respiratory control program kit Zurich
foreward
overview
implementation
sample program
respirator selection
hazard evaluation
medical records
training program
training records
fit test records
maintenance
cartridge
osha_resp_std
osha_chemicals
glossary
program_audit
OSHA chemicals medical questionnaire fit testing voluntary use
overview
Introduction Identifying Responsible Staff
What is a Respiratory Protection Program? Identifying when Program is Needed
Becoming Familiar with the Standards Preparing and Implementing a Respiratory Protection Program
Scope of Kit Voluntary Use of Respirators

Introduction
Hazards to the lungs are not always easy to detect. Some of the most common hazards are the lack of oxygen and the presence of harmful dust, fogs, smokes, mists, fumes, gases, vapors or sprays. Depending on the chemical, exposure to these airborne contaminants may cause cancer, lung impairment, other diseases or death. Properly selected and fitted respirators prevent the entry of harmful substances into the lungs during breathing. Some respirators also provide a separate supply of breathable air so work can be performed where there is inadequate oxygen or where greater protection is needed.

The prevention of atmospheric contamination at the worksite generally should be accomplished as far as possible by accepted engineering control measures (e.g., 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 implemented or evaluated, appropriate respirators should be used.

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What is a Respiratory Protection Program?
The objective of the Respiratory Protection Program is to ensure that the respirators given to employees provide adequate protection, are properly maintained and used, and that their use does not pose an unreasonable health hazard for the wearer.

A written Respiratory Protection Program is required in any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer. The program must be updated as necessary to reflect those changes in workplace conditions that affect respirator use.

The following elements must be included in the Respiratory Protection Program:

  • Procedures for selecting respirators for use in the workplace

  • Medical evaluations of employees required to use respirators

  • Fit-testing procedures for tight-fitting respirators

  • Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations

  • Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding and otherwise maintaining respirators

  • Procedures to ensure adequate air quality, quantity and flow of breathing air for atmosphere-supplying respirators

  • Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations

  • Training of employees in the proper use of respirators, including putting them on and removing them, any limitations on their use and their maintenance

  • Procedures for regularly evaluating the effectiveness of the program.

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Becoming Familiar with the Standards
The Occupational Safety and Health Administration (OSHA) regulates the general use of respirators in the workplace under 29 CFR 1910.134. The standard requires employers to establish a respirator program and to provide NIOSH-certified respirators to employees whenever necessary to protect the health of the employee.

The use of respirators is also covered in a group of substance-specific standards, as well as in standards such as 1910.94 and 1926.57, which deal with abrasive blasting operations. While these standards specify the type of respirators to be used, they reference 1910.134 for the establishment of a Respiratory Protection Program.

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Scope of this kit
The OSHA regulations specify minimum requirements for employers to meet. The standard provisions have been outlined in this kit to assist you in comparing the elements of your program to the OSHA standards. Additional or modified program elements have been included to ensure the respiratory protective programs effectively accomplish what they are designed to do, prevent injury due to exposure to airborne contaminants.

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Identifying Responsible Staff
To be effective, the Respiratory Protection Program should be a continuing program in your facility. This is not a "one-shot deal." In order to have a successful program, responsibility must be assigned for both the initial and ongoing activities.

Program administrator
The responsibility and authority for the respirator program should be assigned to a single person responsible to the facility manager. The administrator should have sufficient knowledge of respiratory protection to supervise the respirator program properly. The program administrator's responsibilities include:

  • Measuring, estimating or reviewing information on the concentration of an airborne contaminant in the work area prior to respirator selection and periodically during respirator use to ensure that the proper type of respirator is being used

  • Selecting the appropriate type or class of respirator that will provide adequate protection for each contaminant, present or anticipated

  • Maintaining records and written procedures in a manner that documents the respirator program

  • Evaluating the respiratory protection program's effectiveness.

Employer
The responsibilities of the employer should be clearly spelled out in the program. These responsibilities include:

  • Designating a program administrator who is qualified by appropriate training or experience to administer or oversee the Respiratory Protection Program

  • Providing respirators when such equipment is necessary to protect the employee

  • Providing respirators that are applicable and suitable for the purpose intended

  • Establishing and maintaining a respiratory protection program, which includes medical evaluations and employee training

  • Allowing employees to leave the hazardous area for any respirator-related cause.

Employee
The respirator program should define the responsibilities of those employees required to wear respirators for routine and/or emergency use. These responsibilities include:

  • Using the provided respirator in accordance with the instructions and training received

  • Guarding against damage to the respirator

  • If the respirator malfunctions, immediately leaving the contaminated area and reporting the malfunction to a responsible person designed by the employer (Program Administrator)

  • Reporting to the responsible person any change in his/her medical status that may impact their ability to wear a respirator safely.

