Respiratory Protection Program Requirements Purpose Scope and Application

Transcription

1 Respiratory Protection Program Requirements Purpose Scope and Application Respirators are required when air contamination cannot be reduced to acceptable levels with engineering or administrative controls. All of 29 CFR applies where respirators are required to protect employee health. Paragraph (c)(2) of 29 CFR applies when respirators are used but their use is not required by OSHA. Users must be medically evaluated, respirators must be maintained, and users need to be provided with Appendix D of 29 CFR titled Information for Employees Using Respirators When Not Required Under the Standard. Background This safety requirement and procedure is established in accordance with Occupational Administration for General Industry 29 CFR Requirement It is the requirement of the State to provide a place of employment that is free from recognized hazards that cause or are likely to cause death or serious physical harm to employees or the public. The purpose of these requirements is to provide guidance to those responsible for administering a respirator program and for complying with the revised OSHA respirator standard, 29 CFR , adopted April 8, These requirements should be applied with flexibility according to the specific situation and the operation performed. Program Respiratory Protection Program The standard requires the employer to appoint a program administrator to carry out a written respiratory protection program for: Selection of respirators Medical evaluation Fit testing Use Maintenance Air supply Training about hazards Training in proper use Evaluation of effectiveness There is a requirement that the respiratory program administrator be qualified based on education and experience that is commensurate with the program s complexity, ability to administrate or oversee the program and conduct required evaluation. 1

2 of Respirators Selection of Respirators Requires employers to: Identify air contaminants and estimate exposure. Consider the atmosphere to be immediately dangerous to life or health (IDLH) when exposures cannot be reasonably estimated. Select respirators based on estimated exposures and on user and workplace factors that affect respirator performance and reliability. Select only NIOSH-certified respirators. The proper selection of respiratory protection can be found in the NIOSH 2004 document RESPIRATOR SELECTION LOGIC. IT CAN BE FOUND ON LINE AT document. Select sufficient models and sizes so respirators fit and are acceptable to users. Requires employers who provide respirators for IDLH atmospheres to: Select (1) a full-facepiece pressure demand self-contained breathing apparatus (SCBA) good for at least 30 minutes or (2) a full-facepiece pressure demand supplied-air respirator (SAR) with auxiliary self-contained air supply. Select respirators used only for escape from IDLH atmospheres that are certified for escape from the atmosphere in which they will be used. Select any SCBA or SAR for oxygen deficient atmospheres if the percent oxygen can be expected to remain in a specified range. The range depends on the elevation; e.g., at less than 3,001 feet it is 16.0% to 19.5% and between 7,001 and 8,001 feet it is 19.3% to 19.5% Requires employers who provide respirators for non-idlh atmospheres to: Select respirators based on the chemical state and physical form of the contaminant. Select a respirator which has an Assigned Protection Factor (APF) that will reduce the exposure to an acceptable level. OSHA has published the APR in a table in the latest standard publication. Select (1) an atmosphere-supplying respirator or (2) an air purifying respirator (APR) for protection against gases and vapors. Select an APR that has (1) an end-of-service-life indicator (ESLI) or (2) when no ESLI is available carry out a change schedule for canisters and cartridges and document the data used to establish the change schedule in the respirator program.

3 Requires employers who provide respirators for protection against particulates to select: An atmosphere-supplying respirator. An APR with a high efficiency particulate air (HEPA) filter. PAPRs will continue to be equipped with HEPA filters. NOTE THAT NIOSH AND OSHA ARE NOT USING THE TERM HEPA BUT RATHER THE N-100 R-100, AND P-100 WITH 99.97% EFFICIENCY. MANUFACTUERS AND OTHERS STILL MAY USE THE HEPA TERM SO UNDERSTANDING WHAT IT MEANS IS IMPORTANT. An APR with a filter certified under 42 CFR CFR 84 sets forth 9 classes of airpurifying particulate (aerosol) respirators; the N-, R-, and P- series with 3 levels of filtration efficiency in each series (99.97, 99, and 95%). The N series can be used only for non-oil aerosols. The R-series can be used for all aerosols providing the filter is not used more than 8 hours. The P-series can be used for all aerosols and there are no time limitations. Breathing resistance increases as efficiency increases. An oil aerosol in the work environment is anything that generates a liquid hydrocarbon aerosol (most commonly a mineral or vegetable oil) must be assumed to have the potential to function as an oil as far as coating a filter medium and causing efficiency degradation. The applications for each filter designation are set forth in the NIOSH Selection and Use of Particulate Respirators. A free copy can be obtained by calling NIOSH. N Non-resistant to oil; N-100, N-99 & N-95 P Partially resistant to oil;p-100, P-99 & P-95 R Resistant to oil; R-100, R-99 & R-95 FOR PRACTICAL MATTERS MOST OF THE RESPIRATORS AVAILABLE ARE THE N SERIES WITH N-95 AND N-100 THE MOST UTILIZED. THE R SERIES IS USED WHERE THERE IS AN OIL AEROSOL IN THE WORK ENVIRONMENT. Medical evaluation Medical Evaluation Requires medical evaluation of all respirator users. While most healthy workers do not have problems wearing a respirator when it is properly chosen and fitted, some workers do have problems that affect their ability to wear respirators such as: Claustrophobia Conditions causing nasal discharges Cardiovascular/respiratory diseases Requires the employer to select a Physician or a Licensed Health Care Professional (PLHCP) to: Evaluate the employee s answers to the questionnaire in Appendix C of or conduct an initial medical examination of the employee that obtains the same information as the questionnaire before the employee wears a respirator. Conduct a follow-up medical examination if the responses to the questionnaire or the results of the initial examination indicate a need for one.

