Filling the Manager's Toolkit
Jim Johnson, past chairman of AIHA’s Respiratory Protection Committee, said he hopes training modules will be ready by the 2012 AIHce conference in Indianapolis.
- By Jerry Laws
- Nov 01, 2011
Work being done by several leaders of the American Industrial Hygiene Association’s Respiratory Protection Committee soon may give respiratory program managers much-needed help, both in ensuring wearers of this PPE are safe and in demonstrating their competency to run those programs.
They want to fill a gap that has existed for decades. OSHA's respiratory protection standard, at 1910.134(c)(3), states this: The employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness. But what constitutes "appropriate training or experience"?
"We've always had this need to define better and provide training for respirator program managers," said Jim Johnson, CIH, a consultant in Pleasanton, Calif. The past chairman of the committee, he retired five years ago after working for 34 years at the U.S. Department of Energy's Lawrence Livermore National Laboratory, where he managed its respiratory protection program. "If you look, what you find in the OSHA regulations are the terms 'qualified by appropriate training or experience.' What does that really mean? One extreme is, when you don't know what to do with someone in the Safety Department, you put him in charge of respirators. Or when the person is injured, like in fire departments, they end up over in respiratory protection. Or when somebody comes out of school with a health and safety background, hopefully with at least four hours of respiratory protection training, they take over the programs and start managing them. They take short courses, or whatever, to get up to speed."
It is assumed that everyone managing a respiratory program understands respiratory protection, Johnson said. Yet OSHA enforcement data belie that notion: Respiratory protection citations are among its top five most-cited standards in recent years. (It ranked fourth on the list of cited standards from Oct. 1, 2009, to Sept. 30, 2010, after scaffolding, fall protection, and Hazard Communication, according to the list posted at http://www.osha.gov/Top_Ten_Standards.html.)
"It pops up," Johnson said. "So you're saying, 'Who's running these programs? Do the folks involved in managing the programs really understand what's involved in respiratory protection?'"
Those working with Johnson on this project include CR (Gus) Manning, Ph.D., of Assay Technology Inc., the committee's current chairman; Rich Metzler, former director of NIOSH's National Personal Protective Technology Laboratory; and several other experts on the subject.
A Basic Disconnect
Johnson said from conversations with respirator manufacturers, he knows that some customers who call them for help are asking basic questions. "It's pretty scary as far as understanding how you use respiratory protection, how to do the risk assessment of the workplace, exposure assessment, cartridge changeout schedules, and some of the things that are built into the standard. They're not there," he said. "That's pretty indicative to us of a real need."
As an example, he mentioned visiting a business where bathtubs were refinished, which involved sanding the tubs and applying a new epoxy coating. The site had done no airborne testing to assess potential exposures, however.
"This is typical," said Johnson. "A majority of respirator use, even in industrial hygiene applications, when you talk to people and ask how they selected respiratory protection, they'll say, 'Oh, we give them a half mask, a full-face respirator.' Do you have a technical basis for that selection? 'No, we think it's OK.' How do you know?"
"That then goes back to the questions asked of respirator manufacturers," he said.
He contends very little air sampling data are used to select respirators, even though the OSHA standard requires it. At 1910.134(d)(1)(iii), the standard says: The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.
Similarly, the OSHA citation history shows that program managers make basic assumptions and errors that prove they don't understand what the standard requires.
Both OSHA and the respirator manufacturing community support the effort to develop training modules to fill a need for defined training that has existed for the past 35 to 40 years, he said. "We cycle through these discussions. One of my colleagues says your professional career goes around like a circle -- you go around and see some of these things keep popping up that are needed. When you get around the circle too many times and you get tired of some of the things on the circle, it's time to retire.
"This one has been there for a significant amount of time, and we were back at talking about what the Respiratory Committee can provide to the profession. Sometimes the interest in respirators is variable; you find the profession itself either feels they know it or are not that interested in it."
However, Johnson said he recently conducted a survey of industrial hygienists and received slightly more than 1,000 responses, representing a response rate of about 20 percent. He said 68 percent of the respondents -- more than 700 industrial hygienists overall --- said they are involved with managing the respiratory program where they work.
"Respiratory protection is not a glitzy topic, but it is a foundational tool, just like a ventilation fan, that goes into an industrial hygienist's toolkit to protect the worker," he said. Johnson has served on the committee since the mid-1970s.
An end result of the project will be a training certificate of some kind, one that would demonstrate the individual has gone through a training program supporting an appropriate respiratory program that meets the OSHA standard. What made Respiratory Protection Committee members think this might be the time to dive back into this question was AIHA’s introduction of Registry Programs in 2010. They want to develop the technical knowledge needed for it, plus information on how one demonstrates that knowledge. It would not necessarily have to be tied to training provided by AIHA, Johnson said.
Early in his career, Johnson visited what are now DOE sites in Colorado, Tennessee, and around the country to assess their respiratory programs and bring their knowledge and practices back to the Lawrence Livermore program. Today's respiratory program managers may attend sessions at the annual AIHce conferences or might attend manufacturers' road shows to build their knowledge, but the opportunities are limited, Johnson said.
This group is now developing the knowledge base or courses that would be offered to provide the background to make someone qualified as a respiratory protection program manager. He said he hopes the group will finalize the program and have the modules ready to present at the 2012 AIHce conference in Indianapolis (June 16-21, 2012).
The courses could be delivered during the annual AIHce as four half-day classes:
- Overview/introduction, 1910.134 requirements, and ANSI Z88 standards
- Function of the human respiratory tract, medical evaluation, and ANSI standards
- Respirator fit testing, both qualitative and quantitative, with hands-on fit testing using the major, commercially available systems for tests
- Cartridge testing, cartridge selection, and changeout schedules
Other important topics, such as CBRN respirators, will be offered as additional modules to supplement or maintain the basic knowledge base.
"We're really looking at identifying an opportunity to make the respirator classes that we offer of significance for the industrial hygienist community. In addition, in terms of protection for the worker, it would improve the knowledge base of the various respiratory protection program managers out there to implement a more compliant and broad-based program," Johnson said. "In my experience, typically the medical side is woefully overlooked, where respirators are medically screened. That whole area needs some attention."
The reason why OSHA and manufacturers support the effort are crystal clear: Respiratory protection is a big business, with manufacturers selling lots of respirators every year and many workers wearing them. If the respiratory protection programs at most workplaces aren’t being managed properly -- "My opinion is that the majority of [respiratory protection] is not being used as intended by OSHA," Johnson said – both manufacturers and OSHA have a vested interest in improving the situation. Everyone involved in using this type of PPE has the same vested interest, for that matter.
For more information and updates on the project, contact Gus Manning at [email protected]
This article originally appeared in the November 2011 issue of Occupational Health & Safety.