Is Your Respiratory Protection Program Administrator Qualified?

Date First Published on SafetySmart Compliance: July 16th, 2012
Topics: Airborne Contaminants | PPE |

Every year, Respiratory Protection is at or near the top of OSHA’s 10 most frequently cited standards. One reason so many employers get cited for respiratory protection violations is that they don’t have the right person running their Respiratory Protection Program (RPP). Here’s how to make sure you don’t fall into this trap.

OSHA Requirements for Respiratory Protection Program Administrators

The OSHA Respiratory Protection standard requires employers to ensure that workers exposed to dusts and other airborne contaminants use a respirator (Sec. 1910.134(a)(1)). And where respirators are required, employers must implement a written RPP setting out specific safety measures for respirator the workplace (Sec. 1910.134(c)).

The RPP must designate the person who administers the Program. And the administrator can’t be just anyone. The RPP be run by a “suitably trained program administrator.”

What Training Does Respiratory Protection Program Administrator Need?

The Standard doesn’t define what “suitably trained” means. But according to OSHA guidance, to be qualified as a program administrator the individual must have the training or experience necessary to carry out all aspects of the program, i.e., recognizing, evaluating and controlling the respiratory hazards at the particular workplace.

Exactly what training or experience is needed to do those things varies depending on the complexity of the RPP. So, for example, the administrator better know how to ensure safe use of air-supplying respirators if your RPP requires your workers to use them. Less extensive training is required where respirator use is limited to simple dust masks to protect against low toxic nuisance dusts.

How OSHA Enforces the Rules

The RPP administrator requirements aren’t just a formality. OSHA inspectors typically review the RPP and interview the administrator during the inspection.

Is Administrator Qualified: The first phase of the interview generally focuses on whether the administrator is qualified. Inspectors will quiz the administrator about the program to verify that they:

  1. Know all of the crucial details about the RPP and what it requires; and
  2. Are knowledgeable enough about respiratory protection to carry out his duties under the RPP.

Is Administrator Doing the Job: Next, inspectors will ask questions to ensure that administrators actually are doing what they’re supposed to do under the RPP. Typical duties of the RPP administrator include:

  • Periodically evaluating the RPP’s effectiveness;
  • Assessing the workplace for potential respiratory hazards;
  •  Determining safe levels of worker exposure to those hazards;
  • Selecting appropriate respirators to protect against those hazards;
  • Ensuring that workers required to use respirators undergo medical evaluation before fit testing;
  • Ensuring that all workers have undergone the necessary fit testing and received the appropriate training;
  • Making sure worker use respirators appropriately;
  • Making sure respirators are  properly cleaned, disinfected, stored, inspected, repaired, discarded and maintained; and
  • Verifying that supplied air respirators are supplied with air of adequate quality.