OSHA Respiratory Protection Program Requirements

OSHA Respiratory Protection Program Requirements

OSHA RESPIRATORY PROTECTION PROGRAM

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Learn How to Develop a Change ScheduleAny employer who requires or permits employees to wear a respirator must have a written respiratory protection program. This is required by OSHA in both of their asbestos standards and their respiratory protection standard (29 CFR 1910.134). The written respirator program establishes standard operating procedures concerning the use and maintenance of respiratory equipment. In addition to having such a written program, the employer must also be able to demonstrate that the program is enforced and updated as necessary.
Respirators should be used for protection only when engineering controls have been shown to be infeasible for the control of the hazard or during the interim period when engineering controls are being installed. (See the Exposure Control Priority.)
Learn How To Select an Appropriate Respirator

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Contents

WHAT'S REQUIRED IN THE PROGRAM?

The OSHA regulations spell out just what must be included in a written program. Below, these items are discussed with special emphasis on applications to work performed by asbestos abatement personnel.

An effective respirator program as adapted from A Guide to Respiratory Protection for the Asbestos Abatement Industry, (U.S.EPA/NIOSH publication, EPA-560- OPTS86-001 September 1986) should include:

  1. A written statement of company policy, including assignment of individual responsibility, accountability, and authority for required activities of the respiratory protection program.
  2. Written standard operating procedures governing the selection and use of respirators.
  3. Respirator selection (from NIOSH/MSHA approved and certified models) on the basis of hazards to which the worker is exposed.
  4. Medical examinations of workers to determine whether or not they may be assigned an activity where negative pressure respiratory protection is required.
  5. Employee training in the proper use and limitations of respirators (as well as a way to evaluate the skill and knowledge obtained by the worker through training).
  6. Respirator fit testing.
  7. Regular cleaning and disinfecting of respirators.
  8. Routine inspection of respirators during cleaning, and at least once a month and after each use for those respirators designated for emergency use.
  9. Storage of respirators in convenient, clean, and sanitary locations.
  10. Surveillance of work area conditions and degree of employee exposure (e.g., through air monitoring).
  11. Regular inspection and evaluation of the continued effectiveness of the program.

All of the above items are required by OSHA if employees wear respirators during work (which they should be if they are working with or around friable asbestos-containing materials ACM!).

Keep In Mind

Respirators should be used for protection only when engineering controls have been shown to be infeasible for the control of the hazard or during the interim period when engineering controls are being installed. (See the Exposure Control Priority.)

ESTABLISHING A POLICY

Every employer should prepare a clear concise policy regarding the use of respirators by their employees when performing asbestos abatement activities. This policy should serve as the guiding principal for the preparation, implementation, and enforcement of an effective respiratory protection program.

DESIGNATION OF A PROGRAM ADMINISTRATOR

A program administrator must be designated by name. This person is responsible for implementation of, and adherence to, the provisions of the respiratory protection program. It is usually a good idea to also designate a person who is responsible for enforcement of the procedures at each job site. Procedures should also be outlined for enforcement of the program. Enforcement procedures and the development of the program as a whole should be done in conjunction with and input from the employees and/or their representatives.

SELECTION AND USE OF RESPIRATORY PROTECTION EQUIPMENT

Respirators used shall be selected from those approved by the Mine Safety and Health Administration (MSHA) or the National Institute for Occupational Safety and Health (NIOSH) for use in atmospheres containing asbestos fibers. A NIOSH-approved respirator contains the following- an assigned identification number associated with each unit; a label identifying the type of hazard the respirator is designed to protect against; additional information on the label which indicates limitations and identifies the component parts approved for use with the basic unit.

Although some single-use disposable dust masks were at one time "approved" by NIOSH for use with asbestos, they should not be used during asbestos abatement projects. NIOSH has stated that these respirators do not provide adequate protection against asbestos. As a rule of thumb, negative pressure, air-purifying respirators with HEPA filters may be used during glovebag procedures.

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Respirator Selection

Which respirator is right for you?
The Selection Advisor can help!

