Respiratory Protection - Respirator Safety Program
General
In the Respiratory Protection program, hazard assessment
and selection of proper respiratory protective
equipment (RPE) is conducted in the same manner as for other
types of personal protective equipment (PPE). In the control
of those occupational diseases caused by breathing air
contaminated with harmful dusts, fogs, fumes, mists, gases,
smokes, sprays, or vapors, the primary objective shall be to
prevent atmospheric contamination. This shall be
accomplished as far as feasible by accepted engineering
control measures (for example, enclosure or confinement of
the operation, general and local ventilation, and
substitution of less toxic materials). When effective
engineering controls are not feasible, or while they are
being instituted, appropriate respirators shall be used.
References: OSHA Standards Respiratory Protection (29
CFR 1910.134)
Responsibilities
All Employees shall follow the requirements of the
Respiratory Protection Program.
Management
- implement the requirements
of this program
- provide a selection of
respirators as required
- enforce all provisions of
this program
- appoint a specific
designated individual to conduct the respiratory protection
program
Program Administrator
- review sanitation/storage procedures
- determine effectiveness for each type & model
respirator based on Assigned Protection Factors
- ensure respirators are
properly, stored, inspected and maintained
- monitor compliance for this
program
- provide training for
affected Employees
- review compliance and
ensure monthly inspection of all respirators
- provide respirator fit
testing
Designated Occupational Health care Provider
- conduct medical aspects of
program
Program
Administrator
Each Facility
will 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.
Voluntary
Use of Respirators is
Prohibited
OSHA
requires that voluntary use of respirators, when not
required by the company, must be controlled as strictly as
under required circumstances. To prevent violations of the
Respiratory Protection Standard Employees are not allowed
voluntary use of their own or company supplied respirators
of any type. Exception: Employees whose only use of
respirators involves the voluntary use of filtering
(non-sealing) face pieces (dust masks).
Program Evaluation
Evaluations of the workplace
are necessary to ensure that the written respiratory
protection program is being properly implemented, this
includes consulting with employees to ensure that they are
using the respirators properly. Evaluations shall be
conducted as necessary to ensure that the provisions of the
current written program are being effectively implemented
and that it continues to be effective Program
evaluation will include discussions with employees required
to use respirators to assess the employees' views on program
effectiveness and to identify any problems. Any problems
that are identified during this assessment shall be
corrected. Factors to be assessed include, but are not
limited to:
- Respirator fit (including
the ability to use the respirator without interfering with
effective workplace performance);
- Appropriate respirator
selection for the hazards to which the employee is exposed;
- Proper respirator use under
the workplace conditions the employee encounters; and
- Proper respirator
maintenance.
Record Keeping
The Company will retain
written information regarding medical evaluations, fit
testing, and the respirator program. This information will
facilitate employee involvement in the respirator program,
assist the Company in auditing the adequacy of the program,
and provide a record for compliance determinations by OSHA.
Training and Information
Effective training for
employees who are required to use respirators is essential.
The training must be comprehensive, understandable, and
recur annually, and more often if necessary. Training will
be provided prior to requiring the employee to use a
respirator in the workplace. The training shall ensure that each
employee can demonstrate knowledge of at least the
following:
- Why the respirator is
necessary and how improper fit, usage, or maintenance can
compromise the protective effect of the respirator
- Limitations and
capabilities of the respirator
- How to use the respirator
effectively in emergency situations, including situations in
which the respirator malfunctions
- How to inspect, put on and
remove, use, and check the seals of the respirator
- What the procedures are for
maintenance and storage of the respirator
- How to recognize medical
signs and symptoms that may limit or prevent the effective
use of respirators
- The general requirements of
this program
Retraining shall be conducted annually and when:
- changes in the workplace or
the type of respirator render previous training obsolete
- inadequacies in the
employee's knowledge or use of the respirator indicate that
the employee has not retained the requisite understanding or
skill
- other situation arises in
which retraining appears necessary to ensure safe respirator
use
Training will be conducted
by instructors certified by _________________________.
Training is divided into the following sections:
Classroom Instruction
- Overview of the Company
Respiratory Protection Program & OSHA Standard
- Respiratory Protection
Safety Procedures
- Respirator Selection
- Respirator Operation and
Use
- Why the respirator is
necessary
- How improper fit, usage, or
maintenance can compromise the protective effect.
- Limitations and
capabilities of the respirator.
- How to use the respirator
effectively in emergency situations, including respirator
malfunctions
- How to inspect, put on and
remove, use, and check the seals of the respirator.
- What the procedures are for
maintenance and storage of the respirator.
