A P P E N D I X 14 RESPIRATORY PROTECTION PROGRAM AP14.1. Purpose. AP14.2. Policy. To establish a written Respiratory Protection Program for CBP. The purpose of an effective respirator program is to provide information and guidance on the proper selection and use of respirators; define and monitor the use of respiratory equipment; comply with OSHAʼs respiratory protection standard; and to provide respirators that are applicable and suitable for the purpose of providing necessary protection to employees. It is the policy of CBP that respirators will be issued and used where engineering controls, administrative controls, or process design cannot reduce contaminant exposure levels to the lowest feasible level. When effective engineering controls are not feasible, appropriate respirators shall be used pursuant to the requirements of this policy as necessary to protect the health of the employee. AP14.3. Responsibilities. AP14.3.1. Management: a) Respirators shall be provided by the employer when they are necessary to protect the health of the employee. b) Respirators will be provided which are applicable and suitable for the intended purpose. c) Management shall be responsible for the establishment and maintenance of a respiratory protection program. Written program must be reviewed and approved by a qualified industrial hygienist in the Safety and Occupational Health Branch, or contract Industrial Hygienist selected by the SOHB, prior to implementation. d) Management shall determine and maintain appropriate surveillance of work area conditions and the degree of employee exposure or stress. e) Management shall assign responsibility and authority for administration of the respirator program to one individual. f) Field office managers shall contact the HRM, Safety and Occupational Health Branch for assistance in developing a site-specific program. 183
(Note to Respirator Plan Writer: Designate in writing here who in your local organization will be responsible for maintaining records, evaluating program effectiveness, measuring or estimating concentration of airborne contaminants in the work area prior to respirator selection, and selection of the appropriate type or class of respirator. In other words, name the title of the individual, such as the Collateral Duty Safety Officer or the Chemical Hygiene Officer or other individual, with these responsibilities.) AP14.3.2. Employee responsibility a) The employee shall use the respiratory protection in accordance with instructions and training received. b) The employee shall clean and maintain their respirator in accordance with this policy, and manufacturerʼs recommendations. c) The employee shall report any trouble or malfunction of the respirator to the supervisor. d) The employee shall report to the responsible person any change in his/her medical status that may impact the employeeʼs ability to wear a respirator safely. AP14.4. Selection, Issuance and Training Practices AP14.4.1. Selection a) Respirator type and make will be selected by the Area Safety and Occupational Health Manager. (Note to Respirator Plan Writer: Add here the specific designation of responsible party at your location) Respirator selection involves reviewing each operation to determine what hazards may be present, and then selection of the correct type or class of respirator that will offer adequate protection. b) Only respirators approved by NIOSH will be used. Guidance will be from ANSI Z88.2-1992, American National Standards Institute Practices for Respiratory Protection. c) The proper type of respirator for the specific hazard will be selected in accordance with the manufacturersʼ instructions. AP14.4.2. Issuance of Respirators a) Management reserves the right to determine if a respirator is needed. b) Air sampling data will be taken and shall be the determining factor in case of a disagreement between employee and employer. Air sampling is generally not required unless it is suspected that an OSHA Permissible Exposure Limit (PEL) may be exceeded from use of a chemical or physical agent. 184
c) Employees may be required to wear breathing zone sampling to determine the need for respiratory equipment. d) Any respirator equipped with a tight fitting face piece shall not be worn if facial hair comes between the sealing surface of the face piece and the face, or if facial hair interferes with valve function. AP14.4.3. Training Requirements a) Supervisor(s), person(s) issuing respirators, and respirator wearers shall be provided training by a qualified person to ensure proper use of respirators. Written records shall be maintained that give the names of persons trained, the dates and type of training (including a reference of where to find training content), when the training occurred, and the name of the instructor. b) Supervisors will receive adequate training, including the following minimum elements: (1) Basic respiratory protection practices; (2) The nature and extent of respiratory hazards to which persons under his/her supervision may be exposed; (3) Recognition and resolution of respirator use problems; (4) Principles and criteria for selecting respirators used by persons under his/her supervision; (5) Training of respirator