can materially affect fit, seal reliability, and durability.

For filter cartridges, protection depends on the correct filter media or sorbent formulation, a reliable seal between the cartridge and the facepiece, and internal construction that controls airflow distribution and loading. Substitutions in media, sorbent, adhesives, gaskets, or internal geometry can reduce protection immediately and may lead to premature chemical breakthrough or inadequate filtration performance.

Because these performance characteristics cannot be confirmed by inspection, the only practical safeguard is a verifiable supply chain. When chain of custody is unclear, the buyer has no defensible basis to trust authenticity, certification, or performance. The risk is highest when products come from online marketplaces like Amazon, especially third-party sellers, liquidators, or “new in box” resellers with no traceable sourcing. Commingled inventory practices, where “identical” products from different sellers can be pooled in warehouses, further increase the risk of counterfeit products entering the supply chain.

Despite specifically advising clients not to purchase PPE, especially respirators, from Amazon, eBay, or similar online marketplaces, we are seeing this guidance disregarded. We arrive to fit test respirators that show subtle differences from the authentic 3M products we supply. In multiple cases, those units are ultimately confirmed as counterfeits purchased through the exact sources we advised against.

Using price as the primary, or only, selection criterion for a personal protective equipment vendor is irresponsible.

The employer owns the consequences of negligence in purchasing. If there’s an exposure incident, an injury, or an audit, “we got it online” or "it had free Prime shipping" is not a defense. Workers notice too. When employees don’t trust the gear, company safety culture quietly collapses.

Buy PPE through:

- Authorized distributors

- Direct from the manufacturer

- Established industrial or safety suppliers with traceability

The Important Difference Between a Shop Vac with HEPA Filters and a HEPA-rated Dust Extractor

Mon, 27 Oct 2025 00:16:12 GMT

At a glance, a shop vacuum with a HEPA filter and a dedicated HEPA-rated dust extractor might seem to do the same job: collect dust and debris. In reality, the difference between them is substantial, especially for fine particulate control, worker protection, and regulatory compliance. Adding a HEPA filter to a standard shop vacuum improves filtration, but it doesn’t turn the unit into a true HEPA-rated system suitable for hazardous dust.

Key takeaway: If you’re collecting fine dust from hazardous materials, use an extractor designed and certified for that purpose. Don’t rely on a shop vac with a retrofit HEPA filter. Here’s why:

Most shop vacs leak around seals or bypass fine dust through motor vents, even if they use a HEPA filter. A proper dust extractor is designed from the ground up for fine dust control. All seals, gaskets, and joints are engineered to prevent leakage, and the entire system, not just the filter, is tested to meet HEPA performance.
Shop vacs are built for high pulling force (static pressure) to pick up debris, nails, or sawdust through hoses. Dust extractors are designed to steadily move larger volumes of air (airflow) and catch fine, respirable dust particles before they disperse.
Shop vacs clog quickly when used on fine dust; when the filter clogs, vacuum pressure drops, and more dust escapes into the air. Dust extractors include self-cleaning or pulse-clean mechanisms that shake accumulated fine dust off the filter. This leads to consistent pressure levels, and extends filter life.

A shop vac is meant for short-term cleanup. Dust extractors are designed for longer periods of use, often with features like automatic tool-start functions, variable speed control, anti-static hoses, and spark-resistant motors for combustible dust safety.

For operations covered under Cal/OSHA or Federal OSHA silica standards, or for controlling other hazardous respirable dusts like carbon, graphite, metals, wood, or asbestos, a simple shop vac with a HEPA filter is not sufficient. Hazardous materials require commercial-grade HEPA-filtered dust collection systems engineered and tested for fine particulate containment and exposure control.

Respirator Cartridge Changeout Schedules

Sun, 31 Aug 2025 01:57:23 GMT

Respirator cartridges for gas or vapor protection have a limited service life. They need to be changed before they become saturated and can no longer purify the air effectively.

If an employer is using air-purifying respirators for protection against gases and vapors, Cal/OSHA T8 §5144(d)(3)(C) requires that the employer either:

Use a cartridge with an end-of-service-life indicator (ESLI) that provides an indication to the user that the cartridge has reached the end of its service life. Unfortunately, ESLI cartridges are not available for most chemicals.

Implement a time-based cartridge changeout schedule. This must be, per Cal/OSHA, “based on objective information or data that will ensure that ... cartridges are changed before the end of their service life. The employer shall describe in the respirator program the information and data relied upon and the basis for the ... cartridge change schedule.”

Relying on users to detect the end of the cartridge service life by smell, taste, or irritation of the chemical passing through is not compliant as a primary method for cartridge changeout. It may be used only as a secondary safeguard to the employer's time-based changeout schedule.

This is a common mistake: an employer identifies a potential respiratory hazard, buys respirators, and provides fit testing - yet skips the crucial step of a formal, documented hazard assessment and changeout schedule.

For gas or vapor exposures, your written program should clearly specify:

• The correct respirator type for the task

• Appropriate cartridge or combination filter-cartridge

• A time-based changeout schedule supported by data

Safewest can help develop or review your respirator program, including hazard assessments and cartridge change schedules. Contact us to make sure your program is compliant and your employees are protected.

Hazwoper Training Levels

carlo@safewest.com — Mon, 27 Jan 2025 02:50:18 GMT

Hazmat training levels for site workers, emergency response and treatment, storage, and disposal facilities

HAZWOPER (Hazardous Waste Operations and Emergency Response) training requirements apply to certain operations involving hazardous waste. These requirements dictate the amount, type and levels of training that employees working with hazardous waste must receive. The requirements for hazwoper training can be found in Cal/OSHA § 5192 and Federal 49 CFR 1910.120 .

In general, there are three categories of hazmat operations, and specific training requirements for each. These three categories are hazmat site cleanup, emergency response, and operations at treatment, storage, and disposal (TSDF) facilities.

Site Cleanup

Cleanup and removal work at sites that have been identified by a government agency (state, federal, or local) as having an accumulation of hazardous substances that creates a threat to the health and safety of individuals or the environment or both.