- How to recognize medical
signs and symptoms that may limit or prevent the effective
use of respirators.
- Change out schedule and
procedure for air purifying respirators.
Fit Testing
- Respirator Inspection
- Respirator cleaning and
sanitizing
- Record Keeping
- Respirator Storage
- Respirator Fit Check
- Emergencies
Basic Respiratory
Protection Safety Procedures
- Only authorized and trained
Employees may use Respirators. Those Employees may use only
the Respirator that they have been trained on and properly
fitted to use.
- Only Physically Qualified
Employees may be trained and authorized to use Respirators.
A pre-authorization and annual certification by a qualified
physician will be required and maintained. Any changes in an
Employees health or physical characteristics will be
reported to the Occupational Health Department and will be
evaluated by a qualified physician.
- Only the proper prescribed
respirator or self contained breathing apparatus (SCBA) may
be used for the job or work environment. Air cleansing
respirators may be worn in work environments when oxygen
levels are between 19.5 percent to 23.5 percent and when the
appropriate air cleansing canister, as determined by the
Manufacturer and approved by the National Institute for
Occupational Health (NIOSH) or the Mine Safety & Health
Administration (MSHA), for the known hazardous substance is
used. SCBAs will be worn in oxygen deficient and oxygen rich
environments (below 19.5 percent or above 23.5 percent
oxygen).
- Employees working in
environments where a sudden release of a hazardous substance
is likely will wear an appropriate respirator for that
hazardous substance (example: Employees working in an
ammonia compressor room will have an ammonia APR respirator
on their person.).
- Only SCBAs will be used in
oxygen deficient environments, environments with an unknown
hazardous substance or unknown quantity of a known hazardous
substance or any environment that is determined
"Immediately Dangerous to Life or Health" (IDLH).
- Employees with respirators
loaned on "permanent check out" will be
responsible for the sanitation, proper storage and security.
Respirators damaged by normal wear will be repaired or
replaced by the Company when returned.
- The last Employee using a
respirator and/or SCBA that are available for general use
will be responsible for proper storage and sanitation.
Monthly and after each use, all respirators will be
inspected with documentation to assure its availability for
use.
- All respirators will be
located in a clean, convenient and sanitary location.
- In the event that Employees
must enter a confined space, work in environments with
hazardous substances that would be dangerous to life or
health should an RPE fail (a SCBA is required in this
environment), and/or conduct a hazardous material (HAZMAT)
entry, a "buddy system" detail will be used with a
Safety Watchman with constant voice, visual or signal line
communication. Employees will follow the established
Emergency Response Program and/or Confined Space Entry
Program when applicable.
- Management will establish
and maintain surveillance of jobs and work place conditions
and degree of Employee exposure or stress to maintain the
proper procedures and to provide the necessary RPE.
- Management will establish
and maintain safe operation procedures for the safe use of
RPE with strict enforcement and disciplinary action for
failure to follow all general and specific safety rules.
Standard Operation Procedures for General RPE use will be
maintained as an attachment to the Respiratory Protection
Program and Standard Operation Procedures for RPE use under
emergency response situations will be maintained as an
attachment to the Emergency Response Program.
Respirator User
Policies
Adherence to the following guidelines will help ensure
the proper and safe use of respiratory equipment:
- Wear only the respirator you have been instructed to
use. For example, do not wear a self-containing breathing
apparatus if you have been assigned and fitted for a
half-mask respirator.
- Wear the correct respirator for the particular hazard.
For example, some situations, such as chemical spills or
other emergencies, may require a higher level of protection
than your respirator can handle. Also, the proper cartridge
must be matched to the hazard ( a cartridge designed for
dusts and mists will not provide protection for chemical
vapors)
- Check the respirator for a good fit before each use.
Positive and negative fit checks should be conducted.
- Check the respirator for deterioration before and after
use. Do not use a defective respirator.
- Recognize indications that cartridges and canisters are
at their end of service. If in doubt, change the cartridges
or canisters before using the respirator.
- Practice moving and working while wearing the respirator
so that you can get used to it.
- Clean the respirator after each use, thoroughly dry it
and place the cleaned respirator in a sealable plastic bag.
- Store respirators carefully in a protected location away
from excessive heat, light, and chemicals.
Selection of Respirators
The Company has evaluated
the respiratory hazard(s) in each workplace, identified
relevant workplace and user factors and Assigned Protection Factors and has based respirator
selection on these factors. Also included are estimates of
employee exposures to respiratory hazard(s) and an
identification of the contaminant's chemical state and
physical form. This selection has included appropriate
protective respirators for use in IDLH atmospheres, and has
limited the selection and use of air-purifying respirators.