wearers; (6) Fitting and issuance of respirators; (7) Inspection of respirators; (8) Use of respirators, including monitoring of use; (9) Maintenance and storage of respirators; (10) Regulations concerning respirator use. c) The person assigned the task of issuing respirators shall be given adequate training to ensure that the correct respirator is issued for each application in accordance with written standard operating procedures. d) To ensure the proper and safe use of a respirator, the minimum training of each respirator wearer shall include the following elements: (1) The need for respiratory protection; (2) The nature, extent, and effects of respiratory hazards in the workplace; (3) The need to inform their supervisor of any problems experienced by them or their co-workers; 185
(4) An explanation of the use of engineering controls in relation to respirator use; (5) An explanation of why a particular type of respirator has been selected for a specific respiratory hazard; (6) An explanation of the operation, capabilities, and limitations of the respirator selected; (7) Instructions for inspecting and donning the respirator. This includes a requirement that a fit check shall be done each time the respirator is donned or adjusted; (8) Successful completion of a fit test in accordance with Z88.2-1992; (9) An explanation of how to maintain and store the respirator; (10) Instructions in emergency procedures and the use of emergency escape devices; (11) How to recognize medical signs and symptoms that may limit or prevent effective use of respirators; (12) Regulations concerning respirator use. e) Training will include the opportunity for the employee to handle the respirator, wear it in normal air for a long familiarity period, and wear it in a test atmosphere per instructions for fit testing described below. f) Training will be repeated annually for all employees required to wear respirators. AP14.4.4. Operating Procedures. AP14.4.5. Fit-Testing. a) The employer will provide for the proper storage and cleaning of respirators. b) Respirators must be stored in the proper area when not in use. c) Tight fitting respirators may not be worn when conditions prevent a good face seal (such as a beard). d) Before using a respirator, the employee must inspect for tightness of fit and proper mechanical functions, if applicable. a) A qualitative or quantitative respirator fit test shall be used to determine the ability of each individual respirator wearer to obtain a satisfactory fit with a tight-fitting respirator. b) If a quantitative fit test is used, a fit factor that is at least 10 times greater than the assigned protection factor of the negative pressure respirator must be obtained before that respirator is assigned to an individual. If a qualitative test is used (use of irritant fume, isoamyl acetate, or saccharin 186
solution protocols), only validated protocols of the test agents are acceptable (protocol of 29 CFR 1910.134, Appendix A). Successful completion of a qualitative fit test allows use at 10 times greater than the assigned protection factor for the respirator. c) A fit test shall be repeated annually and whenever a change may affect the face seal, such as a significant change in weight (10% or more), significant scarring in the area of the faceseal, dental changes, reconstructive or cosmetic surgery, or any other condition. d) No one size or model of respirator will fit all types of faces, therefore different models and sizes of respirators should be available for selection during fit-testing. e) Fit test procedures will be in accordance with 29 CFR 1910.134. f) Fit-test records will document the following: (1) Written SOPs for the respirator fit test program including pass/fail criteria; (2) Type of respirator fit test(s) used, including the specific fit test protocol; (3) Name or identification of the test operator; (4) Specific make, model, and size of the exact respiratory device tested; (5) Date of the test; (6) Success or failure to obtain a satisfactory fit; and (7) Any special considerations or difficulties in wearing (contact lenses or glasses worn, dentures, etc.) g) Prior to use of a respirator in the workplace, each employee should test the respirator for proper face to face seal fit by performing a positive and negative pressure test of the respirator, as follows: (1) Positive pressure test (a) Cartridge respirator With the face piece in proper position, close or cover exhalation valve. Breathe into the mask. A satisfactory fit is achieved if pressure can be built up in the face mask. (b) Disposable respirator With the respirator in the proper position, cup your hands over the outside surface area of the respirator in an attempt to cover as much surface area as possible. An adequate fit is achieved if pressure can be built up in the face mask. 187
