Developing an OSHA Compliant Respirator Program

Developing an OSHA Compliant Respirator Program
Stan Liang, CIH, CSP, CET KTA-Tator, Inc.

Respiratory Protection Webinar Objectives
Brief overview of the following: Procedures for implementation of respiratory protection Requirements of the OSHA Respiratory Protection Standard Elements of a written respiratory protection program Resources for additional information

Respiratory Protection
Last line of defense in protecting employees from harmful dusts, mists, gases and vapors Feasible engineering controls or work practice must be implemented before the use of respiratory protection can be considered Job rotation not permitted by some OSHA standards Respiratory protection is the last line of defense (e.g., when controls such as ventilation do not reduce exposures below the PEL) from harmful dusts, mists, gases and vapors. Feasible engineering or work practice controls , such as job rotation, must be implemented before the use of respiratory protection can be considered. This is required since failure of respiratory protection can result in exposure of the employee to respiratory hazards which in extreme cases can lead to illness or even death. Note that some comprehensive health standards such as hexavalent chromium may prohibit the use of job rotation.

Engineering Controls Vacuum shrouded power tools Ventilation
Wet surface preparation methods Substitution Examples of engineering controls include: Vacuum shrouded power tools Ventilation, such as dust collection systems for abrasive blasting containment. Wet surface preparation methods Substitution , such as using a coatings system or abrasive with less hazardous characteristics.

Respiratory Protection
Must be selected in accordance with procedures established in the respiratory protection program Must be fitted, used, and maintained properly Must be provided at no cost to the employee Respiratory protection must be selected in accordance with the procedures established in the respiratory protection program. Must be fitted, used, and maintained properly if they are to provide an adequate level of protection. Respirators as well as associated training and medical surveillance must be provided at no cost to the employee

Maximum Use Concentration (MUC)
Key consideration in the selection of respiratory protection Determined by multiplying the respirator’s Assigned Protection Factor (APF) times the Permissible Exposure Limit (PEL) Level of airborne hazards should not exceed the MUC

Respirator Classification
Air-purifying respirators Air-supplied respirators Respiratory protection can be broken down into two primary classifications: Air-purifying respirators Air-supplied respirators

Air-Purifying Respirators
Uses mechanical filters or chemical cartridges to remove contaminants from the air that workers breathe Air-purifying respirators use mechanical filters or chemical cartridges to remove contaminants from the air that workers breathe.

Half Face APR Assigned Protection Factor of 10
Can not be used if respiratory hazards can cause eye irritation The half face air-purifying respirator is most commonly used. This type of respirator provides a protection factor of ten times the Permissible Exposure Limit. This type of respirator can not be used if there is the possibility of eye irritation.

Full Face APR Assigned Protection Factor of 10 or 50
Protection factor depends on fit test method The full face air-purifying respirator has, due to its larger sealing surface, a protection factor of up to 50 times the Permissible Exposure Limit The protection factor can be reduced to 10 depending on the fit test method used.

Powered Air Purifying Respirator
Uses battery operated blower APF ranges from 25 to 1000 Loose fitting hood or helmet type may be assigned to workers unable to wear tight fitting air purifying respirators A blower is used to draw air through cartridge filters The protection factor ranges from 25 to 1000 depending on whether a tight fitting half face, tight fitting full face, or loose fitting hood is used. Hood or helmet type respirators may be used where workers are unable to wear a tight fitting air purifying respirator. For example, some workers may be unable to shave for medical reasons.

Filter Selection for Toxic Metals
HEPA cartridges must be used for toxic metal hazards HEPA cartridges designated as N100, R100, or P100 For protection against toxic metals (e.g., lead, cadmium, etc.), air-purifying respirators and powered air purifying respirators must be used with HEPA cartridges. NIOSH recently designated HEPA cartridges as N100. NOTE: N stands for non-oil based dusts/mists stands for 99.97% efficiency.

