Respiratory Protection Practices
by Sanford Woo CSP
May 1, 2008
When using respirators, the slogan "trust,
but verify" applies
Safety is 99 percent common sense — true or false? That's
the last question in a series of 25 questions I ask new hires at the very start
of orientation to ascertain their existing safety knowledge and their attitudes
about safety. By the time I ask them this question, the classroom of new hires
is at ease and readily participating.
Without fail, someone will respond, "True!" When I
remain silent for a few moments, someone will chime in with a
"false." Eventually I explain, "When I started doing new hire
orientation, I would tell the class that safety is 99 percent common sense. I
was parroting my safety mentors. But one day I had a revelation. If safety is
99 percent common sense, isn't it a slap in your face for me to be here
explaining safety to you? In effect, I'm saying that you don't have common
sense, so I will spend a day-and-a-half drilling common sense into you!"
This story highlights what most, if not all, safety
professionals have done before. Inexperienced or lacking knowledge in a safety
area outside your comfort zone, you relied on the more experienced or learned,
retained the words they imparted and emulated them, assuming what they did or
the information they possessed was accurate.
I was taught about respirators and the OSHA respirator standard from
individuals who seemed so confident in their knowledge that I did not question
them. I patterned my program after theirs, only to learn some things were off
base. This forced me to carefully read the OSHA respirator standard. What
follows may prove insightful to you.
A not-so-quick fit
A mentor taught me to do qualitative fit testing with
irritant smoke. He went through the routine of normal breathing, deep
breathing, turning the head side to side, moving the head up and down, reading
the Rainbow Passage, etc. He demonstrated this process and said that if a
person wears a respirator incorrectly, the irritant smoke will cause an instant
reaction. He was usually done testing a person in less than five minutes,
sometimes much quicker.
Years later I fitted a fellow safety professional. After giving a few
squeezes of irritant smoke, asking him to breath normal, turn his head side to
side, count backwards, etc., I said he was done. He suggested I read the
standard. What a shock! Following the respirator standard, a real-world fitting
including preparation, counseling and paperwork will take at least 15 minutes —
if not closer to 20 minutes — per person.
Let the record show…
In my opinion, computerized quantitative fit testing is the
best way to fit test. The software automatically generates documentation
proving John Doe was fit tested on Day X and had a fit factor of Y. The
software walks the person through the mandatory breathing exercises and times
the exercises. No fuss, no questions. The computer literally does it all for
you. John Doe's claim that he wasn't fitted is easily dismissed.
Equally beneficial, if you delegated fit testing to another individual,
you can readily follow-up on his/her claims on the number of people who have
been fit tested versus those who still needing fit testing. The spreadsheet
doesn't lie.
Cleaning in compliance
A mentor demonstrated how to clean respirators. Take a
packaged towelette specifically made for respirator cleaning and thoroughly
wipe it down, paying particular attention to the areas where moisture is likely
to collect. Disassemble the respirator and wash with warm water and soap weekly
or as required.
This made sense to an impressionable young safety
professional. What's to question? Unfortunately, cleaning with the towelettes
does not meet OSHA requirements, which outlines a prescriptive cleaning
process. According to an OSHA letter of interpretation, the towelettes may be
used during fit testing to clean respirators between the testing of each
employee.
One supplier of respirator cleaner and disinfectant products
once shared a surprising stat. He estimated 70 percent of his clients who used
respirators did not clean them properly.
I had visited a plant with respirator cleaning best practices. At this
plant, employees must wear respirators every day for the entire shift. The
plant created a department for cleaning respirators. Users dropped their respirators
in a bin at day's end. The respirator department used a washing machine
manufactured specifically for respirator cleaning to clean and disinfect the
respirators. Then the respirators would be placed in a dryer. After drying, the
respirators were placed in plastic bags, and finally placed in assigned
lockers. Obviously, the cost to build the washing department and to sustain the
program was significant but it eliminated the problem of employees not cleaning
their respirators and ensured all the respirators were properly cleaned and
disinfected.
Faced with facial hair
According to the respirator standard, the employer shall
ensure the user does not have any facial hair between the sealing surfaces of
the facepiece and the face.
In the U.S., where the "I have a right" attitude
runs rampant, there are recalcitrant individuals who refuse to shave their
beards or whatever hair adorns their face. If wearing a respirator is required
because the permissible exposure limit is exceeded, can you mandate that the
employee shave off his facial hair or face job transfer or even termination?
Respirator Standard 1910.134(d)(1)(iv) says, "The employer shall
select respirators from a sufficient number of respirator models and sizes so
that the respirator is acceptable to, and correctly fits, the user." The
respirator standard is silent about requiring employers to provide a hooded
respirator that accommodates facial hair. Be aware, however, that certain
standards, such as the lead standard, do require employers to provide hooded
respirators if the user so requests.
Verify your practices
If it is true that, as mentioned earlier, so many respirator
users are cleaning their respirators incorrectly, what is the likelihood
something else is wrong with the respiratory protection program? Is it time for
you to check on the accuracy of your program(s)? While you shouldn't doubt
everything you hear from other safety professionals, neither should you assume
things are always correct.
As a safety professional, live by former President Reagan's
words, "Trust, but verify."
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