Part II: What do I really need for a Respiratory Protection Program?
The last time we blogged, we discussed the requirements of OSHA’s respiratory protection standard 29 CFR 1910.134, when companies exceed OSHA’s permissible exposure limits and when engineering controls are not feasible. We covered written plans, medical evaluations, respirator selection and workplace hazard identification. Next comes fit testing.
Fit Testing – In order to provide protection, the respirator must fit properly to the employee’s face. Contaminated air will be inhaled by the employee if a tight face piece seal is not maintained. Fit testing must be a core component of your respirator program when workplace conditions require respirator use. Your occupational medical provider should be able to assist you with this requirement. Review the standard for further information regarding when fit testing needs to be performed.
Training and Information – You could have the greatest written program but it is useless if your employees neglect to wear their respirators, or wear them improperly. Training has two primary components: 1) Awareness of respiratory hazards to which employees are potentially exposed during regular and emergency situations and; 2) Appropriate respirator use including putting them on (donning) and taking them off (doffing), as well as inspection, maintenance, and storage of the respirators along with limitations of use. This training is required annually, or when changes in the workplace occur that affect safe respirator use.
Evaluation and Recordkeeping – OSHA 29 CFR 1910.134(m) requires the employer to “…establish and retain written information regarding medical evaluations, fit testing, and the respirator program” along with an annually documented evaluation of the program’s effectiveness. Among other criteria, recordkeeping will provide a record for compliance determination by OSHA.
When respirators are used by employees on a voluntary basis, the employer must still have a written plan. This plan must include the medical evaluation component and information on employee responsibility for proper care of the respirator. Even if an employee voluntarily uses a paper dust mask or filtering face piece, a copy of Appendix D to the standard needs to be issued to the employee or contents of this form conveyed and documented. Appendix D can be found here. You can access MEMIC’s Safety Director Resource Library via memic.com for respirator program resources.
Posted by Donna Clendenning and Greg LaRochelle
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