PPE and Respiratory Compliance

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Ed Keating Robert L. Brady, JD David L. Galt Ana Ellington Isabelle B. Smith Vincent Skyers Sheryl Boutin

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TABLE OF CONTENTS
PPE and Respiratory Protection Compliance ................................................................................1 OSHA respiratory protection rules ................................................................................................1 Exposure hazard assessment ..........................................................................................................3 5 best practices to effective respiratory protection ......................................................................7

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PPE and Respiratory Protection Compliance

ccupational diseases and even death can be caused by air contaminants or oxygen deficiency in work areas. Employers must provide respirators and training to each employee who is or may be exposed to air contaminants or oxygen-deficient atmospheres when engineering and administrative controls cannot feasibly or effectively reduce exposures to safe levels. Workplaces with respirators must establish a written respiratory protection program that includes respirator selection criteria, employee training, medical evaluations, and fit-testing procedures. If employees of a small business are exposed to only nuisance dusts and relatively nontoxic chemicals and use only a few types of relatively simple respirators, knowledge of the guide and materials supplied by the respirator manufacturer may be sufficient for the small-business owner or an employee to become qualified to administer a respiratory protection program. If more dangerous chemicals, high levels of exposure, or dangerous atmospheres are present and sophisticated respirators are used, the respiratory protection program will be more formal and comprehensive. In these circumstances, it may be necessary for the program administrator to seek out the expertise needed or to obtain appropriate training.

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OSHA respiratory protection rules

In order to control or eliminate workplace breathing hazards, the Occupational Safety and Health Administration (OSHA) has adopted a respiratory protection standard for general industry and construction workplaces at 29 CFR 1910.134 (29 CFR 1926.103 adopts 1910.134 for construction) and related rules for specific air contaminants. All mandatory respirator use is covered by the respiratory protection standard. The rule also deals with respirators in immediately dangerous to life or health (IDLH) atmospheres, including fire fighting. It covers respiratory protection criteria for substances that are dangerous when inhaled (e.g., asbestos, lead, benzene) as well as processes and activities related to airborne hazards (e.g., ventilation, fire fighting, and welding). OSHA estimates that its respiratory protection

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standard could save as many as 900 lives and prevent more than 4,000 injuries and illnesses every year. Other OSHA general industry rules that include respiratory protection requirements for special site conditions include: Dipping and coating operations at 29 CFR 1910.124 HAZWOPER at 29 CFR 1910.120 Laboratories at 29 CFR 1910.1450 Permit-required confined spaces at 29 CFR 1910.146 Pulp, paper, and paperboard mills at 29 CFR 1910.261 Ventilation at 29 CFR 1910.94
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Toxic and hazardous substances and air contaminants with permissible exposure limits (e.g., asbestos, lead, cadmium, benzene) at 29 CFR 1910.1000 to 1910.1052 Welding, cutting, and brazing at 29 CFR 1910.252 to 1910.255

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Role of other federal agencies

National Institute for Occupational Safety and Health (NIOSH) certifies respirator cartridges. All respirators must be certified by NIOSH and must be used in accordance with the terms of that certification. Also, all filters, cartridges, and canisters must be labeled with the appropriate NIOSH approval. The label must not be removed or defaced while it is in use. As required by NIOSH approval, employees must use only filters and cartridges made by the manufacturer of the respirator face piece. The filters of one manufacturer must not be used on the face piece made by another manufacturer. EPA pesticide protection requirements. The U.S. Environmental Protection Agency (EPA) regulations require workers to wear respirators in restricted-entry areas that have been treated with pesticides. There are no additional respiratory protection requirements under EPA rules; all employers must comply with OSHA requirements.

The basic elements of an OSHA-compliant respiratory protection program

OSHAs respiratory protection regulation applies to virtually any situation that requires respirator use in any industry except agriculture. In summary, the regulation requires: Assessment of exposure hazards A written respiratory protection program with worksitespecific procedures

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 Selection criteria for appropriate respirators certified by NIOSH and matched to the identified respiratory hazards in that workplace Medical evaluation of each employee by confidential questionnaire or exam before being assigned to wear a respirator Respirator fit testing for each employee assigned to wear a respirator with a negative- or positive-pressure tight-fitting face piece Training employees on why and how to select, use, fit, maintain, and store respirators Recordkeeping Periodic evaluation of the respiratory protection programs elements to be sure they are protecting employees
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Exposure hazard assessment