General site workers removing hazmat with potential exposure to hazardous substances and health hazards shall have 40 Hours of Training + 3 Days Supervised Field Experience.
General site workers in areas where hazard levels have been fully identified, exposures are below published safety limits, there are no health hazards, no possibility of an emergency release, and respirators are not required shall have 24 hours of training + 1 day supervised field experience.
Occasional/limited site workers (such as those doing monitoring or surveying) and are unlikely to be exposed to dangerous levels of hazmat shall have 24 hours of training + 1 day supervised field experience.
Supervisors of general site workers shall meet the same training requirements as that category of general site worker, plus have an additional eight additional hours of specialized hazardous waste operations management training.

All categories of site cleanup workers shall have 8 hours of annual refresher training.

Emergency Response

Emergency response to releases of, or substantial threats of releases of, hazardous substances, regardless of location.

Awareness Level (FRA): Basic awareness, recognize hazmat threat, call for help. Competence based, no hourly requirement.
Operations Level (FRO): Defensive response, contain and limit the release. 8 hours of training required (or a competence-based option exists for experienced workers).
Hazmat Technicians and Hazmat Specialists: Direct response to stop a release of hazardous substances. Training scope and duties varies depending on position/role. 24 hours of training required.
Incident Commander/Manager: Control and manage scene, implement response plans. 24 hours of training required.

All emergency response workers shall receive annual refresher training or evaluation to demonstrate competency in their required areas.

TSDF Operations

Operations at Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDFs)

Workers are required to have 24 hours of initial training, and 8 hours annual refresher training.

Snakebite First Aid Guidelines

Sat, 28 Dec 2024 01:42:02 GMT

The most important thing to know about snakebites is that people drastically overestimate both the likelihood and the severity of venomous snake bites in the US. Snakebites are fairly rare, and fatalities from snakebites are so unlikely (generally 5-10 per year in the entire country), a person is many times more likely to die from a lightning strike, or a heat-related emergency, or any number of other outdoor hazards.

Prevention is simple. It is relatively simple to avoid most snakebites by being aware of where you step, not reaching or climbing on any area you haven't visually inspected first, and not approaching snakes to catch, kill, or photograph them.

There are some significant misunderstandings about first aid measures for snake bites, many unfortunately perpetuated by uninformed first aid instructors and irresponsible equipment vendors.

Do NOT apply suction. Avoid the use of commercial snakebite kits with suction pumps, like the Sawyer Extractor. See our article on venom extractors for more information on these ineffective and dangerous devices.
Do NOT apply tourniquets or constricting bands.
Do NOT cut the skin.

Basic first aid measures are simple. Here's what you should do:

Keep the person calm and avoid unnecessary movement.
Why: Keeping the person's heartrate in a normal range slows the distribution of venom in their body.
Remove watches, rings, and other tight fitting items.
Why: These can constrict bloodflow if the person's limbs start to swell due to the venom.
Call 911. If you do not have cellphone service, you will have to consider either finding a way to transport the person, or leaving them while you try to reach an area with cellphone service.
Why: The only definitive care for a venomous snakebite is transport to a hospital for supportive care, and possibly anti-venom medication.

For people working (or recreating) outdoors, mindfulness of where you place your feet and hands is your best defense against snakebites. If you will be in an area without cellphone coverage, investing in a means of emergency communication such as a satellite phone or messenger, personal locator beacon, two-way radio is the most important part of your emergency response plan.

Three action steps for California employers:

Review this information with your workers in April or March, which is when snake sightings will begin to increase.
Ensure workplace first aid supplies do not contain outdated and dangerous supplies like snakebite kits and venom extractors.
Ensure workers in remote areas have adequate means of emergency communications.

Cal/OSHA Respiratory Protection Regulations

Sat, 28 Dec 2024 01:33:44 GMT

Cal/OSHA's requirements for workplace respiratory protection can be found in 8 CCR §5144 . Violations of the respiratory protection standard are one of the top 10 most frequently cited violations by Cal/OSHA, and a high-priority enforcement area.

Any employer whose employees are required to use respirators must develop a written respiratory protection program and provide employees with medical evaluations, respirator training, and fit testing before they use respirators at work.

This article summarizes these regulatory requirements and explains why they are important.

Written Program

Why: Trying to run a respirator program without a written plan is like building a house without blueprints. Work will happen, but not in a consistent, reliable, or compliant way.

Your written program must be customized to your workplace. It should specify which positions or tasks require respirator use, what types of NIOSH-approved respirators are to be used, and how your company will provide required medical evaluations, fit testing, and training for your employees. The program should also describe procedures for respirator use and maintenance, ongoing program evaluation, and who is responsible for overseeing the respirator program.

Cal/OSHA §5144(c): "The employer shall ... develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The program must be administered by a suitably trained program administrator."

Medical Evaluation

Why: Respirator use puts greater stress on the worker’s body, especially the heart and lungs. A medical evaluation helps rule out any serious health problems that could be worsened by respirator use.

Before wearing a respirator at work, employees must complete a health history questionnaire that is evaluated by a healthcare provider, who then determines whether the employee is approved to wear a respirator or if additional evaluation (such as a physical exam or pulmonary function test) is required.

Cal/OSHA §5144(e): "The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace."

Employee Training

Why: Workers need to know how the respirator works, how to use it correctly in the workplace, and what problems to watch out for.

Employees should receive training on the capabilities and limitations of the respirator, what tasks they should use the respirator for, how to inspect, put on, remove, and use the mask, procedures for maintenance (if applicable) and storage, identifying and troubleshooting problems, and the general requirements of the OSHA standard.

Cal/OSHA §5144(k): "The employer shall ... provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary."

Fit Testing

Why: Every person's body is different, and employees need to make sure they are wearing a respirator that makes an adequate seal to their face.

Employees should be fit tested to identify the specific make, model, style, and size of the respirator that is best suited for each employee, and check for problems with respirator condition, use, and donning procedure.

Cal/OSHA §5144(f): "...before an employee may be required to use any respirator with a negative or positive pressure tight-fitting facepiece, the employee must be fit tested with the same make, model, style, and size of respirator that will be used."

Together, the written program, medical evaluations, employee training, and fit testing form the core of an OSHA-compliant workplace respirator program. Safewest can assist employers with all required elements of a respiratory protection program. If you need help, or just want a few questions answered, contact us for a free consultation.