Filter Selection for Painting Operations
Organic vapor (black) cartridges for roller/brush application Organic vapor (black) cartridges with mist pre-filter for spray painting For roller/brush application or other conditions where only organic vapors are present, use an organic vapor cartridge. This cartridge is identified by a black color code. For spray painting, organic vapor cartridges must be used with mist pre-filters

Air-Purifying Respirator and PAPR Limitations
Can not be used in conditions considered immediately dangerous to life and health Can not be used where oxygen concentrations are below 19.5% Can not be used if concentration of respiratory hazards exceed the protection factor of the respirator Can not be used in conditions considered immediately dangerous to life and health. Can not be used where oxygen concentrations are below 19.5%. Can not be used where concentrations of respiratory hazards exceed the protection factor of the respirator (e.g., ½ mask APR effective only up to 500 µg/m3 of lead dust).

Air-Purifying Respirator and PAPR Limitations
Cartridges have a limited service life Cartridges have a limited shelf life Personnel who have severe scarring or other conditions which prevent the mask from sealing to the face may not use tight fitting air-purifying respirators Cartridges have a limited service life. Particulate cartridges eventually trap enough particles that they become difficult to breathe through. When organic vapor cartridges become saturated, the vapor will break through the cartridge and the wearer will be exposed. We will discuss this issue more, later in this session. Cartridges have a limited shelf life. Before using cartridges, the packaging should be checked to see if the cartridge has exceeded the shelf life established by the manufacturer. Personnel who have severe scarring or other conditions which prevent the mask from sealing to the face may not use tight fitting air-purifying respirators.

Air-Supplied Respirators
Provides the wearer with a continuous supply of clean, breathable air delivered to a tight- fitting facepiece or loose-fitting hood Air-supplied respirators provide the wearer with a continuous supply of clean, breathable air delivered to a tight-fitting facepiece or loose-fitting hood. NOTE: Not all air-supplied respirators are continuous flow, but most respirators used on industrial painting projects are continuous flow.

Supplied Air Respiratory Protection
Assigned Protection Factor up to 10,000 (depending on the type of respirator) Tight fitting full face air line with auxilliary SCBA can be used in confined spaces with IDLH atmospheres A type of supplied-air system which may be used for working in confined spaces is a supplied-air respirator with a full face tight-fitting mask, and pressure demand regulator (maintains a positive pressure in the mask at all times), an auxiliary bottle of compressed air which serves as an emergency reserve of breathing air (5 minutes approximately). This type of respirator is assigned a protection factor of 10,000 times the PEL. A full face air line respiratory with an auxilary SCBA may be used where there may be an immediately dangerous to life and health atmosphere (e.g., high concentrations of toxic chemicals present in the confined space atmosphere, oxygen deficiency, etc.).

Air-Supplied Respirator Limitations
Length of air line must not exceed 300 feet Line may kink, be cut, or be entangled Line may become contaminated Users of air-supplied respirators must be aware of the limitations to ensure that they will provide an adequate level of protection. Length of air line must not exceed 300 feet. If the length exceeds 300 feet, air flow will not be adequate. Air lines can not be less than 30 feet, or the flow rate may be too high. Lines may kink, be cut, or entangle. The wearer must be aware of any conditions (e.g., sharp corners) which may affect the air line. The line may become contaminated. If the line is contaminated with hazardous materials such as lead, decontamination (e.g., clean with soap and water) is required. Consult with an industrial hygienist if the line comes in contact with highly hazardous chemical residues.

Use only air line, vortex, and other equipment specified by the manufacturer Pressurize the air line in accordance with manufacturer specifications Air line couplings must be compatible with breathing air systems only Use only air lines specified by the manufacturer. Using non-approved air lines may result in inadequate air flow or exposure from toxic chemicals used to produce non-breathing air lines. Pressurize the air line in accordance with manufacturer specifications. Improperly pressurizing the air line will result in inadequate air flow to the wearer. Air line couplings must be compatible with breathing air systems only.

The compressed air bottle for the escape SCBA must be hydrostatically tested in the following intervals: Every 3 years - aluminum wrapped with fiber glass Every 5 years - steel Supplier of breathing air must certify in writing that breathing air is Grade D quality The compressed air bottle for the escape SCBA must be hydrostatically tested at the following intervals: Every 3 years – aluminum wrapped with fiber glass. Every 5 years – steel cylinders. NOTE: The date of the last test is stamped on the cylinder. The supplier of breathing air must certify in writing that breathing air is Grade D quality.

