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 Introduction
Selecting the respirator appropriate for a given hazard is important, but equally important is using the selected device properly. Proper use can be ensured by carefully training both supervisors and workers in the selection, use and maintenance of respirators.
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Employee Training
Any employee required to use respirators must receive effective training. This training must be comprehensive, understandable and recur annually, and more often if necessary. The employer must 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
- 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 respiratory protection
standard.
This training is to be conducted in a manner that is understandable to the employee.
Respirator training must be provided before requiring an employee to use a respirator in the workplace.
Some of the topics you need to train on may have already been covered in other training programs. For example, in training for Hazard Communication, the information you provide about the hazardous nature of chemicals generally describes why respirator protection is needed. However, unless you have provided this training in the last year, it must be included in the training program for respirators, initially and annually.
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Employee Retraining
Retraining should be conducted annually, and 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.
The training program may be structured in any format, with different portions conducted by different individuals at different times, as long as the required topics are covered.
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Developing the Training Program
The following sections illustrate how a typical training program might be designed. Following the sample program are voluntary training guidelines developed by OSHA for conducting an effective training program. Using the sample and these guidelines, you can develop an effective training program. You can use the Training Checklist as a guide to developing and completing the necessary elements of your training program.
Identify employees to be trained
- Following the assessment of chemical exposures in the
workplace, identify those areas where respiratory protection
will be required and those employees who are to be trained.
- Determine the appropriate method to train new employees
and supervisors.
- Determine the appropriate method to conduct annual refresher
training for employees included in the training program.
Instruct employees on the purpose, use and limitations of respiratory protection
- Explain the purpose of respiratory protection. (For
example, respirators are provided to protect employees
from occupational diseases caused by breathing air contaminants
when engineering controls are not feasible, or while they
are being instituted.)
- Explain how improper fit, usage, or maintenance can
compromise the protective effect of the respirator. (For
example, respirators do nothing to control the concentration
of airborne contaminants in the work environment. They
function by providing a barrier between the employee and
the "hazardous" environment. If the barrier fails, immediate
exposure is the result.)
- Explain the limitations and capabilities of the respirator(s)
provided to employees. (For example, a dust mask does
not provide protection against organic solvent vapors.
)
- Explain how to inspect, put on and remove, use, and
check the seals of the respirator. (Allow employees to
try on respirators. Demonstrate how to conduct a user
seal check. Have the employee demonstrate their skills).
- Explain when employees should change respirator cartridges
(where applicable). Explain the ESLI (end-of-service-life
indicator) and/or the cartridge change schedule.
- Explain the procedures to be followed for maintenance
and storage of the respirator. (If employees are responsible
for maintaining their own respirators, demonstrate how
employees should disassemble, clean, sanitize, reassemble
and inspect the respirator.)
- Explain how to recognize medical signs and symptoms
that may limit or prevent the effective use of respirators.
- Explain the general requirements of the OSHA Respiratory
Standard 1910.134.
Training of employees who wear respirators voluntarily
Provide employees who voluntarily use respirators with the informational material in Appendix D of 1910.134 so that the employee will be familiar with the basic respirator use procedures.
Keep a record of employee training
- Keep a record of training activities utilizing the Respirator
Assignment and Training Record. Respirator assignment
and training activities are recorded on the same form
because the best time to provide training is when the
respirator is first given to an employee.
- Follow up and evaluate your training program to make
sure employees know how to use and maintain their respirators.
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Voluntary Training Guidelines
- Introduction
The Occupational Safety and Health Act of 1970 does not
address specifically the responsibility of employers to
provide health and safety information and instruction
to employees, although Section 5(a)(2) does require that
each employer "... shall comply with occupational safety
and health standards promulgated under this Act." However,
more than 100 of the Act's current standards do contain
training requirements.
Therefore, the Occupational Safety and Health Administration
has developed voluntary training guidelines to assist
employers in providing the safety and health information
and instruction needed for their employees to work at
minimal risk to themselves, to fellow employees and to
the public.
