Chapter 18: Respiratory Protection

Purpose

This Respiratory Protection Program specifies standard operating procedures o protect specified employees from respiratory hazards, according to the requirements of 29 CFR 1926.103 which simply refers to 29 CFR 1910.134. Respirators are to be used only where engineering control of respirator hazards is not feasible, while engineering controls are being installed, or in emergencies.

Administrative Duties

At UMW, our Respiratory Protection Program Administrator is OEMS. OEMS is solely responsible for all facets of the program and has full authority to make necessary decisions to ensure success of this program. Their authority includes hiring personnel and purchasing equipment necessary to implement and operate the program. The Director of OEMS will develop written detailed instructions covering each of the basic elements in this program and is authorized to amend these instructions.

The Director of OEMS is also qualified by appropriate training and experience that is commensurate with the complexity of the program to administer or oversee our Respiratory Protection Program and conduct the required evaluations of program effectiveness.

Employees may review a copy of our Respiratory Protection Program. It is in OEMS at Hamlet House. The Director of OEMS reviews this program periodically to ensure its effectiveness.

Respirator Selection

Respirators are selected based on respiratory hazards to which the worker is exposed and workplace and user factors that affect respirator performance and reliability. All selections are made by trained supervisors with the advice from OEMS.

The Director of OEMS will develop written standard operating procedures governing the selection of respirators using the standard guidelines. Detailed procedures will be included as appendices to this respirator program. Outside consultation, manufacturer’s assistance, and other recognized authorities will be consulted if there is any doubt regarding proper selection.

Selection Procedure Checklist

When Selecting Any Respirator in General:

Select and provide respirators based on respiratory hazards to which a worker is exposed and workplace and user factors that affect respirator performance and reliability.
Select a NIOSH-certified respirator. (NIOSH stands for the National Institute for Occupational Safety and Health)
Identify and evaluate the respiratory hazard(s) in the workplace, including a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant’s chemical state and physical form. Consider the atmosphere to be immediately dangerous to life or health (IDLH) if you cannot identify or reasonably estimate employee exposure.
Select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user.

When selecting respirators for IDLH atmospheres:

A full face-piece pressure demand Self-contained breathing apparatus (SCBA) certified by NIOSH for a minimum service life of thirty minutes
A combination full face-piece pressure demand supplied-air respirator self-contained breathing apparatus (SAR) with auxiliary self-contained air supply.
Provide respirators that are NIOSH-certified for escape from the atmosphere in which they will be used when they are used only for escape from IDLH atmospheres.
Consider all oxygen-deficient atmospheres to be IDLH.

When selecting respirators for atmospheres that are not IDLH:

Provide a respirator that is adequate to protect the health of the employee and ensure compliance with all other OSHA statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations.
Select respirators appropriate for the chemical state and physical form of the contaminant.

For protection against gases and vapors, provide:

An atmosphere-supplying respirator, or
An air-purifying respirator, provided that:
- The respirator is equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant
- If there is no ESLI appropriate for conditions in our workplace, implement a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life. Describe in the respirator program the information and data relied upon and the basis for the canister and cartridge change schedule and the basis for reliance on the data.

For protection against particulates, provide:

An atmosphere-supplying respirator
An air-purifying respirator equipped with a filter certified by NIOSH under 30 CFR part 11 as a high efficiency particulate air (HEPA) filter, or an air-purifying respirator equipped with a filter certified for particulates by NIOSH under 42 CFR 84
For contaminants consisting primarily of particles with mass median aerodynamic diameters (MMAD) of at least 2 micrometers, an air-purifying respirator equipped with any filter certified for particulates by NIOSH.

Respirator Types and Uses

Only NIOSH-certified respirators are selected and used. Respirators will be assigned to individual workers for their exclusive use.

Medical Evaluations

A medical evaluation to determine whether an employee is able to use a given respirator is an important element of an effective Respiratory Protection Program and is necessary to prevent injuries, illnesses, and even, in rare cases, death from the physiological burden imposed by respirator use.

