Do you know if your facility needs a respiratory protection program? Once you have determined you need a program, do you know how to build an OSHA compliant respiratory program? In 2018, respiratory protection was the fourth most cited OSHA violation. Our expert will walk you through the nine key steps to building an OSHA compliant respiratory program.
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4. Michelle Coutu Fluck, MSPH, CIH
Mid-Atlantic EHS Consulting Manager
Triumvirate Environmental
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Meet Your Presenter
5. Agenda
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History of Respiratory Protection
Who Needs a Respiratory Protection Program?
Nine Key Steps to Your Respiratory Protection Program
Recordkeeping and Voluntary Use
Q&A
6. Terms
• OSHA: Occupational Safety and Health Administration
• NIOSH: National Institute of Occupational Safety and Health
• RPP: Respiratory Protection Program
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7. Regulations and Standards
*Does not cover agricultural operations; respirator use during pesticide application is covered by EPA
Federal Insecticide, Fungicide, and Rodenticide Act 40 CFR 170
Organization Regulation
OSHA General Industry 29 CFR 1910.134
Shipyards 29 CFR 1915.154
Marine Terminals 29 CFR 1917.92
Longshoring 29 CFR 1918.102
Construction 29 CFR 1926.103
Air Contaminates 29 CFR 1910.1000
NIOSH Approval of Respiratory Protective Devices 40 CFR 84
NIOSH Respirator Selection Logic 2004
ANSI Practices for Respiratory Protection ANSI/ASSP Z88.2
Color Coding Of Air-Purifying Respirator Canisters, Cartridges, And Filters
ANSI/AIHA/ASSP Z88.7
8. Route of Exposure - Inhalation
• Most significant route of
exposure
• OSHA exposure limits
are based on air
concentrations
• Lungs are directly
connected to our blood
stream
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9. History of Respiratory Protection
• Documentation from first century of
humans using animal bladder skins to
protect miners from lead oxide dust
• 1848 Lewis Haslett first US Patient for
a ‘Lung Protector”
• 1854 John Stenhouse first powdered
charcoal respirator
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10. History of Respiratory Protection
• WWI: gas masks developed
• Early and mid 20th century: focus on
miner safety only
• 1970: Occupational Safety and Health
Act – general industry standards
• 1971: NIOSH approval authority for
respirators
• 1972: OSHA set standards for
respiratory protection
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11. Poll Question
Do you have a respiratory
protection program in place
in your facility?
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12. Agenda
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History of Respiratory Protection
Who Needs a Respiratory Protection Program?
Nine Key Steps to Your Respiratory Protection Program
Recordkeeping and Voluntary Use
Q&A
13. Who Needs a RPP?
• In any workplace where respirators are necessary to protect the
health of the employee or whenever respirators are required by
the employer, the employer shall establish and implement a
written respiratory protection program with worksite-specific
procedures. The program shall be updated as necessary to
reflect those changes in workplace conditions that affect
respirator use. – 29 CFR 1910.134(c)(1)
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15. Who Needs a RPP? – Breakdown
• Employers who after exhausting all other methods
of control still have employees at risk of an over
exposure to airborne hazards
• When employers cannot demonstrate that an
exposure it not occurring for a known hazard
▪ No exposure data for a known hazard
• When engineering controls are not feasible to
control a hazard
▪ Mobile work environments
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16. Agenda
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History of Respiratory Protection
Who Needs a Respiratory Protection Program?
Nine Key Steps to Your Respiratory Protection Program
Recordkeeping and Voluntary Use
Q&A
17. Nine Key Steps to Building Your RPP
1) Respirator selection
2) Medical evaluation procedure
3) Fit testing procedure (for tight fitting respirators)
4) Procedures for routine use
5) Procedures for emergency use
6) Procedures for cleaning and maintaining equipment
7) Air quality monitoring procedures for air supplying respirators (if applicable)
8) Training
9) Program review process
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18. Respirator Selection
• Requires a through process and hazard evaluation
▪ Identify hazards
▪ Measure airborne concentrations
▪ Determine maximum use concentration (MUC)
▪ When exposures approach the MUC → use a respirator with a higher
APF
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MUC = APF X PEL
19. Respirator Selection – Example
An employer has measured an airborne concentration of 0.025
mg/m3 of lead dust during a routine cleaning task. They want to
use half masks (APF = 10) during the clean up. The PEL for lead
is 0.050 mg/m3.