4 Submit a written recommendation to the employer and to the employee regarding limitations on respirator use and the need for follow-ups, if any. Reevaluate the employee if there are changes in his condition or in conditions in the workplace that could affect respirator selection and use. Also requires the employer to provide the PLHCP with information about the employee s working conditions and use of respirators and other personal protective equipment together with a copy of the employer s respiratory protection program and a copy of Include the type of respiratory protection to be used, length of use, physical activity of the work and the environmental conditions which the employee may be subject to. Also, include any PPE that will be used while wearing the respirator. NOTE: THE LICENSED HEALTH CARE PROFESSIONAL SHOULD BE MEDICAL DOCTOR, OCCUPATIONAL HEALTH NURSE OR PHYSCIAN ASSISTANT. DO USE A DENTIST, CHIROPRACTOR, MASSAGE THERAPIST, OCCUPATIONAL THERAPIST OR PHYSICAL THERAPIST. Fit Testing Fit Testing Requires fit testing of employees required to wear respirators with negative or positive pressure tight-fitting face pieces before initial use and at least annually thereafter. Nonscheduled testing when physical changes or changes in work practices or conditions occur that could affect respirator use. Appendix A sets forth both qualitative and quantitative methods of fit testing. Qualitative tests use agents detectable by irritant properties, taste, or smell irritant smoke, saccharin, Bitrix and isoamyl acetate. Use organic vapor cartridges with isoamyl acetate, high efficiency filters with irritant smoke, and an approved particulate filter (any class) with saccharin and Bitrex. Qualitative tests have limitations related to sensitivity of test subjects. Quantitative tests determine the ratio of the average known concentration of a test agent outside the face piece and the average concentration inside the facepiece. Only the acrylonitrile standard requires that quantitative fit testing be done for all respirators. Other acceptable quantitative methods include a respirator leak test and the use of a particle counter. Since respirator effectiveness relies on a face piece to face seal (including supplied air respirators fitted with emergency back-up filters), OSHA forbids fit tests if there is hair growth between the skin and face piece sealing surface, such as stubble beard growth. Leaks due to beard growth can shorten the service life of the air supply, especially if the wearer over breathes when doing heavy work. Over breathing can also pull air contaminants inside the face piece if there is a leak Furthermore, a beard can interfere with the sealing of the exhalation valve. Use of Respirators Use of Respirators The proper use of a respirator is used when engineering controls are not feasible or have not yet been put in place or in emergency situations where a material cannot be fully contained and employees must be in a zone of contamination. If handling a chemical truly

5 merits a respirator, the correct procedure is to use closed handling with a glove bag, fume hood, local exhaust, etc. Either that, or modify the material or the procedure. Requires that employers make sure that: Employees with facial hair or other conditions that prevent a seal or cause valves to malfunction do not wear tight fitting respirators. PPE such as corrective glasses or goggles do not interfere with the seal. Respirator users must check the seal of the face piece each time they don their respirators using the procedures in Appendix B-1 of Users be observed for changes in exposure and for signs of stress. Users are permitted to leave the respirator area to: Wash their faces as necessary to deal with potential health problems of skin irritation and contamination. Change filters/cartridges when breathing resistance indicates that the load on a particulate filter may be approaching capacity or as determined to be changed based on level of exposure. Chemical cartridges are subject to change out based on an end of service life indicator (ELSI) on the cartridge or by estimating the change out before contaminant breaks through the absorbing material. Where an ELSI is not available the two acceptable methods of determining when to change out the cartridges are: (1) using data from the manufacturer to determine break through based on exposure levels and breathing rate (work activity);(2) modeling the exposure and estimating when to change the cartridges. This will require the input from an industry hygienist who is familiar with the chemical, exposure parameters, contaminant emissions, mixtures and modeling techniques to include their deficiencies. Replace respirators that are no longer in their original working condition; e.g., a strap breaks, the respirator loses its shape, or the seal can no longer be maintained. If users detect breakthrough, changes in breathing resistance, or leakage of the face piece, respirators are replaced or repaired. Requires employees to enter IDLH environments the employer shall: Train and equip employee(s) stationed outside the IDLH atmosphere for emergency rescue and make sure they maintain communication with employee(s) inside the IDLH atmosphere. Equipment consists of SCBAs or supplied-air respirators with auxiliary SCBA and appropriate retrieval equipment. Make sure persons trained to provide assistance are notified before emergency rescue is carried out. OSHA requires when employees fight interior structural fires the employer:

