6 Steps to an OSHA Compliant Respiratory Protection Plan
When working in a lab, one of the more complex hazards to protect against is inhaling hazardous substances. To combat this, all labs should have a respiratory protection program. Respiratory protection programs are strictly regulated by OSHA (29 CFR 1910.134), and can be difficult to effectively implement and administer. Here are 6 steps you need to take to successfully implement an OSHA-compliant respiratory protection plan.
1. Identify the Hazard
The first thing you should do before selecting a respirator is identify why you need one. In order to determine the hazard and need, there several questions you should ask:
- Is there a new process slated to begin that has a foul odor?
- Will a specific chemical be used that has a low OSHA Permissible Exposure Level (PEL)?
- Will there be particulates in the atmosphere that will cause respiratory tract irritation?
- Will the respirator be used in an atmosphere that is Immediately Dangerous to Life or Health (IDLH)?
The answers to these questions as well as the specific hazard will dictate if you need a protection plan and what kind of respirator is needed.
2. Select a Respirator
Selecting a respirator that protects you or your employees from the hazard at hand can be a cumbersome task. A respirator should be chosen based on the hazard that the affected employee will be exposed to.
Each respirator type has an Assigned Protection Factor (APF). The APF is the level of protection a respirator provides to an employee. The APF should be used in conjunction with the results of the air sampling to ensure that the atmosphere is not at or above Maximum Use Concentration (MUC).
3. Medical Clearance
Using a half-face, full-face or SCBA can be a physiological burden and some people may not be healthy enough to endure the extra effort required to draw air through a respirator. Before an employee starts wearing a respirator or is fit tested to wear one, they must go through a medical evaluation process. A medical questionnaire located in Appendix C of 29 CFR 1910.134 may be filled out and submitted to an occupational health care professional for review. Based on the results of the questionnaire, the employee may either be cleared to wear a respirator, or may need a follow up medical examination for a definitive determination on whether the employee is able to wear a respirator.
The health care professional will also need to know the following before clearing an employee to use a respirator:
- Type and weight of respirator the employee will be using
- Duration and frequency of respirator use
- Expected physical work effort
- Additional PPE the employee will be wearing
- Any extreme weather conditions the employee may experience
After the questionnaire and evaluations have been completed, the health care professional will submit a written recommendation regarding the employee’s ability to use a respirator.
Along with quantitative and qualitative fit testing and medical clearance, all employees must be trained to use, store and maintain their respirators. Training is required on an annual basis and should include the following:
- Why the respirator is necessary, and how improper fit usage, or maintenance can compromise its effectiveness
- The limitations and capability of the respirator
- How to effectively use the respirator in an emergency situation, including when the respirator malfunctions
- How to don, doff, inspect and use the respirator
- How to properly store and maintain the respirator
- How to recognize medical signs and symptoms that may limit the respirator’s effectiveness
Besides training on an annual basis, retraining must be administered when workplace conditions affecting the respirator occur, or when an employee demonstrates they haven’t retained or understood the training.
5. Fit testing
To ensure that each employee is completely protected by the respirator they are using, you should perform a qualitative or quantitative fit test. Qualitative Fit Testing (QLFT) and Quantitative Fit Testing (QNFT) are the two approved methods for fit testing.
QLFT’s vary on procedure depending on the test solution, but the goal is to determine if a test solution (bitter, sour or otherwise easily detectable in its nature) can penetrate into the employee’s respirator. If the employee can detect the presence of the test solution, then there is insufficient contact between the respirator and the employee’s face, meaning another size respirator must be selected and the fit test must be completed again.
QNFT’s use a computer to interface with the respirator and calculates the fit factor of the respirator, which is programmable. As a result of the specific data that can be obtained through a Quantitative Fit Test to determine exactly how protected the employee is using the respirator, a greater fit factor can be achieved than with a Qualitative Fit Test.
6. The Written Program
A written program for the required use of respirators will need to be implemented. This program should include the site-specific processes that require the use of a respirator, the process used to select the respirator and cartridge type, the employees’ medical evaluations, the fit testing procedures used to determine the appropriate respirator size, the procedures for proper use of respirators, and the trainings employees are given.
In addition to the topics that have been discussed, the written program should include the procedures employees must follow to ensure that they can clean and disinfect their respirators, how to store the respirator to ensure it does not become contaminated or is broken, and procedures to inspect the respirators ensuring it is able to properly protect the employee.
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