Respiratory Protection Practices
May 1, 2008
Safety is 99 percent common sense â€” 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 fitA 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 â€” if not closer to 20 minutes â€” per person.
Let the record showâ€¦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 complianceA 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 hairAccording 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 practicesIf 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."