6 Assign at least two SCBA-equipped employees inside the IDLH atmosphere and that they remain in contact with each other. Assign at least two SCBA-equipped employees outside the IDLH atmosphere. Maintenance and Care of Respirators Maintenance and Care of Respirators Failure to clean and disinfect respirators can: Cause skin irritation and dermatitis Reduce the protection factor Lead to deterioration of materials Respirators be cleaned and disinfected using the procedures in Appendix B-2 of : Respirators need to be cleaned after each use by following the manufacturer s procedures. After each use if used routinely by more than one employee. After each use if maintained for emergency use. After each use if used in fit testing and training. Respirators should be assigned to each employee for their exclusive use by the employee. Requires that respirators be packed or stored in a manner that will prevent deformation and protected from damage, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals. Routinely used respirators may be stored in plastic bags. Emergency respirators need to be stored according to the manufacturer s instructions, must be accessible to the work area, and if kept in compartments, the compartments need to be clearly marked. Inspection of respirators: Before each use and during cleaning when used routinely. At least monthly when used for emergencies and checked for proper function before and after each use. Before being carried into the workplace if used for emergency escape. At least monthly for all SCBAs. Minimum requirements that the inspection consist of checking the: Respirator function

7 Tightness of connections Condition of the face piece, head straps, valves, connecting tube, and filters Pliability and signs of deterioration of rubber and elastomer parts Requires monthly checks of air and oxygen cylinders to make sure that: They are maintained in a fully charge state and recharged when the pressure falls to 90% of the manufacturer s recommended pressure level. The regulator and warning devices function properly. Employers shall certify respirators maintained for emergency use by: Documenting the date the inspection was performed, the name of the inspector, the findings, required remedial action, and identification of the inspected respirator. Placing current inspection information on a tag or label kept attached to or kept with the respirator or filed with inspection reports. Repairs or adjustments be made only by persons trained to perform them using parts designed for that respirator. Furthermore, only the manufacturer or a technician trained by the manufacture can adjust or repair reducing and admission valves. Breathing Air Quality and Use Breathing air meet the requirements for the Type 1-grade D air classification in the ANSI/Compressed Gas Association Commodity Specification G This means that the oxygen content must be between 19.5 to 23.5% by volume, and that these concentrations must not be exceeded: Hydrocarbons, 5 milligrams per cubic meter of air Carbon monoxide, 10 parts per million (ppm) in air Carbon dioxide, 1,000 ppm Plus there must be lack of noticeable odor prohibits use of compressed oxygen in atmosphere-supplying respirators or in open circuit SCBAs that have previously used compressed air and limits use of oxygen concentrations greater than 23.5% to equipment designed for oxygen service or distribution. The standard permits breathing air to be provided from cylinders or compressors. Cylinders need to be tested and maintained according to the Shipping Container Specification Regulations of the Department of Transportation (49 CFR Parts 173 and 178). Cylinders must: Be certified by the supplier Meet the requirements for type 1-Grade D air

8 Contain air that has a moisture content that does not exceed a dew point of minus 50 degrees F at 1 atmosphere pressure Exhaust gases from internal combustion engines and the intake of contaminated air are major threats to breathing air quality. Compressors be designed and situated so: Contaminated air cannot enter the air supply system. This is especially important when compressors are powered by internal combustion engines because of possible re-entrainment of exhaust gases from the engines. Ensure that air line couplings are incompatible with outlets for non-respirable worksite air or other gas systems and ensure that asphyxiating substances are not introduced into breathing air lines. The moisture content of compressed air is low enough so that the dew point at 1 atmosphere pressure is 10 degrees F below the ambient temperature. In-line air-purifying sorbent beds and filters are in place to clean the air and assure breathing air quality. They are tagged to show the most recent change date and signature of person authorized to perform the change. Carbon monoxide levels do not exceed 10 ppm in air from non-lubricated compressors. Oil-lubricated compressors are equipped with a high-temperature or carbon monoxide alarm, or both. If only high-temperature alarms are used, employers need to monitor the air at intervals sufficient to prevent carbon monoxide from exceeding 10 ppm Breathing gas containers marked according to NIOSH respirator certification standard, 42 CFR 84, are used. Identification of Filters, Cartridges, and Canisters Cartridges and canisters be color coded labeled and with the NIOSH approval label. Training All employees required by OSHA to use respirators receive instruction before use and as needed or at least annually thereafter including demonstrations and practice in how the respirator should be worn, how to adjust it, and how to determine if it fits properly. Employees who wear respirators when not required to by OSHA need to be provided with the information in Appendix D of , either orally or in writing. Training shall include information about:

