How does the well-established program work? Exert control and manage it from the outset.
Few programs related to items of PPE are as necessary or as hard to establish and manage as respiratory protection. How does your respiratory protection program measure up? While our goal for any safety program is to be the very best, reality is much less sunny. Our best efforts may set up a quality program, but the follow-up, staff changes, and shifts in program emphasis may cause the updates to be fewer and farther between. Or no updating or auditing is ever done if management assumes all is well with the program.
How are your resources? The quick answer usually is, "We do all right. We order whatever we need." One critical missed resource that must be managed and allowed for is staff to oversee and manage the program itself. Program management of respiratory protection runs the gamut. In-house program set-up, physicals, PPE selection, and fit testing by a qualified staff are one approach. Then there are completely outsourced programs and testing by vendors assumed to be qualified.
What type of program is really needed? The requirement is simple: "The employer must establish and maintain a respiratory protection program whenever respirators are required to protect the health of the employee." Have a written program and make sure all of the requirements of 1910.134 are covered as they affect your employees. Sounds simple, right? Starting respiratory programs from scratch can be cumbersome, time-draining, resource-sucking enterprises. But if you manage the program from the beginning, you have a better chance of controlling it before the program controls you.
Start with your process and employees. Review your industry classification and the potential hazards of your workplace. Are they doing work that exposes them to potential respiratory hazards? Are they currently wearing or using any type of respiratory protection, either provided by the company or voluntarily? Is there a history of respiratory protection at the site? (Many great respiratory protection programs fall by the wayside during budget cuts or staffing changes and are forgotten.)
Setting up a Program that Works
1. Get management's support and approval. No management likes surprises, and respiratory protection programs can mean big bucks fast! Start with education for the upper management personnel (including those pesky bean counters) to justify your program.
Pull in potential employee injuries, long-term liability, and also possible citation costs from OSHA.
A meeting of this sort does not mean an entire day; a sound introduction to the problem, actions that are needed to bring the company into compliance, and a good handout should cover the bases. Make sure you have the necessary codes at hand to back you up. Pull in potential employee injuries, long-term liability, and also possible citation costs from OSHA. Be realistic in what you ask for. (I highly recommend you add in at least an additional 20 percent for unexpected items and costs you have not considered, more for high-hazard or large or complex operations.) Nothing is worse than having to go back and beg additional money for a half-developed program.
Provide adequate feedback throughout the development and implementation process, but try not to overload administrators with trivia. They need results, not dozens of daily updates on initiatives. Safety must walk the fine line between being informative and being a dreaded pain of useless drivel. Establish a reasonable three-to-five-year budget analysis. Meet regularly with your budget folks to establish what can and cannot be done for the amount of money available to you. And unless dire circumstances occur, stay within that budget!
2. Develop a plan of action. This is one of the hardest parts to do in respiratory protection. Do your homework and research. Find out what has worked at other places and what does not work. Base real needs on your industry type, and follow the same pattern for successful programs of like size and need.
While you can aim high for the perfect respiratory program, you also have to understand that one program's place in the company safety net of programs. All too often, safety folks place all efforts into one program such as respiratory protection and then move on to other initiatives, leaving the program to fall into disuse. Have benchmarks for one year, two years, five years --whatever is needed. Refer to this often and change it as necessary. This plan shows what needs to be done by whom and must include target dates of implementation. If you do not have the skills to develop this, contract it out or get assistance from other safety professionals. For the most part, safety managers share information, programs, and even failed efforts. There is a lot of wisdom out there for the asking.
3. Establish priorities that make sense. Organize needed elements by function, department, or hazard. Start with needed protections, and hold off on the frills till later. Make a list and update it often, denoting who will complete each priority and what the target date is. This helps reduce miscommunication later and the "who, me?" response when asked why something was not completed. For example, employee training should be done much later in the program development rather than earlier. Until you know who will be affected, who passed the physicals, and what PPE they will be wearing, your time will be better spent working on other program elements. Initial program awareness (such as "a new program coming") can help energize employees and reduce frustration, but actual training is a more formal, involved process.
4. Use available technology. Make sure what you use is appropriate to your program's goals and the needs of your employees, from training tracking software to PPE selection and replacement. Update regularly. Ask for item samples so you know what you are purchasing in bulk. Software can assist in numerous ways and is a king-sized time saver.
5. Use a committee for PPE selection. This group selects and "de-selects" items used by employees. Give employees a say in what is used, and listen to them. (They do wear it, after all, and know the good and questionable qualities of each item.) Never allow the bean counters to be the selection source, because some will always go for the cheaper item. Your employees will use quality PPE. The poorer the quality of your PPE, the lower your program acceptance, in many cases.
6. Call on outside assistance. Few safety programs have unlimited time and employees to do needed work. Many are one-person shops trying to do everything that is safety-related. Program burnout and overload are rampant. Consultants, pre-written programs, audio-visuals, and some free programs and avenues for advice are available. One often-overlooked avenue is hiring a temporary employee to set up and manage the program; many highly qualified, retired professionals are available short term, and this arrangement can save you time, effort, and money.
Obtain high-quality assistance on both the front end of the program and again for auditing the program later on.
Obtain high-quality assistance on both the front end of the program and again for auditing the program later on. That skill will be well worth your time and funds. Another good resource is to utilize student interns from reputable safety and industrial hygiene colleges and universities. This can be a cheaper option for research or development of a specific item.
7. Get inside help. Who within the company is showing aptitude and interest? The new maintenance fellow? A line supervisor with some related background? Review safety committee minutes for possible skills. Ask for assistance from committee members and even secretarial staff; obtain assistance from untapped sources such as light-duty employees for filing or copying materials for training programs; recruit volunteers for program reviews of non-critical areas.
8. Ensure HR is ready. If employees fail physicals or refuse to wear PPE, changes in duties or sensitive HR issues will have to be faced. Make sure management knows the options, responsibilities, and laws/codes pertaining to each.
9. Be realistic. No program is perfect. There will always be updates, new products available for review, better ways of doing things, or emerging hazards to consider. No one person can do everything. Schedule your time, but include time for the unknown crisis and "do it now" projects we all face. Plan ahead and plan wisely.
10. Audit the program. Make sure you schedule audits to provide program successes and corrective actions needed, and also allow for program updates as standards, equipment, or tests improve. Plan to revisit the written program at least once a year, including all policies and contracts. Updates are an important feature of a working program, not just a pile of paper to which no one refers.
Most safety programs can be life-changing and even lifesaving; this is certainly true of respiratory protection when it is appropriately implemented and monitored. By setting, managing, and maintaining a realistic program schedule, you can manage a respiratory program to be proud of, including employees' acceptance and management's support. The easiest way to fail miserably is to try to do everything alone and end up with a half-completed program (sometimes worse than no program at all).
While we know safety is a shared responsibility, the safety professional is the steward of the program, and our interest and leadership can set the tone for the entire company.
This article appeared in the January 2007 issue of Occupational Health & Safety.
This article originally appeared in the January 2007 issue of Occupational Health & Safety.