Assessing Your Respiratory Program

How good is it? The answer could mean the difference between life and death.

• By Ken Vaughan
• May 01, 2004

ASSESSING your company's respiratory protection program is serious business. In some instances, it may mean the difference between life and death. As the owner or manager of a company, you probably implemented a plan after consulting OSHA/NIOSH standards for your industry. But no two workplaces are the same; hence, no two respiratory protection programs should be alike.

Whether you are a billion-dollar chemical giant or a four-person autobody shop, employees' well-being should be your foremost reason for implementing a well-thought-out respiratory protection program.

A safe workplace is one where employees do not get sick, do not get injured, and do not die. Company health and safety policies must be in alignment with OSHA standards and workplace practices, training programs, actual company conditions and experiences, and industry best practices. Concerns about liability and public perception follow, but they need only be a cause for concern when internal practices are compromised and become ineffective.

Determining Risk
Regardless of the size and nature of your business or its annual revenues, an effective respiratory protection program reflects a company's leadership and management team's understanding of the degree and type of risk to which their employees may be subjected. Keen awareness of these factors is critical because effective respiratory protection is specific to the contaminant and the environment in which employees are exposed.

Broad OSHA standards require that the workplace be safe, and that employers ensure the safety of their workers at the workplace. Specific OSHA and state health and safety guidelines have been established for some traditional high-profile industries and applications. For example, in heavy industry where substances such as lead and asbestos are encountered, OSHA provides detailed and specific rules for respiratory protection against these dangerous materials. In these areas, federal standards are by and large synonymous with industry best practices because enforcement is aggressive and failure to conform can cause injuries and deaths, destroying lives as well as corporate reputations.

Ironically, the urgent need for a sound respiratory protection program is sometimes greatest in small employment situations--the four-man team or small business shops--where awareness relevant to risk may be less than in large, structured companies. A concerted effort needs to be made to break comfortable but bad habits. Industries in which this scenario may be found include farming, auto body repair, air conditioning and heating, painting services, even health care.

Surprisingly, health care workers--especially emergency services workers--may be particularly vulnerable to risk because they may be exposed to infection and contamination without knowing that the hazard exists. Because health care workers look after those of us who are sick and injured, their professional dedication puts them at risk in unknown and emergency situations. Respiratory protection for health care workers is an area of increasing concern. The risk of being exposed to patients with infectious diseases such as SARS and the risk of being challenged to care for victims of terrorist attacks are ever-present. Health care workers deserve the highest level of respiratory protection.

The Value of a Program Administrator
Once risk has been identified, a respiratory protection plan must be put into effect and an administrator appointed to oversee adherence to recommended OSHA standards of practice, as well as state and industry best practices. Such action is critical if your company is involved in workplace activity categorized as Immediately Dangerous to Life and Health (IDLH).

In any case, the role of the administrator should always exceed that of paper trail manager. OSHA requires that an administrator be a qualified and conscientious person. Corporate operations demand an industrial hygiene or safety specialist, a manager with certification and higher education credentialing in safety management. In smaller companies, the program administrator is often a responsible and highly motivated member of the management team without formal training. This member of the team is frequently trained by independent specialists or by the respirator manufacturer--an attractive partnership because respirator manufacturers have a vested interest in securing the safety of their customers.

Once an administrator has been selected, a program must be put in place that reflects close examination of site-specific needs, company accident record, employee complaints, and specific health concerns, as well as standards for OSHA and state compliance. Maintaining consistent and documented enforcement of the program is critical to safeguarding employees. Compliance bears a close relationship to collective awareness and individualized training: Appoint an administrator who can teach and motivate your staff. Educating those who will benefit most from respiratory protection should be your number one priority.

Selecting Appropriate Protection
Having determined risk, the program administrator must choose appropriate respiratory protection. Workplace environments are unique. It's not enough to review the OSHA guidelines and select protection based on generic guidelines.

Consider the following before you select respiratory protection for your business:

• Call in an expert to sample the air at your plant or shop. Analyzing an air sample will identify contaminants in the atmosphere.
• Measure or calculate the concentration levels of the identified contaminants.
• Consult OSHA, NIOSH, or ACGIH standards, determine permissible exposure levels for your hazard and industry.
• Check to see whether a specific OSHA standard regulates the hazard identified. If there is, refer to the standard for instructions on how to select the correct type of respirator.
• Calculate the hazard ratio by dividing the measured concentration level by the permissible exposure limit.

With this baseline information, you are ready to make appropriate choices. Ask the respirator manufacturer to assist you, and don't overlook several other factors important to your program's success before you make your final selection. These factors include:

• The nature of the processes involved.
• The location of the hazardous area.
• The duration of time the protection must be worn.
• The activities of the workers in the area.
• The physical characteristics and capabilities of the respirators and the comprehensive goals of the respiratory protection program.

Re-Evaluation
The paper trail serves a purpose, and meticulous records should be kept for two reasons: one, to demonstrate to OSHA regulators that compliance has been met; and two, to allow for regular, periodic internal checks to monitor accident reports and the physical and emotional well-being of employees. In the case of the latter, here is an opportunity as an employer or manager to determine where your program has weaknesses.

You may be surprised to learn that safety is being compromised because several employees need to be encouraged to break old habits and wear protection while they're refinishing cars or fertilizing crops, something they never did before--or, based on regular medical profiling, that certain employees need greater protection than others because of specific health conditions.

No matter how conscientious your intentions, the program you implement is only as effective as your understanding of what constitutes comprehensive protection. Learning everything you can to keep your employees safe is tantamount to program success. Arming employees with the same knowledge provides incentive for their full participation in a protection program that will safeguard their health.

Present training as an adult activity that deserves their respect. Remember: Employees who fully understand the risk involved in the job they do are employees more likely to take the training program seriously and comply with workplace safety practices, hence fewer accidents, better overall work environment, and a solid company profile. The basic goal of an effective respiratory protection program is keeping workers alive and well.

This article originally appeared in the May 2004 issue of Occupational Health & Safety.