The guidelines are designed to help employers to (1)
determine whether a worksite problem can be solved by
training; (2) determine what training, if any, is needed;
(3) identify goals and objectives for the training; (4)
design learning activities; (5) conduct training; (6)
determine the effectiveness of the training; and (7) revise
the training program based on feedback from employees,
supervisors and others.
The development of the guidelines is part of an agency-wide
objective to encourage cooperative voluntary safety and
health activities among OSHA, the business community and
workers. These voluntary programs include training and
education, consultation, voluntary protection programs
and abatement assistance.
- Training model
The guidelines provide employers with a model for
designing, conducting, evaluating and revising training
programs. The training model can be used to develop
programs for a variety of occupational safety and
health hazards identified at the workplace. Additionally,
it can assist employers in their efforts to meet the
training requirements in current or future occupational
safety and health standards.
A training program designed in accordance with these
guidelines can be used to supplement and enhance the
employer's other education and training activities.
The guidelines afford employers significant flexibility
in the selection and content and training program
design. OSHA encourages a personalized approach to
the informational and instructional programs at individual
worksites, thereby enabling employers to provide the
training that is most needed and applicable to local
working conditions.
Assistance with training programs or the identification
of resources for training is available through such
organizations as OSHA full-service area offices, state
agencies which have their own OSHA-approved occupational
safety and health programs for employers, local safety
councils, the OSHA Office of Training and Education
and OSHA-funded New Directions grantees.
- Review Commission implications
OSHA does not intend to make the guidelines mandatory.
And they should not be used by employers as a total
or complete guide in training and education matters
which can result in enforcement proceedings before
the Occupational Safety and Health Review Commission.
However, employee training programs are always an
issue in Review Commission cases which involve alleged
violations of training requirements contained in OSHA
standards.
The adequacy of employee training may also become
an issue in contested cases where the affirmative
defense of unpreventable employee misconduct is raised.
Under case law well-established in the Commission
and the courts, an employer may successfully defend
against an otherwise valid citation by demonstrating
that all feasible steps were taken to avoid the occurrence
of the hazard, and that actions of the employee involved
in the violation were a departure from a uniformly
and effectively enforced work rule of which the employee
had either actual or constructive knowledge.
In either type of case, the adequacy of the training
given to employees in connection with a specific hazard
is a factual matter which can be decided only by considering
all the facts and circumstances surrounding the alleged
violation. The general guidelines presented here are
not intended, and cannot be used, as evidence of the
appropriate level of training in litigation involving
either the training requirements of OSHA standards
or affirmative defenses based upon employer training
programs.
- Training guidelines
OSHA's training guidelines follow a model that consists
of:
- Determining if training is needed
- Identifying training needs
- Identifying goals and objectives
- Developing learning activities
- Conducting the training
- Evaluating program effectiveness
- Improving the program
The model is designed to be one that even the owner of
a business with very few employees can use without having
to hire a professional trainer or purchase expensive training
materials. Using this model, employers or supervisors
can develop and administer safety and health training
programs that address problems specific to their own business,
fulfill the learning needs of their own employees and
strengthen the overall safety and health program of the
workplace.
- Determining if training
is needed
The first step in the training process is a basic
one: to determine whether a problem can be solved
by training. Whenever employees are not performing
their jobs properly, it is often assumed that training
will bring them up to standard. However, it is possible
that other actions (such as hazard abatement or the
implementation of engineering controls) would enable
employees to perform their jobs properly.
Ideally, safety and health training should be provided
before problems or accidents occur. This training
would cover both general safety and health rules and
work procedures, and would be repeated if an accident
or near-miss incident occurred.
Problems that can be addressed effectively by training
include those that arise from lack of knowledge of
a work process, unfamiliarity with equipment or incorrect
execution of a task. Training is less effective (but
still can be used) for problems arising from an employee's
lack of motivation or lack of attention to the job.
Whatever its purpose, training is most effective when
designed in relation to the goals of the employer's
total safety and health program.
- Identifying training needs
If the problem is one that can be solved, in whole
or in part, by training, then the next step is to
determine what training is needed. For this, it is
necessary to identify what the employee is expected
to do and in what ways, if any, the employee's performance
is deficient. This information can be obtained by
conducting a job analysis which pinpoints what an
employee needs to know in order to perform a job.
