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Final Guidelines for the Protection and Training of Workers Engaged In Maintenance and Remediation Work Associated with Mold 10 appropriate training for maintenance workers who disturb less than ten square feet of insulation (see section 2.4.1.3). 2.2.7 Previous training provided to the trainees Workshop participants recognized some overlap in work practices and personal protections employed on asbestos/lead remediation sites and on mold sites, and that it would be reasonable to exempt mold trainees from training on these topics if they recently completed asbestos/lead training and can demonstrate proficiency. This applies to workers engaged in hazardous waste operations remediation and trained in accordance with the OSHA HAZWOPER standard as well. For example, a worker who was recently trained and fit tested to wear a respirator, and who can demonstrate competence in wearing and maintaining it, may be exempted from additional training on this particular respirator. 2.2.8 Regulatory requirements and existing guidance OSHA does not have a standard that is specifically focused on mold or bioaerosols, but there are several standards that would impact a major mold remediation project and should be covered in any mold remediation course and possibly in awareness training. They include: • Hazard Communication standard training per the applicable OSHA standard (29 CFR 1910.1200) with additional materials specific to microbial materials. • Respiratory protection training in accordance with the OSHA standard at 29 CFR 1910.134 (or construction equivalent). • Employers Site/Facility Safety and Health Plan required by OSHA standard 1910.38. It is assumed that the employer's Emergency Response Plan per applicable OSHA standard and a "working with mold procedures plan" (signs, disposal, etc.) would be included. Even though there are very few applicable OSHA standards, there are several major guidelines from governmental organizations and consensus bodies. This guidance document is built upon the excellent recommendations, where applicable, from the following: • 1993 NYC Department of Health and Mental Hygiene – "Guidelines on Stachybotrys" • 1995 Health Canada – "Fungal Contamination in Public Buildings: Guide to Recognition and Management" - addresses training (Workplace Hazardous Materials Information System) and specifies PPE similar to that recommended by NYC DOHMH. • 1996 National Air Duct Cleaners Association (NADCA) – "Microbial Contamination in HVAC" - evolved into the "Assessment, Cleaning, & Restoration Industry Standard ACR" in 2002. • 1998 – American Society of Testing and Materials E1971-98, "Standard Guide for Stewardship for the Cleaning of Commercial and Institutional Buildings" – provides a broad approach to keeping commercial and institutional buildings clean while protecting cleaning personnel and occupants. • 1999 American Conference of Governmental Industrial Hygienists (ACGIH) – "Bioaerosols: Assessment and Control" - differentiates PPE recommendations based on small, medium, and large schemes, and respiratory protection ranges from N95 to full face (PAPR). • 2000 NYC DOH – "Guidelines on Assessment and Remediation of Fungi in Indoor Environments" (discussed above) • 2001 US EPA – "Guidelines on Fungi" - Respiratory protection also ranges from N95 to full face (PAPR).