Developing an OSHA Compliant Respirator Program

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Developing an OSHA Compliant Respirator Program

• Stan Liang, CIH, CSP, CET
• KTA-Tator, Inc.

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Respiratory Protection Webinar Objectives

• Brief overview of the following
• Procedures for implementation of respiratory
  protection
• Requirements of the OSHA Respiratory Protection
  Standard
• Elements of a written respiratory protection
  program
• Resources for additional information

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Respiratory Protection

• Last line of defense in protecting employees from
  harmful dusts, mists, gases and vapors
• Feasible engineering controls or work practice
  must be implemented before the use of respiratory
  protection can be considered
• Job rotation not permitted by some OSHA standards

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Engineering Controls

• Vacuum shrouded power tools
• Ventilation
• Wet surface preparation methods
• Substitution

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Respiratory Protection

• Must be selected in accordance with procedures
  established in the respiratory protection program
• Must be fitted, used, and maintained properly
• Must be provided at no cost to the employee

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Maximum Use Concentration(MUC)

• Key consideration in the selection of respiratory
  protection
• Determined by multiplying the respirators
  Assigned Protection Factor (APF) times the
  Permissible Exposure Limit (PEL)
• Level of airborne hazards should not exceed the
  MUC

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Respirator Classification

• Air-purifying respirators
• Air-supplied respirators

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Air-Purifying Respirators

• Uses mechanical filters or chemical cartridges
  to remove contaminants from the air that workers
  breathe

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Half Face APR

• Assigned Protection Factor of 10
• Can not be used if respiratory hazards can cause
  eye irritation

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Full Face APR

• Assigned Protection Factor of 10 or 50
• Protection factor depends on fit test method

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Powered Air Purifying Respirator

• Uses battery operated blower
• APF ranges from 25 to 1000
• Loose fitting hood or helmet type may be assigned
  to workers unable to wear tight fitting air
  purifying respirators

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Filter Selection for Toxic Metals

• HEPA cartridges must be used for toxic metal
  hazards
• HEPA cartridges designated as N100, R100, or P100

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Filter Selection for Painting Operations

• Organic vapor (black) cartridges for roller/brush
  application
• Organic vapor (black) cartridges with mist
  pre-filter for spray painting

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Air-Purifying Respirator and PAPR Limitations

• Can not be used in conditions considered
  immediately dangerous to life and health
• Can not be used where oxygen concentrations are
  below 19.5
• Can not be used if concentration of respiratory
  hazards exceed the protection factor of the
  respirator

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Air-Purifying Respirator and PAPR Limitations

• Cartridges have a limited service life
• Cartridges have a limited shelf life
• Personnel who have severe scarring or other
  conditions which prevent the mask from sealing to
  the face may not use tight fitting air-purifying
  respirators

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Air-Supplied Respirators

• Provides the wearer with a continuous supply
• of clean, breathable air delivered to a tight-
• fitting facepiece or loose-fitting hood

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Supplied Air Respiratory Protection

• Assigned Protection Factor up to 10,000
  (depending on the type of respirator)
• Tight fitting full face air line with auxilliary
  SCBA can be used in confined spaces with IDLH
  atmospheres

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Air-Supplied RespiratorLimitations

• Length of air line must not exceed 300 feet
• Line may kink, be cut, or be entangled
• Line may become contaminated

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Air-Supplied Respirator Limitations

• Use only air line, vortex, and other equipment
  specified by the manufacturer
• Pressurize the air line in accordance with
  manufacturer specifications
• Air line couplings must be compatible with
  breathing air systems only

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Air-Supplied RespiratorLimitations

• The compressed air bottle for the escape SCBA
  must be hydrostatically tested in the following
  intervals
• Every 3 years - aluminum wrapped with fiber glass
• Every 5 years - steel
• Supplier of breathing air must certify in writing
  that breathing air is Grade D quality

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Air-Supplied RespiratorLimitations

• Grade D requirements
• 19.5 to 23.5 oxygen
• Less than 10 ppm CO
• Less than 1,000 ppm CO2
• Less than 5 mg/m3 hydrocarbons
• Do not use pure oxygen as breathing air

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Air-Supplied RespiratorLimitations

• Portable or self contained compressed air
  cylinders used as breathing air sources last from
  30 minutes to 60 minutes
• Escape SCBAs usually provide 5 minutes of air
• A low pressure alarm must be provided (if using a
  breathing air cylinder)

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Abrasive Blasting Respirators Type CE

• Required for abrasive blasting
• Check with manufacturer if using for other
  applications
• Provides a protection factor of 1,000 (selected
  makes and models) or 25
• Not for immediately dangerous to life and health
  atmospheres

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Inspection of Respiratory Protection

• Respirators must be inspected before and after use

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Inspection of Respiratory Protection

• Inspect facepieces for
• Excessive dirt or contamination
• Cracks, tears or holes
• Cracked, scratched, or improperly mounted
  facepieces (on full facepiece masks)
• Cracked or broken air purifying element holders
• Damaged threads/gaskets

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Inspection of Respiratory Protection

• Inspect headstraps or head harness for
• Broken straps or headbands
• Loss of elasticity
• Broken or malfunctioning buckles and attachments

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Inspection of Respiratory Protection

• Inspect facepiece interior for
• Foreign material
• Cracks, tears, or distortion in valve material
• Cracks, breaks, or chips in the valve body,
  particularly at the sealing surfaces
• Missing or defective valve covers
• Improper installation of valve bodies

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Inspection of Respiratory Protection

• Inspect air-purifying elements for
• Incorrect cartridges/pre-filters
• Loose connections/cross threading
• Expired cartridge shelf life date
• Cracks/dents on cartridge
• Evidence of prior use