Facial Hair and Respirator Use

carlo@safewest.com — Thu, 31 Oct 2024 16:56:31 GMT

OSHA’s respiratory protection standard leaves no ambiguity: tight-fitting respirators cannot be used with facial hair in the seal area of the facepiece. Non-compliance remains common, creating unnecessary risk to employee health, and exposing employers to OSHA penalties for worker noncompliance.

What follows is a summary of the relevant regulations and guidance:

CALIFORNIA OSHA RESPIRATORY PROTECTION GUIDE

“Employees cannot have facial hair that interferes with the face-to-facepiece seal during the fit testing procedures.”

FEDERAL OSHA LETTER OF INTERPRETATION, 9/14/2012

“An employer whose records show a respirator wearer passing a fit-test with facial hair in the respirator sealing surface area is not considered to be compliant with the standard. The fit that is achieved with...facial hair is unpredictable; it may change daily depending on growth of the hair and position of the hair at the time the fit is tested.”

OSHA REGULATIONS CALIFORNIA T8 §5144/FEDERAL 29 CFR §1910.134

“The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have...facial hair that comes between the sealing surface of the facepiece and the face...”

FEDERAL OSHA LETTER OF INTERPRETATION, 10/11/1984

“...when a respirator must be worn to protect employees from airborne contaminants, it has to fit correctly, and this will require the wearer's face to be clean-shaven where the respirator seals against it.”

FEDERAL OSHA LETTER OF INTERPRETATION, 10/03/1996

The regulatory language...does not make any exceptions when fit testing shows a good fit has been achieved for persons with beards, [because] hair growth occurs daily...”

FEDERAL OSHA INTERNAL DIRECTIVE FOR ISSUING CITATIONS, 6/26/2014

“...be alert for the presence of facial hair (more than one day's growth)...cite (g)(1)(i)(A) when employees' facial hair comes between the sealing surface of the facepiece and the face or interferes with valve function...”

Written Respiratory Protection Program Basics

carlo@safewest.com — Fri, 17 May 2024 21:35:22 GMT

If workers need to wear a respirator for safety, the employer is required by Cal/OSHA §5144(c) to have a written respiratory protection program. In an OSHA inspection or a workers’ compensation claim where work-relatedness is disputed, investigators will typically request the written respiratory protection program early in the process. However, a written program is not just a compliance document. It serves three practical purposes:

– Ensures respiratory hazards are accurately identified

– Identifies the correct type of respiratory protection required for the hazard

– Establishes clear, consistent rules for respirator use, maintenance, and storage

Without a clear written program, respirator use tends to devolve into informal, inconsistent practices that are poorly supervised and vulnerable to compliance failures.

Common Problems with Respiratory Protection Programs

In practice, we see two recurring issues:

– Generic templates that are not meaningfully customized. These are often downloaded online, AI-generated, or provided as a free “value add” by a vendor. They do not reflect the company’s actual hazards, equipment, or work practices.

– Overly long programs that no one reads or uses.

These programs are often not properly customized either. Even when they are, they tend to be so dense that supervisors and employees cannot reasonably understand or follow them in day-to-day operations.

A compliant respiratory protection program must be both accurate and usable.

Required Elements of a Respiratory Protection Program

Below are the core components Cal/OSHA expects to see in a compliant program.

1. Responsibilities

– Who will oversee the program and what will their specific duties be?

– How often will the program be reviewed for effectiveness, and what does that process involve?

2. Hazards and Controls
Note: This is often the most complex part of the program and is where many DIY programs fall short.

– What airborne contaminants are employees exposed to? This may require research, process review, and in some cases air monitoring.

– What efforts have been made to eliminate or reduce the hazard using the hierarchy of controls? Employers are legally required to make a good-faith effort to reduce hazards before relying on respirators.

– Based on the hazard and exposure level, what type of respiratory protection is appropriate? This should be specific: brands, models, part numbers.

3. Usage

– When do employees need to use the respirators?

– How should the employees don (put on) and doff (remove) the respirators? Consider how this will work with other protective equipment the worker may be wearing.

– Facial hair requirements for respirator use.

4. Equipment

– How are respirators stored, cleaned, maintained, and replaced?

– What inspection procedures are required?

– If the respirator uses filters and/or cartridges, when must they be changed?

– If full-face respirators are used, how are prescription lens inserts provided for employees that use glasses?

5. Medical Evaluations

– What methods will be used for medically clearing employees for respirator use?

– How are medical restrictions handled? Larger organizations may need a formal procedure, while smaller employers may manage this case by case.

6. Training

– What methods will be used to provide employee training? Employees must be provided training on safe use of the respirator (including what it is and isn't effective against, how to care for and maintain the respirator, and how to use it correctly).

7. Fit Testing

– What methods will be used for fit testing the respirators?
– Employees required to wear a tight-fitting respirator must be fit tested on the specific size, make, and model of mask they will be using at work. For half face respirators, either a qualitative or quantitative fit test method may be used. Most full face respirator usage will required quantitative fit testing.

Every workplace will have different needs, but these elements form the basics for a complaint respirator program. If you need additional help creating a written respirator program, or reviewing a program you have created, contact us.

Safety Worst Practices: Shaking or Inverting Fire Extinguishers During Inspection

Wed, 06 Mar 2024 21:07:27 GMT

When inspecting fire extinguishers, some people (including a troubling number of safety professionals and extinguisher training instructors) think that it is necessary to shake, tap, or invert the extinguisher contents to keep them properly mixed, or prevent them from solidifying.

However, this is not only unnecessary but also potentially unsafe, and can damage the extinguisher. The myth of needing to shake or invert extinguishers is so common, Amerex, the world's largest manufacturer of fire extinguishers, has had to release a notice telling people NOT to do this because it can damage the extinguisher.

Dry chemical extinguishers are essentially a pressurized cylinder containing a powder extinguishing agent, which is released when the extinguisher is activated. Modern extinguishers are designed and tested so that the extinguishing agent is distributed evenly and remains effective even when the extinguisher is stored for long periods.

