November 21, 2013
Construction industry employers in Oregon receive more citations for violations of lead, asbestos, hazard communication, and respiratory protection standards than other health standards.
In part 4 of this series, the Construction Depot explains the requirements of the written respiratory protection program [1910.134(c), Respiratory protection program], which are often overlooked by contractors.
You can't just hand out respirators to your employees and expect them to be used properly. If respirators are necessary to protect your employees, you must have a written program that describes how you will:
Appoint an administrator. You will also need to appoint an administrator to develop, manage, and evaluate your respiratory-protection program. The administrator can delegate parts of the program to other qualified employees, such as respirator fit-testing and maintenance, but must oversee their activities.
Before you select respirators for your employees, make sure you identify the respiratory hazards they will be exposed to as well as their exposure levels. If respirators are necessary, you must ensure they are appropriate for the tasks your employees perform and that they fit your employees.
Before employees use respirators, they must have confidential medical evaluations to ensure that their safety or health will not be at risk. A physician or other licensed health-care professional (PLHCP) must do the evaluation at no cost to the employee. The evaluation must be based on the questionnaire in Part A of Appendix C to 1910.134. The PLHCP can examine the employee or evaluate the employee's written responses to the questionnaire in Appendix C, but the determination must be based on information obtained from answers to the questionnaire.
Human faces vary in size and shape and so do respirator facepieces. A tight-fitting facepiece needs to fit so that the face-to-facepiece seal doesn't leak. You can use one of two fit-test methods (qualitative or quantitative) to determine the correct fit for most tight-fitting facepieces.
Regardless of the method you use, you must conduct the test using a specific protocol to ensure that the test is done properly. Appendix A to 1910.134 includes protocols for qualitative and quantitative fit tests.
Your respiratory protection program must have written procedures that:
Employees' respirators must be clean and work properly. Your employees can clean and maintain their equipment or you can have it serviced for them. Those who do the cleaning and maintenance must be properly trained.
Compressed air, compressed oxygen, liquid air, and liquid oxygen used for breathing air must meet specific standards for quality. You can rely on certificates of analysis from suppliers to meet the standards. If you produce breathing air from a compressor, you must follow requirements for the location of the compressor, moisture content of ambient air, carbon monoxide level, and filter change dates [see 1910.134(i)(5)-(7)].
If you require employees to use respirators, they must be trained before they use them for the first time. You can choose the trainer and determine the training format; however, the training content must include the following:
Periodically review each of the written elements of your respirator program:
You don't need to do evaluations on a fixed schedule - do them frequently enough to keep the program current and to ensure that written procedures are effective.
You can find a link to sample programs on Oregon OSHA's "Forms" A-Z topic page. Look for the heading, "Respiratory protection."
Reprinting, excerpting, or plagiarizing any part of this publication is fine with us!
But remember: the information in this newsletter is intended to highlight safe work practices, but it does not replace Oregon OSHA workplace safety and health rules.
For information about Oregon OSHA services and answers to technical questions, call (503) 378-3272 or toll-free within Oregon, (800) 922-2689.