Environmental Health & Safety Compliance Blog

Respiratory Protection Plan

Posted by Rebecca McDaniel on Aug 11, 2010 1:31:00 PM

By Matthew Teeter, Environmental Compliance Consultant

The use of respirators is wide spread throughout higher education, healthcare, life science and industrial facilities. However, OSHA regulations state that respirators should be the last line of defense.

The use of respirators is only allowed if you have tried to employ some type of engineering control first. If this does not work then administrative controls is the next step. This could be items such as using a less toxic material, use of fans and/or automated equipment. The last line of defense is then the use of respirators. 

In the event engineering and administrative controls prove ineffective in controlling the hazards, the employer may issue a respirator to an employee if the employee has passed a medical evaluation, been fit tested and the employer has a written respiratory protection plan. All employer issued respirators except for under certain circumstances filtering face pieces (dust masks), fall under the respiratory protection standard. Prior to issuing a respirator, the employer must have a written respiratory protection plan. The plan is required to include mention of some key information including respirator selection, medical clearance/questionnaire, training, fit testing and proper use/storage of the respirator.

Before donning a respirator, employees must be medically cleared to wear a respirator by a physician or other licensed health care professional. As part of the medical clearance process, a medical questionnaire is required to be answered by the employee. The questionnaire is confidential and has questions related to the employee’s health history and focuses on the task in which the employee is required to wear the respirator. The physician or other licensed health care professional will make the determination if the employee is physically fit to wear a respirator.

Those employees that have been cleared to wear a respirator shall be trained on the following:

  • Why the respirator is necessary and how improper fit, usage or maintenance can compromise the protective effect of the respirator;
  • What the limitations and capabilities of the respirator are;
  • How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions;
  • How to inspect, put on and remove, use and check the seals of the respirator;
  • What the procedures are for maintenance and storage of the respirator; and
  • How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.

After an employee has been medically cleared to wear a respirator, each employee must be initially fit tested and annually thereafter to assure the respirator provides a tight fitting seal. Fit testing can be done using either qualitative or quantitative methods. Qualitative fit testing procedures rely on sensation (taste, irritation, smell) to the respirator wearer while quantitative fit testing relies on specialized equipment to measure the fit of the respirator. Additionally, workplace exposure level determines what constitutes an acceptable fit and which fit test procedure is required. Per the Occupational Safety and Health Administration (OSHA), “negative pressure air purifying respirators, users may rely on either a qualitative or a quantitative fit test procedure for exposure levels less than 10 times the occupational exposure limit. Exposure levels greater than 10 times the occupational exposure limit must utilize a quantitative fit test procedure for these respirators. Fit testing of tight-fitting atmosphere-supplying respirators and tight-fitting powered air-purifying respirators shall be accomplished by performing quantitative or qualitative fit testing in the negative pressure mode.”

The employer is required per OSHA regulations to perform a program evaluation to determine if the written respiratory protection program is being properly implemented and to consult employees to ensure they are using the respirators properly. The evaluation should be completed as necessary with any noted deficiencies being corrected as soon as possible.

Tags: Respiratory Protection