Shaking or inverting the extinguisher can damage the internal parts of the extinguisher, including the gauge and pressure valve. This can reduce the extinguisher’s effectiveness or even cause it to malfunction when needed.

Extinguishers are also heavy, and difficult to grip when shaking or inverting. There is the risk that the person inspecting the extinguisher may accidentally drop it, injuring themselves or damaging the extinguisher.

Avoid this safety "worst practice" and instead focus on the essentials of a good extinguisher inspection:

Look for Physical Damage: Check the extinguisher body, valve, nozzle, and hose for any signs of damage or corrosion.
Check the Pressure Gauge: If the extinguisher has a gauge, verify that the needle is in the green zone, indicating that the extinguisher is properly pressurized.
Inspect the Pin and Seal: Verify that the safety pin and plastic seal are intact, ensuring the extinguisher hasn’t been used or tampered with.

By following these steps, you ensure that the extinguisher remains in good working order without the risk of damaging it or injuring yourself by shaking, taping, or turning it upside down. Proper inspection, handling and storage are key to ensuring that a fire extinguisher is ready when you need it most.

The Dangers of Irritant Smoke as a Respirator Fit Testing Method

carlo@safewest.com — Sat, 10 Feb 2024 00:13:35 GMT

Safewest uses a quantitative fit test (QNFT) method for all respirator types, as it’s the standard for objectively and accurately assessing respirator fit using specialized air measurement equipment.

The alternative, a qualitative fit test (QLFT), relies on spraying a chemical at the user while they are wearing their respirator. If the user detects the chemical, the respirator has a leak. If they don't, the respirator is assumed to have an adequate seal. The amount of chemical sprayed and the sequence used is important, and this fit test method is often done incorrectly by inexperienced and insufficiently trained fit test providers. Qualitative fit testing (QLFT) is done by companies that cannot or do not want to make the investment in quantitative fit test (QNFT) equipment, which generally costs between $15,000 and $18,000 per machine.

One problem with qualitative fit tests (QLFT) is that they are less accurate. For this reason, this method generally cannot be used for fit testing full face respirators; OSHA requires a quantitative fit test (QNFT) for these respirator types, unless their use is in a lower-contamination scenario where a half-face respirator would also have been appropriate.

Another problem with qualitative fit testing (QLFT) is that the chemical sprayed at the respirator user can cause health problems. There are a few different chemicals used for this type of fit testing, and one of the most popular, and the most dangerous, is called "irritant smoke."

This fit test method relies on spraying a hazardous chemical called hydrogen chloride towards the employee’s face while they are wearing the respirator; if this chemical irritates their eyes, nose, and lungs, this indicates the respirator is leaking. It’s a less accurate, dangerous, and error-prone method which NIOSH strongly recommends not ever be used. NIOSH is the Federal agency that conducts research on occupational safety and health. One of their purposes is to give scientific and technical advice to OSHA on regulations.

In a published policy statement(1), they said the following:

"NIOSH, in its formal comments to OSHA [on fit testing methods]..strongly recommended against the use of this fit test method because of the health risk associated with exposure to the irritant smoke [and] NIOSH continues to recommend against the use of irritant smoke fit testing for these same reasons . . . Air sampling has shown that ventilation smoke tubes can produce highly variable and unpredictable hydrogen chloride concentrations far exceeding 5 ppm."

The reason 5 ppm is emphasized is because by law (under the exposure limits established by OSHA), that is the maximum airborne concentration of hydrogen chloride that an employee can be exposed to. In other words, this common qualitative fit testing method can, ironically, expose employees to unsafe concentrations of a dangerous chemical, and violate OSHA regulations.

If you are an employer on a budget conducting fit testing internally, avoid using irritant smoke, and select one of the alternative qualitative (QLFT) methods such as saccharin or Bitrex. If you are evaluating vendors to provide fit testing for your employees, we recommend selecting those that have made the appropriate investment in quantitative fit testing (QNFT) equipment.

References:
1. NIOSH Respirator Use Policy Statement, August 4 1999 In: NIOSH policy statements. Cincinnati, OH: U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health

California's Workplace Violence Prevention Law and SB-553

carlo@safewest.com — Thu, 19 Oct 2023 17:21:26 GMT

In the wake of workplace shootings and other violent events, there’s been a lot of pressure to require workplaces to have workplace violence prevention programs. The California legislature felt Cal/OSHA was taking too long to act on this, so they passed a law requiring most companies to develop and implement a workplace violence prevention program.

This article will provide an overview of which workplaces must comply with this new law, what the main requirements are, and provide some insights from a Certified Safety Professional (CSP) on common mistakes to watch out for.

Who Does It Apply To?

This applies to most employers. It’s easier to make a list of who it doesn’t apply to.

The following workplaces are exempt:

Places of employment that have 10 or fewer employees working at any time, and are not open to the public.
Healthcare and some related occupations that were already required to have a violence prevention program under §3342 .
Prisons and law enforcement agencies.
Remote workers who can work from any location of their choosing.

There’s still some ambiguity there, and it is likely there will be some early test cases as to how this will apply to certain employers, especially mobile/field jobs.

What Is Required?

An employer must develop a written workplace violence prevention plan. Here are some of the key requirements:

Specific steps for how the plan will be implemented, and communicated to employees; identification of specific persons/roles who have key responsibilities.
Procedures for employees to report concerns/complaints, and how management will follow up with and handle these reports.
Procedures for assessing potential workplace violence risks, and mitigating those risks.
Emergency procedures for workplace violence events (like what to do during an active shooter event).
Procedures for post-incident review and communication.
Requirements for effective employee training (initial and annual refreshers).
A process for keeping records of key program elements like hazard assessment, investigation, and followup, and a violent incident log to track workplace incidents.

What Should California Employers Do?

The deadline is about 8 months out. Companies not in one of the exempt categories will want to work on creating and implementing a violence prevention program by summer 2024.

Companies with an existing workplace violence prevention plan will want to make sure it meets the new requirements.

Safewest offers safety consulting in San Diego and throughout California. If you are considering consulting support on this project, send us a message and we can chat.

