Let's Clear the Air on Respiratory Protection

Though there is no one-size-fits-all template, here are some straightforward guidelines even a safety novice can use in developing an effective program.

• By John B. Vincent, Q.S.S.P.
• Nov 01, 2003

HOW should you go about establishing or revising a respiratory protection program for a small or medium-size business? Many managers and newly appointed safety administrators who call us looking for advice seem overwhelmed at the prospect of wading through reams of government documents and possibly misinterpreting the regulations or selecting the wrong equipment. Often, they ask whether there is a template for a written respiratory program, hoping simply to fill in the blanks to create their own documentation.

Though there is no one-size-fits-all template, here are some straightforward guidelines even a safety novice can use in developing an effective respiratory protection program. After reviewing the basics, you also may want to check some of the resources referenced in this article. Even safety professionals at larger companies who are searching for clarifications and answers to particular respiratory protection situations may find some of the reference materials useful. In addition, many respirator manufacturers provide training videos and technical support to help safety administrators with answers to their respiratory questions.

What Are You Facing?
Providing proper respiratory protection is not as simple as selecting the appropriate respirator. It's also not as difficult as some may imagine--although it requires time and careful attention to details. To get started, you should become familiar with the Occupational Safety and Health Administration's respiratory protection regulation, found on the OSHA Web site at www.osha.gov under Law & Regulations--Standards.

Another extremely useful OSHA Small Entity Compliance Guide provides explanatory notes on these regulations for small businesses, complete with photos and a sample respiratory program. It can be found at www.osha.gov/pls/publications/pubindex.list.

Identify and Evaluate Respiratory Hazards
First, you need to survey all of the work sites in your facility to identify and catalog any respiratory hazard. The Small Entity Compliance Guide suggests a format for doing this.

Once toxic substances are identified, review the appropriate Material Safety Data Sheets (MSDSs) to determine the hazards associated with each contaminant. You can get these sheets from the companies that supply or manufacture the materials you use. Each MSDS defines a substance's characteristics: fire, explosion, and health hazards; precautions for safe handling and use; and ways to control its dangers.

Air sampling or monitoring will give you more precise information on the degree of contamination at each work site in your facility. Check your company's worker's compensation insurance carrier to see if it might do this type of testing as part of its coverage program. Other resources for information or testing include industrial hygiene consultants, state health departments, and commercial industrial service providers.

Implement Engineering and Administrative Controls
Whenever possible, respiratory hazards should be engineered out of the work environment. Installing ventilation equipment or using alternative and less-toxic chemicals are examples of reducing respiratory hazards. Administrative controls, such as limiting a worker's exposure time, also should be used.

If it is not possible to eliminate or reduce the hazard below permissible exposure limits (PELs), respirators correctly matched to the type of hazard must be used to reduce employee exposures to toxic materials. Respirators also should be used during the time the hazard is being eliminated or reduced through engineering or administrative controls.

If you cannot eliminate the respiratory hazards, then you must create a written respiratory program.

Appoint a Respiratory Program Administrator
If you do not already have a respiratory program administrator, you must appoint one. The respiratory program administrator must have training and qualifications that match the complexity of the program and must be able to evaluate the program's effectiveness. Top management support for the program administrator is essential to ensure an effective program.

The administrator and top management must collaborate on involving other employees in developing the respiratory protection program. Employees who participate on safety committees, in auditing their own work areas, and in designing the program tend to "buy into" the program, better ensuring effective implementation.

Prepare a Written Respiratory Program
OSHA requires that the employer establish a written respiratory program that documents each hazard, site-by-site, based on a work site survey and evaluation. The written respiratory program should spell out the site-specific procedures you will implement to reduce the dangers, including:

• Procedures for selecting respirators
• Medical evaluation of employees required to wear respirators
• Fit testing procedures
• Procedures for proper use of respirators in routine and emergency situations
• Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and maintaining respirators
• Procedures for ensuring adequate air quality for supplied air respirators
• Training in respiratory hazards
• Training in proper use and maintenance of respirators, and
• Program evaluation procedures.

• The written respiratory program should be updated whenever changes at various work sites affect respirator use.

Select Appropriate Respirators
Respirator selection is based on the identification and evaluation of the work site respiratory hazards and use factors. Once the hazards are identified and evaluated, the employer then must estimate the employee exposure to those hazards and determine whether the environment is immediately dangerous to life or health (IDLH).

If an employer cannot identify or "reasonably estimate" the employee exposure, the atmosphere must be considered IDLH. In an IDLH environment, a full facepiece self-contained breathing apparatus (SCBA), certified by the National Institute for Occupational Safety and Health with a minimum service life of 30 minutes, or a full facepiece NIOSH-certified pressure-demand airline respirator with auxiliary self-contained air supply, must be used.

