Does your employee need a respirator? This is an important question to ask, but it can be difficult to answer.
There are several steps along the way that must be conducted before you can answer this question. The first step is to determine if there is a risk of exposure.
Step 1: If a respiratory hazard is present, ask: “Is this material present in the air at a concentration which may affect worker health?”
This question requires an answer from a qualified Industrial Hygienist who will perform an air quality test, monitor employees and their tasks to determine the representative amount or concentration of the contaminant in the air during the employee’s various work tasks. This monitoring will allow the employer to work with the Industrial Hygienist to make informed decisions about protecting their employees.
Step 2: Can the hazard be eliminated or reduced?
According to OSHA, respirators are required when “effective engineering controls are not feasible, or while they are being instituted.” What does this mean? Essentially, engineering controls reduce worker exposure to hazards using items such as exhaust systems. If these are not yet in place, respirators are to be used as a short-term or long-term solutions.
To find out if the hazard can be reduced or eliminated, several controls will need to be evaluated. Elimination can be done by substituting the hazardous material for a less hazardous option. You can also reduce the risk by instituting engineering controls such as enclosing the process or installing source ventilation to remove the contaminant before it can become a respiratory issue.
Step 3: Mandatory vs. Voluntary
When an employer has determined that a respirator will become mandatory for their employees, all requirements of the OSHA Respiratory Standard must be followed. These requirements include but are not limited to, a written Respiratory Protection Program, medical clearance specific to the type of respirator used and the work to be performed, a fit test for the specific make, model, and size of respirator, and training, all of which is done annually.
If it has been determined that a respirator is not needed, an employee may still like to use a respirator for “comfort” even when it is not required. In this case, you should still have plans in place to manage Voluntary Respirator Use, and some requirements of the OSHA Respiratory Protection Standard will apply as indicated in Figure 1.
FIGURE 1
Respirator-Use Requirements Flow Chart 29 CFR 1910.134(c) from
MAJOR REQUIREMENTS OF OSHA’S RESPIRATORY PROTECTION STANDARD 29 CFR 1910.134
Whether employees are provided respirators for voluntary use, or bring in their own, they must be provided with a copy of Appendix D of the OSHA Respirator Program. This appendix instructs respirator users how to follow the equipment manufacturer’s recommendations for use and maintenance, as well as understanding the limitations of respirators. If respirator use is voluntary, other than a dust mask, the employer must establish and implement a written respirator program necessary to ensure that the employee is medically able to use that respirator. These are generally written by an Industrial Hygienist.
While voluntary respirator use may be acceptable under the OSHA requirements, it may not eliminate an employer’s liability. All respirators may put a burden on the cardiovascular system. A worker with pulmonary issues such as Chronic Obstructive Pulmonary Disease COPD may not be physically capable of breathing through the additional resistance of a respirator which may result in aggravation of a pre-existing condition.
Step 4: Deciding what type of respirator to use.
Once all engineering controls have been considered and implemented, if there is still a risk to the employee from an airborne contaminant, then respiratory protection is necessary.
Various types of respirators are available and are chosen based on the type of airborne contaminant, the exposure concentration, and the protection factor of the respirator. Some respirators filter the air to remove the contaminant, known as an air purifying respirator or APR, and some respirators supply fresh air to the employee known as a supplied air respirator or SAR.
- Air purifying respirators (APR) include dust masks as well as systems that filter the air through a cartridge specific to the contaminant of concern. These types of respirators have many strengths and weaknesses and must be carefully considered before choosing.
- Supplied air respirators (SAR) include Self Contained Breathing Apparatus (SCBA)s and airline respirators which are generally used in highly hazardous conditions or for contaminants for which a purifying filter is not available.
Step 5: Follow OSHA Respiratory Standards
Whether the employer has determined if a respirator will be mandatory or worn voluntarily, there are requirements of the Occupational Health and Safety Administration (OSHA) Respiratory Protection Standard that must be followed. These requirements include but are not limited to, a written Respiratory Protection Program, medical clearance specific to the type of respirator used and the work to be performed, a fit test for the specific make, model, and size of respirator, and training, all of which is done annually.
Gallagher Bassett Technical Services division has qualified Industrial Hygienists who can perform air quality testing of any type and create a Respiratory Program that is compliant with all OSHA requirements.
Please contact us for more information or if you have questions or would like to discuss a particular opportunity at: GBTS.marketing@gbtpa.com.