Nationwide, approximately 1.4 million workplaces provide at least some of their employees with respiratory protection. Studies indicate that at these workplaces, gaps exist in either their written respiratory protection program, their understanding of OSHA requirements, or the administration of the program. These gaps lead to issues in mandatory compliance or recommended practices, and the improper use of respiratory protective devices can lead to employee exposure to respiratory illnesses.
There are many challenges in the administration of a respiratory protection program. Each employer has its own unique concerns and needs depending on the industry, whether it be health care, general industry, construction, or emergency response. To meet these concerns, OSHA states in 29 CFR 1910.134(c)(3) that:
“The employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness.”
Let’s consider this statement … The employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness. It means key elements of an OSHA-compliant respiratory protection program must be customized based on hazard assessments of a specific workplace to prevent exposure from air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, vapors, or sprays.
According to OSHA’s Respiratory Protection Standard (29 CFR 1910.134), key elements are necessary for compliance. In my respiratory protection program, I have included 11. They are:
- A written plan detailing how the program will be administered.
- The selection of respirators based on hazards that will be encountered in the job-specific workplace.
- A medical evaluation must be provided to determine an employee’s ability to use a respirator before fit testing and use.
- Fit testing must be provided to all employees using a negative or positive pressure respirator, and the respirators must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) procedure.
- Respirators must be correctly used based on site-specific job hazards.
- Maintenance and care of respirators must be appropriate, based on the procedures in Appendix B-2, or equally effective or greater manufacturer’s procedures.
- Breathing air quality and use shall meet the requirements for Type 1-Grade D breathing air as described in ANSI/CGA Commodity Specification for Air, G-7.1-1989.
- All filters, cartridges, and canisters used in the workplace must be labeled and color-coded with the NIOSH approval label.
- Training and information must include:
- Why the respirator is necessary;
- How improper fit, use, or maintenance can compromise the protective effect of the respirator;
- The limitations and capabilities of the respirator;
- Proper use in emergency situations;
- How to inspect the respirator;
- Procedures for donning and doffing respirators;
- Seal checks;
- Procedures for maintenance and storage; and
- Recognition of medical signs and symptoms that may limit or prevent effective use of the general requirements of this standard.
- A Respiratory Protection Program Evaluation must conduct evaluations of the site-specific workplace as necessary to ensure proper implementation of the program and consult with employees to ensure proper use.
- Recordkeeping! Records of medical evaluations must be retained and made available per 29 CFR 1910.1020. Also, a record of fit tests must be established and retained until the next fit test and a written copy of the current program must be retained.
To meet these challenges, it is necessary that the program administrator is qualified based on the complexity of the specific site and job activities to be better prepared to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness.
|Dennis A. Terpin, PhD, O.H.S.T. is the Retiring Senior Industrial Hygienist/Emergency Manager for the University of Illinois at Chicago with over 49 years of experience in the occupational safety and health, laboratory safety, and emergency management fields. Join Dr. Terpin for his live webinar, Respiratory Protection Requirements: Letting the Respiratory Protection Standard Work for You, on Tuesday, October 16, 2018.
In this webinar, you will gain these valuable insights to help your business: