OSHA's respirator standard is often misunderstood and companies issue respirators to their employees without understanding the requirements in 29 CFR 1910.134. Although the standard is very complex and should be managed by an experienced administrator, there are four basic elements you must make sure you have in place.
- Respiratory Protection Program Specific to Your Company
- Worker Training
- Medical Evaluation
- Fit Testing
This article will touch on the major points pertaining to each of these subjects.
Respiratory Protection Program
If respirators are required to protect the health of the employee or the employer requires its employees to use respirators, a program must be implemented. The plan must contain the following elements.
- Must designate a qualified program administrator to oversee the program
- Must provide respirators, training, and medical evaluations at no cost to the employee.
- Must address the selection of respirators, medical evaluations, fit testing, use of respirators, maintenance, and care, breathing air quality and use, identification of filters, cartridges and canisters, training, program evaluation and record keeping.
Must provide effective training to respirator users, including:
- why the respirator is necessary and how improper fit, use, or maintenance can compromise the protective effect of the respirator
- limitations and capabilities of the respirator
- use in emergency situations
- how to inspect, put on and remove, use and check the seals
- procedures for maintenance and storage
- recognition of medical signs and symptoms that may limit or prevent effective use
- general requirements of this standard
Training is required prior to initial use unless acceptable training has been provided by another employer within the past 12 months.
Retraining required annually and when
- :workplace conditions change
- new types of respirator are used
- inadequacies in the employee’s knowledge or use indicate the need
The basic advisory information in Appendix D shall be provided to employees who wear respirators when their use is not required.
- Must provide a medical evaluation to determine employee’s ability to use a respirator, before fit testing and use.
- Must identify a physician or other licensed health care professional (PLHCP) to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire (information required is contained in mandatory Appendix C).
- Must obtain a written recommendation regarding the employee’s ability to use the respirator from the PLHCP.
- Additional medical evaluations are required under certain circumstances, e.g.:
- employee reports medical signs or symptoms related to the ability to use a respirator;
- PLHCP, program administrator, or supervisor recommends reevaluation;
- information from the respirator program, including observations made during fit testing and program evaluation, indicates a need; or
- change occurs in workplace conditions that may substantially increase the physiological burden on an employee.
- Annual review of medical status is not required.
- All employees using a negative or positive pressure tight-fitting facepiece respirator must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT).
- Fit testing is required prior to initial use, whenever a different respirator facepiece is used, and at least annually thereafter. An additional fit test is required whenever the employee reports or the employer or PLHCP makes visual observations of, changes in the employee’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight).
- The fit test shall be administered using an OSHA-accepted QLFT or QNFT protocol, as contained in mandatory Appendix A.
- QLFT Protocols:
- • Isoamyl acetate
- • Saccharin
- • Bitrex
- • Irritant smoke
- QNFT Protocols:
- • Generated Aerosol (corn oil, salt, DEHP)
- • Condensation Nuclei Counter (PortaCount)
- • Controlled Negative Pressure (Dynatech FitTester 3000)
- • Controlled Negative Pressure (CNP) REDON