With the new year, now is a good time to reevaluate your respiratory program to ensure you’re OSHA compliant. OSHA’s standard on respiratory protection (1910.134) is one of the agency’s most frequently cited each fiscal year.
So, what do we need to know?
First, let’s start with what OSHA says regarding when and why we may need to wear respiratory protection: “Whenever there is a respiratory hazard, or potential for a respiratory hazard at a worksite, all employers are required to establish a written respiratory protection [program].”
A respiratory hazard can be identified in several ways. Most often, it’s through air monitoring in the potentially hazardous area to identify the contaminant present and its concentration. Hazard identifications can also be made simply by reviewing your Safety Data Sheet (Section 8) to see what the manufacturer’s recommendations are.
Once a hazard that warrants respiratory protection has been discovered, what’s next? OSHA lists the guidelines as to what’s required in a written respiratory program in Section 29 of 1910.134:
1. Respiratory selection
Understanding the contaminant and its concentration will be key. This will help you determine the appropriate assigned protection factor that fits your needs and what you can use, including air-purifying respirators, powered air-purifying respirators, etc.
2. Hazard identification/concentrations
Can be done with an industrial hygienist or by purchasing a device that will collect air samples within the work environment in question.
3. Maximum use concentrations
PEL (permissible exposure limit) x APF (assigned protection factor) = MUC (maximum use concentration)
4. Medical evaluations (Appendix C)
Can be completed through an online portal or by visiting a physician in person.
5. Initially, prior to issuing a respiratory and fit testing – Fit Testing (Appendix A)
Required initially and annually whenever there’s a change in respirator or facial features of the user.
6. Training and recordkeeping
7. Why, when, and where, as well as respirator limitations
8. Procedures for use, inspection, maintenance, cleaning, and storage
9. Proper care and use of respirators
10. Routine and emergency use
11. Depending on the type of respirators used
- Filter/cartridge change out schedule and disposal
- Breathing air quality
Implementing a respiratory protection program involves a lot of preparation, planning, and maintenance. Many resources are available that can help you establish a program or maintain your current program. First and foremost, OSHA and NIOSH have a wealth of knowledge on their websites. You can always rely on the expertise of the respiratory manufacturer of choice. The important part is to make sure you’re compliant and that your employees go home safely each day.
Voluntary Use of a Respirator
Even when respirators are not required to be worn in a work area to protect employees, they can provide additional comfort and protection for employees. If an employee desires to wear a respirator on a voluntary basis, this must be discussed with their supervisor and the supervisor should request assistance from the RPP (Respiratory Protection Program) Manager if needed to determine that there are no airborne hazards that would require the use of a respirator.
Additionally, the use of the respirator itself must not present a health hazard to the wearer. To ensure this, certain elements of the RPP may need to be implemented, which will vary based on the type of respirator desired to be worn.
A filtering facepiece respirator (dust mask) is the most common respirator chosen to be worn on a voluntary basis. It is strongly recommended to wear a NIOSH-approved filtering facepiece respirator (dust mask) which will be labeled with a series of required markings.
An “N95 respirator” is the most common particulate filtering facepiece respirator, which refers to the series (N; not resistant to oil) and the efficiency level (95; filters at least 95% of airborne particles). The performance of a dust mask which is not NIOSH-approved may vary, which is why they are not recommended for use, even on a voluntary basis.
If after a discussion with the supervisor and the RPP Manager (if needed) and voluntary use of a filtering facepiece respirator (dust mask) has been permitted, employees must review the information contained in Appendix D of 29 CFR 1910.134, (Mandatory) Information for Employees Using Respirators When Not Required Under the Standard.
It is important to note that surgical masks do not meet the definition of a respirator but may be considered for wear based upon a hazard analysis of the employee’s specific work environment. For instance, in the context of respiratory infection control, surgical masks may be worn to protect a user from splashes of large droplets of blood or body fluids, or by an infected person to trap large particles of body fluids expelled by the wearer.
Coincidentally, there are combination products that are NIOSH-approved respirators and have also been cleared by the Food and Drug Administration as a surgical mask. These products are respirators, and so Appendix D information shall be provided to the user prior to voluntary use.
Voluntary use of any other respirator besides a filtering facepiece (dust mask) (e.g., an elastomeric half-mask with cartridge filters, or a full-face respirator) will require additional program elements. Contact the RPP Manager for assistance in making voluntary respirator use decisions and completing relevant program element requirements associated with their use.
Spencer-SHE has been providing Safety, Health, and Environmental Compliance Guidance since 1980. Our team can evaluate hazards and respiratory protection needs particular to your work environment.
Contact us here to help you to develop and maintain a safe and healthy workforce.
Sources:
https://www.safetyandhealthmagazine.com/articles/24979-osha-compliance
https://www.osha.gov/respiratory-protection
https://ors.od.nih.gov/sr/dohs/safety/ppep/Pages/respiratory_protection.aspx