To determine if air contaminants or oxygen-deficient atmospheric hazards are present or are likely to be present that require the use of respirators, employers must identify and evaluate respiratory hazards, identify relevant workplace and user factors, and base respirator selection on these factors. The hazard evaluation must include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminants chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the atmosphere must be considered to be IDLH. Although the most reliable and accurate method to determine exposure is to conduct personal air monitoring, it is not explicitly required by the OSHA rule. Instead, other means can be used to estimate workplace exposures, including the use of objective data, application of mathematical approaches, and others.
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Written respiratory protection program

In any workplace in which a respirator is required, the employer must establish a written respiratory protection program with specific procedures for all sites covered by it. The program must be updated as necessary to reflect changes in conditions and must be administered by a trained administrator. An OSHA-compliant respiratory protection program must include written procedures for: 1. The specific workplace 2. Selecting respirators

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3. Medical evaluations of employees required to wear respirators 4. Fit testing 5. Routine and emergency respirator use 6. Schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and maintaining respirators 7. Ensuring adequate air quality for supplied-air respirators 8. Training in respiratory hazards and in proper use and maintenance of respirators 9. Program evaluation
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10. Ensuring that employees who voluntarily wear respirators (excluding filtering face pieces) comply with the medical evaluation and cleaning, storing, and maintenance requirements of the standard 11. Designating a program administrator who is qualified to administer the program

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12. Updating the written program as necessary to account for changes in the workplace affecting respirator use 13. Providing equipment, training, and medical evaluations at no cost to employees All required elements of the respiratory protection program must be in writing unless a particular element does not apply to your workplace. For example, if no employees volunteer to wear respirators, the program administrator does not need to develop procedures for that type of respirator use.

Respirator selection
As described in the Exposure hazard assessment section, the selection of appropriate respirators must be based on the exposure hazards and workplace and user factors identified in the assessment. The employer must select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user. NIOSH-certified or approved. All respirators must be certified by NIOSH and used in accordance with the terms of that certification. All filters, cartridges, and canisters must be labeled with the appropriate NIOSH approval. IDLH atmospheres. Atmosphere-supplying respirators must be used in oxygen-deficient atmospheres (where oxygen is less than 19.5 percent).

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Non-IDLH atmospheres. For non-IDLH atmospheres, select respirators: Certified by NIOSH Adequate to protect employee health and ensure compliance with all other OSHA requirements under routine and reasonably foreseeable emergency situations After considering the Maximum Use Concentrations (MUCs) in your workplace under which respirators are used According to the Assigned Protection Factor (APF) of the respirator That are appropriate for the chemical state and physical form of the contaminant Gases and vapors. For protection from gases and vapors, the employer must provide either an atmosphere-supplying respirator or an air-purifying respirator.
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APF
APFs are numbers that indicate the level of protection a respirator or class of respirators is expected to provide employees when used as part of a respiratory protection program. Employers must use the APF listed in Table 1 of the rule to select a respirator that meets or exceeds the required level of employee protection. When using a combination respirator (e.g., airline respirators with an air-purifying filter), employers must ensure that the APF is appropriate to the mode of operation in which the respirator is being used.

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Calculating MUC
Employers must select respirators according to a mathematical formula that uses a contaminants permissible exposure limit (PEL) and the MUC of the contaminant in which a particular type of respirator can be used. The MUC is generally determined by multiplying the respirators APF by the contaminants PEL. For example, when the hazardous substance is lead with a PEL of 50 micrograms per cubic meter (g/m3) and the respirator used by employees has an APF of 10, the calculated MUC is 500 g/m3, or 0.5 milligrams per cubic meter (mg/m3) (calculated 50 g/m3 x 10). If the level of contaminant is expected to exceed the MUC, the employer must choose a respirator with a higher APF.

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Medical evaluation
Employers must provide a medical evaluation to determine each employees ability to use a respirator before the employee is fit-tested or required to use the respirator in the workplace. Medical evaluations may be discontinued when the employee is no longer required to use a respirator. The medical evaluation is free to the employee, confidential, and performed at a time and place convenient to the employee. A physician or other licensed healthcare provider (PLHCP) either administers OSHAs Respirator Medical Evaluation Questionnaire (provided at 29 CFR 1910.134, Appendix C) or gives an exam that covers the same material in the questionnaire. The medical evaluation is not a full physical. It covers only health issues that could affect the employees ability to work safely while wearing a respirator

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Fit test
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Only employees who pass the medical evaluation can be fit-tested. The fit test must use the same respirator make, model, style, and size the employee will use on the job. The fit tests must follow the qualitative fit testing (QLFT) or quantitative fit testing (QNFT) procedures described in the appendix to OSHAs respiratory protection regulation. Voluntary use of respirators. If an employee chooses to wear a tightfitting face piece respirator (including a negative-pressure air-purifying respirator or a filtering face piece (dust mask)) in a worksite environment where such equipment is not necessary, the employer is not required to conduct fit testing.

