Revised Interim Inspection Checklist Procedures

The Interim Inspection Procedures that you received with the Interim Inspection Checklist in ENF 08-16 have been revised based on comments received from the Department of Pesticide Regulation’s Worker Health and Safety Branch. Please discard the procedures previously sent and replace with the attached Interim Inspection Procedures. The Interim Inspection Checklist remains the same.

The changes to the procedures pertain to the respirator regulations (3CCR section 6739) and are designated by vertical lines in the margin of the document. The changes include:

1. A number of exemptions that incorrectly included respirator uses that are “directed” by the employer. (When an employee is directed by the employer to use a respirator, the voluntary use provisions of 3CCR section 6739 do not apply).
2. More specific language was employed in the guidance section of 3CCR section 6739 for the use monitoring inspections that instructs the inspector to verify that the employee utilizes the appropriate type of respirator.
3. The language addressing the time period that the written program must be retained by the employer was clarified in the guidance section for the written respiratory protection program on the Pest Control Headquarters Inspection Report.
4. A correction of a statement in the previous procedures that required the employer to fit test employees for employer-supplied voluntary respirator use.
5. The language describing the amount of air required in routine and emergency-use SCBA units was clarified.
6. The language describing the exemption for employer-supplied voluntary use of a filtering face piece (dust mask) was clarified.

If you have questions about the revised interim inspection procedures, please contact the EBL assigned to your county.

Sincerely,