Step-by-step tools to help ensure safety programs achieve their respiratory safety goals.
As the safety administrator, running a successful respiratory protection program means navigating a maze of regulations and anticipating hazards. Consider us your resource. Whenever you are in the process, we can help guide you to the information and details you need.
To run a successful workplace respiratory protection program, you must understand and comply with the standards set by state and federal administrations like the Occupational Safety and Health Administration (OSHA). If you’ve already started your research, you know it can be overwhelming. To help you make sense of it all, we’ve summarized key elements of the federal standard and what you need to do to comply with each one.
When respiratory protection is required by OSHA, a written respiratory protection program should be established. That means the designated program administrator must oversee the following:
Each part of the program can seem complex. Although as a safety administrator you must follow all applicable rules and regulations, we’ve outlined key highlights to help you navigate them.
Site: OSHA Federal Regulation 29 CFR 1910.34
OSHA requires employers to evaluate respiratory hazards in the workplace. You can bring in an independent or OSHA consultant if you don’t have a trained safety professional on staff or for an additional opinion on your hazards. The results of the assessment can help determine:
You should conduct a new assessment periodically and every time there are changes in the workplace that could result in new exposures — such as a change in equipment, process, products or control measures.
Some contaminants have a specific standard requiring a certain type of monitoring protocol or frequency. For others, OSHA says personal air monitoring — where samples are collected by attaching a monitor directly to the worker* — is the most reliable and accurate method to determine exposure. But other methods may be used.
Objective data from industry studies, trade associations, or tests conducted by chemical manufacturers that show air contaminants can’t be released in concentrations that are “immediately dangerous to life or health” (IDLH). The highest foreseeable exposures should be used.
Mathematical approaches: combining data on the properties of air contaminants, room dimensions, air exchange rates, contaminant release rates, and other data — including exposure patterns and work practices — to estimate the maximum exposure anticipated.
If there’s no feasible way to estimate exposure, consider the atmosphere to be IDLH. All oxygen-deficient (<19.5%) atmospheres are considered IDLH, unless it can be demonstrated that oxygen concentration can be maintained within the ranges shown in Table II of the OSHA standard.
If the assessment shows that exposure levels of airborne contaminants are unacceptable, as the safety administrator you should first see if you can control them by engineering controls (changing procedures, swapping out chemicals) or administrative controls (limiting worker exposure). If there’s no feasible way to bring exposure to acceptable levels, then you’re responsible for providing respirators, training and medical evaluations at no cost to the employee.
Keeping a written record provides proof of compliance with the regulatory standards to OSHA. It also gives employees a reliable source for information about respiratory protection procedures, and it’s invaluable in helping evaluate the program.
The record should:
It takes work and organization to set up and maintain each part of a respiratory protection program. Requirements may vary by state, and by type and level of respiratory hazards employees face, but it’s essential for meeting governmental requirements and helping keep your workforce safe.
* This is an overview only, not an official, legal or complete interpretation of the standard.
OSHA mandates that when respirator use is required in the workplace, respirators must be approved by the National Institute for Occupational Safety and Health (NIOSH).
As a safety administrator, you must select respirators according to the assigned protection factor (APF), which is the workplace level of respiratory protection that a respirator or class of respirators is expected to provide to employees when the employer implements a continuing, effective respiratory protection program.
Another consideration is maximum use concentration (MUC), which is the maximum concentration a worker can be expected to be protected from using the chosen respirator. Multiplying the APF by the permissible exposure limit (PEL) gives you the MUC for a respirator; it should be less than both the PEL and the IDLH levels for that hazard.
PEL X APF = MUC
And finally, the respirators you select have to be appropriate for the type of hazard. Different types of respirators, filters and cartridges are needed depending on whether the airborne contaminants in your workplace are particles, gases, vapors or other hazards. Respirators also need to be compatible with any other personal protective equipment (PPE) that workers need to wear for protection against other types of hazards.
There are two main kinds of respirators:
Respirators can also be classified as tight-fitting or loose-fitting.
Common types of respirators include:
Before employees can wear a respirator, you need to make sure they’re medically approved to do so. Not everyone is physically able to wear respiratory protection while on the job, because it can make breathing more difficult and may place additional stress on the body.
Initially, OSHA requires workers to complete a questionnaire, where they’ll provide information about medical conditions that could affect their ability to wear a respirator, as well as information about workplace conditions and the hazards they face. Make sure you provide employees all the data they need to complete the questionnaire.
A physician or licensed health care professional (PLHCP) must then evaluate the employee’s responses. The PLHCP will recommend whether follow-up medical examinations are required, and if so, what tests are necessary.