At UMW, persons will not be assigned tasks requiring use of respirators nor fit tested unless it has been determined that they are physically able to perform the work and use the respirator.

A qualified physician or health care professional will perform medical evaluations using a medical questionnaire found in Sections 1 and 2, Part A of Appendix C of 29 CFR 1910.134.

All medical questionnaires and examinations are confidential and handled during the employee’s normal working hours or at a time and place convenient to the employee. The medical questionnaire is administered so that the employee understands its content. All employees are provided an opportunity to discuss the questionnaire and examination results with their physician or other licensed health care professional (PLHCP).

Before any initial examination or questionnaire is given, we supply the PLHCP with the following information so that he/she can make the best recommendation concerning an employee’s ability to use a respirator:

Type and weight of the respirator to be used by the employee
Duration and frequency of respirator use (including use for rescue and escape)
Expected physical work effort
Additional protective clothing and equipment to be worn
Temperature and humidity extremes that may be encountered

Once the PLHCP determines whether the employee is able use or not use a respirator, they send UMW a written recommendation containing only the following information:

Limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether the employee is medically able to use the respirator
The need, if any, for follow-up medical evaluations
A statement that the PLHCP has provided the employee with a copy of the PLHCP’s written recommendation

Follow-Up Medical Examination

A follow-up medical examination will be provided if a positive response is given to any question among questions 1 through 8 in Section 2, Part A of Appendix C of 29 CFR 1910.134 or if an employee’s initial medical examination demonstrates the need for a follow-up medical examination. Our follow-up medical examination includes tests, consultations, or diagnostic procedures that the PLHCP deems necessary to make a final determination.

If the respirator is a negative pressure respirator and the PLHCP finds a medical condition that may place the employee’s health at increased risk if the respirator is used, UMW will provide a powered air-purifying respirator (PAPR) if the PLHCP’s medical evaluation finds that the employee can use such a respirator. If a subsequent medical evaluation finds that the employee is medically able to use a negative pressure respirator, then we are no longer required to provide a PAPR.

Additional Medical Examinations

UMW provides additional medical evaluations if:

An employee reports medical signs or symptoms that are related to ability to use a respirator
A PLHCP, supervisor, or the Director of OEMS informs the employer that an employee needs to be reevaluated
Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation
A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

Contact the examining physician for a copy of your confidential medical evaluation or questionnaire.

Fit Testing Procedures

It is imperative that respirators fit properly to provide protection. If a tight seal is not maintained between the face-piece and the employee’s face, contaminated air will be drawn into the face-piece and be breathed by the employee. Fit testing seeks to protect the employee against breathing contaminated ambient air and is one of the core provisions of our respirator program.

In general, fit testing may be either qualitative or quantitative. Qualitative fit testing (QLFT) involves the introduction of a gas, vapor, or aerosol test agent into an area around the head of the respirator user.

In a quantitative respirator fit test (QNFT), the adequacy of respirator fit is assessed by measuring the amount of leakage into the respirator, either by generating a test aerosol as a test atmosphere, using ambient aerosol as a test agent, or using controlled negative pressure to measure the volumetric leak rate. Appropriate instrumentation is required to quantify respirator fit in QNFT.

UMW will make sure those employees are fit tested at the following times with the same make, model, style, and size of respirator that will be used:

Before any of our employees are required to use any respirator with a negative or positive pressure tight-fitting face-piece
Whenever a different respirator face-piece (size, style, model, or make) is used
At least annually
Whenever the employee reports, or UMW, PLHCP, supervisor, or Director of OEMS makes visual observations of changes in the employee’s physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight
When the employee, subsequently after passing a QLFT or QNFT, notifies UMW, Director of OEMS, supervisor, or PLHCP that the fit of the respirator is unacceptable. That employee will be retested with a different respirator face-piece.