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Identifying when a Respiratory Protection Program is Needed
Respiratory protection is needed whenever employees are exposed to hazardous concentrations of airborne substances. In most cases, some type of air sampling or other evaluation of employee exposures must be conducted to determine if the exposure is above acceptable limits. Air sampling may be mandated by OSHA substance-specific standards, or be part of the company's ongoing safety and health program.

When sampling results show that employees are overexposed to hazardous chemicals, controls are to be implemented to reduce employee exposures to acceptable levels (e.g., below the OSHA Permissible Exposure Limits, ACGIH Threshold Limit Values or NIOSH Recommended Exposure Limits). To safeguard employees while the controls are being implemented, or if the controls do not reduce exposures to acceptable levels, respirators may be required. The use of respirators by affected employees would come under the requirements of the Respiratory Protection Program.

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Chemical Exposures
OSHA defines a hazardous chemical as a substance which meets the definition for "health hazard" under the Hazard Communication Standard (29 CFR 1910.1200 [c]) ( "...a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees.").

Exposure levels which would prompt the need for respiratory protection include:

  • The OSHA Permissible Exposure Limit (PEL) for the hazardous chemical

  • The Threshold Limit Value (TLV) recommended by the American Conference of Governmental Industrial Hygienists (ACGIH)

  • If there is no PEL or TLV for the hazardous chemical, the NIOSH Recommended Exposure Limit (REL)

  • If there is no PEL, TLV or REL for the hazardous chemical, an exposure level based on available scientific information including material safety data sheets (MSDSs).

Zurich Services Corporation Risk Engineering recommends the use of the ACGIH TLVs for determining when employees should be required to wear respirators. The exception would be if there is an OSHA substance-specific standard for the chemical in question, or the OSHA PEL is lower.

Generally, industrial hygiene exposure monitoring is conducted to determine whether employee exposures to hazardous chemicals exceed these standards. In some cases, e.g., sandblasting with silica, empirical data is sufficient to prescribe respirators for this activity.

OSHA PELs - General industry
The OSHA PELs for General Industry are found in 29 CFR 1910.1000, Tables Z-1, Z-2, and Z-3. In addition, the OSHA regulations include substance-specific standards (e.g., asbestos, formaldehyde, lead).

The standard states "An employee's exposure to any substance listed in Tables Z-1, Z-2, or Z-3 of this section shall be limited in accordance with the requirements of the following paragraphs of this section."

To achieve compliance, administrative or engineering controls must first be determined and implemented whenever feasible. When such controls are not feasible to achieve full compliance, protective equipment or any other protective measures shall be used to keep the exposure of employees to air contaminants within the limits prescribed in this section. Any equipment and/or technical measures used for this purpose must be approved for each particular use by a competent industrial hygienist or other technically qualified person. Whenever respirators are used, their use shall comply with 1910.134, Respiratory Protection.

Employers located in states with OSHA-approved state plans should be aware that the state PELs may differ from federal PELs.

OSHA PELs - Construction
The OSHA PELs for construction are found in 29 CFR 1926.55, gases. vapors, fumes, dusts and mists. In addition the OSHA regulations include substance-specific standards (e.g., lead, asbestos, benzene, etc.).

The standard states that, "Exposure of employees to inhalation, ingestion, skin absorption, or contact with any material or substance at a concentration above those specified in the 'Threshold Limit Values of Airborne Contaminants for 1970' of the American Conference of Governmental Industrial Hygienists, shall be avoided."

ACGIH Threshold Limit Values
The Threshold Limit Values (TLVs) are developed as guidelines to assist in the control of health hazards. They are not developed for use as legal standards, but as mentioned above, have been adopted as PELs, by OSHA.

TLVs refer to conditions "under which it is believed that nearly all workers may be repeatedly exposed day after day without adverse effect." The TLVs are updated annually by the American Conference of Governmental Industrial Hygienists.

NIOSH Recommended Exposure Limits
NIOSH is responsible for identifying occupational safety and health hazards and for recommending changes in regulations limiting them. One of the institute's most important responsibilities is to transmit recommended standards to OSHA. The NIOSH recommendations are intended to serve as the basis, along with other available information, for assisting OSHA in developing new standards.

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Preparing and Implementing a Respiratory Protection Program
All workplaces where employees are overexposed to airborne contaminants and required to wear respirators must have a written plan which describes how the respirator program will be implemented in that facility. Preparation of a plan is not just a paper exercise - all of the elements must be implemented in the workplace in order for the program to be effective.

The plan does not have to be lengthy or complicated. It is intended as a blueprint for implementation of the program -- an assurance that all aspects of the requirements have been addressed.

This kit provides a "generic" example of a written program. Although such general guidance may be helpful, you must remember that the written program has to reflect what you are doing in your workplace. Therefore, if you use a generic program, it must be adapted to address the facility it covers. For example, the written plan must list the affected employees or areas at your site, indicate who is responsible for the various aspects of the program in your facility and indicate how any written materials or exposure records will be made available to employees.

