How to Comply with Respiratory Protection Requirements

Date First Published on SafetySmart Compliance: March 3rd, 2012
Topics: Airborne Contaminants | PPE |

RESPIRATORY PROTECTION

If there are chemicals (gases or vapors) or particulates present in the air that are harmful to employees when inhaled, you must provide a barrier to them. As with the evaluation of noise levels, special monitoring equipment is needed to determine the level of airborne contamination and how it compares to established exposure levels.  As is also the case with noise levels, it is up to you to “prove the negative”—that the levels are not harmful. Unless you have documentation otherwise, you could be in violation of OSHA Standards.

There are many options for protecting employees from airborne contamination, from half mask air purifying respirators to a full face piece pressure demand Self Contained Breathing Apparatus. Each type of respirator applies to varying situations, has its own criteria for use, fit testing, donning, doffing and wearing.

In addition, OSHA requires a full written Respiratory Protection Program stipulating the conditions under which respirators will be used, procedures for medical surveillance and fit testing, training, and inspections. Without some professional background in the use of respirators and the regulatory Standards, outside assistance may be a good idea. Once again, technical representative from vendors, and your insurance carrier are good resources to start with.

OSHA

The OSHA requirements for respiratory protection are an example of where OSHA cross-references a standard. The General Industry requirements are found at 29 CFR 1910.134 and the Construction Industry requirements are found at 29 CFR 1926.103, which says the requirements are found at 29 CFR 1910.134.

Like the standards for hearing protection, requirements for respiratory protection are fairly complex and first require an employer to determine whether or not there are any work areas or tasks where employees are exposed above the Permissible Exposure Limit (PEL), the Action Limit (AL) or other exposure limits established by OSHA. These limits are found in numerous OSHA standards including those established for many airborne contaminants referenced at 29 CFR 1910.1000 as well as substance-specific standards which established limits for the particular substance. Examples of these include benzene, lead and asbestos.

It’s very important that you understand what the potential contaminants are in your workplace and conduct a thorough exposure assessment to see where your levels fall. Exposure assessments can be fairly complicated and technically difficult for most people to perform who do not have any training or background in the area. It is a good idea to seek outside assistance from someone who understands how to perform hazards assessments such as a Certified Industrial Hygienist.

Once you have completed your Exposure Assessment and after implementing all feasible engineering and administrative controls, your workers are still exposed above the appropriate limits, you must institute a written Respiratory Protection Program that has the following elements:

  • 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 on and removing them, any limitations on their use, and their maintenance; and
  • procedures for regularly evaluating the effectiveness of the program.

There are many different types of respirators available, but they all fall into one of two classifications: air-purifying (APR) and atmosphere-supplying (ASR). Within each major class are many variations and models to chose from and each of the major classes have pros and cons.

ASRs are designed for work in potential life threatening concentrations of toxic substances or oxygen deficient atmospheres, typically emergencies or for short duration, whereas APRs are designed to protect workers during day-to-day operations in concentrations that are fairly low, not likely to vary by much and have sufficient oxygen. They can be worn for longer periods of time and some workers may spend their whole shift in an APR.

ASRs and APRs all require regular inspections, cleaning and maintenance, but as would be expected these tasks are more complicated for ASRs.

Because of the complexity of using respirators in the workplace and the stringent requirements on when respirators are used, it is a good idea to seek outside assistance in getting your respirator program started. Once you have the basic program developed, you should be able to maintain it independently with limited assistance.

 
 
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