Employees must pass one of the following fit test types that follow the protocols and procedures contained in 29 CFR 1910.134 Appendix A:

QLFT – Only used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less. May be used to test tight-fitting atmosphere-supplying respirators and tight-fitting powered air-purifying respirators if tested in the negative pressure mode
QNFT – May be used to fit test a tight-fitting half face-piece respirator that must achieve a fit factor of 100 or greater OR a tight-fitting full face-piece respirator that must achieve a fit factor of 500 or greater OR tight-fitting atmosphere-supplying respirators and tight-fitting powered air-purifying respirators if tested in the negative pressure mode

UMW presently uses QNFT testing.

Proper Use Procedures

Once the respirator has been properly selected and fitted, its protection efficiency must be maintained by proper use in accordance with 29 CFR 1910.134(g). UMW will ensure written procedures that respirators are used properly in the workplace.

OEMS has used the following checklist to ensure that proper use procedures include coverage of OSHA requirements:

Face-Piece Seal Protection

Do not permit respirators with tight-fitting face-pieces to be worn by employees who have:

Facial hair that comes between the sealing surface of the face-piece and the face or that interferes with valve function.
Any condition that interferes with the face-to-face-piece seal or valve function.
If an employee wears corrective glasses or goggles or other Personal Protective Equipment, ensure that such equipment is worn in a manner that does not interfere with the seal of the face-piece to the face of the user.
For all tight-fitting respirators, ensure that employees perform a user seal check each time they put on the respirator using the procedures in 29 CFR 1910.134 Appendix B-1 (User Seal Check Procedures) or procedures recommended by the respirator manufacturer that you can demonstrate are as effective as those in Appendix B-1.

Continuing Respirator Effectiveness

Appropriate surveillance must be maintained of work area conditions and degree of employee exposure or stress. When there is a change in work area conditions or degree of employee exposure or stress that may affect respirator effectiveness, reevaluate the continued effectiveness of the respirator.
Ensure that employees leave the respirator use area:
- To wash their faces and respirator face-pieces as necessary to prevent eye or skin irritation associated with respirator use.
- If they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the face-piece.
- To replace the respirator or the filter, cartridge, or canister elements.
If the employee detects vapor or gas breakthrough, changes in breathing resistance, or leakage of the face-piece, replace or repair the respirator before allowing the employee to return to the work area.

Procedures for IDLH Atmospheres

Ensure that:

One employee or, when needed, more than one employee is located outside the IDLH atmosphere.
Visual, voice, or signal line communication is maintained between the employees in the IDLH atmosphere and the employees located outside the IDLH atmosphere.
The employees located outside the IDLH atmosphere are trained and equipped to provide effective emergency rescue.
OEMS and Rescue Teams are notified before the employees located outside the IDLH atmosphere enter the IDLH atmosphere to provide emergency rescue.
The employee or designee authorized to do so by OEMS, once notified, provides necessary assistance appropriate to the situation.
Employees located outside the IDLH atmospheres are equipped with:
- Pressure demand or other positive pressure SCBAs, or a pressure demand or other positive pressure supplied-air respirator with auxiliary SCBA; and either:
  - Appropriate retrieval equipment for removing the employees who enter these hazardous atmospheres where retrieval equipment would contribute to the rescue of the employees and would not increase the overall risk resulting from entry.
  - Equivalent means for rescue where retrieval equipment is not required under the bullet item above this one.

Maintenance and Care Procedures

In order to ensure continuing protection from respiratory protective devices, it is necessary to establish and implement proper maintenance and care procedures and schedules. A lax attitude toward maintenance and care will negate successful selection and fit because the devices will not deliver the assumed protection unless they are kept in good working order.

Cleaning & Disinfecting

UMW provides each respirator user with a respirator that is clean, sanitary, and in good working order. We ensure that respirators are cleaned and disinfected using the procedures below:

In Appendix B-2 of 29 CFR 1910.134. See this attached appendix.
Recommended by the respirator manufacturer. See these attached procedures. These procedures are of equivalent effectiveness as Appendix B-2 of 29 CFR 1910.134.