(c) Emergency Respirator (SCBA) With the face piece in proper position, check the seal by closing of the inhalation tube with your hand and slowly exhale. An adequate fit is achieve is pressure can be built up in the face mask. (2) Negative pressure test (a) Cartridge Respirator Block cartridge intake areas with your hands or remove cartridges and close or cover inlet valves. Inhale to build a vacuum. If vacuum is maintained for approximately 10 seconds, a satisfactory seal is achieved. (b) Disposable Respirator With the respirator in the proper position, cup your hands over the outside surface area of the respirator in an attempt to cover as much surface area as possible. An adequate fit is achieved if a slight vacuum can be felt inside the mask, with the air not rushing in around the face seal. (c) Emergency Respirator (SCBA) With the face piece in proper position, check the seal by closing off the inhalation tube with your hand and slowly inhale. No leakage should be detected and a vacuum should be noticed by the face piece being drawn onto or close to the face. h) Voluntary use respirators. Dust mask (filtering facepiece) respirators may be used for comfort provided that they are not being used in situations that require the use of a respirator. Dust mask respirators used for this purpose must be kept clean and worn according to the manufacturerʼs instructions. Employees who voluntarily use a dust mask respirator will be given a copy of 29 CFR 1910.134, Appendix D. Medical examinations and fit testing are not required for voluntary use dust mask respirators. Voluntary use of respirators other than dust mask (half-mask, full-face, etc.) requires a written program to establish and implement the medical requirements, and cleaning, maintenance, and storage aspects of the program as a minimum. i) Escape-only respirators. Escape-only respirators only need to be inspected prior to being brought into the workplace. No additional requirements are necessary. Escape-only respirators may not be used for protection during planned entry or response into a hazardous atmospheric environment. 188
AP14.4.6. Maintenance and Care. a) Inspection: (1) Respirators shall be properly maintained to retain its original effectiveness. (2) Filters with end of life indicators will be used when possible. When other filters are used, a schedule for filter changes will be established using manufacturer recommendations. (3) Inspection for Defects: (a) All respirators shall be inspected by the user before and after each use. A respirator that is not routinely used but is kept ready for emergency use shall be inspected by the user after each use and at least monthly to insure that it is in satisfactory working condition. (b) Self-contained breathing apparatus shall be inspected monthly. Air and oxygen cylinders shall be fully charged according to the manufacturerʼs instruction. (c) Respirator inspection shall include a check of the tightness of connections and the condition of the face piece, headbands, valves, connecting tube, and canisters. Rubber or elastomer parts shall be inspected for pliability and signs of deterioration. (4) A record shall be kept by the supervisor of inspection dates and findings for respirators maintained for emergency use. (5) Repairs: Replacement or repair shall be accomplished only by experienced persons with parts designed for the respirator. No attempt shall be made to replace components or to make adjustment on repair beyond the manufacturerʼs recommendations. b) Cleaning and Disinfecting (1) Routinely used respirators shall be cleaned, and disinfected after each use, or as frequently as necessary to insure that proper protection is provided to the wearer. In general, use of disposable particulate respirators may be reused if the shape and effectiveness has not been compromised to prevent an effective face to face piece seal. If the respirator wearer determines that the disposable respirator will not afford the proper protection and cannot be reused for any reason, the respirator will be discarded. 189
(2) Respirators maintained for emergency use shall be cleaned and disinfected after each use. Emergency use and cartridge respirators must be inspected before and after each use. Emergency respirators will also be inspected on a monthly basis to assure they are functioning properly. (3) Cleaning procedures for emergency and cartridge respirators should include the following (or follow manufacturer recommended procedures): (a) Wash face piece assembly with soap or detergent solution and thoroughly rinse in clean water. (b) Rinse face piece by flushing with clean water. For emergency use respirator, flush water through breathing tube. (c) Disinfect the face piece in accordance with guidelines contained in Appendix B-2 of 29 CFR 1910.134. (d) Rinse and allow to air dry completely. (e) Inspect all parts and replace as necessary. (f) Reassemble and replace cartridge and/or air cylinder. (g) Store per recommendations provided by the manufacturer. c) Repair of Respirators: Emergency and cartridge use only. All repairs are to be made by the Safety Officer using only manufacturerʼs recommendations or parts. AP14.4.7. Storage of Respirators a) Respirators must be stored in a manner that will protect them against physical and chemical agents such as vibration, shocks, sunlight, heat, extreme cold, excessive moisture, or damaging chemicals. Respirators must be stored to prevent distortion of rubber or other elastomeric parts. (Note to Respirator Plan writer: Describe specific storage locations at your worksite) b) All disposable respirators shall be stored in the manufacturerʼs container, free from contaminants. If a disposable respirator will be reused (routine use), it should be stored in a plastic bag. 190