Grade D requirements: 19.5% to 23.5% oxygen Less than 10 ppm CO Less than 1,000 ppm CO2 Less than 5 mg/m3 hydrocarbons Do not use pure oxygen as breathing air Requirements for Grade D breathing air are the following: 19.5% to 23.5% oxygen Less than 10 ppm CO Less than 1,000 ppm CO2 Less than 5 mg/m3 hydrocarbons NOTE: Do not use pure oxygen as breathing air.

Portable or self contained compressed air cylinders used as breathing air sources last from 30 minutes to 60 minutes Escape SCBAs usually provide 5 minutes of air A low pressure alarm must be provided (if using a breathing air cylinder) Compressed air cylinders used as breathing air sources last from 30 minutes to 60 minutes. Escape SCBAs usually provide 5 minutes of air. A low pressure alarm must be provided.

Abrasive Blasting Respirators Type CE
Required for abrasive blasting Check with manufacturer if using for other applications Provides a protection factor of 1,000 (selected makes and models) or 25 Not for immediately dangerous to life and health atmospheres Type CE respirators are typically used by personnel engaged in abrasive blasting and vacuuming grit. Approved by the manufacturer for particulate hazards only. For example, they are not to be used for spray painting. Selected makes and models (Bullard 77/88 and Apollo 20/60) have been assigned a protection factor of 1,000. Other models have a lower default protection factor (25). NOTE: Type CE respirators can not be used in work areas (e.g., confined spaces) where oxygen levels are below 19.5% as determined by direct reading meters or if the atmosphere is immediately dangerous to life and health.

The compressor should be provided with the following:
Carbon monoxide alarm operating continuously. Filter equipped with a gauge. The filter must have a tag indicating the date of last change. Compressor must be placed where no paint vapors or exhaust from compressors or vehicles will be drawn in. NOTE: Violating these requirements have resulted in fatalities. For example, oil lubricated compressors have resulted in carbon monoxide poisoning due to combustion of lubricating oil.

Inspection of Respiratory Protection
Respirators must be inspected before and after use Respiratory protection must be inspected before and after use. NOTE: Inspection of respiratory protection is critical since defective parts may result in malfunction of the respirator and exposure of the wearer to atmospheric hazards (e.g., a defective/missing exhalation valve will result in contamination entering the mask).

Inspect facepieces for: Excessive dirt or contamination Cracks, tears or holes Cracked, scratched, or improperly mounted facepieces (on full facepiece masks) Cracked or broken air purifying element holders Damaged threads/gaskets Facepieces must be inspected for: Excessive dirt or contamination Cracks, tears, or holes Inflexibility of elastomeric parts Cracked, scratched, or improperly mounted facepieces (on full facepiece masks) Cracked or broken air-purifying element holders Damaged thread/gaskets

Inspect headstraps or head harness for: Broken straps or headbands Loss of elasticity Broken or malfunctioning buckles and attachments Inspect head straps or head harness for: Broken straps or headbands Loss of elasticity Broken or malfunctioning buckles and attachments

Inspect facepiece interior for: Foreign material Cracks, tears, or distortion in valve material Cracks, breaks, or chips in the valve body, particularly at the sealing surfaces Missing or defective valve covers Improper installation of valve bodies Inspect facepiece interior for: Foreign material Cracks, tears, or distortion in valve material Cracks, breaks, or chips in the valve body, particularly at the sealing surfaces Missing or defective valve covers Improper installation of valve bodies

Inspect air-purifying elements for: Incorrect cartridges/pre-filters Loose connections/cross threading Expired cartridge shelf life date Cracks/dents on cartridge Evidence of prior use Inspect air-purifying elements for: Incorrect cartridges/pre-filters Loose connections/cross threading Expired cartridge shelf life date Cracks/dents on cartridge Evidence of prior use

Inspect breathing tube (if air line used) for: Broken or missing gaskets or O-rings Missing or loose hose clamps Deterioration found by stretching hose and looking for cracks and tears Inspect breathing tube (if air line used) for: Broken or missing gaskets or O-rings Missing or loose hose clamps Deterioration found by stretching hose and looking for cracks and tears

