"I usually tell class participants that conditions have probably changed, processes have changed in five, ten, fifteen years, and you should constantly be sampling and updating your initial exposure assessment results."
- By Jerry Laws
- Jun 01, 2013
Something David C. Roskelley sees frequently when he teaches respiratory protection classes for the University of Utah Rocky Mountain Center for Occupational and Environmental Health is students who are following a predecessor's written plan but don't know whether the recommendations in it still apply at their workplaces.
Roskelley, MSPH, CIH, CSP, said he also finds many students haven't done fit testing or an exposure assessment and lack a written program entirely.
"I think that's one of the challenges in the health and safety field to begin with: A lot of times, the safety guy is the guy who showed up late to a meeting or drew the short straw. And the boss says, 'OK, you're the safety guy now.' And he was originally a heavy equipment operator," Roskelley said.
"Deficiencies are widespread, and there are many of them."
A Chicago native, Roskelley has a master's degree in public health with an emphasis in industrial hygiene from RMCOEH and teaches a variety of courses there as an adjunct faculty member. He is a director for the American Board of Industrial Hygiene and is the founding partner of R&R Environmental, Inc., an EHS consulting firm based in Sandy, Utah. He's been teaching respiratory protection courses for about 15 years, Roskelley said.
"I think one of the big deficiencies is having no written program," he said. "It's always interesting to meet people, and you see the wheels turning when I mention the written respiratory protection program. I've had people raise their hands in class and say, 'Are we supposed to have a policy in place?' I'm betting it exists at your facility. You may not know where it is. But if OSHA shows up, it's pretty much low-hanging fruit for them. They want to get a copy of the program and examine it.
"With most of the OSHA standards, there's usually a written component," he added. "I always tell students, 'Have this stuff at your fingertips if you get audited. They're going to ask for it. That's half the battle.' So, hopefully, if you've got your fingers on it, you know what's in there. But without having some written policy, I don't know how they would manage a respiratory program, how they would even deal with it. But it's always kind of amazing to get those blank stares where they say, 'Really? There's supposed to be a written program?'
"I think what happens is through positions rolling through and promotions or firings, people just lose track of that documentation. And even if they have it, it's out of date or hasn’t been visited for a while. I think that's probably one of the big issues. Another one that goes hand in hand with that is lack of training.... I have a sneaking suspicion that if you went out and asked the rank and file who are wearing respirators, asking them specific questions, you would likely get some of the blank stares."
Roskelley said he had a hazardous materials job while in college. "My boss literally threw a [half facepiece respirator] at me and said, 'Here you go.' No fit test, no medical surveillance, nothing. He just said, 'Here you go, wear this.' I didn't even know how it worked. I knew there were filters on it," he said. "I'm afraid that happens. I know it happens out in the field, where people are just given a respirator and very little training."
He said as one training class was about to begin, one student donned his half-face negative pressure respirator upside down, and so the part that was supposed to go over the bridge of his nose was down under his chin.
Few Students Understand Changeout Schedules
Few students understand how to develop or use a cartridge changeout schedule. "Most of them don't know what a changeout schedule is or that one even exists. A lot of them have just adopted what their predecessor did, and they don't really understand the background or why they're even using the cartridge or the respirator that they're using, let alone that it needs to be changed out," he said.
Roskelley advises his students to visit the OSHA website because it lists ways to estimate respiratory cartridge service life and has an advisory genius tool (http://www.osha.gov/SLTC/etools/respiratory/advisor_genius_nrdl/advisor_genius.html) to help visitors develop a changeout schedule based on their workers' exposures. He also steers them to the NIOSH website's respirator selection logic document (http://www.cdc.gov/niosh/docs/87-108/).
Roskelley also teaches courses for RMCOEH on lead and asbestos. He said about 30 percent of his time is devoted to teaching and 70 percent to his consulting practice for R&R Environmental, whose professionals have done work in western United States and Canada.
"It's always interesting to teach. The respiratory protection course we teach at the university is just a two-day class. It's designed for someone who may be new to respiratory protection, or they're in the health and safety field and they've been tasked to take over as the lead [person] on respiratory protection.
"It's a really quick, invasive class on respiratory protection; it's really not for beginners. If you can't spell respiratory protection, it might not be the class for you. But we do get beginners in there, and it does get challenging to teach someone who's experienced and just wants an update and someone who really has a hard time knowing anything about respirators."
He said he frequently instructs managers of respiratory protection programs who don't even know why their workers are wearing the level of protection that they're wearing. "Maybe it was documented years ago, and they're still using the same type of respirators. I usually tell folks that conditions have probably changed, processes have changed in five, ten, fifteen years, and you should constantly be sampling and updating your initial exposure assessment results, revisiting those from time to time."
Most people in his respiratory classes know about fit testing and know that they have to retest annually, but not many know that a worker's weight gain or loss, dental surgery, and other physical changes can necessitate fit testing that worker prior to the next annual date. Another requirement in the OSHA standard, medical evaluation of a worker's fitness for duty, is supposed to be performed by a licensed health care provider. But more and more, Roskelley said he see certificates signed by chiropractors, nurses, and others who might not possess the necessary medical expertise to do this evaluation.
'You Really Have People's Lives in Your Hands'
Roskelley said he has noticed some progress during his 15 years of teaching this topic. "Being optimistic, I'd like to say that there's more awareness. By and large, I would say awareness has increased," he said. "You still get a lot of the same retread stuff, somebody just taking over for somebody who's been there for five years and they don't know how to spell respirator or why they're even doing the things they're doing. I think it's important that you know why you're wearing that level of protection and that it's still valid for what you're doing. That kind of scares me a little bit, but I think that just falls through the cracks.
"I try to stress the importance of respiratory protection," he explained. "You really have people's lives, in some instances, certainly their health and well-being, in your hands. If you're making the improper decision, maybe they're protected 90 percent of the time, but 10 percent of the time, you might be doing them harm. In 50 years, that means a couple of years off their life. Well, to somebody young, that doesn't mean much. But to somebody with grandkids, you may want a couple of extra years on your life or you may want a little extra lung function because you want to play tennis in your golden years."
This article originally appeared in the June 2013 issue of Occupational Health & Safety.