Comment from Moffett, Patrick, Environmental Management & Engineering, Inc.

Document ID: OSHA-2008-0031-0003
Document Type: Public Submission
Agency: Occupational Safety And Health Administration
Received Date: August 22 2008, at 12:00 AM Eastern Daylight Time
Date Posted: August 22 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: August 19 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: September 18 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 806d32a9
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As an industrial and environmental hygienist for 25 years, I do my best to teach the proper use of PPE to the remediation and restoration industry (e.g., Katrina, 911, mold, asbestos and meth lab cleanup contractors). That said, I see PPE used inappropriately many times a week. The newest students I'm teaching in the U.S. and Canada are sewage cleanup and remediation contractors. They are exposing workers to raw sewage waste that carrys numerous viruses and other pathogens including the super bugs (i. e., MRSA). Contractors have no idea what they are exposing their workers too and they have very little in regulations besides the BBP regs which they feel are not adequate. Revision of PPE regulations, training and citation requirements are past due. Patrick Moffett CHMM, REA

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