Respiratory Hazard Assessment: When? What? How Much?

Paragraph (d)(1)(iii) of the Respiratory Protection Standard (29 CFR 1910.134) requires you to identify and evaluate the respiratory hazards in your workplace.

Specifically it says:

“The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant’s chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.”

Your evaluation has to identify the physical state and chemical form of these airborne contaminants.

You must also make a “reasonable estimate” of the employee exposures that could occur as a result of those hazards, including those likely to be encountered in reasonably foreseeable emergency situations. Note that OSHA does not specify how to make reasonable estimates of employee exposures for the purposes of selecting respirators. This is your choice and your decision.

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When?

Examples of when to assess respiratory hazard exposures include:

• When OSHA has a substance-specific standard (for example, lead or methylene chloride)
• When employees notice signs (for example, odor) or complain of respiratory symptoms (for example, irritation in the throat or nose)
• When the workplace contains visible emissions (for example, fumes, dust, or aerosols)

What?

Specific characteristics of the airborne hazard must be established in order to select an appropriate respirator. Questions such as these can help you make that determination:

• Is the airborne contaminant a particulate (dust, fumes, mist, aerosol) or a gas/vapor?
• Is the airborne contaminant a chemical and are material safety data sheets available?
• Is the airborne contaminant a biological (bacteria, mold, spores, fungi, virus)?
• Are there any mandatory or recommended occupational exposure levels for the contaminant?

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How Much?

The respiratory protection standard allows you to use many approaches for estimating worker exposures to respiratory hazards. For example:

Sampling. OSHA calls personal exposure monitoring the “gold standard” for determining employee exposures because it is the most reliable approach for assessing how much and what type of respiratory protection is required in a given circumstance. To comply with the standard, sampling should:

• Use methods appropriate for contaminants;
• Present the worst-case exposures; or
• Represent enough shifts and operations to determine the range of exposure.

Objective Information. OSHA identifies different kinds of information as acceptable. For example:

• Information and data that indicate that use or handling of a product or material cannot, under worst-case conditions, release concentrations of a respiratory hazard above a level that would trigger the need for respirator use or require use of a more protective respirator.
• Data on the physical and chemical properties of air contaminants, combined with information on room dimensions, air exchange rates, contaminant release rates, and other pertinent data, including exposure patterns and work practices, to estimate the maximum exposure that could be anticipated in the workplace.
• Data from industry-wide surveys by trade associations for use by their members, as well as from stewardship programs operated by manufacturers for their customers, are often useful in assisting employers, particularly small business owners, to obtain information on employee exposures in their workplaces.

OSHA points out that when assessing respiratory hazard exposure, you have to account for potential variation in exposure by using exposure data collected with a strategy that recognizes exposure variability, or by using worst-case assumptions and estimation techniques to evaluate the highest foreseeable employee exposure levels.

Tomorrow, we stay with respiratory protection and review the rules for cartridge change schedules.

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