All selected respirators are NIOSH-certified .
Filter Classifications - These
classifications are marked on the filter or filter package
N-Series: Not Oil Resistant
- Approved for non-oil particulate contaminants
- Examples: dust, fumes, mists not containing oil
R-Series: Oil Resistant
- Approved for all particulate contaminants, including
those containing oil
- Examples: dusts, mists, fumes
- Time restriction of 8 hours when oils are present
P-Series: Oil Proof
- Approved for all particulate contaminants including
those containing oil
- Examples: dust, fumes, mists
- See Manufacturer's time use restrictions on packaging
Respirators for Immediately Dangerous to Life
and Health (IDLH)
atmospheres.
- The following respirators
will be used in IDLH atmospheres:
- A full face piece pressure
demand SCBA certified by NIOSH for a minimum service life of
thirty minutes, or
- A combination full face
piece pressure demand supplied-air respirator (SAR) with
auxiliary self-contained air supply.
- Respirators provided only
for escape from IDLH atmospheres shall be NIOSH-certified
for escape from the atmosphere in which they will be used.
Respirators for
atmospheres that are not IDLH.
The respirators selected shall be adequate to protect the
health of the employee and ensure compliance with all other
OSHA statutory and regulatory requirements, under routine
and reasonably foreseeable emergency situations. The
respirator selected shall be appropriate for the chemical
state and physical form of the contaminant.
Identification of Filters
& Cartridges
All filters and cartridges
shall be labeled and color coded with the NIOSH approval
label and that the label is not removed and remains legible.
A change out schedule for filters and canisters has been
developed to ensure these elements of the respirators remain
effective.
Respirator Filter &
Canister Replacement
An important part of the
Respiratory Protection Program includes identifying the
useful life of canisters and filters used on air-purifying
respirators. Each filter and canister shall be equipped with
an end-of-service-life indicator (ESLI) certified by NIOSH
for the contaminant; or
If there is no ESLI
appropriate for conditions a change schedule for canisters
and cartridges that is based on objective information or
data that will ensure that canisters and cartridges are
changed before the end of their service life.
Filter & Cartridge
Change Schedule
Stock of spare filers and
cartridges shall be maintained to allow immediate change
when required or desired by the employee
Cartridges shall be
changed based on the most limiting factor below:
- Prior to expiration date
- Manufacturer's recommendations for use and environment
- After each use
- When requested by employee
- When contaminate odor is
detected
- When restriction to air
flow has occurred as evidenced by increase effort by user to
breathe normally
- Cartridges shall remain in their original sealed
packages until needed for immediate use
Filters shall be changed
based on the most limiting factor below
- Prior to expiration date
- Manufactures recommendations for the specific use and
environment
- When requested by employee
- When contaminate odor is
detected
- When restriction to air
flow has occurred as evidenced by increase effort by user to
breathe normally
- When discoloring of the
filter media is evident
- Filters shall remain in
their original sealed package until needed for immediate
use.
Respiratory Protection
Schedule by Job and Working Condition
The Company maintains a
Respiratory Protection Schedule by Job and Working
Condition. This schedule is provided to each authorized and
trained Employee. The Schedule provides the following
information:
- Job/Working Conditions
- Work Location
- Hazards Present
- Type of Respirator or SCBA
Required
- Type of Filter/Canister
Required
- Respirator Assigned Protection Factor
- Location of Respirator or
SCBA
- Filter/Cartridge change out schedule
The schedule will be
reviewed and updated at least annually and whenever any
changes are made in the work environments, machinery,
equipment, or processes or if respirator different
respirator models are introduced or existing models are
removed.
Permanent respirator
schedule assignments are:
Each person who engages in
welding will have their own company provided dust-mist-fume
filter APR. This respirator will be worn during all welding
operations.
Assigned Protection Factors
No respirator can provide 100% effectiveness. OSHA has implemented
Assigned Protection Factors (APFs) for various types of respirators. The purpose
of APFs is to ensure use of respirators does not cause over-exposure to
specific contaminants. Maximum permissible exposure levels (PEL) are
generally based on specific concentrations over an 8 hour daily period without
using a respirator. As an example if a respirator has a 90% effectiveness,
then a respirator wearer would reach the maximum permissible exposure level in
10 hours IF the atmospheric conditions were 10 times the PEL.
Our company selects respirators by comparing the exposure level and
the maximum concentration of the contaminant in which a particular type of
respirator can be used. Known as the Maximum Use Concentration or MUC, this is generally determined by multiplying the
respirator's APF by the contaminant's exposure limit. If the level of
contaminant is expected to exceed the MUC, the company will select a respirator
with a higher APF.