A Common Issue with Written Safety Programs

A lot of workplaces (and far too many safety consultants) take what might be called an “insert company name here” approach to written safety programs. Find a free template online, paste in the company name, add it to the safety binder or share drive, and...never think about it again. While there is value to templates for certain program areas that have common elements, it’s easy to get a false sense of security with an generic approach.

Be wary of templates, especially ones that just require filling in a few blanks, rather than completing worksheets and a thorough internal assessment of company-specific risks.
Be wary of consultants that are just filling in a few blanks on a template, and not doing the work of a proper hazard assessment.

Some Thoughts on Workplace Violence in General

From the perspective of a Certified Safety Professional (CSP) with an armed security and emergency response background, the most concerning gaps that have been noted on safety audits and program assessments have been:

Not considering workplace violence indicators early in the hiring and probationary process. This goes beyond doing a “background check” (and the rules on this in California are changing), and one needs to tread carefully with privacy and fair hiring laws. Be creative: You can learn a lot about threat potential from a potential hire’s social media presence, bumper stickers, and tattoos, or casual chats with their ex-coworkers; more than any background check would show. Potential for violence needs to be considered during the hiring process, and any potential concerns after hire need to be addressed as early as possible. Security expert Gavin DeBecker’s book “The Gift of Fear'' has a great pair of chapters on this in a discussion on workplace violence.

Note: This isn’t saying anyone with a criminal history should be eliminated as an applicant. Many people have made mistakes earlier in their lives, and especially if those mistakes were not of a violent nature, they could be a great employee. The key is to develop a comprehensive approach to assessing someone’s potential for violence; their past is one part of that picture.
Failure to plan for and take effective action when a potential threat is identified. There have been too many observed instances of “walking red flags” who show clear indications of being on a gradually escalating path that could lead to violence, being ignored, or addressed at the same level one might address non-violent harassment, “missing” office supplies, or absenteeism. Absolutely, every case deserves both due process and confidentiality, but the plan (and resources brought in) for a potentially violent threat are of a fundamentally different nature. This plan, and these resources, need to be developed in advance.
Active shooter training being mistaken for workplace violence prevention training. Active shooter response training is important, but that is when things are already upside down. A proactive approach to workplace violence requires teaching employees what pre-event warning signs and hazards to watch out for, who to talk to if something doesn’t seem right, and having an effective safety management system in place that follows up on these concerns (which also requires managers and HR professionals to have additional training).

This is a complex issue that requires a multi-disciplinary approach with professionals from human resources, safety, security, and mental health. It’s also an emotionally heavy issue to confront the reality of violent attacks in the workplace.

Don’t forget that this is a brand new law, so there will be a period where everyone, including regulatory agencies, politicians, and safety professionals, will be learning the best ways to meet the objective of reducing workplace violence risks. For safety professionals (or employees wearing the safety hat at their company) that are feeling a bit overwhelmed, start with something simple, but appropriately customized to your workplace, start testing it out and gathering feedback, and make incremental improvements over the course of the year.

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Safewest can offer health and safety program consulting support on a per-project or part-time basis. Contact us to discuss your needs.

Home Fire Safety Checklist

carlo@safewest.com — Wed, 23 Nov 2022 22:07:05 GMT

We start our fire extinguisher training courses by emphasizing something important: extinguishers protect property; evacuation protects lives.

When a fire occurs in the workplace, the safest action is for all employees to immediately evacuate, and call 911. Attempting to use an extinguisher instead of evacuating exposes workers to greater danger, which is why Cal/OSHA requires annual training for extinguisher users who are risking their lives for the sake of protecting their employer's building, equipment, or inventory.

A combination of Cal/OSHA regulations, fire and building codes, regulatory inspections, and fixed fire suppression systems (like fire sprinklers) have made workplace deaths from fire much less common than in the past. For example, in 2021 there were less than 75 deaths from fires in workplaces, but over 4,000 deaths from fires in homes.

There are a variety of considerations for home fire safety, both in terms of fire prevention and emergency response. While future articles will outline more detailed best practices, our training philosophy emphasizes providing simple, actionable steps that everyone will be able to follow to improve their safety, without spending a lot of time or money.

Here is a simple list of 4 things anyone can do to improve fire safety at home:

Establish primary and backup evacuation routes and meeting point.
Practice a fire drill (especially if you have young children).
Make sure smoke and carbon monoxide alarms are installed in your home. Test monthly.
Consider having a small extinguisher in the kitchen and garage. Inspect monthly.

Note: Extinguisher Options for Home

A 5 lb ABC dry chemical extinguisher is relatively affordable and easy to find at home improvement stores and hardware stores, and is suitable for most locations in your home.

Note: If you have an extinguisher at home that's the Kidde brand, and it has a plastic handle/lever, check here to make sure it isn't one of the recalled ones:
https://www.kidde.com/home-safety/en/us/support/product-alerts/recall-kidde-fire-extinguisher/

Cal/OSHA Covid Standard PPE Requirements

carlo@safewest.com — Tue, 15 Jun 2021 19:01:15 GMT

There's been significant confusion regarding recent updates to the Cal/OSHA’s Covid-19 standard. After controversial revisions on June 3rd, 2021, there was another round of changes approved June 17th by the Department of Industrial Relations Standards board, and made effective immediately by executive order.

The most confusion seems to be regarding (D) Personal protective equipment.

To better understand Cal/OSHA’s convoluted and hasty attempts at regulating here, it helps to understand there are two broad categories of respirator use in the workplace. Side note: N95 filtering facepieces (aka: “N95 masks”) ARE respirators.

RESPIRATOR USE TYPES

Mandatory Respirator Use

Use of a respirator is required by the hazard or regulation. Employees must wear the respirator, they can’t choose not to. This has very comprehensive requirements that are explained in more depth in this article . But, in summary, the following requirements apply:

Written Program: The employer must have a comprehensive written respiratory program compliant with Cal/OSHA §5144(c)(1), and have an administrator in charge of the program.
Medical Approval: Required for all respirator users.
Training: Comprehensive training on respiratory protection and respirator use.
Fit Testing: Required for the specific model/size the employee is wearing at work.

