Sample Written Respiratory Protection Program

REGULATORY BACKGROUND: 29 CFR §1910.134 applies to all respirator use in general industry and construction workplaces. The standard applies when (1) employees are required to wear respirators to protect themselves from exposure to air contaminants above a specific exposure limit, (2) if the employer requires respirators to be worn, or (3) if respirators are otherwise necessary to protect employee health. Additionally, limited requirements apply when employees, for personal, comfort, or other reasons, voluntarily choose to wear certain kinds of Air-Purifying Respirators (APR). The standard affirms OSHA’s long-standing policy that personal protective equipment -- in this instance, respirators -- be the last line of defense when engineering and work practice controls are inadequate to reduce employee exposure, or during the development and installation of other controls.

Among other requirements, the standard mandates that employers:

• Develop a written program;
• Assign a program administrator;
• Prepare work site-specific procedures;
• Select respirators based on the hazard(s) and the required protection;
• Train employees on the usage, fit, maintenance, cleaning, and storage of respirators;
• Fit test employees who will use any respirator with negative or positive pressure tight-fitting face piece, prior to first use and annually thereafter;
• Provide medical evaluation to determine employee ability to wear the selected respirator via (1) medical examination or (2) confidential questionnaire and, (3) when required by the responses to the questionnaire, a follow-up medical examination;
• Provide the tools and replacement parts necessary for respirator cleaning, maintenance, and repair; and
• Perform periodic program evaluation to ensure effectiveness.

A major change in the standard is the provision governing when APR may be used. In the past, OSHA and the National Institute for Occupational Safety and Health (NIOSH) both prohibited the use of APR against gases and vapors that had inadequate warning properties — principally when the odor threshold was above the applicable exposure limit. The new standard permits the use of APR without limit, if the employer has objective data (1) that APR provide adequate protection, and (2) on the service life of the cartridges, upon which a cartridge change out schedule may be based.

TABLE OF CONTENTS

• Purpose
• Scope and Application
• Responsibilities
  1. Program Administrator
  2. Responsibilities of Supervisors
  3. Employees
• Program Elements
  1. Selection Procedures
  2. Medical Evaluation
  3. Fit Testing
  4. Respirator Usage
  5. Respirator Malfunction
  6. Air Quality
  7. Cleaning, Maintenance, and Storage
  8. Cartridge & Canister Change Out Schedules
  9. Training
• Program Evaluation
• Documentation and Recordkeeping
• Index of Attachments

I. Purpose

The purpose of this program is to ensure that all employees of (Name of Business) are protected from exposure to respiratory hazards and that (Name of Business) is in compliance with 29 CFR§1910.134(c). Engineering controls, such as ventilation and substitution of less toxic materials, are used where feasible; however, engineering controls are not always completely effective in controlling the identified airborne hazards. In these situations, respirators, and other types of personal protective equipment must be used. Respirators are also needed to protect your health during emergencies. The work tasks requiring respirator use are outlined in Table 1 in the Scope and Application section of this program. All employees performing the tasks for the periods or under the conditions specified in the table must wear the designated equipment, or one providing greater or equivalent protection, as a condition of continued employment. It is (Name of Business)’s policy that use of PPE, including respirators, will be enforced, and failure to comply may result in disciplinary action, up to and including termination for serious or repeated infractions.

In addition, if an employee desires to wear respirators during certain operations that do not involve exposures to airborne contaminants requiring respiratory protection, as a general policy, each such request will be reviewed on a case-by-case situation. If the use of respiratory protection in a specific case will not jeopardize an employee’s health or safety, or that of coworkers, an employee may use the respirators provided or may provide his/her own for voluntary use, subject to approval by the Program administrator. As outlined in the Voluntary Usage section of this program, voluntary usage is subject to certain additional program requirements.

II. Scope and Application

(Name of Business) has determined that some employees are exposed to respiratory hazards during routine operations. This program applies to all employees who are required to wear respirators during normal work operations, and during some non-routine or emergency operations such as clean-up of spills of hazardous substances. All employees working in these areas and engaged in certain processes or tasks found in Table 1 must be enrolled in the company’s respiratory protection program.. Employees participating in this program do so at no cost to them; the expense associated with training, medical evaluations and equipment are to be paid by the company. In addition, where any employee voluntarily wears a respirator when one is not required (i.e., a hazard assessment reviewed by the Program administrator revealed respirators are not required), the employer must implement the medical evaluation provisions of a program, and is responsible for ensuring that employees comply with cleaning, maintenance, and proper storage of the respirators.