The respirators are cleaned and disinfected at the following intervals:

Issued for the exclusive use of an employee – Before being worn by different individuals
Issued to more than one employee – Before being worn by different individuals
Maintained for use in emergency situations – After each use
Used in fit testing and training – After each use

Storage

Storage of respirators must be done properly to ensure that the equipment is protected and not subject to environmental conditions that may cause deterioration. We ensure that respirators are stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, damaging chemicals, and they are packed or stored to prevent deformation of the face-piece and exhalation valve. In addition, emergency respirators are kept accessible to the work area, stored in areas that are clearly marked as containing emergency respirators, and stored in accordance with any applicable manufacturer instructions.

Inspection

To assure the continued reliability of respirator equipment, it must be inspected on a regular basis. The frequency of inspection is related to the frequency of use. Here are our frequencies for inspection:

All types used in routine situations – Before each use and during cleaning

Maintained for use in emergency situations – At least monthly and in accordance with the manufacturer’s recommendations, and checked for proper function before and after each use

Emergency escape-only respirators – Before being carried into the workplace for use

Any one of our respirator inspections includes a check:

For respirator function, tightness of connections, and the condition of the various parts including, but not limited to, the face-piece, head straps, valves, connecting tube, and cartridges, canisters, and filters.
Of electrometric parts for pliability and signs of deterioration.
For self-contained breathing apparatus, in addition to the above, monthly, we maintain air and oxygen cylinders in a fully charged state and recharge when the pressure falls to 90% of the manufacturer’s recommended pressure level and determine that the regulator and warning devices function properly.

Also for respirators maintained for emergency use, we certify the respirator by documenting the date the inspection was performed, the name (or signature) of the person who made the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator. See attached documentation. This information shall be maintained until replaced following a subsequent certification.

Repairs

Respirators that fail an inspection or are otherwise found to be defective are removed from service, and are discarded or repaired or adjusted in accordance with the following procedures:

Repairs or adjustments to respirators are to be made only by persons appropriately trained to perform such operations and only with the respirator manufacturer’s NIOSH-approved parts designed for the respirator.
Repairs must be made according to the manufacturer’s recommendations and specifications for the type and extent of repairs to be performed.
Reducing and admission valves, regulators, and alarms must be adjusted or repaired only by the manufacturer or a technician trained by the manufacturer.

Discarding of Respirators

Respirators that fail an inspection or are otherwise not fit for use and cannot be repaired must be destroyed and discarded.

Air Quality Procedures

When atmosphere-supplying respirators are being used to protect employees, it is essential to ensure that the air being breathed is of sufficiently high quality. UMW procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators include coverage of the following OSHA requirements:

Compressed Air, Compressed Oxygen, Liquid Air, and Liquid Oxygen Used for Respirators:
- Compressed and liquid oxygen must meet the United States Pharmacopoeia requirements for medical or breathing oxygen.
- Compressed breathing air must meet at least the requirements for Grade D breathing air described in ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-1989, to include:
  - Oxygen content (v/v) of 19.5-23.5%.
  - Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less.
  - Carbon monoxide (CO) content of 10 ppm or less.
  - Carbon dioxide content of 1,000 PPM or less.
  - Lack of noticeable odor.
- Ensure that compressed oxygen is not used in atmosphere-supplying respirators that have previously used compressed air.
- Ensure that oxygen concentrations greater than 23.5% are used only in equipment designed for oxygen service or distribution.

Cylinders Used to Supply Breathing Air to Respirators:

Cylinders must be tested and maintained as prescribed in the Shipping Container Specification Regulations of the Department of Transportation (49 CFR 173 and 178).
Cylinders of purchased breathing air must have a certificate of analysis from the supplier that the breathing air meets the requirements for Grade D breathing air.
The moisture content in the cylinder must not exceed a dew point of -50 deg. F (-45.6 deg. C) at 1 atmosphere pressure.

