SHA's revised respiratory protection standard (CFR 1910.134), published Jan. 8, 1998, in the Federal Register, sets out to cure many of the ills of its predecessor. Out-of-date and confusing, the earlier standard often fell short of affording adequate worker protection because it was not clearly understood by the regulated community. With its revised standard, therefore, the agency's goal is to create regulatory consistency and clarify the standard's requirements through specific and detailed methodology and procedures. But, therein lies the rub.

It's all about details

The standard includes a 150-page preamble, definitions of the terminology used in the standard, as well as four appendices describing procedures for fit testing, user seal check, respirator cleaning and the voluntary use of respirators. The first three of these appendices cover mandatory information, while Appendix D is non-mandatory.

Compliance with this new and revised version of the standard requires a careful study of the specifics, some of which are probably already in place if you have a good program, while some may pose a challenge.

The deadline for evaluating workplace hazards and identifying a need for a respiratory program is Sept. 8, and for compliance with all other provisions is Oct. 5. The revised standard applies to general industry (part 1910), construction (part 1926), shipyards (part 1915), longshoring (part 1918) and marine terminal (part 1917) workplaces. It does not apply to the agricultural sector.

Who benefits?

According to the agency's estimates, 75 percent of employees work in places which do not have the elements of an effective respiratory protection program. Proper respirator use will add up to a savings of $94 million in related costs, OSHA says. The cost per employee will be $22 and per establishment, $94.

Most safety personnel have reacted positively to this standard saying it gives them the flexibility to tailor the respirator program to their worksite's particular needs. However, it has also challenged employers in terms of money and production time for training and medical evaluation and raised invasion of privacy issues, according to Frank Perry, director of safety and health at Cameron, in Houston, TX. Much of the rationale and ultimate benefits to workers and employers have been explained in a memorandum dated Aug. 3, posted on the OSHA Web site at: www.osha.gov/wutsnew.html.

Zeroing in on specifics

A written respiratory protection program Using respiratory protection, according to OSHA, should be your last resort. First, you must conduct a detailed hazard evaluation of your facility and determine that other 'preferred preventive measures' - implementing engineering controls, materials substitution, and administrative controls - will not be effective in controlling them. But once you decide to use a respiratory protection program, all of the elements listed in the standard should be put in writing.

What are the elements that should be included? These elements include procedures for

  • selecting respirators,

  • medical evaluations for employees using respirators,

  • fit testing for tight fitting respirators,

  • using respirators in normal and emergency situations,

  • cleaning, disinfecting, storing, inspecting, repairing, maintaining and discarding respirators,

  • ensuring adequate quality and quantity of breathing air,

  • annual training required for respirator use in normal and emergency situations,

  • annual training in respirator use for fit, usage, limits, capabilities,

  • program reevaluation and recordkeeping.

Even if workers are not exposed to contaminants above the PEL limit, whenever an employer requires the use of respirators, there should be a written program.

Who will administer the program? An appropriately trained program administrator must be designated to oversee the program. 'Appropriately trained' means a person with adequate training, knowledge or experience to administer a respiratory protection program depending upon its complexity. The compliance safety and health officer will review the written program and interview the administrator to determine the person's capability to run an effective program. There is no mention of any specific training courses, though.

How often should the written program be updated? Whenever there is a change in workplace hazards, respirator choices, fit testing procedures or the nature of the employees' work, the program must be updated. OSHA is working on a Small Entity Compliance Guide with a sample respirator program to provide employers with guidance on putting a program in place. It will be available at the OSHA Web site at www.osha.gov. According to the agency, under the Small Business Regulatory Enforcement Act, small business owners can use the guide to challenge the appropriateness of an OSHA penalty.

Medical evaluation Only healthcare professionals who are licensed, certified or registered by the state or certification agencies can perform these evaluations. A listing of all state licensing boards and a medical evaluation questionnaire is attached to the memorandum that appears on OSHA's Web site at www.osha.gov/wutsnew/html. An employer can opt to provide a physical exam over a questionnaire as long as it elicits the same kind of information. The cost and time for performing these evaluations must be borne by the employer.

When should the medical evaluation be done? The medical evaluation should be done before any fit test because some employees may not be able to use respirators even for the duration of the test.

Do temporary and seasonal employees need the medical evaluation too? Yes. Any employee who is required by the employer to don a respirator for any period of time needs the medical evaluation.

What about employees who use filtering facepieces (dust masks) voluntarily? If the employer is sure there is no hazard, no medical evaluation is necessary. However the information in Appendix D must still be provided to employees to safeguard against these filtering facepieces from becoming hazards in themselves.

What if an employee declines to undergo a medical evaluation? Then they must provide a medical evaluation to the employer. Otherwise, they cannot continue to use a respirator. Also, it is the employer's responsibility to see that the employee understands the questionnaire and provide the necessary help in interpreting the questions if the employee cannot read English.