Dust masks (filtering facepiece) are not subject to even these minimal requirements. Voluntary use of dust masks alone does not require the employer to have a written program. For filtering facepiece respirator use, the employer needs only ensure that dust masks are not dirty or contaminated, that their use does not interfere with the employee’s ability to work safely, and that a copy of Appendix D (Section VI, Attachments) is provided to each voluntary wearer.

III. Responsibilities

A. Program Administrator

The program administrator is responsible for administering the respiratory protection program. Duties include:

• Identifying work areas, processes, or task that require workers to wear respirators, and evaluating the associated hazards.
• Selecting appropriate, approved respiratory protection options.
• Monitoring respirator use to ensure that respirators are used in accordance with their certifications.
• Arranging for and or conducting training.
• Ensuring proper storage and maintenance of respiratory protection equipment.
• Conducting qualitative fit testing.
• Administering the medical surveillance program.
• Maintaining required program records.
• Evaluating the respiratory protection program.
• Updating the written program, as necessary.

The program administrator is (Name or Title of Program Administrator).

B. Supervisors

Supervisors are responsible for ensuring that the respiratory protection program is implemented in their work areas. In addition to being knowledgeable about the program requirements for their own protection, supervisors must also ensure that the program is understood and followed by the employees under their charge. Supervisors are required to:

• Ensure that employees under their supervision (including new hires) have received appropriate training, fit testing, and annual medical evaluation.
• Ensure the availability of appropriate respirators and accessories.
• Be aware of tasks requiring the use of respiratory protection.
• Enforce the proper use of respiratory protection.
• Ensure that respirators are properly cleaned, maintained, and stored in accordance with the program.
• Monitor work areas and operations with sufficient frequency to identify respiratory hazards and select proper equipment.
• Coordinate with the program administrator on how to address respiratory hazards or other concerns regarding the program.

C. Employees

Each employee must wear his or her respirator when and where required and in the manner in which they were trained. Employees also are required to:

• Be familiar with this program.
• Care for and maintain the respirators as instructed, and store in a clean sanitary location.
• Inform the supervisor if the respirator no longer fits well, and request a new one that fits properly.
• Inform the supervisor or program administrator of any potential respiratory hazards or other concerns regarding the program.

IV. Program Elements

A. Selection Procedures

The program administrator selects the respirators to be used, based on the hazards employees encounter and in accordance with all OSHA standards. (Name of Business) has performed an exposure assessment identifying the respiratory hazard(s) found in its workplace.

B. Medical Evaluation

Employees who (1) are required to wear respirators, or (2) choose to wear an APR voluntarily, must pass a medical examination before being permitted to wear a respirator on the job. Employees are not permitted to wear respirators until they are medically approved to do so. Employees refusing the medical evaluation are not permitted to work in an area requiring respirator use. The medical evaluation is conducted using the questionnaire provided in Appendix C of the respiratory protection standard (Section VI, Attachments) or an actual examination that obtains the same information as contained in the questionnaire.

All employees requiring medical evaluations are provided a copy of the medical questionnaire as found in Appendix C of the standard (Section VI, Attachments).

Medical evaluation procedures are as follows:

• All examinations and questionnaires are to remain confidential between the employee and the Physician or other Licensed Health Care Professional (PLHCP).
• All affected employees are given a copy of the medical questionnaire to complete, along with a stamped, addressed envelope for mailing the completed document to the PLHCP.
• The questionnaire is completed confidentially during the employee’s usual work shift.
• To the extent feasible, the company accommodates employees who are unable to read the questionnaire. Someone other than the employer, at the employee’s request, may be asked to assist in reading the document. If this is not possible, the employee will be sent to the physician or other licensed health care professional (PLHCP) for a medical evaluation.
• Follow-up medical exams are granted to employees as required by the standard, and/or as deemed necessary by the PLHCP.
• All employees are provided the opportunity to speak with the PLHCP about their medical evaluation, if requested.
• Any employee required, for medical reasons, to wear a Powered Air Purifying Respirator (PAPR) is provided a powered air purifying respirator.

After an employee has received approval and started to use a respirator, additional medical evaluation is provided if:

1. The employee reports signs and/or symptoms related to their ability to use a respirator, such as shortness of breath, dizziness, chest pains, or wheezing.
2. The PLHCP or supervisor informs the program administrator of a need for reevaluation.
3. Information from this program, including observations made during fit testing and program evaluation, indicates a need for reevaluation.
4. A change occurs in the workplace conditions that may result in an increased physiological burden on the employee.