Respirator Fit Testing
Before an employee is
required to use any respirator with a negative or positive
pressure tight-fitting face piece, the employee must be fit
tested with the same make, model, style, and size of
respirator that will be used. The
Company shall ensure that an employee using a tight-fitting
face piece respirator is fit tested prior to initial use of
the respirator, whenever a different respirator face piece
(size, style, model or make) is used, and at least annually
thereafter
The Company has establish a
record of the qualitative and quantitative fit tests
administered to employees including:
- The name or identification
of the employee tested
- Type of fit test performed
- Specific make, model,
style, and size of respirator tested
- Date of test
- The pass/fail results for
Qualitative Fit Test (QLFT) or the fit factor and strip
chart recording or other recording of the test results for
Quantitative Fit Test (QNFT)
Additional fit tests will be
conducted whenever the employee reports, or the Company,
Physician, supervisor, or program administrator makes visual
observations of, changes in the employee's physical
condition that could affect respirator fit. Such conditions
include, but are not limited to, facial scarring, dental
changes, cosmetic surgery, or an obvious change in body
weight.
If after passing a QLFT or
QNFT, the employee notifies the Company, program
administrator, supervisor, or Physician that the fit of the
respirator is unacceptable, the employee shall be given a
reasonable opportunity to select a different respirator face
piece and to be retested.
Types of Fit Tests
The fit test shall be
administered using an OSHA-accepted QLFT or QNFT protocol.
The OSHA-accepted QLFT and QNFT protocols and procedures are
contained in Appendix A of OSHA Standard 1910.134.
- QLFT may only be used to
fit test negative pressure air-purifying respirators that
must achieve a fit factor of 100 or less.
- If the fit factor, as
determined through an OSHA-accepted QNFT protocol, is equal
to or greater than 100 for tight-fitting half face pieces,
or equal to or greater than 500 for tight-fitting full face
pieces, the QNFT has been passed with that respirator.
- Fit testing of
tight-fitting atmosphere-supplying respirators and
tight-fitting powered air-purifying respirators shall be
accomplished by performing quantitative or qualitative fit
testing in the negative pressure mode, regardless of the
mode of operation (negative or positive pressure) that is
used for respiratory protection.
- Qualitative fit testing of
these respirators shall be accomplished by temporarily
converting the respirator user's actual face piece into a
negative pressure respirator with appropriate filters, or by
using an identical negative pressure air-purifying
respirator face piece with the same sealing surfaces as a
surrogate for the atmosphere-supplying or powered
air-purifying respirator face piece.
- Quantitative fit testing of
these respirators shall be accomplished by modifying the
face piece to allow sampling inside the face piece in the
breathing zone of the user, midway between the nose and
mouth. This requirement shall be accomplished by installing
a permanent sampling probe onto a surrogate face piece, or
by using a sampling adapter designed to temporarily provide
a means of sampling air from inside the face piece.
- Any modifications to the
respirator face piece for fit testing shall be completely
removed, and the face piece restored to NIOSH approved
configuration, before that face piece can be used in the
workplace.
Fit test records shall be retained for respirator users
until the next fit test is administered. Written
materials required to be retained shall be made available
upon request to affected employees.
Physical and Medical
Qualifications
Records of medical
evaluations must be retained and made available in
accordance with 29 CFR 1910.1020.
Medical evaluation
required
Using a respirator may place
a physiological burden on employees that varies with the
type of respirator worn, the job and workplace conditions in
which the respirator is used, and the medical status of the
employee. The company
provides a medical evaluation to determine the employee's
ability to use a respirator, before the employee is fit
tested or required to use the respirator in the workplace.
Medical evaluation
procedures
The employee will be
provided a medical questionnaire by the designated
Occupational Health Care Provider
Follow-up medical
examination
The company shall ensure
that a follow-up medical examination is provided for an
employee who gives a positive response to any question among
questions in Part B of the questionnaire or whose initial
medical examination demonstrates the need for a follow-up
medical examination. The follow-up medical examination shall
include any medical tests, consultations, or diagnostic
procedures that the Physician deems necessary to make a
final determination.
Administration of the
medical questionnaire and examinations
The medical questionnaire
and examinations shall be administered confidentially during
the employee's normal working hours or at a time and place
convenient to the employee. The medical questionnaire shall
be administered in a manner that ensures that the employee
understands its content. The
company shall provide the employee with an opportunity to
discuss the questionnaire and examination results with the
Physician.