Inspection of air line systems for: Bottle on escape pack fully recharged Cylinder for supplying breathing air fully charged Breathing air in cylinder (if used) certified as Grade D Pressure in air line as specified by manufacturer Low pressure alarm functional Inspection of air-supplied systems for: Bottle on escape pack fully recharged (if used in an IDLH atmosphere) Cylinder for supplying breathing air fully recharged Breathing air cylinder certified as a source of Grade D breathing air Pressure in air line as specified by manufacturer Low pressure alarm for breathing air cylinder functional

Donning Respiratory Protection
Once the respirator is donned, the wearer should check that the mask is properly placed on the face and the straps are properly tightened The positive or negative pressure check must be performed each time the respirator is donned Once the respirator is donned, the wearer should check that the mask is properly placed on the face and that straps are properly tightened. For example: The mask is properly placed on the chin and on the bridge of nose Straps are not too tight The positive or negative pressure check must be performed each time the respirator is donned.

Negative Pressure Seal Check
Question: How is the negative pressure seal check performed? Answer: Cover respirator inlets (with or without cartridges). Inhale normally for ten seconds. If leakage is detected, readjust respirator mask and straps. NOTE: This test can be performed on a tight fitting air line mask by covering the end of the breathing tube.

Positive Pressure Seal Check
. Question: How is the positive pressure seal check performed? Answer: Close off exhalation valve with the palm of the hand and exhale normally. A slight pressure build-up in the mask should be detected. NOTE: This test can not usually be performed on a tight fitting air line mask.

Procedures for Use of Respiratory Protection
Users of tight-fitting masks must not have facial hair that interferes with facepiece seal Contact lenses may be worn with respiratory protection Other PPE worn with respiratory protection can not interfere with the seal of tight fitting respirators Users of tight-fitting masks must not have facial hair that interferes with face piece seal. The limit in the compliance directive is twenty four hours of facial hair growth. Facial hair that does not affect face peice seal may be permitted as long as it does not interfere with valve function. Contact lenses may be worn with respiratory protection. Other ppe worn with respiratory protection, such as hoods and safety glasses, can not interfere with the face to mask seal.

Procedures for Use of Respiratory Protection
Respirator users shall leave the work area when: Workers need to wash their face and respirators to prevent skin irritation Vapor or gas breakthrough is detected Filters require replacement Respirator users shall leave the work area when: Workers need to wash their face and respirators to prevent skin irritation Vapor or gas breakthrough is detected Filters require replacement

Cleaning Respiratory Protection
Wipe interior/exterior of respirator with manufacturer approved towelette at the end of the shift Use mandatory OSHA procedures when: Respirator is heavily contaminated Respirator is used by another person Wipe respiratory protection at the end of the shift using manufacturer approved towelettes to thoroughly clean the interior/exterior of the respirator. NOTE: Some towelettes contain alcohol which can damage the facepiece. Use the mandatory OSHA procedures in Appendix B2 of the standard when: Respirator is heavily contaminated Respirator is to be used by another person.

Respirator Storage What is a good practice in this picture?
What mistakes are shown here? Prior to storage, remove cartridges on air-purifying respirators to prevent contamination of face piece Place respirator into zip lock bag. Put cartridges into separate bag. If the respirator is wet, it must dry first. Hang bag from hook. NOTE: This slide gives an example of a bad storage practice. Respirators should not be stored with used cartridges. Placement by the window may expose the respirators to direct sunlight while in storage.

Respirator Storage Do not store respirators in areas where they are exposed to the following: Contamination Direct sunlight Dust Extreme temperatures Must be packed or stored to prevent deformation Do not store respirators in areas where they are exposed to the following: Contamination (e.g., solvent vapors from stored paint) Direct sunlight Dust Extreme temperatures Must be placed or stored to prevent deformation (e.g., do not hang respirator by straps, place other tools directly on top of respirator). Not following proper storage procedures will contaminate the mask or damage it, resulting in malfunction.

Repairing Respiratory Protection
Remove defective respirators from service Make repairs in accordance with manufacturer recommendations Use only manufacturer approved parts Remove defective respirators from service (e.g., tag defective respirators) or destroy them if repair is not practical. Make repairs in accordance with manufacturer recommendations. Use only manufacturer approved parts to replace missing/damaged parts. NOTE: For supplied-air respirators, regulators, reducing and admission valves, and alarms must be adjusted and repaired by the manufacturer.

