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Starting a Respiratory Protection Program

Quick Tips #195

Introduction

A respiratory protection program ensures that all employees are properly protected from respiratory hazards. According to 29 CFR 1910.134, employers must create and maintain an individualized, written respiratory program if their employees use respirators. Also, employers must choose National Institute of Occupational Safety and Health (NIOSH) certified respirators for their employees when respirators are required.

29 CFR 1910.134(c) requires employers to develop and implement a written respiratory protection program with worksite-specific procedures and elements for respirator use. A suitably trained program administrator must lead the program. Some voluntary procedures might also be needed to prevent potential respirator hazards.

Minimum respiratory requirements for all contaminants can be found in 29 CFR 1910.134, and in separate sections for specific contaminants, such as CFR 1910.1001 for asbestos and CFR 1910.1025 for lead. The employer must also follow all federal, state and local respiratory protection regulations.

 

Starting a Respiratory Protection Program

An employer must evaluate workplace contaminants before beginning a respiratory program. Air contaminants can include harmful dusts, fogs, fumes, mists, gases, smoke, sprays and vapors. Consult an industrial hygienist to evaluate work-area exposure levels. Employers should require employee respirator use only when engineering controls aren't available, when controls are being installed, or in emergencies. The following is an overview of the 11 requirements for starting an effective respiratory protection program.

 

Step 1: Respiratory protection program — An employer is required to develop and implement a written respiratory program with required worksite-specific procedures and elements for required respirator use, according to 29 CFR 1910.134(c). The written program must include a respirator-selection process; medical evaluations; fit testing; procedures for use; procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing and discarding; procedures to ensure adequate air quality, quantity and flow; training in respiratory hazards; training in use limitations and maintenance; and procedures for regularly evaluating the program's effectiveness.

If respirators are worn voluntarily, employees must first determine that the respirators will not create hazards. Employers must supply employees with Information from appendix D and other necessary elements to guide proper respirator cleaning, storage and maintenance procedures, and decisions on whether an employee is medically eligible to wear a respirator. Written programs are not required for voluntary use of dust masks.



Step 2: Selection of respirators — An employer must evaluate respiratory hazards in the workplace before selecting a respirator. This evaluation must identify contaminants in their chemical state and physical form, and include a reasonable employee exposure-level estimate. If an employer can't identify or reasonably estimate employee exposure, the employer should consider the atmosphere to be immediately dangerous to life and health (IDLH), according to 29 CFR 1910.134(d)(i)(III).

An employer then should select respirators based on the identified hazards, and workplace and user factors that might hinder respirator performance and reliability. Respirators must be NIOSH certified. In atmospheres IDLH, use a full face piece, pressure-demand SCBA with a minimum service life of 30 minutes, or a combination full face piece, pressure-demand SAR with auxiliary self-contained air supply. In atmospheres not IDLH, employers should provide an atmosphere-supplying respirator or an air-purifying respirator, providing it has an end-of-service-life indicator or a replacement schedule for protection from gas and vapors. For particulates, make sure your equipment is NIOSH certified under 30 CFR Part II as a HEPA filter, or that an air-purifying respirator equipped with a filter is NIOSH certified for particulates under 42 CFR part 84.

 

Step 3: Medical evaluations — An employer must provide a medical evaluation to determine an employee's medical eligibility for respirator use. The medical evaluation must occur before an employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluation when the employee is no longer required to use a respirator (29 CFR 1910.134(e)(1)). Initial exam results or a physician or licensed healthcare professional's findings might require further evaluations.

Employers should allow for confidential and convenient evaluations during normal work hours, and the physician or licensed healthcare provider should ensure that an employee understands the exam's results. The physician or licensed healthcare provider must note any limitations the employee might have if there is a need for follow-up exams. The physician or licensed healthcare provider also must provide the employee with a written copy of any recommendations. If medical conditions prevent an employee from using a negative-pressure respirator, a powered air-purifying respirator (PAPR) will be provided.

Additional medical evaluations might be necessary if:

  • the employee reports symptoms
  • the physician or licensed healthcare provider, supervisor or program administrator recommends them
  • observations or evaluations indicate that they're necessary
  • a change in the workplace affects physical burden

 

Step 4: Fit testing — Employees must be fit tested with the same make, model, style and size of respirator that will be used if respirator use is required, according to 29 CFR 1910.134(f).

An employer must ensure that employees who use a tight-fitting facepiece respirator pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT). A QLFT may only be used where the fit factor is 100 or less. A QNFT must be used when it is equal to or greater than 100 for half-face masks and equal to or greater than 500 for full-face masks.

Atmosphere-supplying respirators and tight-fitting, powered air-purifying respirators must be fit tested through quantitative or qualitative testing in negative-pressure mode, regardless of its negative or positive operation, according to 29 CFR 1910.134(f)(8). Employees then should be retested annually, when there is a change in the type of respirator used, or when there is a change in an employee's physical condition, such as an obvious change in body weight.

