Understanding Requirements of an OSHA Respiratory Protection Program

If there is no way through engineering or administrative controls to get exposure to acceptable levels, respiratory protection must be provided.

• By Scott Larson
• Jul 01, 2016

Respiratory protection is often used to protect against chronic hazards. Unlike a fall from height or an impact to the head, where the effects of the injury are immediately apparent, the effects of prolonged exposure to respiratory hazards may not manifest for quite some time afterwards. For some substances, a person could be exposed to airborne contaminants for minutes or even years before showing signs of exposure. Respirators are the tools with which employers equip workers to help them protect themselves from airborne hazards.

Establishing a Respiratory Protection Program
In an effective respiratory program, an employer aims to protect workers from exposure to airborne hazards. To create a strong program, there are many factors to consider, some of which we will discuss in this article.

Of course, respiratory protection program administrators must understand applicable OSHA state and federal respiratory protection regulations. If respiratory protection will be used in a facility, then a written respiratory protection program must be developed. The written program must incorporate all the requirements from the OSHA respirator standard (29 CFR 1910.134), identify and address the known and anticipated workplace hazards, and account for the health of workers needing respiratory protection. A number of online resources exist to assist health and safety managers in creating an effective respiratory protection program. These include OSHA, NIOSH, and certain respirator manufacturers.

In this article we'll outline considerations for health and safety managers to help them create an effective program, as well as steps to take to protect workers.

Respiratory Protection Starts and Ends with the Written Program
A written program is required by OSHA and is a core component to an effective and complete respiratory protection program. Per 29 CFR 1910.134, every respiratory protection program requires a program administrator and must include documentation and written work site-specific procedures for:

• Respirator selection
• Medical evaluations
• Use of respirators
• Maintenance and care
• Assuring adequate air quality
• Training and fit testing
• Program evaluation

Exposure Assessment
Employers are required by OSHA to evaluate respiratory hazards in the workplace. An independent consultant or on-site health and safety professional trained in exposure assessment methods can evaluate workplace hazards. They need to determine:

• What hazards are present
• Exposure levels
• Whether or not those levels are acceptable

Any time there are changes in the workplace that could result in new or altered exposures, a new assessment needs to be conducted. Changes in the workplace could involve new equipment, processes, products, control measures, or seasonal changes.

Hazard Control Evaluation
If the assessment shows that exposure levels of airborne contaminants are outside of the limits OSHA has established, the respiratory protection program administrator should first see whether the exposure can be controlled through engineering controls (i.e., elimination, substitution, or local exhaust ventilation) or administrative controls (i.e., use of relief workers, rotation of workers or work breaks). If there is no way to effectively reduce the exposure to acceptable levels, respiratory protection must be provided.

Respirator Selection
After identifying the hazards, the exposure levels from the exposure assessment must be compared to the permissible exposure limit, or PEL, as set by OSHA, to determine whether respiratory protection is needed. Occupational exposure limits, or OELs, as set by alternative agencies also can be considered if exposure levels are below the PEL or if respiratory protection is not required by OSHA.

Any respirator used in a U.S. workplace must be approved by the National Institute for Occupational Safety and Health (NIOSH). All NIOSH-approved respirators have an assigned protection factor (APF) ranging from 10 to 10,000. The APF is the workplace level of respiratory protection that a respirator or class of respirators is expected to provide to employees when a respiratory protection program is implemented. An APF of 10, for example, means that, when selected and used correctly, a particular class of respirators can reduce exposure levels that are up to 10 times the PEL for the hazard to a level determined by OSHA to be acceptable for workers.

When considering respiratory products, first identify the necessary APF and other protective equipment a worker must wear. If they have to wear glasses, a half-face respirator may compete for space on the bridge of the nose. Considering multiple options for not only respiratory protection but also other personal protective equipment is the best way to help ensure that the worker is comfortable and protected. Because faces come in many shapes and sizes, workers may need to try on a variety of models and/or sizes for their PPE in order to find a combination that is acceptable to the worker. It can also be important to consider comfort, such as looking for equipment that is lightweight and streamlined. After all, the best tools are those the worker will want to wear. There are multiple online resources to help health and safety managers select the right equipment.

Medical Evaluation and Fit Testing
Before wearing a respirator, workers need medical approval. OSHA requires workers to first complete a questionnaire that asks questions about medical conditions that could affect their ability to wear a respirator, as well as the workplace conditions and hazards they face. A licensed health care professional then must evaluate the employee's responses and advise whether the worker is able to wear the class of respirator being considered. If a worker is medically approved, he or she must then undergo fit testing for tight-fitting respirators to ensure that the selected respirator is capable of fitting the worker correctly.

OSHA has not established a time frame for when to repeat the medical evaluation. However, all workers using respirators must be reevaluated when:

• A worker reports signs or symptoms that may affect his or her ability to safely use a respirator
• A physician, supervisor, or respiratory program administrator requests an evaluation
• Information during fit testing or program evaluation indicates a need for re-evaluation
• Changes in workplace conditions increase the burden on the worker, such as temperatures, level of exertion, or equipment needs

Respirator Training and Maintenance
OSHA mandates that employers ensure that workers are trained annually. This provides a forum for users to become reacquainted with the importance of respiratory protection and to give everyone a refresher course in properly using and caring for their equipment. At a minimum, training should cover:

• Why employees need to use respirators
• What a respirator can and cannot do to protect them
• How to properly inspect, put on, take off, and use a respirator
• How to perform a "user seal check"
• How to use the respirator effectively in emergency situations, including what to do if it does not work properly
• How to recognize medical signs and symptoms that may limit or prevent workers from using a respirator
• How improper fit, use, or maintenance can reduce the effectiveness of the respirator
• Maintenance and storage procedures
• The requirements for federal/state OSHA respiratory protection standards

Respirators should be inspected before each use and during cleaning and users must follow the manufacturer's user instructions for specific inspection and maintenance procedures. Emergency respirators should be inspected at least monthly and before and after every use. Consider:

• Respiratory function
• Tightness and connection
• Pliability of elastomeric parts
• The condition of various parts, including the facepiece, head straps, valves, connecting tube, cartridges, canisters, or filters

Program Evaluation
All elements of a respiratory protection program should be evaluated regularly. The respiratory protection administrator should examine all records to make sure tests and inspections are up to date. They should also observe and talk to users of respiratory protection equipment to ensure respirators are meeting their needs and that workers understand and follow procedures for using and maintaining them. It is important to make a record of evaluations and findings, to note any deficiency, and to document all necessary corrective measures. All of these observations and records help when updating a written respiratory protection program.

Managing an effective respiratory protection program not only keeps companies compliant with relevant regulations, but a well-run program also is the best way to help ensure that your workers are protected from respiratory hazards.

Types of Respirators
Elastomeric Respirators

• Half or Full Facepiece elastomeric respirators; with the proper filters or cartridges, they can filter certain particles and/or gases and vapors.

Filtering Facepiece Respirators

• Filtering facepiece respirators cover the nose and mouth and are used to help protect against certain particulate hazards.

Powered Air Purifying Respirators and Supplied Air Respirators

• Powered or supplied air respirators do the work of pushing air to the respirator headtop or facepiece; they can either be powered air, using a battery-powered blower to pull air through a filter, or supplied air, bringing clean air through a hose from a source outside of the contaminated work area.
• Tight-fitting respirators must be fit tested when use is required and users must perform seal checks every time a tight-fitting negative pressure respirator—a filtering facepiece or half facepiece respirator—is worn.
• Loose-fitting respirators typically have a hood or helmet.

This article originally appeared in the July 2016 issue of Occupational Health & Safety.