Medical Evaluations Medical evaluations must be provided to wearers of respiratory protection before fit testing or use Employees who refuse an evaluation can not be assigned to tasks where respirators are required Provided by a physician or healthcare professional (within the scope of their license) Evaluations are conducted by having the employee complete the questionnaire in Appendix C of the standard Medical evaluations to determine the fitness of workers to wear respiratory protection must be provided to workers before fit testing use. Employees who refuse to be medically evaluated can not be assigned to work areas where they are required to wear a respirator Medical evaluations will be provided by a physician or licensed health care professional (e.g., nurse, physician’s assistant). The health care professional must act within the scope of their professional license The evaluation is conducted using the questionnaire in Appendix C of the Standard . The questionnaire is completed by the worker. The physician may also perform an examination if information on the questionnaire indicates a need.

Medical Evaluations Questionnaire must be administered in a time and place convenient to the employee Translation of the questionnaire is required for non english speakers Employees have an opportunity to discuss the questionnaire and results with healthcare professional The questionnaire must be administered at a time and place convenient to the employee. The questionnaire must be translated for non english speakers. This can be via a translator or by a translated written copy. Where employees can not read, some one other than the employer can read the questionnaire to the employee such as the health care professsional. The employee must be provided an opportunity to discuss the questionnaire and results with the health care professional if they choose.

Medical Evaluations The employee must be provided with a copy of the medical determination Information collected via questionnaires is kept strictly confidential The employee must be provided with a copy of medical determination by the physician or licensed health care professional. Information collected via questionnaires is kept strictly confidential. Only the physician or licensed health care professional has access to information collected via questionnaires.

Medical Evaluations The medical determinations include the following information: Limitations on respirator use Medical fitness Need for follow-up evaluations The medical determination includes the following information: Limitations on respirator use due to the medical condition of employee or relating to work place conditions. Medical fitness to use respiratory protection. Need for follow-up evaluations (e.g., pulmonary function tests).

Medical Evaluations Evaluations (in addition to initial evaluation) provided if: Employee reports signs or symptoms related to the ability to use a respirator Health care professional or Respirator Program Administrator determines that the employee needs to be evaluated Information from fit testing or program evaluation indicates the need for another evaluation Changes in workplace conditions result in increased physical stress on the employee Additional medical exams are provided if: Employee reports signs or symptoms related to the ability to use a respirator (e.g., breathing difficulty during fit testing) Healthcare professional or Respirator Program Administrator determines that the employee needs to be evaluated. Information from fit testing or program evaluation indicates the need for another evaluation. Changes in work place conditions result in increased physical stress on the employee (e.g., physical work effort, temperature, protective clothing).

Fit Testing Required annually for all tight fitting respirators
Must be performed for each make, model, and size worn Another fit test is needed for a change in weight or other medical condition which could change respirator fit Workers must be clean shaven and medically approved to be fit tested Required annually for all tight fitting respirators. For supplied air and powered air purifying respiratory protection, an air purifying respirator of the same mask style / model must be used. Some manufacturers have supplied air respirators that can be converted into air purifying respirators. Must be performed for each make, model, and size worn. Additional fit testing required for a 10% change in weight or more or other medical condition that could affect respirator fit. Workers must be clean shaven and medically approved to be fit tested.

Qualitative Fit Testing
Must be performed in accordance with Appendix A Several options permitted by OSHA Qualitative fit testing must be performed in accordance with mandatory procedures in Appendix A of the OSHA standard. Examples of OSHA approved fit test procedures include irritant smoke, isoamyl acetate (banana oil), and saccharin. It should be noted that the irritant smoke test, the most common test used, can not be used with a fit test booth. When fit testing air purifying respirators, be sure to use the correct cartridge such as a HEPA filter for the irritant smoke test.

Quantitative Fit Testing
Required only for full face air purifying respirators Must be performed following procedures in Appendix A Quantitative fit testing evaluates fit by measuring differentials of air pressure or ambient dust levels between the air inside and outside the respiratory mask. It is generally considered more accurate as it determines a fit factor number specific to the respirator worn by the worker. Quantitative fit testing is only required when fit testing a full face air purifying respirator and the full protection factor of 50 is desired. If the full face air purifying respirator is qualitatively fit tested its protection factor is lowered to 10.