Respirator use procedures
The respirator program should include written procedures covering the complete respirator program. Copies of the procedures should be readily available for employees to read. The procedures should be periodically reviewed by the program administrator and be revised as necessary. The procedures covered in the written program should include:

  • Respirator selection

  • Fit testing

  • Use of respirators in routine and reasonably foreseeable emergency situations

  • Cleaning, disinfecting, storing, inspecting, repairing, discarding and otherwise maintaining respirators

  • Ensuring adequate air quality, quantity and flow of breathing air for atmosphere-supplying respirators, if any

  • Evaluating the effectiveness of the program.

Selection
Respirators should be selected on the basis of the hazards to which the worker is exposed and workplace and user factors that affect respirator performance and reliability. Employee exposure monitoring (air sampling) may be needed in order to complete the selection process.

Medical evaluation
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. Therefore, employers are to provide 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.

The employer must identify a physician or other licensed health care professional to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire.

Additional medical evaluations should be provided if:

  • An employee reports medical signs or symptoms that are related to the ability to use a respirator

  • A PLHCP (physician or other licensed health care professional), supervisor or the respirator program administrator informs the employer 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.

Fit testing
The purpose of the respirator is to protect employees from airborne contaminants. In order to provide this protection, the respirator not only must be of the proper type for the contaminant(s) and environmental conditions present, it must be of the proper size and fit tightly. This is necessary to ensure that airborne contaminants do not enter the worker's breathing zone through leaks around the respirator facepiece. Therefore, OSHA requires that before an employee is required to use any respirator with a negative or positive pressure tight-fitting facepiece, the employee must be fit tested with the same make, model, style and size of respirator that will be used. The employer must ensure that employees using a tight-fitting facepiece respirator pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT).

Inspection
The employer is responsible for ensuring that respirators are inspected as follows:

  • All respirators used in routine situations shall be inspected before each use and during cleaning

  • All respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with the manufacturer's recommendations and shall be checked for proper function before and after each use

  • Emergency escape-only respirators shall be inspected before being carried into the workplace for use.

Maintenance
Maintenance should be carried out according to the manufacturer's instructions and on a schedule that ensures that each respirator wearer is provided with a respirator that is clean, sanitary and in good operating condition.

Replacement of parts should be done only by persons trained in proper respirator maintenance and assembly. Replacement parts should be only those designated for the particular respirator repaired.

Storage
Respirators should be stored in a manner that will protect them against physical and chemical agents such as vibration, shocks, sunlight, heat, extreme cold, excessive moisture or damaging chemicals. Respirators should not be stored in lockers and tool boxes unless they are protected from contamination, distortion and damage.

Emergency and rescue use respirators that are placed in work areas should be quickly accessible at all times, and the storage cabinet or container in which they are stored should be clearly marked.

Training
The respirator standard requires employers to provide effective training to employees who are required to use respirators. This training must be conducted in a manner that is understandable to the employee. The training program should 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

  • What the limitations and capabilities of the respirator are

  • 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
  • Negative Pressure Fit Check Positive Pressure Fit Check
  • 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 the OSHA Respiratory Protection Standard.

Each respirator wearer should be trained upon initial assignment, prior to requiring the employee to use a respirator in the workplace, and be retrained annually. Retraining should also be conducted when the following situations occur:

  • 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

  • Any other situation arises in which retraining appears necessary to ensure safe respirator use.

Written records should be kept of the names of persons trained and the dates training occurred.

Workplace surveillance
Surveillance must be maintained of the conditions in the work area and of the degree of worker exposure or stress (combination of work rate, environmental conditions and physiological burdens of wearing a respirator).

The role of initial monitoring is to identify those employees or groups of employees who need to wear respirators and determine the type of respirator required (depending on the type of airborne contaminant and exposure levels). The main purpose of periodic monitoring is to evaluate the effect of process, equipment and other changes on the exposed group of employees.

Recordkeeping
The employer must establish and maintain written information regarding medical evaluations, fit testing and the respirator program.

Program evaluation
The employer is required to conduct evaluations of the workplace as necessary to ensure that the provisions of the current program are being effectively implemented and that it continues to be effective.

The employer is also required to regularly consult employees required to use respirators to assess the employee's views on the program effectiveness and to identify any problems. Any problems that are identified during this assessment must 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 workplace conditions the employee encounters

  • Proper respiratory maintenance.

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Voluntary Use of Respirators by Employees
Where respirator use is not required, the employer may provide respirators at the request of employees or permit employees to use their own respirators, if the employer determines that such respirator use will not in itself create a hazard. If the employer determines that any voluntary respirator use is permissible, the employer must provide the respirators users with the information contained in Appendix D of the Respirator Standard ("Information for Employees Using Respirators When Not Required Under the Standard").

In addition, the employer must establish and implement those elements of a written Respiratory Protection Program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored and maintained so that its use does not present a health hazard to the user.

Employers are not required to include in a written Respiratory Protection Program those employees whose only use of respirators involves the voluntary use of filtering facepieces (dust masks).

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