When designing a new training program,
or preparing to instruct an employee in an unfamiliar
procedure or system, a job analysis can be developed
by examining engineering data on new equipment or
the safety data sheets on unfamiliar substances. The
content of the specific federal or state OSHA standards
applicable to a business can also provide direction
in developing training content. Another option is
to conduct a Job Hazard Analysis (see OSHA 3071, same
title, 1987). This is a procedure for studying and
recording each step of a job, identifying existing
or potential hazards and determining the best way
to perform the job in order to reduce or eliminate
the risks. Information obtained from a Job Hazard
Analysis can be used as the content for the training
activity.
If an employee's learning needs can be met by revising
an existing training program rather than developing
a new one, or if the employee already has some knowledge
of the process or system to be used, appropriate training
content can be developed through such means as:
- Using company accident and injury records to identify
how accidents occur and what can be done to prevent
them from recurring.
- Requesting employees to provide, in writing and
in their own words, descriptions of their jobs.
These should include the tasks performed and the
tools, materials and equipment used.
- Observing employees at the worksite as they perform
tasks, asking about the work and recording their
answers.
- Examining similar training programs offered by
other companies in the same industry, or obtaining
suggestions from such organizations as the National
Safety Council (which can provide information on
Job Hazard Analysis), the Bureau of Labor Statistics,
OSHA-approved state programs, OSHA full-service
area offices, OSHA-funded state consultative programs
or the OSHA Office of Training and Education.
The employees themselves can provide valuable information
on the training they need. Safety and health hazards
can be identified through the employees' responses
to such questions as whether anything about their
jobs frightens them, if they have had any near-miss
incidents, if they feel they are taking risks or if
they believe that their jobs involve hazardous operations
or substances.
Once the kind of training that is needed has been
determined, it is equally important to determine what
kind of training is not needed. Employees should be
made aware of all the steps involved in a task or
procedure, but training should focus on those steps
in which improved performance is needed. This avoids
unnecessary training and tailors the training to meet
the needs of the employees.
- Identifying goals and objectives
Once the employees'
training needs have been identified, employers can then
prepare objectives for the training. Instructional objectives,
if clearly stated, will tell employers what they want
their employees to do, to do better, to stop doing.
Learning objectives do not necessarily have to be
written, but in order for the training to be as successful
as possible, clear and measurable objectives should
be thought-out before the training begins. For an
objective to be effective it should identify as precisely
as possible what the individuals will do to demonstrate
what they have learned, or that the objective has
been reached. They should also describe the important
conditions under which the individual will demonstrate
competence and define what constitutes acceptable
performance.
Using specific, action-oriented language, the instructional
objectives should describe the preferred practice
or skill and its observable behavior. For example,
rather than using the statement: "The employee will
understand how to use a respirator" as an instructional
objective, it would be better to say: "The employee
will be able to describe how a respirator works and
when it should be used." Objectives are most effective
when worded in sufficient detail that other qualified
persons can recognize when the desired behavior is
exhibited.
- Developing learning activities
Once employers have stated precisely what the objectives
for the training program are, then learning activities
can be identified and described. Learning activities
enable employees to demonstrate that they have acquired
the desired skills and knowledge. To ensure that employees
transfer the skills or knowledge from the learning
activity to the job, the learning situation should
simulate the actual job as closely as possible. Thus,
employers may want to arrange the objectives and activities
in a sequence which corresponds to the order in which
the tasks are to be performed on the job, if a specific
process is to be learned. For instance, if an employee
must learn the beginning processes of using a machine,
the sequence might be (1) to check that the power
source is connected, (2) to ensure that the safety
devices are in place and are operative, (3) to know
when and how to throw the switch, and so on.
A few factors will help to determine the type of
learning activity to be incorporated into the training.
One aspect is the training resources available to
the employer. Can a group training program that uses
an outside trainer and film be organized, or should
the employer personally train the employees on a one-to-one
basis? Another factor is the kind of skills or knowledge
to be learned. Is the learning oriented toward physical
skills (such as the use of special tools) or toward
mental processes and attitudes? Such factors will
influence the type of learning activity designed by
employers. The training activity can be group-oriented
with lectures, role play and demonstrations, or designed
for the individual as with self-paced instruction.