c) Emergency and cartridge respirators shall be stored in a highly visible and accessible area near the workstation and clearly marked for such usage. Instructions for proper storage of emergency respirators, such as a self-contained breathing apparatus, are found in use and care instructions usually mounted inside the carrying case lid. d) All respirator storage will be stored in a convenient, clean and sanitary location. AP14.4.8. Medical Limitations. a) Persons will not use respirator protective equipment unless they have been found to be physically capable of doing so. (1) Initial and periodic examination should be conducted by a physician to determine the wearers physical ability. (2) The questionnaire from 29 CFR 1910.134 will be used by the physician to determine past medical history to make an informed judgement of an individualʼs ability to wear a respirator. (3) If the physician determines that a physical examination is needed for an informed determination, or due to questions to responses on the questionnaire, the examination will be conducted during working hours (or compensation afforded to the employee), and all costs borne by the employer. (4) A physicianʼs statement that the employee may use a respirator or that the employee should not be allowed to use a respirator will be provided in writing and maintained by the employer. (5) The employee will be advised of the results of the medical examination within 30 days of receiving their physical. AP14.4.9. Emergency Use/Contaminated Atmosphere. a) During normal work activity, no toxic atmospheres should be present as long as established work procedures are being followed. b) In emergency situations where an atmosphere exists in which the wearer of the respirator could be overcome with a toxic or oxygen deficient atmosphere, do not enter the space unless the following procedures are followed. 191
(1) Never enter a dangerous atmosphere without first obtaining the proper respirator and permission to enter from the safety coordinator or responsible individual familiar with the hazards involved and the requirements for confined space or immediately dangerous to life or health (IDLH) requirements. (2) Never enter a potentially dangerous atmosphere without an additional person present. That person must remain in a safe atmosphere. (3) Communications must be maintained between both persons. (4) The person or persons remaining in the safe atmosphere must have the proper reserve equipment to enable him/ her to aid the person in the dangerous atmosphere if problems arise. (5) In general, no entry will be made into a potentially dangerous atmospheric space unless all prior contingencies have been arranged (e.g., prior training, assurance of OSHA compliance, proper notifications, etc.). c) A Confined Space Program must be followed for all areas meeting the definition of a confined space, in accordance with OSHA standard 29 CFR 1910.146. See Appendix 11 for guidance on confined space entry program requirements. AP14.5. Control and Evaluation of Respirator Program. In order to maintain an effective respiratory protective program, control and feedback on how the program is functioning, is necessary. a) Wearer Acceptance: The employee is required to report to the Safety Officer any concerns with the following regarding respirator use: (1) Comfort. (2) Ability to breathe without objectionable effort. (3) Adequate visibility under all conditions. (4) Ability to perform all tasks without undue interference. (5) Confidence in face piece fit. 192
b) Examination of respirators in use AP14.6. References. (1) Even though a respirator may be worn conscientiously, the protection provided is no better than the respirator in use. (2) Inspections, at least once a month and after each use, shall be conducted by a qualified individual to assure that emergency use respirators are properly selected, used, cleaned and maintained. Records of monthly inspections will be maintained. OSHA Respiratory Protection Standard, 29 CFR 1910.134; American National Standard for Respiratory Protection, ANSI Z88.2-1992. (Note to Respirator Plan Writer: When writing/developing local policy, review this document thoroughly and add information at any point which will describe the use of respirators at your location. Add specific job titles where responsibilities are described generally, such as where the employer is used in this document. Add specific locations of where respirators are used, if applicable, where records will be kept, the fit testing reference method and details, etc., to tailor this policy to your location. Also add specific procedures and information on use of SCBA equipment, such as during field inspections. All aspects of routine respirator uses, specific to your location, should be described. The above plan provides the content information required by OSHA for a written plan; however, OSHA would expect additional information in the plan to relate these points to your location.) 193
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