Fit testing, selecting, using and maintaining respirators The revised standard requires all respirators to be NIOSH-approved (42 CFR Part 84). Also, employers must store various sizes, models and types to ensure the best fit.

When should the fit test be conducted? Fit testing with the same respirator that the employee will use must be conducted prior to the initial use. It is mandatory to have a fit test in the negative and positive pressure mode for employer-required tight-fitting respirators, SCBAs, and whenever the employee uses a new respirator. It is not necessary, however, to conduct a fit test for respirators worn voluntarily. A user seal check, which an employee performs each time the respirator is worn, does not suffice as a fit test.

What kind of fit test methods should be used? Acceptable fit test protocols are listed in Appendix A of the standard. If you have a new fit testing method, you must submit a detailed description to OSHA. Then the agency will initiate rulemaking to add this to the respiratory protection standard.

When do you require a quantitative fit test? Most experts agree that the quantitative method is more reliable and accurate than the qualitative method which relies on the wearer's sense of smell or taste. OSHA says, if the required fit factor is greater than 100 for any tight fitting full or half-face mask, a quantitative fit test should be performed. Exercises required for both qualitative and quantitative fit testing under the revised standard are: normal breathing, deep breathing, moving head from side to side, and up and down, talking out loud, bending and grimacing (only for quantitative).

Can a probe hole be drilled into a facepiece and then be sealed so that the respirator can be used? No. Once the probe hole is drilled the respirator cannot be restored back to its NIOSH-approved configuration.

Why has OSHA withheld its statement on APFs (assigned protection factors)? Assigned Protection Factors are numerical ratings given to respirators that tell users how much protection they provide. While OSHA plans to address this in a later rulemaking activity, for now it advises employers to go by the NIOSH APFs, except where they are included in substance-specific standards.

What immediately dangerous to life and health (IDLH) limits will be used by OSHA for enforcement purposes? The 1990 recommended values found in the "NIOSH Pocket Guide to Chemical Hazards" may be used to support enforcement action. But an employer can show another source to be valid, as well.

Who must comply with the two-in and two-out rule during rescue operations? It applies to private sector firefighters such as those in industrial fire brigades and private fire companies.

The two-in two-out rule only applies to interior structural firefighting and not to incipient stage firefighting. The difference is decided by the commander. Also, the rule applies only when the firefighters are actually engaged in interior structural firefighting. OSHA specifies that this does not mean fire departments should hire additional firefighters, or that there should be four-person companies. The requirement only means that there should be at least four men before initiating an interior attack on an interior structural fire.

Who should clean and maintain the respirators? The cleaning, disinfecting and repair of respirators should be done by those who are trained in the proper procedures. It should be checked and cleaned as often as is necessary for it to function properly.

Training Overall, the respirator standard is performance-based, which means the employees who use the respirators should be able to demonstrate their knowledge of how to use, clean and maintain the respirator they use, as well as know its limits and capabilities, especially in emergency situations. This can be tested either by asking questions or observing the use.

What are the elements of the annual retraining? Training elements will vary according to a worksite's particular need, and the extent of the information necessary for workers to handle the respirators in relation to their job functions.

Besides annually, when else is retraining necessary? Whenever there is a change in the level of workplace hazards, or when the respiratory protection program is updated or when an employee has not understood the program sufficiently enough. Employees who wear respirators voluntarily need to receive the basic information only initially.

Program evaluation

How frequently should the respirator program be re-evaluated? Frequency of respirator program evaluation will depend upon the complexity of the program; changes in workplace hazards, processes and operations; types of respirators used; and worker experience in respirator use. When conducting periodic assessment of the program, you would need to ask employees about any difficulties related to respirator use such as breathing, hearing, vision, communication, restriction of movement or any sort of discomfort.

Industry concern One significant compliance challenge centers around the end-of-service-life indicator (ESLI). According to the revised standard, air purifying respirators can be used against harmful gases and vapors only if the chemical cartridge is equipped with the end-of-service-life indicator or the employer provides a change-out schedule based on 'objective data.' Since OSHA has not defined 'objective data,' and there is no substantial supporting information with the manufacturers, this clause has created some concerns among both the manufacturers and end-users.

A letter from the Industrial Safety Equipment Association to OSHA chief Charles Jeffress requests a two-year stay of this requirement until a "reproducible scientific method for determining breakthrough times can be established and until a significant database of objective data is compiled."

At the public meeting held Aug. 6, in Washington, D.C., on respirator cartridge/canister change-out schedules, according to Tom Nelson, independent consultant and a member of American Industrial Hygiene Association's Respiratory Committee, OSHA seemed to indicate that come Oct. 5, a good faith effort is what the agency will look for. Much is dependent upon exercising good professional judgment and due care.

Again, it's first about attention to details.

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