The determination of methods and materials for the
learning activity can be as varied as the employer's
imagination and available resources will allow. The
employer may want to use charts, diagrams, manuals,
slides, films, viewgraphs (overhead transparencies),
videotapes, audio tapes, or simply blackboard and
chalk or any combination of these and other instructional
aids. Whatever the method of instruction, the learning
activities should be developed in such a way that
the employees can clearly demonstrate that they have
acquired the desired skills or knowledge.
- Conducting the training
With the completion of the steps outlined above,
the employer is ready to begin conducting the training.
To the extent possible, the training should be presented
so that its organization and meaning are clear to
the employees. To do so, employers or supervisors
should (1) provide overviews of the material to be
learned; (2) relate, wherever possible, the new information
or skills to the employee's goals, interests, or experience;
and (3) reinforce what the employees learned by summarizing
the program's objectives and the key points of information
covered. These steps will assist employers in presenting
the training in a clear, unambiguous manner.
In addition to organizing the content, employers
must also develop the structure and format of the
training. The content developed for the program, the
nature of the workplace or other training site and
the resources available for training will help employers
determine for themselves the frequency of training
activities, the length of the sessions, the instructional
techniques and the individual(s) best qualified to
present the information.
In order to be motivated to pay attention and learn
the material that the employer or supervisor is presenting,
employees must be convinced of the importance and
relevance of the material. Among the ways of developing
motivation are (1) explaining the goals and objectives
of instruction; (2) relating the training to the interests,
skills and experiences of the employees; (3) outlining
the main points to be presented during the training
session(s); and (4) pointing out the benefits of training
(e.g., the employee will be better informed, more
skilled and thus more valuable both on the job and
on the labor market; or the employee will, if he or
she applies the skills and knowledge learned, be able
to work at reduced risk).
An effective training program allows employees to
participate in the training process and to practice
their skills or knowledge. This will help to ensure
that they are learning the required knowledge or skills
and permit correction if necessary. Employees can
become involved in the training process by participating
in discussions, asking questions, contributing their
knowledge and expertise, learning through hands-on
experiences and through role-playing exercises.
- Evaluating program effectiveness
To make sure that the training program is accomplishing
its goals, an evaluation of the training can be valuable.
Training should have, as one of its critical components,
a method of measuring the effectiveness of the training.
A plan for evaluating the training session(s) should
be developed when the course objectives and content
are developed. It should not be delayed until the
training has been completed. Evaluation will help
employers or supervisors determine the amount of learning
achieved and whether an employee's performance has
improved on the job. Among the methods of evaluating
training are:
- Student opinion. Questionnaires or informal discussions
with employees can help employers determine the
relevance and appropriateness of the training program.
- Supervisors' observations. Supervisors are in
good positions to observe an employee's performance
both before and after the training and note improvements
or changes.
- Workplace improvements. The ultimate success of
a training program may be changes throughout the
workplace that result in reduced injury or accident
rates.
However it is conducted, an evaluation of training
can give employers the information necessary to decide
whether or not the employees achieved the desired
results, and whether the training session should be
offered again at some future date.
- Improving the program
If, after evaluation it is clear that the training
did not give the employees the level of knowledge
and skill that was expected, then it may be necessary
to revise the training program or provide periodic
retraining. At this point, asking questions of employees
and of those who conducted the training may be of
some help. Among the questions that could be asked
are
- Were parts of the content already known and, therefore,
unnecessary?
- What material was confusing or distracting?
- Was anything missing from the program?
- What did the employees learn and what did they
fail to learn?
It may be necessary to repeat steps in the training
process, that is, to return to the first steps and
retrace one's way through the training process. As
the program is evaluated, the employer should ask
- If a job analysis was conducted, was it accurate?
- Was any critical feature of the job overlooked?
- Were the important gaps in knowledge and skill
included?
- Was material already known by the employees intentionally
omitted?
- Were the instructional objectives presented clearly
and concretely?