Voluntary Respirator Use

Respirator use is optional for the employee. The employer has provided respirators for employees to use if they would like to (to feel more comfortable, to reduce levels of contamination that might be annoying but are not known to be harmful). Important point: You can't make a respirator situation "voluntary" just by decided you won't require respirators, it has to be justified that the risk is low enough to not require respirators.

Written Program: The employer should have a simple written respiratory program compliant with §5144(c)(2), and have an administrator in charge of the program.
Medical Approval: Medical approvals only for reusable elastomeric respirators (the rubber or silicone masks with filters on the side). No medical approval is required for filtering facepieces like “N95 masks.”
Training: Simple information on the basics of voluntary respirator use. With some minor modifications adding info on when voluntary use is most encouraged, you could make a handout or short training slide using Cal/OSHA appendix D.
Fit Testing: Not required.

Now, in the past, voluntary programs were at the discretion of the employer, if they wanted to have one. What we’re seeing here in the Covid standard is Cal/OSHA mandating that employers implement a voluntary program, and make respirators available for certain employees that want one. This isn’t totally unprecedented, as they have a similar requirement for outdoor workers when there’s heavy wildfire smoke: employees don't have to wear the respirator, but the employers must make them available.

REGULATORY ANALYSIS
With this understanding, let’s get into the text of the recently approved regs, specifically (E) Personal protective equipment. Regulation in black, Safewest commentary in color.

(D) Personal protective equipment.

1. Employers shall evaluate the need for personal protective equipment to prevent exposure to COVID-19 hazards, such as gloves, goggles, and face shields, and to provide such personal protective equipment as needed.

This is safety 101; employers should always do an assessment of workplace hazards, and provide PPE if needed. A safety program that doesn't operate under this concept has far bigger problems that complying with the nuances of Cal/OSHA's revised Covid 19 standard.

2. Upon request, employers shall provide respirators for voluntary use in compliance with subsection 5144(c)(2) to all employees who are not fully vaccinated and who are working indoors or in vehicles with more than one person.

This is referring to VOLUNTARY use. This requirement to provide a respirator only applies if all these conditions are met:

An employee it not vaccinated
That employee works indoors or rides in a vehicle with others
That employee wants a respirator

In this situation, the employer should make respirators available, and make sure they've had simple training on voluntary use. A written program is still required. A medical evaluation may be required (see the first section "RESPIRATOR USE TYPES"). A fit test is NOT required.

This may not be as burdensome as some employers assume...the vast majority of unvaccinated persons also don't think Covid-19 is a serious concern; they're not likely to want a respirator.

Whenever an employer makes respirators for voluntary use available, under this section or sections 3205.1 through 3205.4, the employer shall encourage their use and shall ensure that employees are provided with a respirator of the correct size.

This is very confusing (and Cal/OSHA is notorious for not providing written interpretations of convoluted standards)...it’s not clear how an employee shall ensure employees are provided with a respirator of the correct size without doing a fit test. However, fit testing is not and has never been required for voluntary respirator use. I think a good faith effort here would be to make sure you have a smaller size option if you have employees with smaller faces, or providing a single respirator model that fits a wide range of employee face sizes, and provide alternatives based on employee feedback.

3. Employers shall provide and ensure use of respirators in compliance with section 5144 when deemed necessary by the Division through the Issuance of Order to Take Special Action, in accordance with title 8, section 332.3.

This is referring to MANDATORY use, in scenarios where Cal/OSHA, under authority in 332.3, has told a specific employer or group of employers they need to have a respirator program. If this applied to your organization, you would almost certainly know it and already be dealing with Cal/OSHA.

4. Employers shall provide and ensure use of eye protection and respiratory protection in compliance with section 5144 when employees are exposed to procedures that may aerosolize potentially infectious material such as saliva or respiratory tract fluids. NOTE: Examples of work covered by subsection (c)(7)(D)4. include, but are not limited to, certain dental procedures and outpatient medical specialties not covered by section 5199.

This is referring to MANDATORY use, and applies primarily to medical clinics and certain research settings where employees are potentially exposed to aerosolized human body fluids. A more detailed hazard assessment is required for these industries, but if there is potential exposure, all the elements of a mandatory respirator program (written program, medical approvals, fit testing, and training, and all required annual renewals) must be implemented.

Need help? Safewest provides consulting, written program development, and onsite respiratory protection services including training and fit testing.

Scott AV-3000 Respirator Facepiece Inspection

carlo@safewest.com — Sun, 02 May 2021 21:02:19 GMT

Recommended guidelines for Scott AV-3000 rapid field inspection.

Inspect the facepiece seal and other rubber components for deformation, wear, and damage. Flex the seal slightly with your fingers, checking carefully for any small slices or splits.
Inspect the lens for scratches, gouges, cracks, crazing, distortion, melting, or any other damage. Pay special attention to the edges of the lens, and the area where the regulator connects
Inspect the lens frame for damage such as cracks or distortion. Make sure the lens frame screws are present and installed correctly.
Check the head harness anchors and straps for damage, wear and proper orientation.
Check the voicemitter ducts and outer grill for damage, and check any attached communication devices devices.
Inspect the nose cup for cuts or damage, and verify that both inhalation valves in the nose cup are present, clean, laying flat, and properly installed.
Verify that the nose cup is properly installed. Check that the nose cup is properly seated between the flanges of the voicemitter ducts and at the port on the front of the facepiece.

If you find any damage to the facepiece, replace or repair it before starting work.

Texting to 911 in San Diego

carlo@safewest.com — Tue, 23 Mar 2021 17:05:49 GMT

Texting 911 in San Diego

Can you text 911 in San Diego? Yes, but with an important caveat.

As of January 2021, San Diego has implemented texting to 911 throughout the county.

However, calling should still be the primary means of contacting 911. It's the most reliable, and will get the fastest response.

However, the ability to text 911 is valuable for:

Situations where it is too dangerous to call or make noise.
This is emphasized in Safewest active shooter courses, as during a violent event in the workplace, one may need to contact 911 silently while hiding. Outside of work, the ability to discretely contact 911 can also be useful for victims of domestic violence.
Persons that are hearing or speech impaired.
Situations is which cell phone signal is too poor to for a reliable voice call. Text messages use less bandwidth and may get through.