Supplemental information
for the Physician
The following information
must be provided to the Physician before the Physician makes
a recommendation concerning an employee's ability to use a
respirator
- The type and weight of the
respirator to be used by the employee
- The duration and frequency
of respirator use (including use for rescue and escape)
- The expected physical work
effort
- Additional protective
clothing and equipment to be worn
- Temperature and humidity
extremes that may be encountered
- Any supplemental
information provided previously to the Physician regarding
an employee need not be provided for a subsequent medical
evaluation if the information and the Physician remain the
same
The Company has provided the
Physician with a copy of the written respiratory protection
program and a copy of the OSHA Standard 1910.134
Medical determination
In determining the
employee's ability to use a respirator, the Company shall
- Obtain a written
recommendation regarding the employee's ability to use the
respirator from the Physician. The recommendation shall
provide only the following information
- Any limitations on
respirator use related to the medical condition of the
employee, or relating to the workplace conditions in which
the respirator will be used, including whether or not the
employee is medically able to use the respirator
- The need, if any, for
follow-up medical evaluations
- A statement that the
Physician has provided the employee with a copy of the
Physician's written recommendation
- If the respirator is a
negative pressure respirator and the Physician finds a
medical condition that may place the employee's health at
increased risk if the respirator is used, the Company shall
provide a APR if the Physician's medical evaluation finds
that the employee can use such a respirator; if a subsequent
medical evaluation finds that the employee is medically able
to use a negative pressure respirator, then the Company is
no longer required to provide a APR
Additional Medical
Evaluations
- An employee reports medical
signs or symptoms that are related to ability to use a
respirator
- A Physician, supervisor, or
the respirator program administrator informs the Company
that an employee needs to be reevaluated
- Information from the
respiratory protection program, including observations made
during fit testing and program evaluation, indicates a need
for employee reevaluation
- A change occurs in
workplace conditions (e.g., physical work effort, protective
clothing, temperature) that may result in a substantial
increase in the physiological burden placed on an employee.
Respirator Operation and Use
Respirators will only be
used following the respiratory protection safety procedures
established in this program. The Operations and Use Manuals
for each type of respirator will be maintained by the
Program Administrator and be available to all qualified
users.
Surveillance by the direct
supervisor shall be maintained of work area conditions and
degree of employee exposure or stress. When there is a
change in work area conditions or degree of employee
exposure or stress that may affect respirator effectiveness,
the Company shall reevaluate the continued effectiveness of
the respirator.
For continued protection of
respirator users, the following general use rules apply:
- Users shall not remove
respirators while in a hazardous environment
- Respirators are to be
stored in sealed containers out of harmful atmospheres
- Store respirators away from
heat and moisture
- Store respirators such that
the sealing area does not become distorted or warped
- Store respirator such that
the face piece is protected
Face piece seal
protection
The Company does not permit
respirators with tight-fitting face pieces to be worn by
employees who have:
- Facial hair that comes
between the sealing surface of the face piece and the face
or that interferes with valve function; or
- Any condition that
interferes with the face-to-face piece seal or valve
function.
If an employee wears
corrective glasses or goggles or other personal protective
equipment, the Company shall ensure that such equipment is
worn in a manner that does not interfere with the seal of
the face piece to the face of the user.
Continuing Effectiveness
of Respirators
The Company shall ensure the
following that employees leave the respirator use area:
- To wash their faces and
respirator face pieces as necessary to prevent eye or skin
irritation associated with respirator use
- If they detect vapor or gas
breakthrough, changes in breathing resistance, or leakage of
the face piece
- To replace the respirator
or the filter, cartridge, or canister elements.
If the employee detects
vapor or gas breakthrough, changes in breathing resistance,
or leakage of the face piece, the Company will replace or
repair the respirator before allowing the employee to return
to the work area.
Procedures for IDLH
atmospheres
For all IDLH atmospheres,
the Company shall ensure that:
- One employee or, when
needed, more than one employee is located outside the IDLH
atmosphere
- Visual, voice, or signal
line communication is maintained between the employee(s) in
the IDLH atmosphere and the employee(s) located outside the
IDLH atmosphere
- The employee(s) located
outside the IDLH atmosphere are trained and equipped to
provide effective emergency rescue
- The Company or designee is
notified before the employee(s) located outside the IDLH
atmosphere enter the IDLH atmosphere to provide emergency
rescue
- The Company or designee
authorized to do so by the Company, once notified, provides
necessary assistance appropriate to the situation
Employee(s) located
outside the IDLH atmospheres will be equipped with:
- Pressure demand or other
positive pressure SCBAs, or a pressure demand or other
positive pressure supplied-air respirator with auxiliary
SCBA; and either
- Appropriate retrieval
equipment for removing the employee(s) who enter(s) these
hazardous atmospheres where
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