OSHA's new respiratory protection standard

by Rick Hillier, CIH

THE LONG-AWAITED REVISION to OSHA's respiratory protection standard (29 CFR 1910.134) is now finalized. The standard goes into effect on April 8, 1998, so until then, companies must maintain compliance with the current version. Here is a quick look at the requirements contained in the revised standard.

General Requirements

Respiratory protection is still considered a secondary level of protection. Employers are required to eliminate adverse exposures using engineering controls. Only if such primary controls cannot be implemented (or while they are being implemented) should respirators be allowed. It is important for workers to always question why respirators are being used and not engineering controls. We also need to insist that the company work on implementing engineering controls and track their progress. Remember, respirators do not eliminate exposure, they merely reduce it.

It is the responsibility of the company to provide respirators, free of charge, when their use is necessary.

The employer is required to develop and implement a written respiratory protection program. While most companies do a good job at developing programs that meet the minimum standards, they are poor at implementation. Workers can test the implementation by understanding the details in the written program and seeing if these details are being carried out in the workplace on a daily basis.

Specific Requirements
(These must be addressed in the written program)

Selection of Respirators

The employer only must select respirators certified by the National Institute of Occupational Safety and Health (NIOSH).

The employer must identify and evaluate the types of respiratory hazards in the workplace and make a reasonable estimate of the number of employees exposed Rick Hillier, CIH to these hazards. The employer cannot designate everyone as a respirator user instead of understanding which employees really need this type of protection. There should be strict documentation addressing who, what, when, where, and why a respirator is being issued.

The employer must select from a sufficient number of respirator models and sizes so that a respirator is acceptable and correctly fits the user.

A respirator used for protection against gasses or vapors must have an end-of-service-life-indicator (ESLI), or the cartridges/canisters must be changed out on a prescribed frequency. (The employer must document the rational for the change-out frequency.)

Medical Evaluation

The employer must determine the employee's ability to use a respirator, before the employee is fit-tested or required to use a respirator.

OSHA allows the employer to use a medical exam or the medical questionnaire contained in the standard, to determine an employee's ability to wear a respirator.

If an employee is not capable of wearing a tight-fitting negative pressure respirator, the employer must provide a Powered Air Purifying Respirator (PAPR) for use if the evaluation allows this. (Hood-type PAPRs are available.)

Fit-Testing

Fit-testing is required for both negative or positive pressure tight-fitting face-pieces.

Either a Quantitative or Qualitative fit-test is allowed.

Fit-testing must be conducted according to the procedures outlined in the OSHA standard.

Fit-testing of tight-fitting supplied air or PAPRs must be done with the respirator in the negative pressure mode (i.e., without the supplied air/blower turned on).

Use of Respirators

The employer must develop and implement specific procedures and conditions for the use of respirators. Procedures need to be developed addressing conditions under which an employee needs to leave a respirator-use area and how to do so safely.

Procedures need to be developed addressing work in IDLH atmospheres and the need for back-up personnel.

Maintenance and Care

The employer is responsible for the maintenance and care of respirators, including cleaning, storage, inspection and repairs. Specific procedures need to be developed for all aspects of maintenance and care. In my opinion and based on my experience in managing two of the largest respirator programs in the country, employees should not be responsible for the cleaning and maintenance of respirators. Respirators should be turned in after each use/shift to a centralized group responsible for cleaning and maintenance and a new, sanitized respirator issued, if necessary.

Breathing Air Quality

Compressed breathing air must meet at least the requirements of Grade D breathing air.

Compressors used to supply breathing air must be located to prevent entry of contaminated air into the air-supply system.

Employees depending on supplied air should ask to see a record of when the air quality was last tested and that it meets Grade D requirements.

Training and Information

The employer must provide respirator training that is effective, comprehensive, and understandable. (The standard lists many specific topics that need to be covered.)

Training must recur annually.

Special situations such as, supplied air work, need to have special training to ensure safe use and necessary actions for emergencies (e.g., loss of air-supply).

Program Evaluation

The employer must evaluate regularly the elements of the respirator program (most places do it annually) to determine effectiveness. The employer must consult the employees during this evaluation. These only are the highlights of the revised standard. There are more details not covered here. Anyone wishing a copy of the revised standard should contact the company H&S department or the OCAW Health and Safety Department. This is my last column. I have found another position outside of OCAW. I have enjoyed working with you all. For health and safety questions, call the International H&S Department.