Respirator use
Employers must establish and implement the following procedures for the proper use of respirators: Prohibit conditions that may result in face piece seal leakage, such as excessive facial hair. Prevent employees from removing respirators in hazardous environments. Take actions to ensure continued, effective respirator operation throughout the work shift. Establish procedures for the use of respirators in IDLH atmospheres or in interior, structural fire-fighting situations.

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Respirator inspection, maintenance, storage, and repair

Respirators used during routine work must be inspected before each use and during cleaning. Self-contained breathing apparatuses (SCBAs) must also be inspected monthly and air and oxygen cylinders maintained in a fully charged state. The employer must provide respirators that are clean, sanitary, and in good working order. The respirators must be cleaned and disinfected using the procedures in Appendix B-2 of the respiratory protection rule or procedures recommended by the respirator manufacturer if such procedures are of equivalent effectiveness. They must be cleaned and disinfected as often as necessary to keep them in a sanitary condition. Respirators must be stored in a way that will not deform the face piece or exhalation valve. In addition, storage must protect respirators from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals. Repairs or adjustments to respirators are to be made only by persons appropriately trained to perform such operations and must use only the respirator manufacturers NIOSH-approved parts designed for the respirator.

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IDLH procedures
OSHA requires that a worker in an IDLH atmosphere must wear the proper respirator and stay in visual, voice, or signal line contact with at least one employee outside that atmosphere. Anyone working in an IDLH atmosphere must be equipped with an SCBA or comparable respirator, retrieval or equivalent equipment, and the training to provide effective emergency rescue. Employees located outside IDLH atmospheres must be trained and equipped to provide effective emergency rescue.

Training
The employer must provide effective training to employees who are required to use respirators before the employee uses a respirator in the workplace. The training must be comprehensive, understandable, and recur at least annuallyand more often if necessary.

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All employees who may use respirators must be trained in their selection, use, inspection, cleaning, maintenance, and limitations. Training must be completed: Before employees are allowed to use a respirator When procedures or hazards change When the employer believes an employees understanding of respirators is inadequate Retraining must be administered annually and whenever there are changes in the workplace that render previous training obsolete, inadequacies in respirator users knowledge or use, and any situations that arise in which retraining appears necessary to ensure safe respirator use.

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Recordkeeping
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The employer must retain written records of medical evaluations, fit testing, and a copy of the current respirator program. Medical evaluation records must be kept according to the employee exposure and medical records rule (29 CFR 1910.1020). Recordkeeping requirements for training are not specified in the standard; however, training records such as training session sign-up sheets should be maintained for documentation of compliance with regulatory requirements. The employer must create and maintain a record of the QLFTs and QNFTs administered to an employee. Fit-test records must be retained for respirator users until the next fit test is administered.

5 best practices to effective respiratory protection

Following are tips for complying with OSHAs fourth most violated standard. Keep in mindRespirators should be used for protection only when engineering controls have been shown to be infeasible for the control of the hazard or during the interim period when engineering controls are being installed. 1. Develop and maintain an up-to-date, written respiratory protection program. One of the most common mistakes employers make is failing to have a written respiratory protection program. If your employees are exposed to airborne contaminants, its not enough to simply provide them with respirators. You must also have a written plan that lays out the details of a comprehensive respiratory protec-

