ST. PAUL, Minn. – You might be doing everything right when it comes to following respiratory protection regulations, but without good records it can be difficult – if not impossible! – to prove it. Better records also mean peace of mind, since you always know you’re on top of training and testing.
Don’t be caught playing catch up. Make sure the records for your respiratory protection program include at least all the parts below, which are required by the U.S. Occupational Safety and Health Administration (OSHA):
1. Exposure assessment: 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 health and safety professional on staff or for an additional opinion on your hazards. The results of the assessment can help determine:
* Exposure levels, and whether they’re acceptable or unacceptable.
* Effective ways to control exposure.
* Which types of respirators (if any) can help provide the right protection for your workers.
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.
2. Respirator selection: 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 program 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.
3. Medical evaluation: 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.
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.
4. Fit testing: Tight-fitting respirators can only provide expected protection if they fit correctly, so fit-testing each employee is require. There are two kinds of tests (qualitative and quantitative), and OSHA specifies which can be used depending on the respirator type.
5. Respirator training: Annual training is an important (and OSHA-mandated) piece of the respiratory protection program. OSHA states that, at a minimum, training should include:
* Why employees need to use the respirator.
* What the respirator can and cannot do to help protect them
* How to properly inspect, put on and take off, and use their respirators
* How to perform a “user seal check” on their respirators.
* How to use the respirator effectively in emergency situations, including what to do if it doesn’t work properly.
* How to recognize medical signs and symptoms that may limit or prevent workers from using a respirator.
* How improper fit, usage or maintenance can reduce the respirator’s ability to protect them.
* The procedures for maintenance and storage of the respirator.
* The requirements for federal/state OSHA respiratory protection standards.
6. Respirator maintenance: Employers must provide procedures for the proper use and care of all respirators.
7. Program evaluation: All the elements of the program listed above should be evaluated regularly. 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.
Be sure to review your records at least once every year, and always update them every time you perform one of the actions above. To help, we’ve put together a Respiratory Protection Program Checklist you can download here. Feel free to use these forms as much as required.
For more tips on how to build an effective respiratory protection program, visit the 3M Center for Respiratory Protection. We’ve created this free of charge resource to help keep you informed about best practices for respiratory protection and to provide resources to help you keep your employees safe. Here, you’ll find step-by-step guides, training materials and other expert-created content.
And while you’re there, don’t forget to sign up for the 3M Online Medical Evaluation. (see #3 above). This makes compliance even easier with fast, confidential results and automatic reminders that help with record keeping. Employees can be evaluated in as little as 15 minutes and there’s no need to leave the work site.