A physician or other licensed health care professional (PLHCP) at (name of clinic, or name of Physician/PLHCP) evaluates the information found in Sections 1 and 2, Part A of Appendix C of the standard. The PLHCP, prior to making a determination for fitness of duty, is provided vital information for respirator usage. This includes the type and weight of the respirator, duration and frequency of use, expected work effort, additional personal protective clothing/equipment to be used, and estimated temperature and humidity extremes that may be encountered. If an employee responds positively to any of questions 1 through 8 in Section 2 of the questionnaire, or if the PLHCP upon initial review of the questionnaire deems it necessary, a follow-up medical examination is provided. This follow-up exam includes any medical tests, consultations, or diagnostic procedures that the PLHCP deems necessary to make a final determination for safe respirator usage.

C. Fit Testing

Fit testing is required for employees wearing respirators with a negative or positive pressure tight-fitting facepiece. The fit test is conducted prior to the employee being required to use the respirator and uses the same make, model, style, and size of respirator to be used on the job. The company may use a qualitative fit test (QLFT) or a quantitative fit testing (QNFT) approach. Fit test forms may by found in Section VI, Attachments. Fit testing is conducted:

• Prior to initial use of the respirator.
• If a different respirator facepiece (size, style, model or make) is used.
• On an annual basis.
• If the employee, employer, PLHCP, supervisor or program administrator makes a visual observation of changes in the employee’s physical condition that would affect respirator fit. (This might include: facial scarring, dental changes, cosmetic surgery or a drastic change in weight.)
• If an employee passes either test, but notifies the employer that the fit is unacceptable, the employee is allowed to select a different respirator and is retested.

D. Respirator Usage

Employees use their respirators under conditions specified by this program, and in accordance with the training they receive on the use of each particular model. In addition, the respirator shall not be used in a manner for which it is not certified by NIOSH or by its manufacturer. Each time a respirator is put on, employees must conduct a positive and negative pressure user seal check. Additional personal protective equipment, combined with respirator use, may be necessary to adequately prevent exposure. Use of eye, face or skin protection may be required in certain processes.

Tight fitting facepiece respirators are not permitted for use if:

• An employee has facial hair that interferes with the sealing surface of the respirator and the face, or interferes with the valve function.
• Corrective glasses/goggles or other personal protective equipment interferes with the seal of the facepiece.
• Any other condition interferes with the facepiece seal.

The employee must vacate the respirator use area:

• To wash face and respirator facepieces as necessary to prevent respirator induced eye or skin irritation.
• If vapor or gas breakthrough is detected.
• If there is a change in breathing resistance.
• If there is facepiece leakage.
• To replace the respirator or filter, cartridge, or canister elements.

If any of the above conditions are caused by a failure of the respirator or any of its components, or if cartridges or filters need to be changed, the company provides replacement parts or repairs the respirator prior to allowing the employee to return to the respirator use area.

Voluntary Usage of Respirators: At the request of employees, the company may provide respirators or permit employees to use their own respirators for voluntary use in areas where respirators are not mandatory. However, prior to the voluntary use of respirators and on a case-by-case basis, the program administrator first determines that the use of such a respirator does not, in itself create a hazard. Once this determination is established, employees voluntarily using respirators are issued a copy of “Information for Employees Using Respirators When Not Required Under the Standard,” Appendix D of the standard as found in Section VI, Attachments. In addition, employees voluntarily using tight-fitting respirators are governed by the medical surveillance, cleaning, storage and maintenance aspects of the respirator as outlined in the respiratory protection program. However, employees who voluntarily wear disposable filtering facepieces or those whose only respirator is an escape-only respirator are not subject to the medical evaluation provision of this program.

E. Respirator Malfunction

1. APR Respirator Malfunction: In the event of an APR malfunction (such as breakthrough, facepiece leakage, or improperly working valve), the employee should inform the supervisor that the respirator is no longer functioning as intended, leave the respirator use area and repair or replace the defective respirator. The supervisor is responsible for ensuring that the employee receives the necessary parts for repair or a new functional respirator.
2. Atmosphere-supplying Respirator (SAR) Malfunction: Usually employees using atmosphere-supplying respirators work in pairs. If one worker is experiencing a SAR malfunction, by using hand signals, he or she notifies the partner of the problem. The partner then escorts the employee with SAR malfunction outside the respirator use area to assess and rectify the malfunction.

