This standard is very detailed and contains many rules that companies often fail to meet. Before we get into the rule, let’s talk about applicability.
How do you know if you need a respiratory protection program? The starting point is to determine if you have any air contaminants in your workplace. In some cases, that answer is pretty obvious. Certain industries have exposures to well-known air contaminants i.e. asbestos, lead, silica, spray painting.
One document to check is the Material Safety Data Sheet for substances that are commonly used. What does it say about respirator use for a solvent that is used in the shop or the aerosol that is used for cleaning?
In nearly all cases, it will state something to the effect that respiratory protection is required when exposure limits are exceeded. How do we know if the air contaminant level is excessive?
Sometimes you can use industry guidelines or other comparative data to determine when respiratory protection is needed. This is often based on the activity being performed i.e. heating or grinding a material. This generalized information can be helpful.
The most conclusive way to determine indoor air quality is to perform air sampling. These tests will determine specific air contaminant levels in a given area or as experienced by a worker over their shift.
If you have excessive levels of contaminants including dust, mists, vapors or fumes the first consideration should be engineering controls. The use of ventilation, whether a local exhaust system or a more general approach when applicable should be evaluated for feasibility. Taking care of the contaminant at its source is the most effective approach. Some standards require ventilation.
If you land at the required use of respiratory protection as either a primary or secondary measure, a respiratory protection program must be established.
The starting point is to develop a written respiratory protection program. Required elements include:
- Designating a program administrator.
- Selecting appropriate respirators for use in the workplace.
- Training employees in the proper use of respirators (including putting them on and removing them), the limitations on their use and their maintenance.
- Providing medical evaluation of employees who must use respirators.
- Fit testing tight-fitting respirators
- Use respirators properly in routine situations as well as in reasonably foreseeable emergencies.
- Ensuring adequate air supply, quantity and flow of breathing air for atmosphere-supplying respirators.
- Establishing and adhering to schedules for cleaning, disinfecting, storing, inspecting, repairing, removing from service or discarding, and otherwise maintaining respirators.
The most likely OSHA Citations relating to the respiratory protection program requirements include:
- Failure to have a written program
- No employee training or not training annually
- Improper storage/maintenance
- Failure to perform annual fit testing
- Not providing the required information to employees who use respirators voluntarily.
The last point of the above list regards the voluntary use of respirators. This voluntary use of a dust mask respirator does not require any of the program elements. Employees must be given Appendix D of the OSHA Respiratory Protection Standard which discusses the voluntary use of a dust mask. When employees voluntarily use another tight fitting mask type, a written plan that just includes the need for medical evaluations and cleaning, maintenance and storage must be developed.
OSHA has developed an excellent resource called the Small Entity Guide for the Respiratory Protection Standard. Here is the link https://www.osha.gov/Publications/3384small-entity-for-respiratory-protection-standard-rev.pdf
Rich Galutia CSP specializes in the areas of employee safety (OSHA), trucking compliance (FMCSA) and animal feed safety (FDA).