9 Why the respirator is necessary and how improper fit, usage, or maintenance can compromise its protective effect. Limitation and capabilities of the respirator. How to use the respirator in emergency situations (including respirator malfunctions), how to inspect, put on and remove, use, and check the seals. Procedures for maintenance and storage. How to recognize medical signs and symptoms that may limit or prevent use. The general requirements of Since training for hazard communication overlaps respirator training, combining hazard communication and respirator training has advantages. Program Evaluation Program Evaluation The respiratory protection program requires the administrator to: Review the program at least annually. Conduct frequent random inspections of the workplace to make sure that the provisions of the program are being properly carried out. Consult users to learn if they have problems with their respirators such as comfort, resistance to breathing, fatigue, interference with vision or communication, restriction of movement, interference with job performance, and confidence in the respirator s effectiveness, and that they are using the correct respirator and the respirator is properly maintained. See that problems are corrected. Recordkeeping Recordkeeping The employer needs to maintain and make available: Medical and monitoring records according to 29 CFR Recordkeeping is covered in a separate requirement titled Recordkeeping. Fit test records from one fit test to the next. Fit test records need to include: Name of employee Type of test Make, model, style, and size of respirator tested Date of test Pass/fail results

10 A copy of an updated written respirator program Specific applications and requirements Specific Applications and Requirements Nuisance particulates This standard does not apply to employees who wear dust masks for protection against nuisance particulates. Surgical masks if used for infection control are covered by specific standards. These masks do not need to display a NIOSH-certification notice because they are not designed for protection against harmful air contaminants. The filtration efficiency is lower than approved respirators and the face seal around the nose and mouth is less effective. They can provide relief from irritation of the nose, mouth, and throat caused by non-hazardous dusts and are appropriate for use against large particles, such as those from mowing grass or sweeping floors. Use of these non-certified dust masks where potentially hazardous exposures exist is, are a violation of the OSHA respirator standard. Surgical masks used by employees as part of a blood borne pathogen program are not designed or certified as respiratory protective devices. Surgical masks are used to protect the user against blood splatters and splashes on the skin or mucous membranes of the face and upper respiratory tract. Pesticides Pesticide users need to get the information about which respirator to use from the vendor. In July, 1995, NIOSH ruled that the pesticide respirator was unacceptable because it was never tested against pesticides. Now it s left up to the user to call the vendor and find out the type of respirator that s needed, e.g., one protective against acid gases, acid gases and organic vapors, chlorine gas, organic vapors, ammonia gas, carbon monoxide, hydrocyanic acid gas, or particulates or a combination of these air contaminants. Viruses and the tuberculosis bacillus The P-100 filter will protect against the Hantaan virus which is transmitted by saliva and excreta of infected rodents. Viruses are in the range of 0.5 to 1.0 microns in size. The N-95 filter will protect against tuberculosis. As long as there is no oil mist, reuse is limited only by considerations of hygiene, damage, and breathing resistance. A respirator classified as disposable may be reused by the same health worker as long as remains functional. Asbestos, lead, arsenic, cadmium, benzene, cotton dust, formaldehyde, methylenedianiline, and 1,3-butadiene The OSHA asbestos, lead, arsenic, cadmium, benzene, cotton dust, formaldehyde, methylenedianiline, and 1,3-butadiene standards require that powered air purifying respirators be given to employees who request this type of respirator, as long as they provide adequate protection. PAPRs provided to asbestos workers must be of the tightfitting type. OSHA Standards That Contain Respirator Requirements That Were Revised As A Result of the 1998 Revision to 29 CFR : Fire brigades Welding, cutting, and brazing

11 Pulp, paper, paperboard mills and Asbestos carcinogens Vinyl chloride and Inorganic arsenic and Lead and Cadmium Benzene and Coke oven emissions Cotton dust and Acrylonitrile and Ethylene oxide and Formaldehyde and Methylenedianiline ,3-Butadiene Methylene chloride Ventilation Respiratory protection Underground construction Resources OSHA Standard for Respiratory Protection 29 CFR