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 their written respiratory protection program, their understanding of Occupational Safety and Health Administration (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.
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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. Your programs must be updated if new challenges occur.
Our latest challenge is the 2019 novel coronavirus (2019-nCoV) or patients under investigation for 2019-nCoV in healthcare settings.
Respiratory Protection Review Points from the Centers for Disease Control (CDC)
- Use respiratory protection (i.e., a respirator) that is at least as protective as a fit-tested National Institute for Occupational Safety and Health (NIOSH)-certified disposable N95 filtering facepiece respirator before entry into the patient room or care area.
- Disposable respirators should be removed and discarded after exiting the patient’s room or care area and closing the door. Perform hand hygiene after discarding the respirator.
- We need to stop referring to N95 respirators as “masks.” They are filtering facepiece respirators.
- If reusable respirators (e.g., powered air purifying respirators (PAPRs)) are used, they must be cleaned and disinfected according to the manufacturer’s reprocessing instructions before reuse.
- Respirator use must be in the context of a complete respiratory protection program in accordance with the OSHA Respiratory Protection Standard. Staff should be medically cleared and fit-tested if using respirators with tight-fitting facepieces (e.g., a NIOSH-certified disposable N95) and trained in the proper use of respirators, safe removal and disposal, and medical contraindications to respirator use.
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Key Elements of Respiratory Standard Compliance
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 as effective as or greater than the manufacturer’s procedures.
- Breathing air quality and use shall meet the requirements for Type 1-Grade D breathing air as described in American National Standards Institute (ANSI)/Compressed Gas Association (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 evaluate 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 for the program administrator to be 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. EMT-P, is a member of the retired Z88 and Z88.10, as well as the new ASTM International Technical Committee F23.65 on Personal Protective Clothing and Respiratory Protection/Equipment. Terpin is also Retired Senior Industrial Hygienist and Emergency Manager for the University of Illinois at Chicago, as well as a Certified Master Level Instructor for the Federal Emergency Management Agency (FEMA)/Department of Homeland Security, teaching at the Center for Domestic Preparedness (CDP) CORBRA live agent training center and instructing in respiratory protection. He has over 50 years of experience in the occupational safety and health, laboratory safety, and emergency management fields.
Join Terpin for his free live webinar, “Managing Respiratory Protection Programs: Letting the Standard Work for You,” taking place Tuesday, February 18, 2020, at 2:00 p.m. Eastern Time (11:00 a.m. Pacific). Register Now! |