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tion program. If you use a boilerplate or prewritten template, you must modify it to add the site-specific information about hazards, protective procedures, types of respirators and cartridges, and conditions of use. 2. Implement a respirator selection protocol and procedure. Another common mistake is using an inappropriate type of respirator for the conditions at a worksite. Employers must evaluate the respiratory hazards their workers are exposed to in order to make a proper respirator selection. In addition, respirators must be certified by NIOSH and used in accordance with NIOSH specifications. 3. Perform fit tests. Do your supervisors know a basic exercise sequence respirator users must follow to test the fit of their respirators? For qualitative tests and some quantitative tests, workers must perform a series of exercises to test respirator fit. The following sequence provides the basic descriptions for these exercises. Each exercise, except for the grimace, must be done for 1 minute. The grimace is for only 15 seconds. 1. The normal breathing exercise is done in a standing position and involves normal breaths. 2. The employee then takes slow, deep breaths. 3. The next exercise involves turning the head from side to side. The employee must hold the head at each extreme momentarily and inhale. 4. The worker then moves the head slowly up and down, inhaling in each position. 5. The fifth exercise requires the employee to talk out loud. Workers can read from a prepared text, count backward from 100, or anything else that will keep them talking continuously for 1 minute. 6. The next exercise, the grimace, applies only to quantitative tests, not qualitative tests. 7. The bend over exercise requires employees to bend at the waist as if trying to touch their toes. Jogging in place for 1 minute may be substituted in test environments such as shroud units that dont permit bending over. 8. Finally, the worker resumes normal breathing. 4. Conduct required medical evaluations. Not everyone is physically able to use a respirator. A medical evaluation is required before fit testing and respirator use. The initial evaluation is a questionnaire. All medical evaluations must be confidential. You may discuss your questionnaire with the licensed healthcare professional. Follow-up
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evaluations must be conducted if conditions of use or the users health change. 5. Train employees. To protect your investment, its also critical to train employees on using respirators properly. Employees should understand why respirator use is necessary, the limitations and capabilities of respirators, and the proper procedures for using, storing, cleaning, and handling respirators. Once employees have mastered this knowledge, theyll be fully equipped to protect themselves from the airborne hazards in your facility. Retrain employees in respirator use whenever:
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Changes in the workplace render previous training obsolete; Changes in the types of respirators to be used render previous training obsolete; or Inadequacies in an employees knowledge or use of assigned respirators indicate that the employee has not retained the requisite understanding or skill.

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Frequently asked questions

If my employee has a beard, does he have to shave it off Q. in order to use a respirator? The employer must not permit respirators with tight-fitting A. face pieces to be worn by employees who have facial hair that comes between the sealing surface of the face piece and the face or that interferes with valve function. Beard growth at points where the seal with the face and respirator occurs is a condition that has been shown by numerous studies to prevent a good face seal. Beards are permitted for voluntary use of respirators.

Q. Can we use QLFT for all types of respirators being used?

A. (air-supplying and powered air-purifying respirators). Your

QLFT may be used to fit test all positive-pressure respirators use of QLFT on negative-pressure air-purifying respirators is limited to those that must achieve a fit factor of 100 or less. Dividing the fit factor of 100 by a standard safety factor of 10 indicates that the negative-pressure air-purifying respirators that have successfully completed a qualitative fit test can be relied on to reduce a workers exposure by a protection factor of 10. The safety factor of 10 is used because protection factors that workers achieve at worksites tend to be much lower than the fit factors achieved during fit testing.

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Q. medical evaluation for respirator use? Yes. This may be a workable system where few employees are A. involved. The employer will have to contact the doctor or
healthcare professional and provide a copy of the OSHA respiratory protection standard and other required supplemental information, as well as updates when required. The employer has to pay for the evaluation. It is not acceptable for an employee to use their health insurance for this purpose, unless the employer pays 100 percent of the insurance premiums.

Can I send my employees to their own doctors for a

Q.

If your employees are using disposable respirator masks, do you have to comply with the respiratory standard? Nonvoluntary use of a filtering face piece (dust mask/disposestablish and implement a written respiratory protection program with worksite-specific procedures. The respiratory protection program must include the medical evaluation of employees. Fit testing is also required.

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A. able paper-type dust respirator) requires that the employer

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Q. to conduct fit test using kits that can be purchased or

does a third-party expert have to perform the test?

When providing respirators to employees, is it allowable

A.

OSHA does not specify who does the tests. The respiratory protection rule says, The employer shall ...which means it is up to the employer to determine who does the testing. Use whatever testing personnel and procedures that meet the requirements of the respiratory protection rule at 29 CFR 1910.134(f)(5), as follows: [T]he fit test shall be administered using an OSHA-accepted QLFT or QNFT protocol. The OSHAaccepted QLFT and QNFT protocols and procedures are contained in Appendix A.... For example, when conducting QLFT, make sure you have the personnel who are trained to do the following as described in Appendix A, Qualitative Fit Test (QLFT) Protocols: The employer shall ensure that persons administering QLFT are able to prepare test solutions, calibrate equipment and perform tests properly, recognize invalid tests, and ensure that test equipment is in proper working order.

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