- Did the objectives state the level of acceptable
performance that was expected of employees?
- Did the learning activity simulate the actual
job?
- Was the learning activity appropriate for the
kinds of knowledge and skills required on the job?
- When the training was presented, was the organization
of the material and its meanings made clear?
- Were the employees motivated to learn?
- Were the employees allowed to participate actively
in the training process?
- Was the employer's evaluation of the program thorough?
A critical examination of the steps in the training
process will help employers to determine where course
revision is necessary.
- Matching training to employees
While all employees are entitled to know as much as possible
about the safety and health hazards to which they are
exposed, and employers should attempt to provide all relevant
information and instruction to all employees, the resources
for such an effort frequently are not, or are not believed
to be, available. Thus, employers are often faced with
the problem of deciding who is in the greatest need of
information and instruction.
One way to differentiate between employees who have priority
needs for training and those who do not is to identify
employee populations which are at higher levels of risk.
The nature of the work will provide an indication that
such groups should receive priority for information on
occupational safety and health risks.
- Identifying employees at risk
One method of identifying employee populations at
high levels of occupational risk (and thus in greater
need of safety and health training) is to pinpoint
hazardous occupations. Even within industries which
are hazardous in general, there are some employees
who operate at greater risk than others. In other
cases the hazardousness of an occupation is influenced
by the conditions under which it is performed, such
as noise, heat or cold, or safety or health hazards
in the surrounding area. In these situations, employees
should be trained not only on how to perform their
job safely but also on how to operate within a hazardous
environment.
A second method of identifying employee populations
at high levels of risk is to examine the incidence
of accidents and injuries, both within the company
and within the industry. If employees in certain occupational
categories are experiencing higher accident and injury
rates than other employees, training may be one way
to reduce that rate. In addition, thorough accident
investigation can identify not only specific employees
who could benefit from training but also identify
companywide training needs.
Research has identified the following variables as
being related to a disproportionate share of injuries
and illnesses at the worksite on the part of employees:
- The age of the employee (younger employees have
higher incidence rates).
- The length of time on the job (new employees have
higher incidence rates).
- The size of the firm (in general terms, medium-sized
firms have higher incidence rates than smaller or
larger firms).
- The type of work performed (incidence and severity
rates vary significantly by Standard Industrial
Classification, or SIC Code).
- The use of hazardous substances (by SIC Code).
These variables should be considered when identifying
employee groups for training in occupational safety
and health.
In summary, information is readily available to help
employers identify which employees should receive
safety and health information, education and training,
and who should receive it before others. Employers
can request assistance in obtaining information by
contacting such organizations as OSHA area offices,
the Bureau of Labor Statistics, OSHA-approved state
programs, state on-site consultation programs, the
OSHA Office of Training and Education or local safety
councils.
- Training employees at risk
Determining the content of training for employee
populations at higher levels of risk is similar to
determining what any employee needs to know, but more
emphasis is placed on the requirements of the job
and the possibility of injury. One useful tool for
determining training content from job requirements
is the Job Hazard Analysis described earlier. This
procedure examines each step of a job, identifies
existing or potential hazards, and determines the
best way to perform the job in order to reduce or
eliminate the hazards.
Its key elements are:
- job description
- job location
- key steps (preferably in the order in which they
are performed)
- tools, machines and materials used (5) actual
and potential safety and health hazards associated
with these key job steps
- safe and healthful practices, apparel and equipment
required for each job step
- Conclusion
In an attempt to assist employers with their occupational
health and safety training activities, OSHA has developed
a set of training guidelines in the form of a model. This
model is designed to help employers develop instructional
programs as part of their total education and training
effort. The model addresses the questions of who should
be trained, on what topics and for what purposes. It also
helps employers determine how effective the program has
been and enables them to identify employees who are in
the greatest need of education and training. The model
is general enough to be used in any area of occupational
safety and health training, and allows employers to determine
for themselves the content and format of training. Use
of this model in training activities is just one of many
ways that employers can comply with the OSHA standards
that relate to training and enhance the safety and health
of their employees.
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Respirator Training Program Checklist
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