F. Air Quality

Supplied-air respirators use only Grade D breathing air as described in ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-1989 meeting the following specifications:

• Oxygen content (v/v) of 19.5-23.5%
• Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less
• Carbon monoxide content of 10 ppm or less
• Carbon dioxide content of 1000 ppm or less
• Lack of noticeable odor

The program administrator maintains a certificate of analysis from the supplier that (1) Grade D breathing air is contained in the cylinders used to supply breathing air; (2) cylinders are tested and maintained as required in the Shipping Container Specification Regulations of the Department of Transportation; and (3) the moisture content in the cylinder does not exceed a dew point of -50 degrees Fahrenheit at 1 atmosphere pressure.

Compressors used to provide breathing air to respirators shall be constructed and situated so as to

• Prevent entry of contaminated air into the air supply system
• Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees F below the ambient temperature
• Have suitable in-line air purifying sorbent beds and filter to further ensure breathing air quality. Sorbent beds and filters shall be maintained and replaced or refurbished periodically following manufacturer’s instructions
• Have a tag containing the most recent change date and the signature of the person authorized to perform the change
• For compressors that are not oil-lubricated, the employer shall ensure that carbon monoxide levels in the breathing air do not exceed 10 parts per million (ppm).
• For oil-lubricated compressors, a high temperature alarm or carbon monoxide alarm, or both, shall be used to monitor carbon monoxide levels
• Breathing air couplings must be incompatible with outlets for nonrespirable worksite air or other gas systems.

G. Cleaning, Maintenance, and Storage

Respirators are to be regularly cleaned and disinfected in accordance with the manufacturers instructions. APR are to be cleaned and disinfected as often as necessary, but at least every day used or as outlined in 29 CFR §1910.134(h)(1) of the standard. SAR and emergency use respirators are to be cleaned and disinfected after each use.

The following procedure is to be used for cleaning and disinfecting, unless the manufacturer directs otherwise:

• Disassemble respirator, removing all filters, canisters, or cartridges.
• Wash the facepiece and associated parts in a mild detergent with warm water. Do not use organic solvents or bleach.
• Rinse completely in clean, warm water.
• Wipe the respirator with disinfectant wipes (70% isopropyl alcohol) to kill germs.
• Air dry in a clean area. If a clean area is not available, use clean disposable paper towels to blot excess moisture.
• Reassemble the respirator and replace any defective parts (noting the condition of the head straps and valve flaps.)
• Place in a clean, dry plastic bag or other air tight container.

Note: The program administrator ensures an adequate supply of the appropriate cleaning and disinfection supplies. If supplies are low, employees should notify the supervisor or program administrator.

Respirators are to be properly maintained at all times in order to ensure that they function properly and can adequately provide protection to the employee. Maintenance involves a thorough visual inspection for cleanliness and/or defects. Worn or deteriorated parts must be replaced prior to use. No components are replaced or repairs made beyond those recommended by the manufacturer. Regulator or alarm repair of atmosphere-supplying respirators are conducted by the manufacturer.

The following list is used when inspecting respirators:

• Facepiece: cracks, tears, or holes, facemask distortion, cracked or loose lenses/face shield
• Head straps: breaks or tears, broken buckles/clasps, overstretched elastic bands
• Valves: residue or dirt, cracks or tears in valve material, absence of valve flap
• Filter/Cartridges: proper cartridge for hazard, approval designation, intact gaskets, cracks or dents in housing
• Air Supply Systems: breathing air quality/grade, condition of supply hoses, hose connections, settings on regulators and valves

Respirators that are defective or have defective parts are taken out of service immediately. If an employee discovers a defect in a respirator during an inspection, the employee shall bring the defect to the attention of the supervisor. Supervisors give all defective respirators to the program administrator or the person responsible for replacement or repair.

The appropriate person then decides whether to:

• Temporarily take the respirator out of service until it can be repaired;
• Repair the respirator; or
• Dispose of the respirator due to a defect or irreparable problem.
• Employees are permitted to leave their work area to perform limited maintenance on their respirator in an area that is free from respiratory hazards. Situations when this is permitted include: face or respirator washing to prevent skin/eye irritation; replacement of filter, cartridge or canister; leakage is detected in the facepiece; vapor or gas breakthrough is detected; or detection of any damage to the respirator or its components.

Note: When a respirator is taken out of service, it is tagged as such to prevent accidental use of a malfunctioning device. All defective respirators are stored separately from functional respirators.

APR are stored in a clean, dry area and in accordance with the manufacturer’s recommendations. Each employee cleans and inspects their own respirator in accordance with the provisions of this program and stores their respirator in a plastic bag or air tight container. Each employee has his or her name on the bag/container and only stores his or her own respirator in that container. Atmosphere supplying respirators will be stored in (insert name of area or location). A supply of respirators and replacement components will be stored in the original manufacturer’s packaging in the (insert name of area or location).