 

Step 5: Use of respirators — Employers must establish rules and procedures for respirator use. These rules must prohibit an employee from removing a mask in a hazardous environment, and prevent conditions that could result in face-piece seal leaks. The rules must also ensure continued effective respirator use throughout work shifts, and establish procedures for respirator use in atmospheres IDLH and in structural firefighting situations, according to 29 CFR 1910.134(g).

Employers must not allow an employee with facial hair or any condition that limits a face-piece seal or valve function to wear a tight-fitting face piece. If an employee wears glasses, goggles or personal protective equipment, the employer must ensure that the equipment doesn't interfere with a face piece's seal.

Employers must maintain work-area surveillance for stress and exposure. Employees should leave the respirator work area to replace parts, or to wash their face if there's a breakthrough, leak or change in the breathing resistance. Include special requirements for interior structural firefighting, standby procedures, duties, training, communication and rescue in areas IDLH.

Step 6: Maintenance and care — The employer must provide for the cleaning and disinfecting, storage, inspection and repair of respirators, according to 29 CFR 1910.134(h). The cleaning and disinfecting shall be done for exclusive-use respirators as needed, for multiple-use respirators before other uses, for rescue respirators after each use, and for those used for fit testing after each use. Stored respirators should be protected from environmental damage, and face-piece and exhalation-valve deformation. Emergency respirators must be accessible and clearly marked. Perform routine-use respirator inspections before each use and when cleaning. Emergency respirators must be inspected monthly, before and after each use, and in accordance with the manufacturer's recommendations. Escape respirators should be inspected before each use. Inspections should include all parts and a check of elastomeric parts for pliability and deterioration. Emergency respirators should include a certification of inspection, name, date, etc. Only appropriately trained employees should perform repairs or adjustments, and only NIOSH-approved parts should be used.

 

Step 7: Breathing air quality and use — An employer must provide employees who use atmosphere-supplying respirators (supplied-air and SCBA) with high-purity breathing gases, according to 29 CFR 1910.134(i). Compressed breathing air must meet at least the Type 1, Grade D breathing-air requirements described in ANSI/Compressed Gas Association Commodity for Air, G-7.1-1989.

 

Step 8: Identification of filters, cartridges and canisters — According to 29 CFR 1910.134(j), an employer must ensure that all filters, cartridges and canisters used in the workplace are labeled and color-coded with NIOSH-approved labels. The employer must also ensure that the labels are not removed and remain legible.

 

Step 9: Training and information — The employer must provide effective training to employees who require respirators. The training must be comprehensive, understandable and reviewed annually or more often if necessary, according to 29 CFR 1910.134(k). Employees must be able to demonstrate why a respirator is necessary, consequences of improper fit, usage and maintenance. They must be aware of limitations and capabilities of the respirator. They must know how to use it in emergency situations or upon failure of the respirator. They must know how to inspect, maintain and store the respirator. They should be aware of medical signs or symptoms that would limit or prevent the use of the respirator. Retraining should occur whenever there are changes in the workplace, when new types of respirators are used, or as necessary.

 

Step 10: Program evaluation — The employer is required to conduct evaluations of the workplace to ensure that the written respiratory protection program is properly implemented and that it continues to be effective. 29 CFR 1910.134(l). The employer shall conduct evaluations as necessary. They should regularly consult employees regarding respirator fit, selection, use and maintenance.

 

Step 11: Record keeping — The employer is required to establish and retain written information regarding medical evaluations, fit testing and the respirator protection program. This information will facilitate employee involvement in the respirator protection program, assist the employer in auditing the adequacy of the program, and provide a record for compliance determinations by OSHA, according to 29 CFR 1910.134(m). Records of medical evaluations required by this section must be retained and made available in accordance with 29 CFR 1910.1020. Fit-testing records must be detailed and retained until the next fit test. The employer also must retain a written copy of the current respirator protection program.

 

Conclusion

Fit testing and fit checks are also a necessary part of respiratory protection. For a complete understanding of the requirements, see Quick Tips #140: Respirator Fit Testing Requirements and Procedures.



Commonly Asked Questions

Q.   Can I use canisters or respirator parts from another manufacturer to repair my respirator?
A.   No. Doing so will void all NIOSH/MSHA approvals.
 
Q.   Do I need a respiratory protection program if I only have employees using disposable dust/mist respirators?
A.   If the employees are required to wear a respirator of any type, a written program is required. If employees voluntarilywear respirators, a written program is not required.
 
Q.   What is IDLH?
A.   IDLH is the concentration at which a contaminant is immediately dangerous to life and health. If the concentration meets or exceeds the IDLH, a Pressure-Demand Self-Contained Breathing Apparatus (SCBA) or Airline Respirator with escape should be selected.

 

Sources

NIOSH

MSHA

OSHA 29 CFR 1910.134

OSHA respiratory etool

(Rev. 6/2014)

 

Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.

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Please Note:
The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.

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