Many valuable publications cover and interpret OSHA’s Respiratory Protection Standard (29 CFR 1910.134), yet respiratory-related violations consistently remain at the top of the list of cited OSHA violations. In October of 2015, OSHA reported respirator-related violations as the fourth most cited standard violation for Fiscal 2015. Since employees face many challenges in keeping up-to-date with the complexities involved in safely maintaining respirators, respirators are the most costly form of worker protection to implement.
Respirators serve an important role in worker protection, but the decision to introduce this equipment into the work environment should be made only after management has ruled out other resources for controlling the risk of exposure. Respirator use is initiated when an exposure assessment indicates that air concentration of hazardous materials will exceed occupational exposure levels. The magnitude of exposure will determine the type of respirator required to achieve adequate protection.
If it is determined that respirator use is the only viable option, then the following elements are necessary to ensure that this equipment is used properly:
1. A Written Program
A written program documents how the employee will manage the selection, use, and care of respirators. Commonly cited OSHA violations typically involve failure to have a written program, or inadequacies within the program.
2. Respirator Selection
Exposure assessment is required to determine if employee exposure to workplace chemical hazards are below a level of concern. This assessment is completed by representative air sampling. Assuming that respirators will be used, the employer is required to select the type of respirator that will adequately control exposure.
Commonly, the options are to use either an air supplying respirator or an air purifying respirator. Respirators can be selected on positive versus negative pressure, and tight-fitting versus loose fitting. There are half-face, full-face, hooded, and disposable units. Employers have many options for respirator selection. With increasing levels of protection, also come greater complexity and expense.
Under paragraph (d)(3)(i)(A) of OSHA’s Respiratory Protection Standard, employers must select respirators according to Assigned Protection Factors (APFs), using Table I: Assigned Protection Factors. Under paragraph (d)(3)(i)(B), employers must select respirators after considering the Maximum Use Concentrations (MUCs) in their workplace where respirators are to be used.
3. Respirator Use
Employees assigned respirators are required to receive annual training, annual fit-testing, and medical clearance to wear a respirator. The burden of using and maintaining the respirator falls on the user. This part of the program is the most difficult to manage and therefore OSHA citations are common. For example, a user may fail to clean, properly store or replace worn parts on their respirator. The worst case scenario is to wear a respirator that is contaminated with a material that the respirator is intended to protect against.
In summary, respirators only protect as rated, if they are used in accordance with all elements of a written respiratory protection program. These details pose a challenge to both employer and respirator user. Respirators can be used effectively, but only with sustained effort from all participants.
Paul J. Webb, MPH, MBA, CIH, CSP