Compressors

Ensure that compressors used to supply breathing air to respirators are constructed and situated 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 (5.56 deg. C) below the ambient temperature.
Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality. Sorbent beds and filters must be maintained and replaced or refurbished periodically following the manufacturer’s instructions.
Have a tag containing the most recent change date and the signature of the person authorized by our company to perform the change. The tag must be maintained at the compressor.

For compressors that are not oil-lubricated, ensure that carbon monoxide levels in the breathing air do not exceed 10 PPM.

For oil-lubricated compressors, use a high-temperature or carbon monoxide alarm, or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, the air supply must be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from exceeding 10 PPM

Breathing Air Couplings

Ensure that breathing air couplings are incompatible with outlets for nonrespirable worksite air or other gas systems. No asphyxiating substance must be introduced into breathing air lines.

Breathing Gas Containers

Use breathing gas containers marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.

Filters, Cartridges, and Canisters

Ensure that all filters, cartridges, and canisters used in the workplace are labeled and color coded with the NIOSH approval label and that the label is not removed and remains legible.

Training

The most thorough respiratory protection program will not be effective if employees do not wear respirators, or if wearing them, do not do so properly. The only way to ensure that our employees are aware of the purpose of wearing respirators, and how they are to be worn is to train them. Simply put, employee training is an important part of the respiratory protection program and is essential for correct respirator use.

Our training program provided by OEMS is two-fold. It covers:

Respiratory hazards to which our employees are potentially exposed during routine and emergency situations.
Proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance.

Both training parts are provided prior to requiring an employee to use a respirator at UMW. However, if an employee has received training within 12 months addressing the seven basic elements of respiratory protection (see “Seven Basic Elements” below) and UMW and the employee can demonstrate that they have knowledge of those elements, then the employee is not required to repeat such training initially.

We do require all employees to be retrained annually and when the following situations occur:

Changes in the workplace or the type of respirator render previous training obsolete.
Inadequacies in the employee’s knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill.
Any other situation arises in which retraining appears necessary to ensure safe respirator use.

Seven Basic Elements

Our employees are trained sufficiently to be able to demonstrate a knowledge of at least these seven elements:

Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator.
What the limitations and capabilities of the respirator are.
How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions.
How to inspect, put on, remove, use, and check the seals of the respirator.
What the procedures are for maintenance and storage of the respirator.
How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.
The general requirements of 29 CFR 1910.134.

The basic advisory information on respirators is provided by OEMS in a written or oral format to employees who wear respirators when such use is not required by the regulations.

Information for Employees Using Respirators When Not Required Under the Standard

Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, or if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard.

You should do the following:

Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirator’s limitations.
Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will tell you what the respirator is designed for and how much it will protect you.
Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke.
Keep track of your respirator so that you do not mistakenly use someone else’s respirator.

Program Evaluation

It is common for issues to arise around the use of respirators, such as problems with protection, irritation, breathing resistance, comfort, and other respirator-related factors. Although it is not possible to eliminate all problems associated with respirator use, we try to eliminate as many problems as possible to improve respiratory protection and encourage employee acceptance and safe use of respirators. By having the Director of OEMS thoroughly evaluate and, as necessary, revise our Respiratory Protection Program, we can eliminate problems effectively.

At UMW, program evaluation is performed by OEMS and involves the following:

Conducting evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.
Regularly consulting employees required to use respirators to assess their views on program effectiveness and to identify any problems. Any problems that are identified during this assessment must be corrected. Factors to assess include, but are not limited to:
- Respirator fit (including the ability to use the respirator without interfering with effective workplace performance)
- Appropriate respirator selection for the hazards to which the employee is exposed
- Proper respirator use under the workplace conditions the employee encounters
- Proper respirator maintenance