MEDICAL APPROVAL

Only those individuals who are medically capable to wear respiratory protective equipment shall be issued a respirator. Initially, before being issued one, an employee will receive pertinent tests to evaluate medical and physical conditions, and annually thereafter. Medical tests to be conducted by a physician often include: pulmonary function tests, a chest x-ray (if a physician deems it necessary), electrocardiogram, and any other tests needed for proper evaluation by a physician. A medical history in the form of a questionnaire is collected as well for each individual. Other factors to be considered by a physician may include: emphysema, asthma, chronic bronchitis, heart disease, anemia, hemophilia, poor eyesight, poor hearing, hernia, lack of finger or hand usage, epileptic seizures, and other factors which might inhibit the ability of an employee to wear respiratory equipment.

EMPLOYER TRAINING PROGRAM

Each employee designated to wear a respirator must receive adequate training. The training session (initial and periodic training) should be conducted by a qualified individual to ensure that employees understand the limitations, use, and maintenance of respiratory equipment. EHSO can provide this training for you. Call us at 770-645-0788!

RESPIRATOR FITTING

One of the most important elements of an effective respirator program is fit. The OSHA Asbestos Standards (29 CFR 1910.1001/ 1926. 1 , 10 4 and the OSHA respirator standard (29 CFR 1910.134) require that the fit of respirators be determined when the respirator is issued and every six months thereafter for all negative pressure respirators. Procedures for fit-testing should be addressed in the written respirator program. A discussion of fit-testing is included elsewhere in this section.

CLEANING AND DISINFECTION OF RESPIRATORS

Whenever possible, a respirator should be reserved for the exclusive use of a single individual. Following each use, the respirator should be cleaned and disinfected. The following procedures can be used to clean a respirator:

  • Wash with a detergent or a detergent/disinfectant combination, in warm water using a brush.
  • Rinse in clean water, or rinse once with a disinfectant and once with clean water. The clean water rinse is particularly important because traces of detergent or disinfectant left on the mask can cause skin irritation and/or damage respirator components.
  • Air dry on the rack or hang; position the respirator so that the facepiece rubber will not dry misshapened.

Inspection of the respirator is an important, routine task. It should be done before and after each use. The following items should be checked, at a minimum.

ROUTINE INSPECTION OF RESPIRATORS

A. Rubber facepiece should be checked for:

  1. Dirt
  2. Cracks, tears, or holes
  3. Distortion from improper storage
  4. Cracked, scratched or loose fitting lens
  5. Broken or missing mounting clips

B. Headstraps should be checked for:

  1. Breaks or tears
  2. Loss of elasticity
  3. Broken or malfunctioning buckles or attachments
  4. Excessively worn serrations of the headstraps which might allow the facepiece to slip.

C. Valves

  1. Detergent residue, dust or dirt on the valve seat
  2. Cracks, tears or distortion in the valve
  3. Missing or defectivevalve cover

D. Filter Elements

  1. Proper type of filter for the job and contaminants
  2. Approved design (TC... ID#...)
  3. Missing or worn gaskets
  4. Worn threads
  5. Cracks or dents in the housing
  6. Spent, dirty, used

The Use of Respirators is the Least Satisfactory Method

Engineering and work practice controls are generally regarded as the most effective methods to control exposures to airborne hazardous substances. OSHA considers the use of respirators to be the least satisfactory approach to exposure control because�

  • respirators provide adequate protection only if employers ensure, on a constant basis, that they are properly fitted and worn.
  • respirators protect only the employees who are wearing them from a hazard, rather than reducing or eliminating the hazard from the workplace as a whole (which is what engineering and work practice controls do).
  • respirators are uncomfortable to wear, cumbersome to use, and interfere with communication in the workplace, which can often be critical to maintaining safety and health.
  • the costs of operating a functional respiratory protection program are substantial - including regular medical examinations, fit testing, training, and the purchasing of equipment.

If you need help developing a respiratory protection program, call EHSO at 770-645-0788!