Texting to 911 has been active in most neighboring counties, including Orange County (since 2019), Los Angeles County (since 2018), Riverside County (since 2019), and San Bernardino County (since 2015). Residents of these counties, please verify this information with your local emergency response officials and check current capabilities.

Healthcare Respirator Programs During (and After) Covid

carlo@safewest.com — Sun, 28 Feb 2021 18:29:10 GMT

For many healthcare employers, the Covid-19 pandemic was the beginning of a workplace respirator program. Most did not have a respirator program prior to the pandemic, and are looking forward to returning to that, but aren't sure how to make that decision moving into 2021.

Without a fairly detailed dive into the specific of your workplace, existing safety policies, types of procedures performed, patient screening methods used, regulations specific to your healthcare sector, and a variety of other risk factors, we cannot advise on a specific course of action. For employers looking for professional guidance of this type, w e offer consulting services and can provide a proposal.

For healthcare employers making this determination themselves, they should carefully review Cal/OSHA's Aerosol Transmissible Diseases regulation, California Department of Public Health requirements, and any local City/County guidelines, and consider the following:

Will employees be seeing confirmed or suspected Covid-19 patients?

I f you are, for example, a medical clinic that will be seeing patients with respiratory or flu symptoms for evaluation and diagnosis, or you are a dental office that will have to provide emergency care for patients who have Covid 19, Cal/OSHA's aerosol transmissible diseases standard requires a full respirator program (with fit testing and training renewed annually).

If you are not seeing confirmed or suspected Covid-19 patients, conduct screening of all patients (recognizing fully the limitations of symptom and history based screening methods that will not detect asymptomatic and presymptomatic individuals), outpatient medical and dental offices have greater leeway in determining whether to continue with a respirator program.

One important point is the nature of healthcare often requires providing urgent or emergency care to patients who may either have Covid-19, or have other fairly common upper respiratory symptoms that would meet the criteria for potential Covid-19 infection.

Will employees be required to wear a respirator? Remember: an "N95 mask" is a respirator.

Regardless of risk, if employees are required to wear a respirator for any work tasks, you must implement a full respirator program (with fit testing and training renewed annually).

Are there other regulations or third party standards requiring a respirator program?
Even though you may not be required to maintain a respirator program by Cal/OSHA requirements, there may be public health requirements specific to your industry that require it. Or, third party organizations may require it as part of their accreditation standards.

How has the availability of vaccination changed risk factors in the workplace?

There is always a benefit from decreased community transmission, but the impact on vaccination programs in your specific organization depends on a variety of factors, including the w illingness of your workers to take the vaccine (and, related, your company policy on requiring them as a condition of employment). Significant ambiguity still exists regarding the duration of protection offered by the vaccine, and its effectiveness against emerging variants of Covid-19.

Is a respirator program needed for other pathogens?

Many employers have discovered that even with a decreasing threat from Covid-19, they still have a need for a respirator program (and in fact, should have had one all along). Particularly within medical clinics and hospitals, there may be a need to protect certain classes of employees from pathogens like tuberculosis. Dental professional may have to provide emergency care to a patient who also has a respiratory illness, and need a higher level of protection than would be provided by a procedure mask.

How effective are other safety controls used in the workplace?

Personal protective equipment like a respirator should be used when there are not other ways to effectively manage a hazard. Safer work practices and engineering controls, like isolation shielding or air purifiers, should be the first line of defense. The more effective these methods are, the less need there is for a respirator. Unfortunately, quantifying the effectiveness of controls against biological contaminants is not as easy as it is for chemical contaminants (where a variety of well-established methods exist to measure airborne concentrations)...so there's a fair amount of research and more qualitative professional judgement required here. A lack of effective safety controls, or ambiguity about their effectiveness means a respirator program should be maintained.

Would a respirator program, even if not required, improve workplace conditions?

Just as they did in early 2020, many employers deciding they will continue to maintain a respirator program through 2021 for all clinical staff, to keep everyone as safe as possible, which paid dividends in terms of morale, employee retention, and job satisfaction in the midst of the pandemic. There are also benefits in terms of reduced workforce disruption (less need to quarantine employees with potential exposure if they are wearing appropriate protective equipment).

Cal/OSHA Voluntary Respirator Programs

carlo@safewest.com — Wed, 05 Aug 2020 17:03:59 GMT

Voluntary respirator usage is a scenario where an employer provides (or allows employees to bring) respirators for use in the workplace even though there isn't a hazard where a respirator is required. In other words, the respirator is worn to reduce nuisance levels of contamination - contamination that's enough to be annoying or uncomfortable, but not at a level where it is dangerous or exceeds OSHA exposure limits. Voluntary respirator programs typically use disposable filtering facepiece respirators such as "N95" masks, but can use other respirator types like half face elastomeric masks with filters and/or cartridges.

Employers must still have a written respirator safety program for voluntary respirator use, though this program will be much simpler than a program for mandatory respirator use. The employer should also have a formal, documented hazard assessment to show that the respirator program truly is voluntary, and that the contamination is at a low enough level to not be dangerous. This is very important; an employer can't just casually decide that respirator use is voluntary. The employer needs to assess the hazard very thoroughly and demonstrate, with documentation, that there is not a hazard requiring respirator use. During this process, they should also verify that voluntary use of a respirator will not in-itself create another hazard (for example, if the respirators interfere with other protective equipment the worker must wear, like eye protection).

If an employer has conducted a hazard assessment, and determined that respirator usage can be voluntary, and not create any additional hazards, the following requirements apply for a voluntary program.

Have a written program outlining how the voluntary program will be implemented and where it applies
Provide employees the information found in OSHA’s Respiratory Protection Standard Appendix D ( link )
Provide employee training on cleaning, storage, and maintenance of respirators (if applicable, this may not be necessary for disposable facepieces)
Ensure that the respirator users are medically qualified to wear respirators, via a medical evaluation questionnaire approved by physician.
Exception: This is not required for voluntary use of disposable filtering facepieces (such as "N95" masks). This is only required for voluntary use of elastomeric respirators.

Masks and Respirators With Exhalation Valves Don't Protect Others

carlo@safewest.com — Sun, 10 May 2020 20:40:19 GMT

Note: This article was written during the Covid 19 pandemic, but applies to any situation where masks or facecoverings are worn are source control (to limit disease transmission or contamination from the wearer's exhaled particles).