Elements of a Respiratory Protection Program
Designation of a Respirator Program Administrator Procedures for selecting respirators (hazard evaluation required) Medical evaluations Procedures for proper use (including written change schedules for gas/vapor cartridges) The OSHA Respiratory Protection Standard requires site specific respiratory protection programs. Elements of the program include the following: Designation of a Respirator Program Administrator. The Program Administrator must have adequate work experience and /or educational background. Procedures for selecting respirators including site specific information on work place hazards and types of respirators used for specific tasks. This includes a hazard evaluation of the types and quantities of atmospheric hazards. Although air sampling is considered to be the “gold standard” other options such as mathematical models or representative historical data maybe used. Medical evaluations. Procedures for proper use, including written change schedules for gas/vapor cartridges. The program must include the data used to develop the schedule. Sample programs or methods to determine the change schedule can be found in the compliance directive and manufacturer web sites .

Procedures and schedules for cleaning, disinfecting, storing, repairing, and maintaining respirators Procedures for evaluating the effectiveness of the program Procedures and schedules for cleaning, disinfecting, storing, repairing, and maintaining respirators. Procedures for evaluating the effectiveness of the program by the Respirator Program Administrator. These evaluations are conducted as needed to identify problems and implement corrective action.

Training Program Requirements
Required annually or if there are changes in the work place, evidence that training is not effective, or other indication that retraining is needed Training topics include why respirator use is required, proper procedures for use, limitations of respirators, and requirements of the standard. Hands on training, information in manufacturer manuals, and documentation of training is recommended Employee training on respiratory hazards and respiratory protection include the following: Required annually or if there changes in the work place, evidence that training is not effective, or other indication that retraining is needed Training topics include why respirator use is required, proper procedures for use, limitations of respirators, and requirements of the standard. It is recommended that training include hands on exercises, such as fit testing and seal checks, to demonstrate that employees can use respirators correctly and the information in the manufacturer ‘s manual. Documentation of training, while not required by OSHA, is also recommended.

Atmosphere must be classified as IDLH under the following conditions: oxygen level less than 19.5% concentrations of toxic gases above IDLH concentrations hazard evaluation is not performed Atmospheres must be classified as IDLH under the following conditions: Oxygen level less than 19.5% Extremely high concentrations of toxic gases (e.g., solvents) above IDLH levels A n evaluation of hazards is not performed NOTE: IDLH atmospheres are most likely to occur in confined spaces.

Procedures for IDLH atmospheres include the following: use SCBA or combination SCBA/air line respirators workers stationed outside the work area for emergency response employer must be notified before start of rescue operations and be able to provide necessary assistance Procedures for IDLH atmospheres include the following: Use of SCBAs or combination air line/SCBA units Workers must be stationed outside the area for emergency response. These workers must be equipped with appropriate rescue equipment (e.g., hoist and tripod, lifeline, harness) and SCBA’s or combination SCBA/air line units. Employer (e.g., foreman, project superintendent, respirator program administrator) must be notified before rescue operations start and be able to provide necessary assistance.

Voluntary Respirator Use
Respirators may be provided to the employee where use is requested but not required Use of respirators must not create a hazard to the worker Worker training must include the content of Appendix D Workers must be medically approved Respirators may be provided to the employee where use is requested but not required Use of respirators must not create a hazard to the worker Worker training must include the content of Appendix D Workers must be medically approved

Additional Information
29 CFR (or 29 CFR ) OSHA Compliance Directive (CPL ) Small Entity Compliance Guide for the Revised Respiratory Protection Standard Respirator manufacturers NIOSH certified equipment list Health and safety professionals This presentation only provides a very brief overview of what is required to implement a program that complies with the OSHA Respirator Standard. Additional guidance should be consulted in developing a respirator program. For example, the following are available for free on www. osha.gov : 29 CFR OSHA Compliance Directive (CPL ) Small Entity Compliance Guide for the Revised Respiratory Protection Standard. Respirator manufacturers and health and safety professionals such as CSPs or CIHs should also be consulted if an employer does not have a health and safety professional in house. As stated at the beginning of this presentation, this is critical to ensure that the respiratory protection program will adequately protect workers from exposure to respiratory hazards that may result in illness or even death.

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