Developing an OSHA Compliant Respirator Program Stan Liang

Developing an OSHA Compliant Respirator Program Stan Liang, CIH, CSP, CET KTA-Tator, Inc.

Respiratory Protection Webinar Objectives Ø Brief overview of the following: ü Procedures for implementation of respiratory protection ü Requirements of the OSHA Respiratory Protection Standard ü Elements of a written respiratory protection program Ø Resources for additional information

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

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

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

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

Respirator Classification • Air-purifying respirators • Air-supplied respirators

Air-Purifying Respirators Uses mechanical filters or chemical cartridges to remove contaminants from the air that workers breathe

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

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

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

Filter Selection for Toxic Metals • HEPA cartridges must be used for toxic metal hazards • HEPA cartridges designated as N 100, R 100, or P 100

Filter Selection for Painting Operations • Organic vapor (black) cartridges for roller/brush application • Organic vapor (black) cartridges with mist prefilter for spray painting

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

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

Air-Supplied Respirators Provides the wearer with a continuous supply of clean, breathable air delivered to a tightfitting facepiece or loose-fitting hood

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

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

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

Air-Supplied Respirator Limitations • 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

Air-Supplied Respirator Limitations • Grade D requirements: – 19. 5% to 23. 5% oxygen – Less than 10 ppm CO – Less than 1, 000 ppm CO 2 – Less than 5 mg/m 3 hydrocarbons • Do not use pure oxygen as breathing air

Air-Supplied Respirator Limitations • 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)

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

Inspection of Respiratory Protection • Respirators must be inspected before and after use

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

Inspection of Respiratory Protection • Inspect headstraps or head harness for: – Broken straps or headbands – Loss of elasticity – Broken or malfunctioning buckles and attachments

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

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

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

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

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

Negative Pressure Seal Check

Positive Pressure Seal Check

Procedures for Use of Respiratory 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

Procedures for Use of Respiratory 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

Cleaning Respiratory Protection • 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

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

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

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

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

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

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

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

Medical 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

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

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

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

Elements of a Respiratory Protection 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)

Elements of a Respiratory Protection Program • Procedures and schedules for cleaning, disinfecting, storing, repairing, and maintaining respirators • Procedures for evaluating the effectiveness of the program

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

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

Elements of a Respiratory Protection 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

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

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

Questions