Does the employer need a RPP program?
Is the half mask sufficient to protect their workers?
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MUC = APF X PEL
MUC = 10 X 0.050 mg/m3
MUC = 0.5 mg/m3
21. Dust Mask vs. Surgical Mask
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Dust Mask Surgical Mask
Air filtering, protects
lungs against airborne
chemicals, NIOSH
Regulated
Barrier against liquid
droplets and aerosols from
the wearer
FDA regulated
Barrier against liquid droplets
and aerosols from the wearer
NIOSH and FDA
regulated
23. Filter Performance
• A N95 is designed to filter out at
least 95% of the particulates in
the air (at its most penetrating
particle size)
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24. Decoding Cartridges
Color Hazards
Black Organic Vapors
White Chlorine
Yellow Acid Gas and
Organic Vapors
Green Ammonia
Purple Particulates
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N NOT resistant to oil
R Somewhat RESISTANT to oil
P Strongly resistant to oil (oil PROOF)
25. Atmosphere Supplying Respirators
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Full Facepiece Supplied Air
Respirator (SAR)
APF = 1,000
Full Facepiece Abrasive
Blasting Continuous Flow
APF = 1,000
Full Facepiece Self Contained
Breathing Apparatus (SCBA)
APF = 10,000
26. Medical Evaluation Procedure
• Needs to occur before fit testing
• No cost to the employee
• Medical Questionnaire – 29 CFR 1910.134 Appendix C
• Conducted by a physician or other licensed health care
professional (PLHCP)
• Employers need to inform PLHCP of the work and
environmental requirements
• PLHCP report basic info:
▪ Approved or not
▪ Follow up required or not
▪ HIPAA still applies
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27. Fit Testing Procedure – For
Tight-Fitting Respirators
• Conducted
▪ Before work starts
▪ Annually
▪ If conditions change
▪ For each applicable respirator
• Qualitative fit testing (QLFT)
▪ Irritant smoke, Bitrex, saccharin, Isoamyl
Acetate
• Quantitively fit testing (QNFT)
▪ Fit factor
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28. Procedures
• Routine use
▪ Provisions for facial hair, glasses, etc.
▪ User seal checks: positive and
negative pressure
▪ Inspection
▪ Limitations of use
▪ Designated areas only
▪ Detecting break through
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29. Procedures
• Emergency use
▪ HAZMAT teams
▪ Emergency scape respirators
• Cleaning and maintaining equipment
▪ Change out schedule for cartridges
▪ Cleaning respirators
▪ Storage
▪ Personal hygiene
▪ Manufacture's preventative maintenance
▪ Breathing air quality (if applicable)
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30. Training
• Required:
▪ Before starting work
▪ Annually
▪ Procedures or work environment changes
• Must be understandable to employees
• Demonstrate knowledge
▪ Written quiz
▪ Individual evaluation
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31. Program Review Process
• Periodic inspections of the
workplace
▪ Consult with employees for
feedback
▪ What's changed?
• Is the program being correctly
implemented?
▪ What barriers are there and how do
we fix them?
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32. Poll Question
Is your facilities respiratory
protection program
regulatory compliant?
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33. Agenda
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History of Respiratory Protection
Who Needs a Respiratory Protection Program?
Nine Key Steps to Your Respiratory Protection Program
Recordkeeping and Voluntary Use
Q&A
34. Recordkeeping
• Written copy of your program
• Medical evaluations
▪ In accordance with 29 CFR 1910.1020
• Training
▪ Sign in sheets or certificates
• Fit testing – keep most current
testing results
▪ Employee tested
▪ Make, model, style and size of mask
tested
▪ Date of testing
▪ Results of testing
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35. Voluntary Use
• Might need a plan
▪ Dust masks only → No plan needed
▪ Half and full face masks → Limited plan needed
• Limited plan requirements
▪ Hazard assessment of mask
▪ Appendix D review and sign
▪ Medical clearance
▪ Training on care, use, and cleaning of mask
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36. Agenda
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History of Respiratory Protection
Who Needs a Respiratory Protection Program?
Nine Key Steps to Your Respiratory Protection Program
Recordkeeping and Voluntary Use
Q&A