Is Your Respiratory Protection Program Administrator Qualified?
What qualities and knowledge do respiratory protection program administrators need?
The Occupational Safety and Health Administration’s section 29 CFR 1910.134(c)(3), requires employers to designate a respiratory protection program administrator who is qualified to handle the complexity of the respiratory protection program for that employer. OSHA also provides more written guidance in its Small Entity Compliance Guide for Respiratory Protection Standard (OSHA 3384).
Taking this guidance into consideration with the rapid growth of new technologies, how do you know if your respiratory protection program administrator is up to the challenge? In many different industries, OSH professionals are looked upon to provide training and fit-testing to personnel who will need respiratory protection to safely complete their job tasks. Another important aspect to the training and fit-testing process is to inspire confidence in the wearer of the respirator so that they know they are being protected.
However, it takes more than just a presentation and shiny fit-test equipment to drive credibility. If your administrator lacks serious time behind a mask or within the workplace in question, they may lack credibility with front-line workers and thus, have a difficult time changing their behaviors.
Employees might believe the administrator does not know what it’s like to wear a mask for an eight-hour-plus day, while wearing other personal protective equipment (PPE) as well. Whether it’s right or wrong, many front-line workers want to know that those performing the training and fit-testing know what it’s like to work in the conditions they experience.
Along the lines of credibility, has your technician been out in the plant, or in the field, or the distribution center, etc.? Have they been in the industry, quantifying the hazard to your employees? Have they been coaching not only the front-line employees but also the line leaders, supervisors, managers and the like?
What About the Process?
Does your administrator know the process? How the widgets are made, from raw materials to finished widgets; what are the processes that are performed to ensure that you can make a sellable product? Do they understand, for example, the waste products that run into the sump system that is pumped out and why your workers need to go into this area to inspect it and possibly clean it? Say once a year, workers are required to change out 500 high-efficiency bags from a bag house used to clean particulates out of the plant air.
Your administrator needs to understand workers could wear a full-face negative pressure air-purifying respirator but depending on the time of year and your geographic location, some sort of atmosphere supplying respirator will go above and beyond when it comes to worker comfort while performing this task.
Knowing this issue with the process and the extreme heat, the administrator can advocate for the increased cost and how it can improve productivity, and at times, reduce heat stress during this annual task. This would go for miles as positive support from the workers.
Safety Science
Does your potential respiratory protection administrator understand the safety science behind the respiratory hazard and how we try to protect from it? Can they explain how certain volatile organic vapors (VOCs) may desorb from the activated charcoal based on high temperatures or humidity levels? Do they know how to fix these types of issues, as well as understand the need to use similar parts and pieces for respirators? If prompted, could he or she explain how NIOSH exposes N95 respirators to 0.3 micron sized sodium chloride particles at a flow rate of 85 liters per minute to simulate high-breathing rates while wearing the N95 masks (NPPTL, 2024)? Can they explain aerosol science in detail?
Let’s not confuse one’s academic prowess with real-world understanding and application of the principles and science. No one cares if the administrator scored an A+ in Aerosol Science 101. All that matters is the confidence the administrator builds in the individuals who are wearing the protective masks.
This discussion emphasizes the importance of a qualified and effective respiratory protection program administrator, highlighting not only technical knowledge but also the ability to communicate effectively and build trust with employees. According to OSHA guidelines (29 CFR 1910.134(c)(3)), the administrator must be well-versed in both regulatory requirements and the specific workplace conditions where respiratory protection is needed.
First, credibility is crucial. The administrator should have hands-on experience working in environments like those of the employees, such as wearing a respirator for extended periods while using other PPE. Second, the administrator must have a deep understanding of the workplace environment. This includes knowing the processes, hazards, and tasks employees perform. By understanding these intricacies, the administrator can recommend appropriate respiratory protection tailored to specific conditions. Lastly, the administrator must grasp safety science behind respiratory hazards. This technical knowledge, combined with clear communication, helps build confidence among workers, ensuring they feel protected while performing their duties.
In summary, a respiratory protection program administrator must not only be knowledgeable, but also be an effective communicator who understands the workers’ environment and can earn their trust, while advocating for solutions that enhance their safety and comfort.
This article originally appeared in the October 2024 issue of Occupational Health & Safety.