"Clean Shaven" policy implementation for Respiratory Protection

[red2012]

Let me start by saying I'm not a nuke worker, but I work with and support them, so my terminology may not be accurate - please forgive and educate.

I work at a Nuclear Crit II facility...the site processes LLW/MLLW...Alpha & Beta particles...yada yada (yes, I yada yada rad details).

Here's my reason for posting: The RadCon department are all held to the standard/expectation that they will report to work "clean shaven" so they are ready to wear respirator when needed (with or without prior warning/notification) as that is the requirement of the job...this includes the RCTs, Rad Supervisors, and Rad Engineers - to be ready even for an emergency situation to don a respirator.

Our Maintenance Department, however, is not held to this same standard as they do not make routine entries.  Okay...sure.  But, I'm told that the Maintenance Manager does enforce the "clean shaven" prior to reporting to work/job site when it is known they will need to make entry into an area that requires respiratory protection.  We are in the Southeast US and realize that guys here like their facial hair (have you guessed that I'm not cursed with facial hair...ha ha, I'm a gal), but any given time an emergency situation could arise requiring maintenance response in to an  area requiring respirator.  Shouldn't they also have to report to work "clean shaven" just as the RadCon personnel are expected to do?

Here's where it gets interesting...Our Operations department are the ones that goes into the areas that require respiratory protection to perform the work, yet they are not required to report to work "clean shaven"...they are allowed to shave at the site just prior to the task...they're supplied with what I hear are very cheap razors and shaving cream and are rushed to shave...which I guess is one of the causes of the nicks that bleed. Here, it is allowable for an Operator that has just nicked themselves to be issued a respirator to enter in to a CA/HCA.  PLus, seems to me it is also a matter of work efficiency waiting on operators to shave (and perhaps stop the bleeding) before beginning the work.

I've heard several RCTs make statements that this is the only and first site they've ever worked that allows this practice, both letting ppl report to work not "clean shaven" and allowing someone to be issued a respirator to enter into CA/HCA with essentially an open wound.  The RCT issuing the respirator may not notice or have knowledge that a person has just cut themselves and have an open wound.  Apparently, there is no concrete policy that requires a respirator user to report any such condition, and even if they did it appears as if it is allowable.

Does any of this sound okay and safe for the workers, both the one's working in a CA/HCA with an open wound and the RCT covering the job?

Would love some discussion on this...I have a questioning attitude and so am asking questions trying to determine if there is a real risk to worker health & safety, but am not asking the questions directly to my site's management yet as I'm not sure they'd answer honestly as I am told this has been a discussion for several years.  It may not truly be a H&S issue, but seems like it might be at least a Mgmt Best Practice as the "clean shaven" expectation/requirement is applied differently depending on department, even though personnel in all three departments (Rad, Ops, Maint) carry the same quals for respirator use and it is this inconsistency that is creating low worker morale, which can contribute to a worker safety issue.

Welcome any input...

[RDTroja]

You have an age old set of questions there...

Since 1974 I have seen policies ranging from 'prove you have a seal and we don't care how much facial hair you have' often using things like vaseline or KY jelly to make the seal (the NRC has nixed this one) to 'everyone has to be clean shaven at all times when on site' (that rarely lasts.)

It is not rare (actually it is very common) for Operations to be treated differently than everyone else and get privileges other departments don't. I will leave the commentary out, but just accept that part as fairly normal. It is also fairly normal for RPs to be held to higher Radiological Standards than other departments (duh.) So, RPs being made to be clean shaven, Maintenance having less stringent requirements, and Ops not held to the standard at all is about par for many courses I have seen. From a practical standpoint, once you have had to shave off a full beard with a disposable razor (or three) you do not want to do it again. I would opt for the daily shave, first.

As for the blood in the RCA... that is never good. It would be one of those situations that I would personally take a stand on. If someone told me that it was OK for someone that is actively bleeding or had an obvious wound to go into a potentially contaminated area, I would disagree and if it was going to happen over my protest I would remove myself from the situation and let anyone that would listen know about it. But, I have been a contractor most of my career and I am used to looking for a job quite often.

Then there is the persistent 'What is Clean Shaven?' question...

[GLW]

......From a practical standpoint, once you have had to shave off a full beard with a disposable razor (or three) you do not want to do it again......

This is a much better than most (if not all) disposable razor for this purpose,...

Rinses clean between strokes and the angle, metal spacer and sharp, single blade perform very well,...

Highly recommended (my beard is tough so I pay attention to these things),...

http://www.bicworld.com/us/products/details/178/metal

[Fermi2]

Odd, I have yet to be at or see a site where respirator qualified Operators did not have to be clean shaven when they are on duty or where Ops isn't held to a higher standard than others for most things...

[Rennhack]

I work at a Nuclear Crit II facility...the site processes LLW/MLLW...Alpha & Beta particles...yada yada (yes, I yada yada rad details).

Odd, I have yet to be at or see a site where respirator qualified Operators did not have to be clean shaven when they are on duty or where Ops isn't held to a higher standard than others for most things...

You work at a lot of DOE sites?

[retired nuke]

Odd, I have yet to be at or see a site where respirator qualified Operators did not have to be clean shaven when they are on duty or where Ops isn't held to a higher standard than others for most things...

You work at a lot of DOE sites?

No, but that doesn't stop him from knowing everything about it...

[Rennhack]

No, but that doesn't stop him from knowing everything about it...

The term "Operator" at the 'Nuclear Criticality facilities' I have worked at refers to the radioactive material handlers (kind of like a deconner).  It's not usually some person out of the navy that is brilliant, and has years of technical training, and lots of respect controlling/operating the facility itself.  It’s a radioactive material handler.

Below is the actual definition from 10 CFR 830

NUCLEAR FACILITY OPERATOR. A person certified by contractor nuclear facility management to manipulate or handle fissionable materials, radioactive materials, or  tritium in such form and quantity that a nuclear hazard potentially exists to the employees or the general public, or to manipulate the controls of equipment used to produce, process, transfer, store, or package such materials at DOE nonreactor nuclear facilities. Nuclear facility operators typically include, but are not limited to, fissionable material handlers, tritium operators, chemical process operators, waste tank operators, and enrichment plant operators.

Other places refer to 'operators' as people that operate heavy equipment.  Some have fancy titles, like "Operating Engineer", when it refers to a guy with a fork lift license. http://www.iuoe.org/ 

Just saying...

[HydroDave63]

And some operators have lots of switches and phones and authority..

"Omneepee-tent"

[Rennhack]

And some operators have lots of switches and phones and authority..

Yeah, but they rarely have problems with being clean shaven.

[Nuclear NASCAR]

From a practical standpoint, once you have had to shave off a full beard with a disposable razor (or three) you do not want to do it again. I would opt for the daily shave, first.

And I keep a battery powered beard trimmer in my locker for that very reason.  I just remember this; "You can't make a mistake twice because the second time it's a choice."

[SloGlo]

oh, hail!  eye thought this was put two rest years ago with the a.l.a.r.a. principal that respirators slowed down the work, a rem was a rem was a rem, etc.  use a p.a.p.r. and let the hirsute have a hairy good time.