OSHA requires periodic re-evaluation but doesn’t specify a time period. Re-evaluation is also necessary if:
Tight-fitting respirators can only provide expected protection if they fit correctly, so fit-testing each employee is critical.
There are two kinds of tests, and OSHA specifies which can be used depending on the respirator type.
A qualitative fit test (QLFT) is pass/fail and relies on the employee’s senses using one of four OSHA-accepted test agents:
Each QLFT method uses seven exercises performed for 1 minute each:
QLFTs may be used to fit-test:
A quantitative fit test (QNFT) uses an instrument to measure leakage around the face seal and produces a numerical result called a “fit factor.” There are three OSHA-accepted QNFT test protocols:
QNFTs use the same seven exercises as QLFTs, plus an additional “grimace” test where the subject smiles or frowns for 15 seconds.
A QNFT can be used to fit-test any type of tight-fitting respirator. A fit factor of at least 100 is required for half-mask respirators and a minimum fit factor of 500 for a full facepiece negative pressure respirator.
Fit tests should be performed per OSHA Regulation 29 CFR 1310.134:
Annual training is an important (and OSHA-mandated) piece of the respiratory safety program. OSHA states that, at a minimum, training should include:
Employers must provide procedures for the proper use and care of half and full-facepiece respirators.
If air-purifying respirators are used, they may have an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant. If there’s no ESLI appropriate for conditions in the workplace, then implement a change schedule for canisters and cartridges, based on objective information or data, to ensure they’re changed before the end of their service life. Keep a record in your respiratory program explaining the information and data relied upon, the basis for the change schedule, and the basis for using that data.
The OSHA standard contains specific rules for proper respirator use in IDLH atmospheres and for interior structural firefighting that must also be part of your procedure if applicable.
Each employee who needs one must receive a respirator that’s in working order, clean and sanitary. OSHA provides procedures for cleaning and disinfecting, or you can use the procedures recommended by the respirator manufacturer in the user instructions.
Frequency of cleaning and disinfection depends on how you use the respirator.
Make sure to have your respirators inspected before each use and during cleaning. All respirators maintained for use in emergency situations should be inspected at least monthly and in accordance with the manufacturer’s recommendations, and checked for proper function before and after each use. Be sure to inspect emergency escape-only respirators before use.
Respirator inspections should include a check of:
For respirators maintained for emergency use, document:
Keep all information on file until the next inspection.
If a respirator fails an inspection or isn’t working, you may discard, repair or adjust it. OSHA states that:
All the elements of the program listed above should be evaluated regularly and discussed at regular safety committee meetings. Examine the written records to make sure all tests and inspections are up to date. Also, talk to the workers who use respiratory equipment to ensure the current respirators fulfill their needs, and that they understand and follow procedures for using and maintaining respirators.
Make a record of your evaluation, summarizing findings, any deficiencies identified and corrective actions to be taken.
There is so much information to get through in long regulatory documents, and respiratory protection can be complex. This list addresses some of the potentially misunderstood or little-known facts surrounding respiratory protection.
Though a dust mask, also known as a comfort mask, looks similar to a filtering facepiece or disposable respirator, dust masks don’t have National Institute for Occupational Safety and Health (NIOSH) approval. NIOSH only approves filtering facepieces that help reduce exposure to particulate hazards.
While there are provisions for powered air-purifying respirators (PAPRs) to be used, currently there aren’t any NIOSH-approved PAPRs on the market that can be used in abrasive blasting.
If it’s not clear from the product information, contact the manufacturer to verify. You may need to select a different respirator for the types of vapors present in your workplace.
The color-coding on cartridges signifies which NIOSH approval the cartridge meets.
A filtering facepiece can help protect the wearer’s lungs from harmful particulates — but only if it fits correctly and forms a tight seal. Fit testing of disposable respirators is required in several countries, including the United States.
Users should also engage in a fit test every time a new model, manufacturer type/brand, or size is worn, and if the shape of their face changes due to weight fluctuations or other causes.
Only tight-fitting respirators, designed to form a complete seal on the face, need a fit test. Loose-fitting respirators, such as the headtop used in a powered- or supplied-air system, don’t require fit-testing.
The standard evaluation is a questionnaire, and many people are cleared based on their answers.
The Occupational Safety and Health Administration (OSHA) standard contains no specific time frames, only recommendations for when workplace conditions change or an employee reports certain symptoms. 3M Respiratory Protection recommends re-evaluating each employee every two to three years.
OSHA specifies that before you resort to respirators for workers, you must first try to eliminate the hazard from the workplace and try to limit worker exposure. If it’s not feasible or financially viable to remove the risk in your workplace, then respiratory protection is required — and vital to help protect your workers from the airborne hazards they face.