If the work site is a non-IDLH environment, the employer must provide employees with respirators appropriate for the contaminant's concentration level and physical characteristics (gaseous or particulates). Respirator choices include full facepieces and half-masks with selection determined by the concentration and characteristics of the contaminant. Respirators for protection against gases and vapors must be selected from:

• Appropriate NIOSH-certified air-supplied respirators, or
• An air-purifying respirator, where the respirator is equipped with:

An end-of-service-life indicator (ESLI) that is NIOSH-certified for the contaminant, or

A change schedule that is based on objective information or data that ensures cartridges are changed before the end of their service life.

For protection against particulates, choices include:

• An appropriate NIOSH-certified atmosphere-supplying respirator, or
• A NIOSH-certified air-purifying respirator equipped with a particulate filter.

In non-hazardous work site atmospheres, the employer may provide respirators at the request of employees, or permit employees to use their own respirators, as long as such use does not create a hazard. If voluntary respirator use is permissible, the employer must implement those elements of a written program concerning:

• The employee's medical status
• Correct respirator selection
• Instruction on respirator cleaning, maintenance, and storage, and
• Respiratory protection capabilities and limitations.

Filtering facepiece (dust/mist masks) respirators are exempt from this OSHA safety regulation when voluntarily used in documented non-hazardous work site atmospheres.

Provide for Medical Evaluations
OSHA requires that the employer provide for a medical evaluation of every employee who will be required to wear a respirator. A physician or other licensed health care professional must administer the evaluation before the employee is fit-tested or allowed to wear a respirator. The evaluation must be based on either a medical exam or a questionnaire mandated by OSHA (see Appendix C of 29 CFR 1910.134 for a copy of the questionnaire).

OSHA also requires that the medical evaluation be administered at no cost to the employee. For any employee who gives a positive response to Questions 1 to 8 in Section 2 of the OSHA medical questionnaire, OSHA requires a follow-up medical exam, also at no cost to the employee.

Conduct Fit Testing
OSHA also mandates fit testing for every employee who will be required to wear a tight-fitting respirator. The fit testing must be done in a negative pressure mode, and it must be repeated annually. Qualitative and quantitative fit test protocols are included in Appendix A of 29 CFR 1910.134. Most respirator manufacturers provide qualitative fit testing kits that include detailed instructions.

Before fit testing, the respirator wearer should become familiar with the respirator and should be taught to do a positive and negative pressure seal check (instructions for seal checks are in the respirator user's manual). Seal checks must be performed before fit testing and each and every time the respirator user is about to enter a contaminated environment.

Quantitative fit testing, which involves instrumentation to quantify the fit or measure the leak rate of the respirator, is an involved, time-consuming, and costly procedure that is not practical for everyone.

Qualitative fit tests such as those using irritant smoke or Bitrex® aerosol are simple, quick, and easy. The irritant smoke test is performed in a well-ventilated area. The test operator directs a stream of smoke from a smoke tube toward the sealing edge of the test subject's respirator. The user then performs several exercises. If the irritant smoke is detected at any time or if the respirator is not comfortable, another size or model should be tried.

The Bitrex test is performed in a hood and employs a sensitivity solution that is atomized into the hood while the user is not wearing the respirator (to determine the subject's taste sensitivity threshold) and again while wearing it. The same exercises are used as during the smoke test. If the respirator wearer can detect the bitter Bitrex taste, then the facepiece must be adjusted or a different size or model facepiece must be used.

Conduct Training
The employer is responsible for pre-use and annual training of employees, at no cost to the employees, in the proper use of respirators. OSHA requires that each trained employee demonstrate knowledge of at least the following points:

• Why the respirator is necessary and how improper fit, usage or maintenance can compromise the protection offered by the respirator.
• What the limitations and capabilities of the respirator are.
• How to use the respirator in emergency situations, including those involving respirator malfunction.
• How to inspect, put on, remove, use, and perform a user seal check.
• Procedures for maintenance and storage of the respirator.
• How to recognize medical signs and symptoms that may limit or prevent the effective use of the respirator.
• What 1910.134 generally requires the employer to do under its respiratory protection program.

By following these guidelines and consulting the references mentioned here, even a small business can be well on the way to implementing an effective respiratory program. In addition to helping employees avoid serious illness, a respiratory protection program also may help improve a company's bottom line, because a healthy work environment promotes productivity, avoids increased worker's compensation costs and sometimes lawsuits, and reduces sick time, absenteeism, and turnover.

This article originally appeared in the November 2003 issue of Occupational Health & Safety.