Wearing masks in public, or when working with other people, helps prevent particles and droplets from the mask wearer's mouth and nose from infecting other people. Masks with an exhalation valve do not provide protection to other people, as exhalations go right out without being filtered or significantly slowed. The exhalation valve is like a vent that flaps open every time the user breathes out; It makes it more comfortable for the wearer, but exposes those around them to contamination.

Here are a few examples of exhalation valves on different styles of masks:

If your employees or customers have masks of this type, they need to wear a covering over the mask, such as a fabric mask, or a disposable medical mask. Healthcare workers can layer a surgical mask or procedure mask. Or, with workers that use elastomeric (re-usable rubber or silicone masks), it's often possible to set up some sort of cover on the vent area. Here is an example of an improvised fabric cover for the exhalation valve on an elastomeric respirator. It is held in place by two elastic loops that loosely go around the filter attachment points:

We should think of masks in two different categories:

-Personal protective equipment (PPE). Masks required for the safety of the persons wearing them, to protect them from some hazard (whether it's biohazards, concrete dust, paint vapors, etc). These require annual fit testing and training, and if selected and worn correctly, keep contaminants out of the user's lungs.

-Community protective equipment (CPE). Masks, usually reusable fabric or disposable medical masks, worn to reduce the risk of getting other people sick by slowing and capturing germs from exhalations, sneezes, coughing, speaking, etc. If there's a giant opening in the front of the mask that flaps open every time the wearer exhales, the community protective effect of the mask is compromised.

Respirators with an exhalation valve can be an excellent choice for personal protective equipment if the wearer is properly trained and fit tested. However, if the exhalation valve is not properly covered, this irresponsibly exposes others to danger if the mask wearer is infected, but not symptomatic (which is very common with Covid 19). This is an issue for all workplaces, but particularly in a healthcare setting, where a provider wearing a valved mask will be in close proximity to a patient to provide care and may infect them.

Additional suggestions that may apply to certain workplaces:

If your workplace is open to clients or the general public, many people are uninformed about this issue with exhalation valves and may be wearing these types of masks. If possible, have some cheap medical or fabric masks available for them to wear instead, or layer over their existing mask to cover the exhalation valve.
For industrial and construction workplaces with jobs that ordinarily require respirator use, where everyone in the work area is wearing a particulate respirator they have been trained on and fit tested for, it's probably not necessary to cover vents. But in areas where some people may not have masks, or only have fabric masks, or other looser fitting masks they haven't been fit tested for, vented masks need to be covered to protect others in the area from potentially getting sick.
For companies that have or are considering prohibiting employees from wearing valved masks (when they are wearing personal masks on a voluntary basis, not due to a specific workplace hazard), this policy should be reconsidered. Vented masks are usually better designed in terms of the way they fit and the protection they provide for the wearer. However, vented masks definitely need to be covered in some way with an unvented mask, filter material or tightly woven fabric.

Some Thoughts on Covid 19 for San Diego Employers

Tue, 31 Mar 2020 04:10:01 GMT

The seriousness of the current situation with Covid 19 should not be underestimated. B ecause of the time in between when someone is infected and when they start showing symptoms, we're going to be constantly behind the curve if we wait for things to "look bad" before we start responding.

Safewest has clients in a variety of industries here in San Diego, including first responders, hospitals, health clinics, and life sciences. There are a tremendous amount of resources being directed toward controlling this pandemic, but those resources can easily be overwhelmed if too many people get sick.

Now is a critical time for anyone with safety responsibilities to step up and lead.

Make sure you have a written plan for a response at different stages of this pandemic, and communicate with your employees. If you provide services at client locations, make sure you have a well-defined plan you can share with them on what safety measures you are taking to keep everyone safe. If the people you serve come to you, make sure you're got rigorous screening protocols in place, but also understand that most of the screening protocols (self reported history of travel/contact with infected, temperature taking) have serious limitations, so don't get a false sense of security.

These are five observations I've made over the past few weeks that employers in all critical industries need to consider:

1. Make sure your employees understand social distancing isn't all or nothing. Just because they have to be close together sometimes to repair equipment, care for patients, build things, etc doesn't mean we shouldn't try as hard as possible to maintain social distance during all other times. We're striving for maximizing the percentage of time we can spend at a safe distance, rather than treating this as something we can either do all the time, or don't bother with.

2. Be aggressive about reminding and then enforcing employee requirements for hand-washing, staying home when sick, and general healthy work practices. It should be very clear to everyone that these behaviors are not optional, but a condition of their employment just like any other essential safety practice. This is also a golden opportunity to finally put some emphasis behind something we should be doing even when there's not a pandemic.

3. Don't trust that your vendors are doing what they say they are in terms of Covid 19 safety. In assessing vendors at client sites, we have observed some troubling discrepancies between what companies SAY they are doing to keep their clients safe, and what they are actually doing. Don't be shy about asking what their plan is, and verifying.

4. If your company utilizes contingent ("temp") workers, realize that many staffing agencies don't provide a lot of resources or support. There are definitely better agencies and worse ones; many seem to go of their way to avoid informing employees that by law in California they have to be provided sick leave days. This leaves contingent workers in a position where they have to choose between going to work when they might be getting sick, or paying the bills. It takes time to get unemployment or disability; sick leave makes it easier to make the right choice to stay home.

5. Especially for field service, construction and healthcare...don't take contamination home. Covid 19 aside, work clothes can end up with a lot of chemical and biological contaminants on them, but especially now, workers should be extra careful. Work shoes should stay at work, or get removed outside. For those who wear work clothes home, they should create an area near the entry door with a hamper where outer clothing can be removed. Work clothes should be laundered by themselves. If a work vehicle is also a personal vehicle, think about towel seatcovers that can be washed, and wiping down steering wheel, shifter, radio controls, and high contact surfaces after the workday.

Additional Information

If you need reliable and relevant sources of information during these times, we suggest:

CDC Business Resources

Johns Hopkins Center for Health Security Covid 19 Updates

San Diego County Official News Center

California Department of Public Health Covid 19 Page