|Steps for Establishing a Respiratory Program|
Steps for Establishing a Respiratory Program
The purpose of a respiratory program is to ensure that all employees are properly protected from respiratory hazards. Creating and maintaining an individualized written respiratory program is the responsibility of all employers who provide respirators to their employees, according to 29 Code of Regulations (CFR) 1910.134. All respirators must be approved by the National Institute of Occupational Safety and Health (NIOSH), and the Mine Safety and Health Administration (MSHA).
29 CFR 1910.134(c) states that proper selection of respirators shall be made according to the guidance of American National Standard Practices for Respiratory Protection Z88.2. Minimum respiratory requirements for all contaminants can be found in 29 CFR 1910.134, and in separate sections for specific contaminants (for example, CFR 1910.1001 for asbestos, CFR 1910.1025 for lead, etc.). The employer will also need to read and comply with all federal, state and local regulations dealing with respiratory protection.
Before beginning a respiratory program, the employer will need to evaluate the workplace contaminants that are present. Air contaminants can include harmful dusts, fogs, fumes, mists, gases, smoke, sprays or vapors. Consult an industrial hygienist to evaluate work area exposure levels. Respirators are to be used only where engineering control of respiratory hazards are not feasible, while controls are being installed or in emergencies. The eleven requirements of an effective respiratory program are detailed in 29 CFR 1910.134(b). Following is an overview of each.
Step 1. "Written standard operating procedures governing the selection and use of respirators shall be established," 29 CFR 1910.134(b)(1). The main focus of your written respirator program is to define the operational guidelines for those who need to wear respiratory equipment. The program should outline all aspects of the respiratory hazards and respirator usage at your workplace. This program determines policies, procedures and record keeping for your company. All employees faced with respiratory hazards should be familiarized with the standard operating procedures of your respiratory program.
Step 2. "Respirators shall be selected on the basis of hazards to which the worker is exposed," 29 CFR 1910.134(b)(2). To determine the type of respirator the worker will use, first determine the concentration of the contaminant. If your concentration exceeds the permissible exposure limit (PEL) set up by OSHA, you will need to reduce your worker's exposure. (PELs are an 8-hour time-weighted average for a 40-hour workweek.)
The two basic types of respirators-air-supplied and air purifying-provide two different levels of protection. Air-supplied respirators include an air line or self-contained breathing apparatus (SCBA) to supply breathable air independent of ambient air. Air-purifying respirators include filters, chemical cartridges or canisters for the removal of air contaminants. The concentration of the air contaminants can be established by different methods of air monitoring, dependent upon whether the contaminants are gases, vapors, dusts or mists. Once this is determined, the three other factors that need to be considered are: length of time workers are exposed; how well the area is ventilated; and if it is an open area or confined space.
Step 3. "The user shall be instructed and trained in the proper use of respirators and their limitations," 29 CFR 1910.134(b)(3). When using a respirator, the wearer should know about the various types available and the conditions under which they should be used. Respirator instructions and cautions should be adhered to so the user can get the proper protection. According to ANSI Z88.2-1980, the supervisor, the issuer of the respirator and the wearer should be trained on proper usage by a qualified person. Wearers should be retrained at least annually on wearing a respirator and updated on your current respirator program.
Step 4. "Respirators should be assigned to individuals," (OSHA recommendation only but a policy strongly encouraged at ARS). Once the proper type of respirator has been chosen, assignment of respirators can take place. It is best to give each respirator user their own respirator which is permanently marked. Record this information in the respiratory program and have it initialed by both the giver and wearer. When choosing the respirator, the user should try on and fit test several sizes (29 CFR 1910.1001 Appendix C) to get the best fitting mask.
Step 5. "Respirators shall be regularly cleaned and disinfected. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use," 29 CFR 1910.134(b)(5). Respirators should be disassembled and washed in warm soapy water (or follow the manufacturers recommendations). The respirator parts should then be rinsed and air-dried. This should be done after each use or on a daily basis.
Step 6. "Respirators should be stored in a convenient, clean, and sanitary location," 29 CFR 1910.134(b)(6). Respirators should be protected from dust, sunlight, cold, heat and excessive moisture. A reusable storage bag or a clearly marked cabinet or container will sufficiently protect them.
Step 7. "Respirators used routinely shall be inspected during cleaning.
Worn or deteriorated parts shall be replaced. Respirators for emergency use, such as self-contained breathing devices, shall be thoroughly inspected at least once a month and after each use," 29 CFR 134(b)(7). Respirators should be cleaned after each use according to the manufacturers instructions. During cleaning, check for damaged or defective parts such as broken straps, ripped valves, or deformed sealing surfaces. Replace parts before an employee uses a respirator in a hazardous environment. Keep a record of all cleaning and maintenance.
Step 8. "Appropriate surveillance of work area conditions and degrees of employee exposure or stress shall be maintained," 29 CFR 1910.134(b)(8). A responsible manager or supervisory leader should continually schedule checks and monitor respiratory exposure levels in the workplace. Any changes in workplace conditions may also involve a change in respirator selection.
Step 9. "There shall be regular inspections and evaluations to determine the continued effectiveness of the program," 29 CFR 1910.134(b)(9). To ensure employee protection, the respiratory program should be evaluated annually or any time a work process changes. Things to look for are proper respiratory protection, comfort, communication problems, interference with work, acceptance and employee or management opinions.
Step 10. "Persons should not be assigned to tasks requiring use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent. The respirator user's medical status should be reviewed periodically (for instance, annually)," 29 CFR 1910.134(b)(10). Before wearing any type respirator, each employee must be pronounced physically able to use respiratory equipment by a local physician. A history of respiratory disease such as asthma or emphysema may exclude a wearer, which means they cannot be allowed to work in areas that require respirator protection. Keep the medical evaluation form signed by the doctor, employee and manager on file.
Step 1 1. "Approved or accepted respirators shall be used when they are available," 29 CFR 1910.134(b)(I 1). All respirators purchased should be labeled with the NIOSH/MSHA approval and the proper TC (Tested and Certified) numbers.
Fit testing and fit checks are also a necessary part of respiratory protection. Use these handouts in association with the respiratory protection policy of your location and the Fit testing SOP (handout # 2).
These Q/A are excerpt from BNA safety newsletters, CHEM and lab Safety Supply.
Commonly Asked Questions
Q. Can I use canisters or respirator parts to repair my respirator from another manufacturer?
A. No-doing so will void all NIOSH/MSHA approvals, may void your warranty and put your at risk of exposure.
Q. Do I need a respiratory program if I only have employees using disposable dustlmist respirators?
A. Yes-all respirators require a written program.
Q. If I am not required to use a respirator, but wear one as a precaution, do I still need an annual medical evaluation?
A. Yes, a medical evaluation is needed whenever a respirator is worn.
Q. What is IDLH?
A. IDLH is the concentration at which the contaminant is Immediately Dangerous to Life and Health. If the concentration meets or exceeds the IDLH, a Pressure Demand Self-Contained Breathing Apparatus (SCBA) or Air-line Respirator with escape should be selected.
Sources for More Information
American National Standards Institute 1 1 W. 42nd St.
New York, NY 10036
National Institute for Occupational Safety and Health 4676 Columbia Pkwy.
Rockville, MD 20852