H. Cartridge & Canister Change Out Schedules

For atmospheres that are not Immediately Dangerous to Life and Health (IDLH), (Name of Business) shall provide a respirator adequate to protect the health of the employee and ensure compliance with OSHA requirements under routine and reasonably foreseeable emergency situations. Ths respirator selected by the Program Administrator shall be appropriate for the chemical state and physical form of the contaminant. See Table 1 in Section VII, Attachments.

The use of APRs requires that the respirator be equipped with an End of Service Life Indicator (ESLI) certified by NIOSH for the contaminant or if there is no ESLI appropriate for conditions in the workplace, (Name of Business) shall implement a change schedule based on objective information that ensures that canisters and cartridges are changed before the end of their service life. The information and data relied upon and the basis for the canister and cartridge change out schedule are included in Section VII, Attachments.

I. Training

The program administrator provides training to respirator users and their supervisors on the contents of this respiratory protection program, their responsibilities under it, and the OSHA respiratory protection standard, 29 CFR1910.134. Employees are trained prior to using respirators in the workplace. Supervisors are trained prior to using a respirator in the workplace or prior to supervising employees required to use respirators.

The training program covers the following topics:

• The company respiratory protection program.
• The OSHA respiratory protection standard.
• The respiratory hazards encountered at the worksite.
• The proper selection and use of respirators.
• Additional personal protective equipment.
• Respirator limitations.
• How to put-on and perform user seal (fit) checks.
• Fit testing.
• Emergency use procedures.
• Maintenance and storage.
• Medical signs and symptoms limiting the effective use of respirators.

Employees are retrained annually, or as needed (i.e. relocation to another department using a different type of respirator). Employees are required to demonstrate their understanding of the topics covered in the training through hands-on exercises and a written quiz. Respirator training is documented by the program administrator. The documentation includes the type, model, and size of respirator for which each employee has been trained and fit tested.

V. Program Evaluation

The program administer and other responsible supervisors conduct periodic evaluations of the workplace to ensure that the provisions of this program are being implemented. The evaluations include regular consultations with employees who use respirators and their supervisors for recommendations of improvement or problematic issues. Records reviews, site inspections and periodic air monitoring also assist in program review.

VI. Documentation and Recordkeeping

A written copy of this program and the OSHA standard is maintained by the program administrator and is available to any employee interested in reviewing the document. Training and fit testing records are also maintained by the program administrator. These records are updated as new employees are trained, when existing employees receive refresher training and/or new fit testing is conducted.

Medical evaluations are maintained in accordance with the OSHA medical records standard 29 CFR1910.1020. However, the PLHCP’s written recommendation regarding the employee’s ability to use a respirator are maintained by the program administrator.

VII. Attachments and Links

• Appendix A to the OSHA Respirator Standard (29 CFR 1910.134): Fit-testing
• Appendix C to the OSHA Respirator Standard (29 CFR 1910.134): Respirator Medical Evaluation Questionnaire (Mandatory)
• Respirator Change Schedules
• Appendix D to the OSHA Respirator Standard (29 CFR 1910.134): Information for Employees Using Respirators When Not Required Under the Standard (Non-Mandatory)
• Qualitative Respirator Fit Test Form

Employee: _____________________________________________________________________

Company: ______________________________________Date: __________________________

Respirator Model: ________________________Respirator Type: ________________________

Respirator Size : _________________________Cartridge(s): ____________________________

PRIOR TO FIT TESTING:

Subject must be allowed to select the correct size respirator and be shown how to assemble, don, doff and adjust the respirator. Once it has been established that the employee is able to detect the fit test challenge agent (isoamyl actate), the test may be administered. If the subject is unable to detect the challenge agent, a different type test must be administered. Contact an industrial hygienist or the respirator vendor for assistance.

To assess proper comfort and fit, the respirator must be worn for at least five minutes, while allowing the subject to determine the following:

Comments:____________________________________________________________________

Tested by: ______________________________________________Date:__________

Employee Signature: ______________________________________Date:__________

Rainbow Passage

When the sunlight strikes raindrops in the air, they act like a prism and form a rainbow. The rainbow is a division of the white light into many beautiful colors. These take the shape of a long round arch, with its path high above, and its two ends apparently beyond the horizon. There is, according to legend, a boiling pot of gold at one end. People look, but no one ever finds it. When a man looks for something beyond its reach, his friends say he is looking for the pot of gold at the end of the rainbow.

• Sample Respiratory Protection Program


• Respirator Medical Evaluation Form


• Respiratory Protection Checklist


• State of Maine Amendments to Respiratory Protection Standard