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Inspection of Respiratory Protection

• Inspect breathing tube (if air line used) for
• Broken or missing gaskets or O-rings
• Missing or loose hose clamps
• Deterioration found by stretching hose and
  looking for cracks and tears

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Inspection of Respiratory Protection

• Inspection of air line systems for
• Bottle on escape pack fully recharged
• Cylinder for supplying breathing air fully
  charged
• Breathing air in cylinder (if used) certified as
  Grade D
• Pressure in air line as specified by manufacturer
• Low pressure alarm functional

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Donning Respiratory Protection

• Once the respirator is donned, the wearer should
  check that the mask is properly placed on the
  face and the straps are properly tightened
• The positive or negative pressure check must be
  performed each time the respirator is donned

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Negative Pressure Seal Check
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Positive Pressure Seal Check
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Procedures for Use ofRespiratory Protection

• Users of tight-fitting masks must not have facial
  hair that interferes with facepiece seal
• Contact lenses may be worn with respiratory
  protection
• Other PPE worn with respiratory protection can
  not interfere with the seal of tight fitting
  respirators

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Procedures for Use ofRespiratory Protection

• Respirator users shall leave the work area when
• Workers need to wash their face and respirators
  to prevent skin irritation
• Vapor or gas breakthrough is detected
• Filters require replacement

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Cleaning RespiratoryProtection

• Wipe interior/exterior of respirator with
  manufacturer approved towelette at the end of the
  shift
• Use mandatory OSHA procedures when
• Respirator is heavily contaminated
• Respirator is used by another person

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Respirator Storage

• What is a good practice in this picture?
• What mistakes are shown here?

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Respirator Storage

• Do not store respirators in areas where they are
  exposed to the following
• Contamination
• Direct sunlight
• Dust
• Extreme temperatures
• Must be packed or stored to prevent deformation

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Repairing Respiratory Protection

• Remove defective respirators from service
• Make repairs in accordance with manufacturer
  recommendations
• Use only manufacturer approved parts

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Medical Evaluations

• Medical evaluations must be provided to wearers
  of respiratory protection before fit testing or
  use
• Employees who refuse an evaluation can not be
  assigned to tasks where respirators are required
• Provided by a physician or healthcare
  professional (within the scope of their license)
• Evaluations are conducted by having the employee
  complete the questionnaire in Appendix C of the
  standard

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Medical Evaluations

• Questionnaire must be administered in a time and
  place convenient to the employee
• Translation of the questionnaire is required for
  non english speakers
• Employees have an opportunity to discuss the
  questionnaire and results with healthcare
  professional

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Medical Evaluations

• The employee must be provided with a copy of the
  medical determination
• Information collected via questionnaires is kept
  strictly confidential

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Medical Evaluations

• The medical determinations include the following
  information
• Limitations on respirator use
• Medical fitness
• Need for follow-up evaluations

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Medical Evaluations

• Evaluations (in addition to initial evaluation)
  provided if
• Employee reports signs or symptoms related to the
  ability to use a respirator
• Health care professional or Respirator Program
  Administrator determines that the employee needs
  to be evaluated
• Information from fit testing or program
  evaluation indicates the need for another
  evaluation
• Changes in workplace conditions result in
  increased physical stress on the employee

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Fit Testing

• Required annually for all tight fitting
  respirators
• Must be performed for each make, model, and size
  worn
• Another fit test is needed for a change in weight
  or other medical condition which could change
  respirator fit
• Workers must be clean shaven and medically
  approved to be fit tested

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Qualitative Fit Testing

• Must be performed in accordance with Appendix A
• Several options permitted by OSHA

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Quantitative Fit Testing

• Required only for full face air purifying
  respirators
• Must be performed following procedures in
  Appendix A

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Elements of a RespiratoryProtection Program

• Designation of a Respirator Program Administrator
• Procedures for selecting respirators (hazard
  evaluation required)
• Medical evaluations
• Procedures for proper use (including written
  change schedules for gas/vapor cartridges)

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Elements of a RespiratoryProtection Program

• Procedures and schedules for cleaning,
  disinfecting, storing, repairing, and maintaining
  respirators
• Procedures for evaluating the effectiveness of
  the program

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Training Program Requirements

• Required annually or if there are changes in the
  work place, evidence that training is not
  effective, or other indication that retraining is
  needed
• Training topics include why respirator use is
  required, proper procedures for use, limitations
  of respirators, and requirements of the standard.
• Hands on training, information in manufacturer
  manuals, and documentation of training is
  recommended

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Elements of a Respiratory Protection Program

• Atmosphere must be classified as IDLH under the
  following conditions
• oxygen level less than 19.5
• concentrations of toxic gases above IDLH
  concentrations
• hazard evaluation is not performed

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Elements of a RespiratoryProtection Program

• Procedures for IDLH atmospheres include the
  following
• use SCBA or combination SCBA/air line respirators
• workers stationed outside the work area for
  emergency response
• employer must be notified before start of rescue
  operations and be able to provide necessary
  assistance

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Voluntary Respirator Use

• Respirators may be provided to the employee where
  use is requested but not required
• Use of respirators must not create a hazard to
  the worker
• Worker training must include the content of
  Appendix D
• Workers must be medically approved

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Additional Information

• www.osha.gov
• 29 CFR 1926.103 (or 29 CFR 1910.134)
• OSHA Compliance Directive (CPL 2-0.120)
• Small Entity Compliance Guide for the Revised
  Respiratory Protection Standard
• Respirator manufacturers
• NIOSH certified equipment list
• Health and safety professionals

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Questions